All posts by Thom Amdur

Thom joined National Housing & Rehabilitation Association (NH&RA) in 2004 and currently serves as its as Executive Vice-President and Executive Director. NH&RA is a national trade association and peer-network for affordable housing and tax credit developers and related professionals including: investors, lenders, public agencies and professional advisers. Thom directs the association’s day-to-day operations including legislative and regulatory advocacy, committee activities, conferences and events, publications, financial management and strategic planning.

Thom also serves as the Executive Director of the Tennessee Developers Council, a state-wide trade association for affordable housing developers and professionals active in Tennessee. In 2013 he spearheaded the launch of NH&RA’s Preservation through Energy Efficiency Project, a major educational initiative supported by the John D. and Catherine T. MacArthur Foundation. Thom also serves on the Board of Directors for International Center for Appropriate & Sustainable Technology (iCAST) as well as the Advisory Board for its ResourceSmart program, a turn-key, cost-effective, green rehab provider for multifamily affordable and market-rate housing communities and nonprofit facilities.

Thom is a frequent speaker at affordable housing, sustainable development and tax credit industry events and has been published in a variety of industry journals including Tax Credit Advisor, Independent Banker, and the Novogradac Journal of Tax Credit Housing. Thom also serves as the Associate Publisher of Tax Credit Advisor, a monthly magazine for tax credit and affordable housing professionals and is an Executive Vice-President at Dworbell Inc., a boutique association management and communications firm in Washington, DC.

Thom was previously employed at a national lobbying firm focusing on financial services and technology issues. Prior to moving to Washington, Thom worked in media relations in the New York State Assembly and as a research assistant for New Hampshire Governor Jeanne Shaheen. Thom graduated Magna Cum Laude from Tufts University with a double major in Political Science and History.

Woda Cooper Companies Celebrates Grand Opening in Hopewell, VA

| Member News

A grand opening celebration was held Tuesday, December 3, at Freedman Point, 311 E. Cawson Street, Hopewell, VA, to mark the opening of the new 68-unit affordable apartments within a mixed-use community. The $14.4 million community was developed by Woda Cooper Companies, Inc., Columbus, OH. Co-developer is Bay Aging,  Urbanna, VA.

In addition to two- and three-bedroom apartments, the new property also brings a large commercial space to be developed for retail businesses or professional offices. This will complement many other nearby retail businesses, restaurants, service outlets, and community amenities including the adjacent Appomattox Regional Library.

Freedman Point was supported through Low Income Housing Tax Credits allocated by the Virginia Housing Development Authority (VHDA).  Rents for apartments at Freedman Point are affordable for families and seniors earning up to 60% of area median income (AMI).

“Across Virginia, we’ve seen how quality, affordable housing has transformed lives and communities,” said VHDA Chief Executive Officer Susan Dewey. “We were pleased for Hopewell that this development received tax credits, because it will offer 68 new, affordable rental homes to make the city an even better, more prosperous place to live, work and raise a family. Woda Cooper has proven once again that it can build and manage high-quality, resident-friendly communities for all Virginians, and we look forward to continuing our work with them in the future.”

The new property is comprised of 48 two-bedroom, and 20 three-bedroom apartment homes in a four-story building with an elevator and onsite parking. Each unit offers attractive open-concept living spaces with modern finishes and many energy-saving features. Apartments feature large closets; ENERGY STAR appliances, including a dishwasher, frost free refrigerator and range; washer and dryer hook up; individually controlled heating/air conditioning; and energy efficient windows. Seven units have ADA features for those with disabilities. There is also an onsite management office, community room with kitchenette, high-speed internet, and rooftop terrace.

Energy efficiency to ensure low monthly utility bills for residents was a key component in designing and building Freedman Point.  It is expected to meet EarthCraft Gold standards certified by Viridiant. Hooker DeJong was architect and Woda Construction, Inc. was general contractor.

