We have received several questions about the arrival of the 2010 income limits that are normally available by now. As you may know, HUD usually publishes their income limits in February/March. This year, they were not released until May 14.
The delay was brought about in part when the Housing and Economic Recovery Act of 2008, commonly referred to as "HERA," requirements were considered. HERA made statutory changes to how income limits are calculated for LIHTC and bond-financed properties. HERA protected owners from rent decreases in 2009, and established a new system for owners to hold their income limits and rents harmless beginning in 2010 - new and extremely convoluted!
IFA, and compliance monitoring agencies like IFA all across the nation, are all working furiously to decipher and take into account all the changes. We have a meeting next week with a national Section 42 expert, Liz Bramlet, who will help ensure we are on the right path.
The IRS requires that new income limits be implemented within 45 days of issuance; this puts us into the last week of June. It is our goal to get these limits out to you, in a format you can easily work with, by June 18. You will receive another notice like this one when we have them posted.
If you have any questions, please contact
Julie Noland, 515-725-4916.
You may also check out the
Novogradac Rent Calculator, which will help you understand the complexity of implementing the new requirements.