RECERTIFICATION EVERYTHING YOU NEED TO KNOW ABOUT

TAX CREDITS VS RURAL DEVELOPMENT There are many minor differences in the certification procedures for tax credit and Rural Development properties. When a property has both programs, use the most conservative of the two, or complete separate certifications if necessary.

WHEN TO RE-CERTIFY Certify initially at move in Recertify annually For Tax credits the 1 st of month of move in – one year later. (example- move in 12/14/08- recertify by 12/1/09) For Rural Development one year from the effective date of the original certification

EFFECTIVE DATES All tenants are certified at move in. Initial certifications are always effective: For Tax credits the date of move in. For Rural Development- the 1 st day of the month following move in date, unless move in is on the 1 st of the month.

ORGANIZING RE-CERT LIST Organize all the tenants in a list (spreadsheet) including their name, unit #, move in date, recert due date and dates to send out notices. All tenants must be notified in writing (with a copy in the file) 90 and 30 days in advance of their effective date.

RE-CERT CHECKLIST The 1 st thing the tenant must complete at move in and each year is the certification checklist. Each household member age 18 or older (even dependents still in school) must complete a separate one, except married couples may complete a joint one. All questions must be answered.

MEDICAL The medical questionnaire must be completed if a household qualifies for medical deductions. To qualify the tenant or co-tenant must be age 62 or older, handicapped or disabled. This must be verified with birth certificates, receipt of Social Security Disability or verification of handicap. (not specific handicap, but that one exists)

WHO CAN DEDUCT MEDICAL? If the tenant or co-tenant qualifies – as an elderly, handicapped or disabled household- the entire household make deduct medical expenses paid out of pocket. If the tenant or co-tenant don’t meet the qualifications- no one in the household may claim medical deductions even if they meet the qualifications.

INTERIM CERTIFICATIONS Interim certifications MUST be completed for changes in: Income Income changes of $ per month Income changes of $50.00 per month if requested by tenant. Must provide time to do verifications and provide 30 day notice if rent increases. Household size or composition

WHEN NOT TO RECERTIFY Interim certifications are NOT completed for: changes in allowances/ deductions Rent changes Utility allowance changes Household transfers to another unit in the same project. When a tenant receives rental assistance Make the appropriate changes to the current certification changes. Effective date remains the same.

HOW FAR IN ADVANCE TO COMPLETE Recommend contacting tenants 120 days in advance of effective date Set date and time giving tenant opportunity to re- schedule if necessary Schedule a recert meeting 90 days in advance of effective date. Send out verifications immediately. Follow up weekly until completed

HOW LONG ARE VERIFICATIONS VALID Tax credit verifications have a life of 120 days and can NOT be renewed or updated beyond that period. Rural Development verifications have a life of 90 days and may be verbally updated with a written clarification for an additional 90 days.

SENDING OUT VERIFICATIONS Verifications may be sent 1 st class mail- include self addressed stamped envelope Fax – leave fax dates on top - include addresses, and date Hand delivered by management May not be carried either direction by the tenant

WHEN TO GET SIGNED Rural Development tenants MUST sign recertification's which result in an increase in their rent portion at least 30 days in advance. All certification must be signed on or before the effective date- never after

PENALITIES FOR LATE RECERTS Rural Development- The rent is raised to note rate rent- Penalties may be waived if failure is tenants fault- Must be well documented. Management must pay penalties if it is their fault, or they can’t document Tax Credits- will result in an 8823 non compliance form sent to the IRS

TENANT FRAUD Managers MUST document failure of tenant to report: All sources of in income or assets Changes in income or assets All household composition or changes in composition Or misrepresentation of allowances All fraud must be reported to Rural Dev.

CORRECTIONS FOR LATE RECERTIFICATIONS For both programs the tenant is back in compliance once the recertification is completed. Penalties may still occur for out of compliance periods. For RD- note rate rent For Tax Credits- possible loss of credits Tenant should be issued lease violation if lateness is their fault.

COMPARISON TO PRIOR YEAR’S CERTIFICATION Compare assets from one year to the next and prepare a written clarification form or self affidavit of any changes from year to year. Verify closed bank accounts – are closed Prior employment- not still current