The New Hampshire Housing Finance Authority (NHHFA) recently issued its Income Averaging (IA) policy. Both four and nine percent Low Income Housing Tax Credit projects are eligible to select IA as a minimum set-aside. According to the federal statue, the average income limitations under this set-aside shall not exceed 60 percent of area median income (AMI). The income limits permitted are: 20 percent, 30 percent, 40 percent, 50 percent, 60 percent 70 percent and 80 percent of AMI.
The monitoring fee will be increased from $600 per unit to $1,000 per unit for any project that elects IA. NHHFA states that all projects which have been issued an 8609 and did not select IA at its minimum set-aside election are unable to change its set-aside election. Also, if a project fails to meet the first-year minimum set-aside requirement at the close of the first taxable year of the credit period, the noncompliance cannot be corrected and the owner is prohibited from ever claiming the credit awarded under the current allocation.