Psst… the IRS Reveals An Important Compliance Secret…
And We’ve Got the Blueprints!
Not sure what I am talking about? Feeling left out ‘cuz ya
haven’t heard about any secret or seen any blueprints? Well
you have… you just may not be aware of it! In fact, it came
directly from the IRS themselves. All laid out in 1 simple
“…the IRS will treat
all households documented as initially income-qualified
households as income-qualified
as long as the owner
demonstrates due diligence when completing the initial
income certification. Therefore, the owner does not violate
the Available Unit Rule when a unit is unintentionally rented
to a nonqualified household.”
[Highlights added for
This statement came directly from Grace Robertson (the
IRS's Program Analyst overseeing LIHC Program compliance) herself
when writing about how the IRS would handle Available Unit Rule
violations on 100% properties implementing the annual
recertification exemption! But she has said it before… numerous
times in fact. And she spelled it out thoroughly in Chapter 3 of the
8823 Guide (both the final and revised versions) when she defined
due diligence and then described what it looks like on a Tax Credit
property. Let me refresh your memory…
“Due diligence can be
demonstrated in many ways, including (but not limited to)
establishing strong internal
controls (policies and procedures) to identify, measure, and
safeguard business operations and avoid material misstatements of
LIHC property compliance or financial information.”
[Highlights added for emphasis]
In our heart of hearts we have always known policies and
procedures are crucial. We really didn’t need the IRS to tell us by
having them we were demonstrating strong internal controls and
standardized operations. Believing this fact isn’t the problem.
Writing them is!! Just finding the time is nearly impossible. Plus,
let’s be honest, it is a nasty job! Boring, tedious, and well, even
a little painful. But as the IRS has so poignantly pointed out to us
WE MUST GET THEM WRITTEN if we are going to avoid noncompliance
ESPECIALLY ON OUR 100% PROPERTIES!!
So here is the million dollar question…
Do You Have Standard Operating
Policies and Procedures Specifically Related To Housing Credits??
Unfortunately, the answer is probably no. At the very least, I
venture to guess they aren’t written down, and tested frequently.
But the time has come… you cannot afford to delay anymore! The IRS
has been very clear and is pushing your State Monitoring Agencies to
look for your policies & procedures especially when deciding if they
need to expand an audit or when making noncompliance determinations!
P&P Boot-Camp-In-A-Box Makes It EASY!!!
In October 2009, we conducted yet another one of our Policy &
Procedure Boot Camps, this one called P&P Boot Camp Revisited. This
was actually our 3 Boot Camp focusing on helping companies design,
WRITE, and implement their compliance policies and procedures in a
conducive environment AWAY from the office and with other industry
professionals focused on the same goal. During these Boot Camps, our
attendees actually wrote their policies with Elizabeth Moreland
helping them every step of the way. When the camp is over... so is
the majority of the policy and procedure task! It truly has been
incredible every time we have held such an event.
Now... we currently don't have another Policy and Procedure Boot
Camp event schedule. Probably will do one again, just not sure when.
BUT, in the meantime, I know you understand just how crucial getting
these policies written is to your company and compliance on your
properties! So we have created our P&P-Boot-Camp-In-A-Box to help
you accomplish this task! And trust me when I tell you… it is
the next best thing to attending an actual live event!
Your P&P Boot Camp-In-A-Box contains…
The Main P&P Boot Camp Guide:
Giving vital information on how & why policies and procedures are
needed plus step-by-step instructions on how to write them. It
also breaks down the critical Tax Credit policies that all of us
need and gives sample policy statements as well as a list of
bullets that walk you through all of the considerations you should
take in writing the procedure portion! All you need to do is fill
in the blanks!
A Housing Credit Compliance
Supplement: Details the important rules of Tax Credit
compliance so you have them at your fingertips when writing your
actual P&Ps. The supplement covers all the important compliance
rules including unit transfers, the Unit Vacancy Rule, students,
Next Available Unit Rule and much, much more! The best part is
that the supplement is written in plain-English and carefully yet
succinctly explains the rules and the considerations each of us
must make when applying it.
and ARE YOU READY FOR
A Disk Containing ELECTRONIC SAMPLES
OF THE ACTUAL P&Ps Produced By The Attendees Of Our Live Events!
Since we know that you have a limited time to write these
procedures, we wanted to give you every advantage and that is the
reason for including this disk! Besides containing our Policy &
Procedure Template, this disk contains the electronic version of
all the actual policies & procedures produced at the two live
events we held in 2002 and the one we did in 2009! So most of the
work is done for you!!! All you have to do is read through the
different samples for each policy created by these attendees and
choose which one you want to adopt as yours. Or you can combine or
pick & choose from several different samples ultimately creating a
set of policies that are perfect for your company! As I said… we
want to help you accomplish this task fast!
PLUS... if you think you might need some
help along the way...
Add a 1 Year
Subscription to the Compliance Coach to your
P&P-Boot-Camp-In-A-Box! The perfect companion! By adding the
Compliance Coach to your P&P-Boot-Camp-In-A-Box, you have the
ability to ask me questions and run your thoughts past me as you
create these policies! Our Compliance Coach service gives you up
to 1 hour of my time per month to ask me questions, so if you get
stuck or find yourself debating which direction to go on a
particular policy, you can run it past me. (This does not include
me researching an issue or reading and/or approving your policies
rather is a Q/A service to assist you in making the correct policy
1 Year Subscription to the Compliance Coach!
1 Year Subscription to the Compliance Coach!
CLICK HERE to add to shopping cart!!
(You will be given the choice
between Option A and Option B when you get to the shopping
CLICK HERE to
order offline now
(This will give you a Product Catalog and Order Form in a PDF
format that you can print and submit via fax or mail with your