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 sentence… “…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 emphasis]

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!

Our 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 THIS?…

• 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 decisions.)

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