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As you all
know, Tax Credit professionals have time to spare. The properties are
overstaffed and no one is ever stressed… Or wait, was that a
dream I had last night?
been! Who am I kidding? Tax Credit managers and compliance specialists
have one of the most stressful, thankless jobs there is. Anyone that
has been in one of these positions for more than a day knows this.
More importantly, YOU know this!
management and compliance can be a very tricky business! The tenant
scenarios alone that you must deal with can easily trip you up and put
you in noncompliance, let alone rules like the Full-Time Student Rule,
Unit Transfer Rule, The Unit Vacancy Rule and The Available Unit Rule.
There are so many scenarios and so many factors that come into play.
The worst thing is…
mistake … one uncooperative tenant … one fraudulent applicant…
can cause you to lose THOUSANDS of dollars in Tax Credits!
Most of the Tax Credit questions you have
are not simple either. They don’t just pertain to a single rule.
Rather they are entangled with a long, drawn out resident scenarios.
The questions you have not only have to be answered on a compliance
level, but also have to be answered within keeping of local landlord
tenant laws, fair housing and they must have a practical application
within the realistic world of property management and resident
relations. That is a lot!
what I mean, you get an applicant that comes in with 3 kids, 1 that is
a full-time student living away from home, and one that is a friend’s
kid that the applicant doesn’t have custody of, plus a boyfriend that
you aren’t sure is going to be living in the unit or appears to be
hiding information and you have to qualify them for a Tax Credit
Or you get
a person that comes in with a living will and a slew of stocks, bonds
and retirement accounts that go beyond the normal income & asset
scenarios and you have to verify and evaluate them and determine how
they will affect eligibility.
about the resident that won’t cooperate with the annual
recertification process and is stirring up trouble with the other
residents convincing them not to cooperate with the process as well
causing you to be late with your annual recertifications!
housing is a huge factor. Landlord/Tenant law has to be considered.
And now we have to deal with potential terrorism threats at our
properties, mold problems and insurance rates that are sky high!!
try to get answers to your questions or guidance, what usually
happens? The deer-in-the-headlights factor! Right? That is if you can
get a hold of anyone to talk. Most of our questions need answering
immediately or else we run the risk of losing an otherwise great
potential resident. Or we run the risk of making a decision without
proper guidance and end up creating more work and potential
you can call your State Agency, your investor, your accountant or your
If you call your STATE AGENCY OR INVESTOR…
what happens? You call attention to yourself and your compliance
problem. You also are not ensured of getting a correct answer!
Especially when the question relates to an entangled resident scenario
that encompasses property management techniques, fair housing,
landlord/tenant law as well as Tax Credit compliance. Certainly you
should ascertain your State Agency’s and your investor’s opinions, but
you can’t stop there as their opinions are limited to their scope of
expertise and you can’t be sure how extensive that scope of expertise
is. State Agency and investor personnel are the first ones to tell you
they are not experts in property management and fair housing! They
will answer the question as it pertains to compliance and compliance
alone! It may not have a sound basis in realistic management
techniques, meet fair housing laws or be legally sound according to
your local/landlord tenant law.
If you call your ATTORNEY OR ACCOUNTANT…
what happens? Well, you can expect to pay anywhere from $200 to $400
per hour! Yikes!! That is just out of the question with your limited
budgets. Plus, most attorneys and accountants are not experts in BOTH
Tax Credits and property management. Again, you will most likely get a
very one-dimensional answer that doesn’t have any practicality in the
real world and often doesn’t encompass the all important fair housing
Hello, my name is Elizabeth Moreland. I own
and operate the Housing Credit College and Elizabeth Moreland
Consulting and through these companies I work hard to make Tax Credit
managers and compliance specialists compliance confident!
I once was a
property manager and a compliance specialist just like you. I remember
the frustrations, the fear of noncompliance and the constant nagging
questions … but mostly, I remember the LACK OF ANSWERS! First, it was
difficult to find anyone to ASK a question to. And then, if I was
lucky enough to talk to someone, it was nearly impossible to get a
honest, the fear of noncompliance was running amok at my properties!
decided to do something about it! I immersed myself in the Tax Credit
Program, the Code and anything I could get my hands on. I read, I
studied … and then I read and studied some more. Every chance I could
get, I networked with others in the business and gleamed as much
information from them as was humanly possible. I pestered my State
Agencies. I called the IRS. I chatted with the gurus of the day.
It took a lot of time. A lot of work. And a
lot of perseverance.
day, I use the same approach to keep myself in the know. I have
accumulated an incredible library of Tax Credit books, Code
provisions, and articles on the subject. I have accumulated a list of
industry contacts that I can call at a moments notice to chat with
about difficult scenarios and I have a working relationship with the
majority of State Monitoring Agencies across the country and with the
IRS personnel administrating the Tax Credit Program for Congress.
