Kolena AI Agent
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.
Impact
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
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
Typical inputs
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
Output
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
What it extracts
· 18 fields
- Form
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.
- Form
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.
- Table
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.
- Table
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%).
- Table
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.
- Table
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.
- Table
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.
- Table
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.
- Table
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.
- Table
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.
- Form
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.
- Table
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.
- Table
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.
- Table
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.
- Text
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.
- Table
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.
- True/False
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.
- Classification
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.
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
Human review
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.
Where it fits
Affordable-housing tenant income certification and file compliance
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
After
Who uses it
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
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See LIHTC / HUD Tenant File Review on your documents
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