Flaherty & Collins Properties' Compliance Department directs and monitors federal, state, and local compliance of approximately 5,000 affordable housing units in Georgia, Illinois, Indiana, Kentucky, Michigan, Ohio, Tennessee, Virginia, and Texas.
All tax credit communities are visited by members of the Compliance Department regularly each month to review files and provide training, answer questions and provide assistance. In addition, all tax credit communities receive a 10% - 20% file review each month performed by Compliance Monitors.
The Compliance Department consists of eight members. The Compliance Department is well trained and, as a whole, has earned the following designations:
• HCCP – Housing Certified Credit Professional
• COS – Certified Occupancy Specialist
• COSP – Certified Occupancy Specialist for Public Housing
• AHM – Assisted Housing Manager
• LIHC – Low Income Housing Tax Credit Specialist
• MORS – Management Occupancy Review Specialist
State Agencies
The Compliance Department has worked extensively with the Indiana Housing and Community Development Authority (IHCDA), and its administration and monitors, and with the 2003 addition of properties in Kentucky , Ohio and Michigan; 2004 addition of properties in Illinois; 2008 addition of properties in Tennessee, Georgia, and Virginia; and the 2009 addition of properties in Texas, relationships have also been established with their respective housing agencies.
To build on the relationships with all state agencies with which we are involved, members of the Compliance Department, as well as other Flaherty & Collins employees ranging from the Vice President of Property Management to our Regional Property Managers and site personnel, regularly attend training and seminars provided by each state.
Report Schedule
To stay on top of all community activities, all sites must complete a monthly Event Tracking report, which is due to the Compliance Department by the 8th of each month. The Event Tracking log lists all move-ins, move-outs, and recertification that occurred during the month.
Additionally, the Compliance Department is responsible for sending the monthly recertification notices to all residents who reside in our affordable housing communities. Each site is responsible for updating a Recertification Tracking report and keeping an updated Recertification Worksheet, which is reviewed during the monthly visits.
Structure & Training
Flaherty & Collins Properties recognize that providing a comprehensive training program is the key to building a solid reputation of excellence in the field of managing affordable housing. The Compliance Department is constantly working to provide training for its on-site compliance staff through in-house training, one-on-one training and outside training courses.
It is the goal of Flaherty & Collins Properties to provide our sites with the training and resources needed to gain knowledge and understanding of the IRS Section 42 program. Moreover, with this training and knowledge, it is our goal for each site PM and/or site compliance member to be responsible for the approval of the move-in and re-certification files at their property
The PM's and/or compliance members assigned to LIHTC communities are eligible to approve applications on site once the following criteria have been met:
• Successfully completed the initial probationary period of 30 to 90 days depending on prior LIHTC experience.
• Successfully participate in the Flaherty & Collins one-on-one and/or in-house training sessions.
• Successfully completes at least one outside training class specifically devoted to the LIHTC program, state agency training, TCS Tax Credit Specialist, and HCCP.
• Consistently has applications approved through the Compliance Department with minor to no follow up.
Compliance provides training at Flaherty & Collins each Wednesday, with two different compliance classes being offered: a basics class and an advanced class. The classes are held on alternating weeks. Any new employee located at an affordable housing community is required to attend the basic compliance training class the first Wednesday it is provided after their hire date. Additionally, compliance training sessions are open to any employee (corporate or site).
Flaherty & Collins also holds annual compliance training. This training is a full day class, which discusses new procedures and/or policies, the industry as a whole, state findings, etc.
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