It takes a lot of time. A lot of work. And
a lot of perseverance. But the good news is…
noncompliance no longer controls me! I can honestly say … I am
"Finally, someone who can
translate IRS verbiage into English. Yahoo!”
Teri Hoerntlein, Comm. Manager, Southern
Cal. Housing, Rancho Cucamonga, CA
"Elizabeth Moreland is
completely Jiggy with Housing Credits."
Jon Brown, Programmer, Real Page, Inc.,
"The absolute industry
leader! A must for anyone in Sect 42 housing."
Kristin Saddoris, Dir. of Section 42
Development, Conlin Properties Inc., Des Moines, IA
"Elizabeth brings a passion to
the housing credit industry with a vast array of
knowledge, practice, application, hands-on experience, then sprinkles
it with a sense of humor." Donna Overstreet,
General Manager, Cypress Point, Casa Grande, AZ
"Tax credit property onsite
staff & managers deserve the knowledge Elizabeth shares. She
definitely delivers.” Barbara W.
Soloway, Senior Property Officer, Westbrook Housing Auth, Westbrook,
So what does this have to do with YOU??
I told you that for LESS THAN $1.92 PER DAY…
You could have me and my
knowledge on your team answering your compliance questions.
You could fax or email me
your scariest, strangest or most confusing compliance scenario and I
will you my expertise and experience to help you resolve it!
You'd have my GUARANTEE that you’d
actually get a response to your question in
48 hours or less!!
like heaven on earth, right? A Tax Credit manager or compliance
specialist’s dream! Actual answers to your questions! Straight answers
backed up by solid research, years of experience and documented
expertise! And all you have to do is send in a faxed question or email
your scenario and I will respond to you within 48 hours or less
We call it
our Compliance Coach! A
technical support hotline for YOU to get the answers to your
questions. Whether you just want to run something by me or
you have a problem that you haven’t been able to get anyone to give
you a straight answer on, with the
Compliance Coach, I AM ONLY FAX OR EMAIL AWAY and I
won’t charge you an arm & a leg!!
Click here to sign up today!
Click here for print version of Compliance Coach Brochure
"The Compliance Coach
has been an excellent resource for me in my responsibility for the
compliance monitoring of multiple projects and thousands of units.
It's great to have a third party consultant that is experienced in
LIHTC compliance and is so easily accessible."
Cathy McCoy Soakai, Compliance
Specialist, Evergreene Management Group, SLC, UT
mere $699 per year, you get:
One hour per month FREE to discuss your compliance issues with the industry’s
most respected compliance expert -- Elizabeth Moreland! Fax me.
Email me. You get 1 hour of our time each and every month to discuss
whatever issues or questions you have. My Compliance Coach
discussions averages 10 to 15 minutes and I have never had a person
use more than 1 hour of their free time unless they requested we
complete a special project for them. You pay $699 per year. Period
the end! (Unless of course you hire us for additional projects,
opinion letters or consulting.)
Access via our
TOLL-FREE telephone number, TOLL-FREE fax or e-mail!! I
will give you our toll-free fax number so you don’t have to spend
extra money making contact. It is on our dime. I will also give you
a special email address as I know that email is one of the most
convenient and useful tools to managers. I am serious when I say I
will make myself available to you!
perspective … state, national and most importantly REALISTIC!!
I personally have been working with this Program since 1989 and
have done everything from site management to compliance specialist
to a director of a large compliance department. I have also been a
leading industry trainer since 1995. My advice is proven and works
in the real world!
A GUARANTEED response in 48 hours or less!!! Our office receives
hundreds of phone calls, countless emails and faxes. They are hard
to get through in a day. Plus, I travel a lot. But as a
Compliance Coach customer, I rank you as our most important. You
get first priority! I will give you an account number and all you
have to do is reference it so I know you get top priority. I then
respond within 48 hours.
price for your entire portfolio!!!! You pay only once not for each
The SECURITY &
CONVENIENCE of assigning up to 3 key people at your company who
can use the Compliance Coach for the same price!!!!! Remember, I
was a manager once too. I’ve supervised site personnel. I understand
that you want to maintain control over who is able to contact your
outside consultants and to ensure that the information that is
gained is given to key people who have the ability to share with
other sites so all your entire staff learns from the answers given
and you reduce repeat questions.
All of that for less than
$1.92 per day!!!
So for only $699 per year … PER YEAR NOT per month, per day or per
hour... PER YEAR… you can have the
confidence to know that I am there to help you answer your compliance
questions and help you resolve your difficult scenarios! For less than
$59 per month, you can have the guarantee that you will get a response
to your email or fax within 48 hours and for less than $1.92 per day I
will answer your question with sound, practical advice based on the
latest rules, interpretations and opinions held by our Industry.
information that is based on true Tax Credit compliance expertise,
steeped in reality and filled with proven management strategies! All
for less than $1.92 per day!!!