Catalyst for development

The City of Hopewell provided strong support the new housing option to answer a strong demand for affordable housing and support downtown. “The 68 affordable, high quality homes for working families will help spur revitalization and economic development in the neighborhood,” said Bruce Watts, Woda Cooper Vice President of Development. “We appreciate the City of Hopewell’s support in providing an incentive grant as one of the primary outreach initiatives of the New Downtown Revitalization Plan.”

The opening of Freedman Point represents the City’s desire to provide housing at all levels of affordability, said Hopewell Mayor Jasmine Gore. “This project addresses the need for affordable housing for public safety employees, downtown business employees and others who are employed but may not be able to afford market rate housing,” she said.

The Hopewell Redevelopment and Housing Authority (HRHA) also committed support, offering project-based rental assistance for eight units at Freedman Point. “Applicants seeking rental assistance are screened and approved by HRHA,” said Steven A. Benham, Chief Executive Officer of HRHA. “The development of Freedman Point and the inclusion of vouchers is consistent with the vison of the housing authority to create or participate in the creation of quality affordable housing for the citizens of Hopewell.”

Bank of America, N.A. was the primary equity investor for the housing tax credits, and contributed a Federal Housing Administration low interest permanent loan in conjunction with JLL.  “Bank of America was proud to work with Woda Cooper Companies to provide financing to help facilitate the revitalization in downtown Hopewell,” said Susan Monaco, Senior Vice President/FHA Chief Underwriter FHA Multifamily. “Freedman Point Apartments is a beautiful, new construction community that will provide 68 families with much needed affordable housing.”

About Woda Cooper Companies, Inc.

Woda Cooper Companies, Inc. and its affiliates are experienced developers, general contractors, and property managers specializing in the design, construction, and management of affordable multi-family apartments, senior communities, and single-family homes. Considered leading experts in the affordable housing industry, the Woda Cooper team is known for producing and maintaining high quality affordable housing. Affordable Housing Finance ranked the firm 13th overall among Developers and 26th overall among Owners in its April/May 2019 issue. Woda Cooper Companies, Inc. has developed and currently manages more than 300 communities and 12,000 units, operating in 15 states. In addition to its Columbus headquarters, the firm has offices in Savannah, Georgia; Indianapolis, Indiana; Shelbyville, Kentucky; Annapolis, Maryland; Mackinaw City, Michigan; Charlotte, North Carolina; and Norfolk, Virginia. For more information, call (614) 396-3200 or visit www.wodagroup.com

Enterprise and Wells Fargo Create the Housing Affordability Breakthrough Challenge

| Member News

Enterprise Community Partners and Wells Fargo are pleased to announce the Housing Affordability Breakthrough Challenge, a bold initiative designed to spark innovations that support housing affordability in the areas of construction, financing, and resident services and support.

A collaboration presented by Enterprise Community Partners with generous financial support from Wells Fargo, the Housing Affordability Breakthrough Challenge invites creative innovators to participate in a competitive application process with an opportunity to receive a grant and technical assistance to further scalable housing affordability solutions.

Upcoming Grant Period

As administrator of the Housing Affordability Breakthrough Challenge, Enterprise will coordinate the three-stage competitive request for proposals (RFP) based on feasibility, creativity and impact at scale of the ideas. The first-round RFP will be made available in mid-January. Fifteen finalists will participate in a pitch competition in advance of naming the final six grant recipients by July 31, 2020.

Total Awards

The Housing Affordability Breakthrough Challenge will award grants to six entities. Each grant will comprise more than $2 million in grant dollars as well as provide technical assistance over a two-year period. In addition, each of the final six grantees will have the opportunity to collaborate with a dedicated support team of Enterprise staff and other leaders in affordable housing and community development to help turn concepts into action.

Key Dates for the Housing Affordability Breakthrough Challenge

Enterprise and Wells Fargo will co-host two optional informational webinars for potential applicants to learn more about eligibility, the three program areas and the application process.

