LIHTC / HUD Tenant File Review
Review an affordable-housing tenant certification file end to end - completeness, income and rent eligibility, income and asset calculation, the student rule, and form validity - with every exception severity-ranked and traceable to the source form.
Line-by-line tenant-file review that took a compliance analyst hours per file compressed to minutes, with every exception severity-ranked and traceable to the source form
per tenant file
What it extracts
18 extraction fields
- File Summary
- A one-look roll-up of the file's spine - unit, set-aside/AMI designation, household size, certification type, total income versus limit, and net rent, utility allowance, and gross rent versus the rent cap - so a reviewer can orient before reading each check.
- Tenant Income Certification (TIC)
- The Tenant Income Certification field set - household members and relationship codes, income by category (A-D and total E), assets, rent, utility allowance, AMI level, and signatures - captured as the certification of record under Section 42.
- Required Documents Checklist
- The file-completeness checklist - one row per document an LIHTC/HUD tenant file must contain, recording whether each is present, where it appears, and any note.
- Income Eligibility Check
- Tests household income against the unit's designation under Section 42(g): total certified income at or below the income limit, at or above any minimum (unless a voucher applies), and whether the household is over-income (140%).
- Rent and Utility Allowance Check
- Tests the rent restriction under Section 42(g)(2): net rent matches the most restrictive limit, gross rent (rent plus utility allowance) is within 30% of the imputed income limitation, and the utility allowance matches the current schedule.
- Tenant Income Certification (TIC) Issues
- Exceptions found on the TIC itself - household composition, income categorization and totals, asset documentation, zero-income certifications, and student marking - with the operator's known-false-positive and de-minimis rules applied.
- Income Calculation Worksheet Issues
- Exceptions in the four-way income calculation worksheet for employment income - all sources captured, the four methods filled, correct pay frequency, and the math footing - scoped to employment income only.
- Employment and Income Verification Issues
- Exceptions in employment and income verification - a valid third-party employment verification plus consecutive paystubs, or a self-employment affidavit with tax-return support - with the correct treatment of government-completed sections.
- Asset Certification and Verification Issues
- Exceptions in the asset self-certification and verification - form presence keyed to the HOTMA indexed threshold, completeness and signatures, and reconciliation of asset amounts and imputed asset income against the TICQ.
- Tenant Income Certification Questionnaire (TICQ) Issues
- Exceptions in the Tenant Income Certification Questionnaire - required rows checked, income and asset values and supporting documentation present, and the questionnaire's category and de-minimis rules honored.
- Student Status Determination
- The student-rule determination under Section 42(i)(3)(D) - whether the household is all full-time students and, if so, which of the five statutory exceptions applies and whether it is documented.
- Child/Spousal Support Verification Issues
- Exceptions in the child/spousal support affidavit - completeness and each adult's signature and date, with name/unit OCR typos flagged as minor.
- Rental History Verification Issues
- Exceptions in the rental-history verification - whether it covers the most recent two years - allowing for an empty form when the applicant was homeless.
- Application for Housing Issues
- Exceptions found only within the Application for Housing form - completeness, internal consistency, un-initialed date corrections, and required Yes/No answers - or a critical flag if the form is missing.
- Applicant Screening Report Result
- The applicant screening report status - approved when the individual result is Accept, or a prompt to submit for review when the report is missing.
- Form Version Validity Issues
- Forms whose version is invalid for the move-in date, checked against the form-validity schedule using the move-in date rather than the current date.
- Unsigned Changes Requiring Initials
- Whether every handwritten change or correction across the forms has been properly initialed - True when the file is clean, False when an initial is missing.
- File Review Determination
- The single overall verdict for the file - pass, approve with minor corrections, return to preparer for a critical or eligibility issue, incomplete for a missing form, or needs manual review - choosing the most severe condition when several apply.
Where it fits
Affordable-housing tenant income certification and file compliance
Upstream
Applicant intake and income/asset collection - a leasing or compliance team assembles the tenant certification packet (application, TIC, verifications) at move-in or annual recertification
This step
Internal tenant-file compliance review
Downstream
- Correction / return to preparer for deficient files
- Submission to the state allocating agency (HFA) and investor/asset-management reporting
- Annual recertification and the available-unit rule at over-income
What it needs
Documents
- Tenant Income Certification (TIC)
- Tenant Income Certification Questionnaire (TICQ)
- Application for Housing
- Employment and income verification and paystubs
- Four-way income calculation worksheet
- Asset self-certification and third-party asset verification
- Student status questionnaire / verification
- Certification of zero income
- Child / spousal support affidavit
- Rental history / landlord verification
- Applicant screening report
- Move-in / rent & income qualification sheet
Systems
- Property management / compliance system
- Document repository
- State agency compliance portal
Prerequisites
- The unit's set-aside / AMI designation and the applicable income and rent limits
- The current utility allowance schedule for the property
- The move-in / rent & income qualification sheet for the unit
- The form-version validity schedule and the issue-severity guidelines
What it produces
A per-file compliance result - a required-documents checklist, income/rent eligibility and student-rule determinations, a severity-ranked exception log per form, and a single overall file determination
Delivered to
- Correction queue / return to preparer
- Compliance workpaper / file of record
- State agency submission package
Review model
A compliance analyst reviews each flagged exception, its severity, and the cited form location before the file is cleared, corrected, or returned to the preparer.
Who uses it
Volume fit
Works best for
compliance teams reviewing dozens to hundreds of move-in and recertification files a month across an affordable-housing portfolio
Too small for
a one-off review of a single file
Grounded in
- Internal Revenue Code Section 42 (Low-Income Housing Credit)verified as of 2026-07-22
- IRC Section 42(g)(1) - minimum set-aside (20-50, 40-60, and Average Income Test)verified as of 2026-07-22
- IRC Section 42(g)(2) - gross rent limitationverified as of 2026-07-22
- IRC Section 42(i)(3)(D) - full-time student rule and the five exceptionsverified as of 2026-07-22
- 26 CFR 1.42-15 - Available Unit Rule (140% over-income)verified as of 2026-07-22
- 26 CFR 1.42-5 - compliance monitoring and tenant file recordkeepingverified as of 2026-07-22
- HUD Handbook 4350.3 REV-1 (Occupancy Requirements of Subsidized Multifamily Housing Programs)verified as of 2026-07-22
- Housing Opportunity Through Modernization Act of 2016 (HOTMA) - HUD final rule, income and asset provisionsverified as of 2026-07-22
Changelog
- July 2026
based on a production deployment at an affordable-housing developer-operator
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