Compliance Frequently Asked Questions
Compliance can be complicated. Below is a compilation of frequently asked questions and answers. If you have questions that aren’t answered below, please contact Multifamily Oversight staff.
FAQs
Yes
It depends. A unit cannot be occupied entirely by full-time students unless at least one of the following exceptions applies:
- A student receiving assistance under Title IV of the Social Security Act (TANF)
- A student enrolled in a job training program receiving assistance under the Job Training Partnership Act, or under a similar federal, state, or local law
- A student previously in foster care
- Students who are a married couple entitled to file a joint income tax return
- Students who are single parents with children, where neither the applicant/tenant nor the children are claimed as dependents on anyone else’s tax return
If the household does not meet one of the above exceptions then the household is not eligible. Management will be required to obtain student status verification from the educational institution. A class schedule or registration record is not sufficient supporting documentation. Refer to TSAHC Compliance Manual Section 2.4(C).
No. Documents must always be dated the actual date of signature.
Yes. All three pages of the Income Certification must be completed at initial certification and recertification. Refer to TSAHC Compliance Manual Section 2.4(D).
No. Residents may opt out of disclosing any/all of that information. Refer to TSAHC Compliance Manual Attachment One.
For asset accounts, checking, savings, and other financial investments, owners must obtain at least one statement reflecting the current account balance. Refer to TSAHC Compliance Manual 2.6(D).
Yes. Where actual income can be determined, use it. Refer to TSAHC Compliance Manual Section 2.6(C)–(D) for the treatment of assets as it depends on total household assets relative to the applicable asset limitation threshold.
Tax-exempt bond properties use the Multifamily Tax Subsidy Income Limits (MTSP), based on the county’s Area Median Gross Income. HUD posts these annually. For limits specific to your property, contact TSAHC Multifamily Oversight staff.
Current forms are posted on the Property Manager Downloads page, on the TSAHC website. Available forms include:
- Tenant Income Certification Form and Instructions
- Student Self Certification, Student Status Verification, and Affidavit of Student Financial Assistance
- Asset Self Certification and Asset Self Certification Worksheet
- Certification of Zero Income
- Documenting Assets for Tax-Exempt Bonds
- TSAHC Tenant Consent and Release
Contact Multifamily Oversight staff with questions about which form applies.
HOTMA established a threshold that determines when income must be imputed on household assets. HUD publishes and annually adjusts the amount. Per the TSAHC Compliance Manual Section 2.6(A), owners must use HUD’s published values, available on HUD’s Annual Inflationary Adjustments and Passbook Rate page (https://www.huduser.gov/portal/datasets/inflationary-adjustments-notifications.html)
Per §2.6(D), all assets must be documented at initial certification and every third year using firsthand or third-party verification. In the intervening years, if household assets are at or below the applicable threshold, they may be documented using the Asset Self Certification form. If assets exceed the threshold, each asset must be documented every time an income certification is required, regardless of where the household falls in the three-year cycle. Refer to TSAHC Compliance Manual Section 2.6(D).
No. As a result of HOTMA, certifications and recertifications completed after January 1, 2024 must not include foster children or foster adults as household members, and their income is not counted. If this change causes a recertified household’s income to exceed 140% of the applicable limit, follow the Available Unit Rule. Refer to TSAHC Compliance Manual Section 2.4(A).
- Third-party payment platforms (Venmo, PayPal, Cash App): payments received for work performed count as income, and any balance maintained in the account is an asset.
- Zelle: payments received for work count as income. Because Zelle does not maintain an account balance, it is not treated as an asset. Reimbursements received through Zelle are not income.
Related: for individuals earning through Uber, DoorDash, or similar contracted transportation and delivery services, two consecutive paystubs are not sufficient — TSAHC requires a minimum of 120 days of income documentation. Refer to TSAHC Compliance Manual Section 2.5(E).
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