Webinar: Understanding the Housing Affordability Breakthrough Challenge RFP Process

Maryland Posts 2020 Draft QAP

| Qualified Allocation Plans

The Maryland Department of Housing and Community Development (DHCD) released the draft of the 2020 Qualified Allocation Plan (QAP) and Multifamily Rental Financing Guide (Guide) for public comment.  Draft comments are due by December 15, 2019 and can be submitted to dhcd.qap@maryland.gov. A summary of proposed revisions is available here. Please note the list only includes the major proposed revisions, not all revisions.

2020 QAP and Guide 1st Draft Document​s

​​​​​Regional meetings were held to solicit comments and discussion.

California Issues New Guidance on Manager Units

| Qualified Allocation Plans

On December 5 the California Tax Credit Allocation Committee issued new guidance relating to on site manager units at LIHTC Properties. California law 25 CCR § 42 requires an onsite manager, maintenance, or other responsible person for rental housing of 16 units or more. The Internal Revenue Service (IRS) guidance for manager or exempt units permits the cost of the unit to be included in eligible basis if the unit is reasonably required for the operation of the residential rental housing (IRS Revenue Ruling 92-61); however, the unit is excluded from the applicable fraction calculation. The IRS has further clarified that the person occupying the unit must be employed at the property where they reside. IRS Revenue Ruling 92-61 pertains to a full-time resident manager. Tenant keyholders, service coordinators, regional managers, and any staff that “float” from one project to another are all ineligible to reside in a manager unit.

California Tax Credit Allocation Committee (TCAC) staff receives applications that propose a manager unit to be occupied by an income-restricted tenant. Staff has become aware that in some cases, owners may be evicting these tenants upon employment termination, and that the eviction requirement is written into the employment contract. TCAC has received guidance from the IRS indicating this practice is not in compliance with federal LIHTC program rules. Restricted unit occupancy cannot be contingent upon the tenant’s employment by the project owner. In addition, by designating the unit specifically for occupancy by a manager, the unit no longer meets the general public use rule. If a unit is designated for a manager and is exempt from the applicable fraction, it is not a restricted low-income unit. As a result, a unit cannot be both an exempt manager unit and a restricted low-income unit.

If a TCAC applicant or project owner proposes to utiltize a low-income unit to meet California and TCAC manager unit requirements, the following applies: (1) the unit is considered a low-income restricted unit and must comply with all requirements associated with low-income restricted units; (2) the unit is included in the applicable fraction; and (3) the tenant cannot be evicted upon employment termination. This is applicable to all existing projects as well as current and future applications. If employment is terminated, the project owner is responsible for continuing to meet California and TCAC onsite manager unit requirements. Any application proposing to utiltize a low-income unit to meet California and TCAC manager unit requirements must include a description of how the project will meet those requirements if employment is terminated. An alternative option for an applicant that asserts the need for every unit to be income-restricted is for the project to provide an equivalent number of desk or security staff capable of responding to emergencies for the hours when property management staff is not working (TCAC Regulation § 10325(f)(7)(J)). These desk or security staff cannot be tenants of low-income restricted units.

New Hampshire Schedules Public Hearing on Draft QAP

| Qualified Allocation Plans

New Hampshire Housing Finance Authority (NHHFA) will hold a formal public hearing on December 20, 2019 at 10:00 AM. The hearing will be held at our office located at 32 Constitution Drive, Bedford, NH. Upon arrival, please enter at the East Entrance to attend the hearing.

The purpose of the hearing is to receive comments on the draft 2021-2022 Qualified Allocation Plan (QAP) for the Low Income Housing Tax Credit program (LIHTC). The QAP defines the process by which NHHFA will allocate LIHTCs to eligible affordable rental housing developments throughout the state of New Hampshire.

The draft 2021-2022 QAP will be available on NHHFA’s website prior to the hearing. You can also obtain a copy by mail by contacting Jessica McCarthy, New Hampshire Housing, PO Box 5087, Manchester, NH 03108-5087, by phone at 603-310-9272, or via email at jmccarthy@nhhfa.org. Written comments in lieu of participation in the public hearing are welcome and may be submitted by mail to Jessica McCarthy at the address noted above or by email to QAP@nhhfa.org.