"Thanks for your outstanding consulting
services. It's great to have an organization with your expertise to
call upon in our hour of need!!" Joan
Taylor, Property Administrator, Corcoran Jennison Management Company
(Villages at Marley Station), Glen Burnie, MD
Click here for print version (PDF) of Compliance Coach Brochure and
The most common start to any telephone
call I get goes something like this…
I’ve got a question and can’t get
anyone to give me a straight
Can you help me?”
Sound familiar? It’s one of the biggest frustrations for site
- NO ONE TO TALK TO!
- NO ONE TO GET ANSWERS FROM!!
- NO ONE TO USE AS A SOUNDING BOARD AND TO HELP THEM
WORK OUT A CONVOLUTED APPLICANT SCENARIO!!!
Stop setting your site staff up to fail
and give them what they need most…
Here is just a sampling of some of the
most recent Tax Credit compliance questions we have gotten from our Compliance Coach
customers and most importantly, the answers they needed.
Question: I am unsure of the policy of the wait list.
How detailed do I have to be and what are the requirements? I am
the manager of a property that has been up and running for
approximately 3 years, although I
have only been here 6 months. The current wait
list has approximately 5 times the applicants than the number of
apartments that I have. There must be a method to this madness,
but unfortunately, I have been unable to determine the “system” they
were using. Do you have any suggestions on how to proceed in the
Answer: Although the IRS does not impose
any wait list requirements, the owner may have agreed to requirements
with other entities. Review your Regulatory Agreement, funding and
syndicator agreements to determine if you have any wait list
requirements. For example, your owner may have agreed to give
preference to households who are on the Public Housing wait list. If a
separate promise or agreement was not entered into, you will need to
create your own policy.
A good starting point is to
create a wait list application and agreement (you do not have to
verify the information on the application). The agreement should state
how many attempts you will make to contact the household and that the
household will be removed if you are unable to reach them or if they
do not respond. Wait lists should be updated regularly.
Stay in contact with the applicants to determine if any changes
occurred that would make them an unqualified household and to make
sure they are still interested. Retain the wait lists to show
the attempts made and the ending result. If used properly, wait
lists can be useful in reducing vacancy and expenses. You may also
want to create a Wait List for each unit type you have. For example, 2
BR/2 BA 60% Income Limit Units; 2 BR/2 BA 50% Income Limit Units.
Question: We are planning to purge our
former resident files, and need to know what we must keep. Our files
are very thick, and we have limited storage space. What must we keep
in order to prove the resident qualified the unit?
Answer: Unfortunately for the on-site
team, you must keep almost everything! When storing records of former
residents, you must retain the following documents: Application,
Verification forms (including clarifications), Tenant Income
Certification, Lease and addenda, and HUD/RD documents (if
applicable). These documents must be retained for each initial
certification and recertification.
You are allowed to purge the
files of information that does not apply to eligibility, such as
letters to residents advising them that the rent is past due, or
disturbance notices. However, in addition to the documents
listed above, it is suggested that you retain a copy of the resident’s
ledger, showing the date and amount of each rental payment. If a
resident paid an amount in excess of the maximum allowable rent,
documentation of the reason should remain in the file. For
example, a resident breaks a window in their apartment, and must pay
for the damage. If the payment for the damage was made with the rental
payment, then you must keep documentation that the payment was not for
rent. If management did not renew a resident’s lease, documentation of
the reasons for non-renewal should be maintained. Also, retain
documentation of the correction of any noncompliance issues raised by
the State Agency or other auditors. The best time to purge your
files is during the year-end audit.
Question: An applicant who owned a home signed a Quit Claim Deed,
which turned the property over to his son about a year ago. Do I need
to verify this? If so, what information do I need to obtain?
Answer: A Quit Claim Deed is treated as
an asset disposed of for less than fair market value. The applicant
needs to provide you with a copy of the deed, and a statement of the
market value of the home. The difference between the actual amount
paid for the home and the fair market value will be considered an
asset disposed of for less than fair market value. Therefore, if the
home has a fair market value of $100,000 and the son only paid $1.00
for it, the disposed of asset is $99,999. You will then treat the
disposed of asset ($99,999, in this example) as if the household still
has the asset for the next two years. This means this value will be
placed in the asset income calculations which will force the manager
to calculate the imputed asset value.
I’ve answered hundreds and hundreds of questions for site
managers, compliance specialists and other Tax Credit professionals
Compliance Coach service!
simple in nature. Some very complex. I am not afraid to answer your
question and will always be sure to tell you when it is based on
current regulations, a common industry opinion and/or my own
worked in the Tax Credit industry since the beginning. I am well
aware of the history, changes and current environment. I've been on
site. I've been in compliance. I've worked closely with State
Agencies and investors across the nation.
Compliance Coach customer,
I will put all that to work for you!!