California Considers Moving Up Placed-in-Service Application Timeframe
The California Tax Credit Allocation Committee (TCAC) is considering several proposed regulation changes to its low-income housing tax credit requirements. One of these changes would include having the owner of a site file a placed-in-service application within six months of the project’s completion instead of the current one-year time frame.
According to the California TCAC, providing earlier notification of a project’s placed-in-service date would enable staff to conduct an initial compliance monitoring by the end of the second calendar year following the placed-in-service date as required by federal regulation Section 1.42-5(c)(2)(ii)(A).
Additional proposed language clarifies that service amenity changes must be explained at the placed-in-service date. In addition, the sponsor would be required to certify that services are in place, and to provide executed contracts and service values. According to the TCAC, these clarifications would help to assure that the committed services are already in place.