Illlinois Proposes Changes to TEB Program; Seeks Comments

| Qualified Allocation Plans

Over the past few years, the Illinois Housing Development Authority (Authority) has seen an increase in applications seeking to use tax-exempt bonds (TEBs) and 4% Low-Income Housing Tax Credits (LIHTC) in connection with the acquisition and rehabilitation of developments that are subsidized by Housing Assistance Payment (HAP) contracts. To clarify information in the 2020-2021 Qualified Allocation Plan, the Authority plans to issue guidance specifically related to the review and underwriting of such applications. The Authority intends to publish this guidance on its website on January 1, 2020 and will refer to it in connection with the assessment of any PPA request currently under review at the Authority, regardless of the date the pending PPA request was submitted. Applicants with an approved PPA for a proposed transaction that (i) has not been presented to the IHDA board or (ii) has been presented to the IHDA board, but has not yet closed, may not be subject to each parameter referred to in the guidance. The Authority will assess transactions with approved PPA’s on a case-by-case basis and apply elements of the guidance in its sole, but reasonable discretion.

Public Comment:

Prior to the January 1, 2020 release of the guidance, the Authority is inviting members of the public to provide comments to the pending guidance in writing. Written comments may be sent to the Authority by or before 5:00 p.m. on December 13, 2019 via Multifamilyfin@ihda.org. In addition, a listening session regarding the proposed guidance will be held the week of December 16th in the Authority’s offices located at 111 E Wacker Drive, Suite 1000. The exact date and time will be communicated in a follow-up notification. Guests will be asked to register in the 111 E. Wacker Drive lobby as part of the building’s standard security protocol. Pre-registration is strongly encouraged. If you have any questions related to this notice or wish to pre-register for the feedback session, please send an e-mail to Multifamilyfin@ihda.org. The Authority kindly requests that registration requests be sent to Multifamilyfin@ihda.org by or before 5:00 p.m. on December 11, 2019.

As a reminder:

The 2020 and 2021 Qualified Allocation Plan is now available in the  Developer Resource Center  section of the IHDA website. Preliminary Project Assessments (PPA) and Low-Income Housing Tax Credit (LIHTC) applications must be submitted via the Multifamily Portal at https://mfportal.ihda.org. To better serve our environment, IHDA no longer accepts paper applications. In order to gain access to the Multifamily Portal, please submit a MF Portal Account Request Form from the IHDA website or you may find the form at https://ppa.ihda.org. If you require assistance with the Multifamily Portal, please contact mfportalhelp@ihda.org.

 

GUIDANCE ON PROJECTS WITH RENTAL ASSISTANCE CONTRACTS REQUESTING TAX-EXEMPT BONDS AND 4% LOW-INCOME HOUSING TAX CREDITS

Please note the following with respect to applications seeking to use tax-exempt bonds (TEBs) and 4% Low-Income Housing Tax Credits (LIHTC) in connection with the acquisition and rehabilitation of developments that are subsidized by Housing Assistance Payment (HAP) contracts.

Preliminary Project Assessments (PPA)

The documentation listed below is required as part of the Preliminary Project Assessment (PPA) review. If the documentation below is not provided to the Authority, or a PPA is otherwise incomplete, the Authority reserves the right to forgo completing its review of the application until the information is made available.

1)      Prior three years of audited property financials.

2)      Current year-to-date property financials.

3)      Current HAP contract with information on HAP renewal options and anticipated rents.

4)      Purchase contract.

5)      Current Physical Needs Assessment (PNA) using the Authority’s Standards for Property Needs Assessments.

6)      Projected replacement reserves trended as required in the QAP.

7)      Current appraisal using the Authority’s Appraisal Guidelines.

