LIHTC Reminder: New HUD Tenant Demographic Data Collection Requirements

The California Tax Credit Allocation (CTCAC) Compliance Section sent a notice to property owners and managers of low-income housing tax credit (LIHTC) sites about policy changes affecting the collection of tenant demographic data. The policy change is the result of the Housing Economic Recovery Act of 2008 (HERA), which requires that all LIHTC programs collect demographic and income information annually via the state housing agencies administering the tax credits.

Starting in 2011, CTCAC’s memo says that LIHTC site owners will need to use one of two forms to collect information: Tenant Income Certification (TIC) with Supplemental Information Form (for all move-ins as of January 1, 2011) or Supplemental Information Form for Existing Households (all existing households at all tax credit projects with tenants living in tax credit units on or before December 31, 2010, including projects in the extended use period). “Data for the form should be captured by the owner or management agent at the annual recertification date for the household,” states the memo.

The CTCAC notice reminds property owners and managers that the conventional number format for the date on the new TIC forms has changed (YYYY-MM-DD instead of the usual MM-DD-YYY). In addition, the new TIC requires the last four digits of a resident’s Social Security Number (SSN), but the LIHTC program does not require citizenship or legal status in this country to occupy a tax credit unit. CTCAC alerted owners and managers that it has discussed this with HUD, but is advising owners and managers that if a resident does not have an SSN, to use the month and year of the resident’s or applicant’s birthday in this format: MMYY. So if a resident’s birthday is January 23, 1965, the owner can use 0165 for the last four Social Security numbers.