Florida Housing Finance Corporation has released a draft policy for allowing the new Income Averaging set aside election. FHFC aims to allow developments that have not yet received their 8609s to elect the new option. The following are some of the proposed requirements around income averaging:
- Units utilizing NHTF funding required to be set aside for households at 22% AMI or below cannot be offset by units at an AMI greater than the AMI category applicable to NHTF.
- For 4% projects, SAIL units must be included with HC units for income averaging.
- On 4% Housing Credit transactions that include SAIL ELI funding, Income Averaging may only be used when the SAIL ELI loan is repaid to Florida Housing within a short period to be determined by Florida Housing and the ELI set-aside requirement is applicable for the 50-year Extended Use Period.
- The ELI set-aside for 9% Housing Credit Family and Elderly developments will be increased to a 15% set-aside. Out of this 15% set-aside, no more than two-thirds (2/3) of the ELI units (10% of the total units) may be included in the Income Averaging calculation, and the remaining one-third (1/3) of the ELI units (5% of total units) will be considered 60% AMI units for the purpose of the Income Averaging calculation.
Projects requesting to change to the income averaging election will also have additional requirements, including:
- Submit an updated market study with an Update Letter provided by the Underwriter
- Board Approval is required
- If Link Memorandum of Understanding was already executed, it must be re-executed
- Additional fees related to the updated market study and CUR