(a) If an appraisal is unavailable, an estimated valuation will be determined by the Authority using the lesser of current market rents or HAP rents and a cap rate obtained from CoStar. Adjustments will be made later once an appraisal is available.

(b) Deductions to the value will be made for immediate needs and deferred maintenance as identified in the PNA.

(c) LIHTC acquisition basis will be limited to appraised value less any immediate needs and deferred maintenance.

Please Note:

Any plan and cost reviews and draw inspection reports engaged by transaction stakeholders will be required to be shared with the Authority prior to closing and, if funded, throughout construction. In the event the transaction is ultimately presented to the IHDA Board, Authority staff will provide the Members of the Authority (IHDA Board) with a detailed disclosure of all fees, sources and uses, cash-out/equity generated, related party interests, date of last syndication (if applicable), and any identity of interests. The Authority reserves the right to order third-party reports directly and/or to provide the applicant with a qualified list of procured vendors.

 

GUIDANCE ON PROJECTS WITH RENTAL ASSISTANCE CONTRACTS REQUESTING TAX-EXEMPT BONDS AND 4% LOW-INCOME HOUSING TAX CREDITS

Please note the following with respect to the underwriting of applications seeking to use tax-exempt bonds (TEBs) and 4% Low-Income Housing Tax Credits (LIHTC) in connection with the acquisition and rehabilitation of developments that are subsidized by Housing Assistance Payment (HAP) contracts.

UNDERWRITING

In connection with the Authority’s underwriting of these types of application and, if funded, the ongoing management of these projects, the Authority will:

1)      Limit developer fee to the lesser of the amount calculated using the base developer fee calculation in the QAP or the Authority’s discretionary cap (currently $2,000,000). If the new owner is affiliated with the general contractor and/or the property manager, the developer fee will be reduced by the following items: general contractor overhead and/or one year of property management fees.

2)      On a related party transaction, require a seller note sized to 75% of the difference between acquisition cost and the exiting mortgage debt on the property. The seller note would be structured as must-pay debt in a second lien position and carry the same (or lower) interest rate as the first mortgage. The combined first mortgage note and seller note must meet the lender’s (the Authority, HUD/FHA, banks, or others) loan to value (LTV) and debt service coverage (DCR) requirements.

3)      Require projects to conduct a PNA every five (5) years to ensure capital needs are met and reserves are sized appropriately (expense paid by the property). Reserves will be adjusted based on the findings of the PNA. Borrowers will be responsible for notifying the investor and any other stakeholders in the deal of the requirement to potentially re-size (increase) reserves in subsequent years.

Please note:

Absent extraordinary circumstances related to providing decent, safe and sanitary housing, the development will be ineligible for a subsequent resyndication of TEBs and LIHTC for twenty-five (25) years, from the date of closing. Projects should be structured so that the immediate rehabilitation, capitalized reserves, and ongoing deposits are sufficient to maintain the property. The Authority reserves the right to limit subordinate resource requests on future deals for sponsors who receive unrestricted proceeds/cash-out on properties financed with resources administered by the Authority.

US Conference of Mayors Calls on Candidates to Expand HUD Funding

| Affordable Housing

The United States Conference of Mayors has issued a new report “Mayor’s Vision For America: A 2020 Call To Action” which calls for new investments in infrastructure, innovation and inclusion.  The report outlines 12 priorities including to “make housing more affordable and end homelessness.”  The report specifically calls for increased funding for the Community Development Block Grant and HOME Program as well as the creation of a new program for blighted neighborhood restoration.  Additionally, the report calls for the expansion of rental housing supply noting, “There is an increased need for rental housing. The nation needs to create and pursue policies to develop more rental housing. Specifically, mayors call on the President and Congress to:

  • Create a new rental housing production program to serve the needs of working families.
  • Support the National Housing Trust Fund.
  • Increase funding for the HOME Investment Partnerships program.
  • Maintain one of the nation’s largest infrastructure investments – public housing – through
    significant funding increases geared toward capital improvements.”

