HUD’s LIHTC Data Collection Improving Completeness and Quality January 14, 2014 Michael Hollar Senior Economist U.S. Department of Housing and Urban Development January 2014 TRACS Industry Meeting

Collection of 2012 LIHTC Data 1.Importance of Submitting Complete & Quality Data 2.Assessment of 2012 Data 3.Schedule for 2013 Data 4.Technical Assistance from HUD

HUD’s LIHTC Data Collection Improving Completeness and Quality 1.Importance of submitting complete & quality data. Provide a clear picture of program for legislators. GAO Report criticizing HUD’s efforts (GAO-13-66) LIHTC: Agencies Implemented Changes Enacted in 2008, but Project Data Collection Could Be Improved “The Department of Housing and Urban Development (HUD) voluntarily compiles the largest public database on LIHTC projects, but the data it collects from HFAs are incomplete. Despite HUD efforts to improve its data collection process, the database may undercount projects, in part because HUD did not follow up on potentially incomplete information.” Inform Federal alignment efforts. Potential savings from reducing regulatory burden.

HUD’s LIHTC Data Collection 2.Completeness of 2012 Data A.Timeliness: 65% of HFAs submitted by first week in Oct. 90% of HFAs submitted by end of Nov.

HUD’s LIHTC Data Collection 2.Completeness of 2012 Data B.Submitted: 1.64 million units (~85%) 2.80 million Individuals

HUD’s LIHTC Data Collection 2.Completeness of 2012 Data C.Unit Identifiers: Complete Address:12% missing 20% non-geocodable to tract PIN:8% missing BIN:5% missing

HUD’s LIHTC Data Collection PIN and BIN : 1.PIN / State ID: consistency b/n tenant and property forms (Tenant Form ‘PIN’ = Property Form ‘State ID’) 2.BIN: HUD requires IRS official format. IRS Notice 88-91: “The BIN will consist of a two character state designation (identical to a postal state abbreviation) followed by a two digit designation representing the year the credit is allocated, and a five digit numbering designation. For example, the identification number for one of 25 buildings allocated a credit in 1987 by the Connecticut Housing Finance Authority (the only housing credit allocating agency in the state) might read CT ”

HUD’s LIHTC Data Collection Address: 1.IRS collects BUILDING address; HUD collects UNIT address. 2.USPS Standard: Publication 28 - Postal Addressing Standards: No punctuation ( periods, commas, slashes, hyphens, etc. ) Example: 1500 E Main St Unit Numbers should not be in Street field.

HUD’s LIHTC Data Collection Common Address Errors: Missing Information: street, city and/or zip Missing Information: street, city and/or zip Multiple Addresses: ANDERSON PARKWAY Multiple Addresses: ANDERSON PARKWAY 61, 63, 65 Holiday Drive Missing street number: OLD CHESIRE TURNPIKE Missing street number: OLD CHESIRE TURNPIKE Apt. # (or range) in Street Field: 437 Manor Road Apts Apt. # (or range) in Street Field: 437 Manor Road Apts Extra Info: BUILDING 4 OF ORCHARD ROAD Extra Info: BUILDING 4 OF ORCHARD ROAD Not Really a City: “X” or “-” Not Really a City: “X” or “-” Wrong State: AL as default Wrong State: AL as default

HUD’s LIHTC Data Collection 2.Completeness of 2012 Data D.Income/Rent Information:

HUD’s LIHTC Data Collection 2.Completeness of 2012 Data D.Household Information:

HUD’s LIHTC Data Collection Prior to submitting remove: Market Rate Units Market Rate Units “Test” Units “Test” Units Tenants who moved out prior to December Tenants who moved out prior to DecemberInclude: Vacant Units Vacant Units All members of household All members of household Tenant information submitted to other HUD systems Tenant information submitted to other HUD systems

HUD’s LIHTC Data Collection 3.Collection of 2013 Data No changes to collection form. No changes to collection form. MITS/NAHMA standard v3.1 (as of 12/13/13) incorporated previous changes. MITS/NAHMA standard v3.1 (as of 12/13/13) incorporated previous changes. Submission due dates staggered in September. Submission due dates staggered in September. May submit as early as June. May submit as early as June.

Schedule 3.Submission Due Dates States beginning withA– H:Week of Sept 1. I– M:Week of Sept 8. N– P:Week of Sept 15. Q– Z:Week of Sept 22.

HUD’s LIHTC Data Collection Improving Completeness and Quality 4.Technical Assistance from HUD: New Funds for Technical Assistance through OneCPD OneCPD provides technical assistance to CPD grantees. How to request technical assistance? Identify specific need related to LIHTC data collection. For example, training property managers or cleaning data. Request assistance from HUD ( or call Mike Hollar ). Work conducted by Abt or subcontractor.