Tenant file audits
Every subsidy dollar rests on a clean, compliant tenant file. HOTMA rewrote HUD Handbook 4350.3 and how income and assets are calculated, and files must follow the new rules for certifications effective on or after January 1, 2027, sooner for the many State Housing Finance Agencies that have already moved LIHTC to HOTMA. We audit files the way reviewers do, and assist your staff in fixing what we find before the monitor visits the property.
Files that survive review
- Full and sampled tenant file audits scored against every documentation standard in the capital stack, from HUD and LIHTC to HOME, CDBG, and HTF, so a mixed-finance unit satisfies all of its overlapping requirements at once
- Every file reviewed for the appropriate income calculation method — HOTMA or HUD Handbook 4350.3 income and occupancy requirements — depending on the date and whether the State Housing Finance Agency has required HOTMA for LIHTC files
- HOTMA-ready income and asset documentation, including the new asset rules and self-certification thresholds
- EIV program compliance: policies, annual security training, Rules of Behavior, access authorization, and separate-file storage. The individual EIV reports are restricted, so we verify the safeguards, not the reports themselves
- Findings remediation and staff training so the next audit finds clean, compliant files, not problems
HUD guidance: HUD's HOTMA notices, H 2023-10 (extended by H 2025-07).
HOTMA: two methods until 1/1/2027, then one
HUD's compliance date for HOTMA in tenant files is January 1, 2027. But many state Housing Finance Agencies already require HOTMA in LIHTC files today, which means multifamily and mixed-finance properties are currently running two methods per file, the old HUD standard and the new HFA-required HOTMA standard, until the HUD date catches up. We help make both leases and files ready now, so the transition on 1/1/2027 is a formality instead of a scramble.
When the monitor has already been
A stack of findings, non-compliance notices, and 8823s is where a corrective action plan matters most. We work it two ways, whichever fits your team.
We can manage the plan directly, using our proprietary corrective action plan software and collaborating with your operations, property management, maintenance, and compliance staff, and meeting as often as the deadlines require to keep every correction on schedule. Or we train your leadership staff to run corrective action plans themselves. Either way, we build the plan and hold the team accountable to the deadlines, so findings are resolved before they turn into LIHTC recapture or disallowance, an enforcement action, or a flag.
Three simple steps
Audit
We start by confirming the applicable State HFA's specific compliance requirements, since these vary agency to agency, then pull and score files against the standards a MOR, state agency, or investor review will apply.
Remediate
Every deficiency gets a fix: missing verifications obtained, certifications corrected, documentation completed.
Train
Your team learns the standard the files were fixed to, so compliance becomes habit instead of cleanup.
Built for the HOTMA era
Income and asset rules changed more in the last three years than in the previous twenty. We track the changes as they land, so your files are reviewed against the current standard, not an outdated one.
When did someone last audit the files?
If the honest answer is too long ago, or the last review left findings behind, a file audit is the least expensive insurance in this business. Reach out.
Email Kari LaLonde