The report also calls for comprehensive approaches to homelessness and to “support holistic and inclusive community development.”

Bill Introduced in South Carolina to Create State LIHTC for OZs

| Affordable Housing

On November 20, 2019 Legislation introduced in the South Carolina Legislature  that would create a state low-income housing tax credit (LIHTC) for properties in opportunity zones. Analysis of the legislation by Novogradac & Company finds that the measure “would create a 25 percent tax credit for investment in the state’s OZs and add OZs to other state incentive programs. H. 4657 would automatically qualify LIHTC developments in OZs for a new state LIHTC equal to the federal credit and would also create a 25 percent credit for investments in OZs, with an annual cap at $50,000 per taxpayer. The bill would also create additional value for the state jobs tax credit for jobs in OZs in lower-income Tier III or Tier IV counties, create a sales tax rebate or credit for grocery stores located in OZ food deserts, add a grant program for OZ investments in Tier III and Tier IV counties and create an OZ leadership task force.”

At press time, the measure has been referred to the Committee on Ways & Means.  All three co-sponsors are members of the Democratic Party, which is in the minority in the State House.  Co-Sponsor Rep. William Clyburn is a member of the Committee on Ways & Means.

Legislation Introduced to Establish Reporting Requirements for Opportunity Zone Incentive

| Federal / Agency News

U.S. Senator Tim Scott (R-SC) was joined today by Senate Finance Committee Chairman Chuck Grassley (R-IA), Senators Marco Rubio (R-FL), Shelley Moore Capito (R-WV), Todd Young (R-IN), Joni Ernst (R-IA), Bill Cassidy (R-LA), and Cory Gardner (R-CO) in the introduction the IMPACT Act, which would reinstate and expand reporting requirements to determine the impact of the more than 8,700 Opportunity Zones across the country. Opportunity Zones were initially proposed by Scott’s Investing In Opportunity Act, first introduced more than four years ago, which included strong reporting requirements. Procedural rules stripped the reporting requirements out of the Opportunity Zones provisions when they were added into the 2017 tax reform package, and Senator Scott has remained committed to restoring and bolstering reporting requirements ever since.

The IMPACT, or Improving and Reinstating the Monitoring, Prevention, Accountability, Certification, and Transparency Provisions of Opportunity Zones, Act includes a variety of reporting requirements, fully listed below, to provide for the most robust and granular analysis over time on the targeted impacts of investments in Opportunity Zones. With more than $63 billion already in anticipated investments, it is critical that this analysis is in place. The IMPACT Act’s requirements do this while protecting taxpayer privacy laws and preserving the ability of communities to utilize a wide-variety of possible investments without overburdening entrepreneurs and local governments with mountains of unnecessary paperwork.

“Opportunity Zones provide thousands of low-income communities, both urban and rural, across the country with the potential to transform the future for generations to come,” Senator Tim Scott said. “The IMPACT Act’s reporting requirements will help show communities and investors that the initiative is working, as well as help root out any fraud or abuse. This is an important piece of the puzzle to help the more than 31 million Americans living in Opportunity Zones experience a brighter future.”

“Opportunity Zones have the potential to transform some of the most economically underdeveloped parts of the country and lift millions of Americans out of poverty. Everyone deserves a shot at the American Dream. This legislation will help make sure the federal government has the information it needs to track the success of Opportunity Zones,” said Senate Finance Committee Chairman Chuck Grassley.

“I was proud to support Opportunity Zones in 2017 with the goal of spurring economic innovation in communities across our nation, giving all Americans the chance to succeed,” Senator Rubio said. “The IMPACT Act will increase accountability to ensure Opportunity Zones are having the positive effect on distressed communities that they were created to.”

“This bill would help us monitor and better understand what’s working and what’s not in the Opportunity Zone program. This program can really be a game-changer for West Virginia because of the chance to leverage investments. Having this information will help the program become more robust and aid the communities that need it the most,” said Senator Capito.

