CHFA eNews: Multifamily
chfa enews - multifamily loan compliance 
April 24, 2017

colorado 2017 income limit and maximum rent tables published

The US Department of Housing and Urban Development (HUD) released income limits for 2017 on April 14, 2017. The 2017 income limit and maximum rent tables for Colorado are now available on CHFA’s website.

IRS Revenue Ruling 94-57 allows LIHTC project owners to rely on the previous year’s income limits and maximum rents until 45 days after HUD has released new income limits. Therefore, the new income and rent limits must be implemented no later than May 29, 2017. Please note the same timeframe applies to multifamily developments financed with loans through CHFA.

Exceptions for LIHTC projects: Since 2008, the IRS allows some LIHTC projects to use higher HERA limits and to be “held harmless” from decreases in limits. To identify the correct limits for your LIHTC project, it is essential to know its placed in service (PIS) date.
  • In 2017, HERA limits are still in place in many counties. To apply HERA limits, a LIHTC project must have PIS as of December 31, 2008.

  • Remember, once your LIHTC project is placed in service, it is NOT subject to any decrease in limits. To be “held harmless,” a LIHTC project must have PIS prior to the implementation date of the new limits. This year, LIHTC projects whose counties experienced a decrease in limits AND PIS before May 29, 2017 may continue to apply the same limits they used in 2016.

  • New projects that place in service on or after May 29, 2017 must use the 2017 income limits.

  • Note: HERA and hold harmless limits do not apply to properties that were not financed with LIHTC (e.g., properties with only HUD or CHFA loans). Multifamily projects that do not have LIHTC must use the 2017 limits.
Utility Allowance Reminder: Gross rents (tenant rent + utility allowance + non-optional fees) may not exceed the applicable maximum rent. As a reminder, updated utility allowances must be implemented no sooner and no later than the first day immediately following the 90-day resident notification period that begins with the new utility allowance schedule’s effective date.

To remain compliant when allowances increase and tenant rent must be decreased not to exceed the maximum rent, ensure that rents are lowered immediately following the 90-day period. Do not wait until a household is due for annual recertification to make this adjustment.

For detailed guidance, see CHFA’s Utility Allowance Memo

resolution trust corporation (rtc) 2017 income limit and maximum rents published

The FDIC has also released the RTC income limits for 2017. Income and rent limit tables for Colorado are now available on CHFA’s website.

If you have any questions, please contact your Program Compliance Officer or visit our website.

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