“When we passed tax reform, I was proud to support the creation of Opportunity Zones to incentivize new investment in distressed communities across the country,” said Senator Young. “The IMPACT Act will help strengthen Opportunity Zones by increasing transparency within the program and creating metrics to measure and improve on its success.”

“As a fifth generation Coloradan who grew up on the Eastern Plains, I know how important it is to attract growth to local communities, and particularly rural communities, in Colorado and throughout the country,” said Senator Gardner. “The IMPACT Act will provide new data on Opportunity Zones, so we can make them as effective as possible at encouraging investment, inciting growth, and extending opportunities for communities across all four corners of Colorado.”

Instead of utilizing a “Band-Aid method” or temporary fix, the Opportunity Zones initiative aims to lift up entire neighborhoods by attracting private investment to areas most in need. With about $6 trillion of capital gains sitting on the sidelines, investors can now take advantage of a tax incentive if they elect to invest resources in the more than 8,700 designated distressed communities across the country.

The law is also written in a way that encourages long-term investment by allowing for a “step-up” approach: There is a greater financial benefit for investing over a 10-year time period, rather than just five years. This type of structure will encourage investors to establish meaningful relationships with the communities they are investing in.

Click HERE to read full bill text.

Specifically, the IMPACT Act:

  • Codifies requirements for Qualified Opportunity Funds to report information on the value of total assets held by the fund, the location and value of Opportunity Zone property held by the fund, whether the property is owner or leased, information on disposed investments during the tax year, information on the location and industry classification codes of businesses receiving equity investments as well as the value of those investments. The IMPACT Act also requires reporting on the number of persons employed through OZ investments, thereby providing data on job creation and firm growth without burdening small businesses and funds alike.
  • Codifies requirements for investors to report critical information on Opportunity Zone investments including funds receiving investments, relevant dates on which investments and dispositions are made, descriptions of Opportunity Zone investments, and measures that will continue to allow IRS to track both the deferral and recognition of gains, the trajectory of OZ investments over time, and compliance more broadly.
  • Adds penalties for both individuals and funds that fail to accurately and appropriately file the required returns or statements and also significantly enhances penalties for any individual who attempts to take advantage of the OZ incentive for fraudulent purposes.
  • Requires that Treasury make public as soon as practicable and annually thereafter timely, comprehensive information tracking Qualified Opportunity Funds and their corresponding investments into zones.
    • Specifically, Treasury shall make public in the aggregate the total number of funds, the total assets of all funds, the distribution of Opportunity Zone investments across different industry classification codes, the percentage of all Opportunity Zones that have received investment through the incentive, the total amount of Opportunity Fund investments made in each census tract, the distribution of investments in real property and active businesses, data deciphering the sizes of businesses receiving OZ investment, and numbers of jobs created or sustained by those businesses in light of Opportunity Zone investments.
  •  In addition to that, this legislation requires the most comprehensive community impact report on Opportunity Zones, which will provide granular data on the real impacts we’re seeing in OZ’s over time. Specifically, in addition to the annual reporting Treasury is required to produce, in five years and again five years thereafter, Treasury shall work with relevant agencies to provide a comprehensive report on an exhaustive list of economic and demographic data points to provide a holistic view on the impact to each census tract over time. This includes but is not limited to the unemployment rate of the zone, education levels of zone residents, the availability of affordable housing and percentage of income used for rent, impacts to median family income, the presence of specific industries and new business starts that create jobs, home equity impacts for residents, and more.
  • But this IMPACT Act doesn’t stop there, it also compares these data points with the time periods before these specific tracts were designated as Opportunity Zones and also compares them against other low income communities that are similarly situated but were not selected for OZ designation. This will ultimately provide us with a holistic understanding of the real impacts to zone residents as well as the benefits and potential of the Opportunity Zones.
  • The IMPACT Act also ensures the protection of private taxpayer information currently safeguarded under federal law, thereby protecting competitive and proprietary information critical to the marketplace.