Services
A. J. Johnson Consulting Services, Inc. offers a comprehensive package of services for clients in the multifamily housing industry, ranging from a variety of training offerings to a complete set of asset management services.
Following is a description of the basic services we offer, beginning with asset management and compliance. Note that the asset management component is broken down into four different levels of review, depending on the needs of the client.
Asset Management Reviews
Asset management reviews entail an on site visit to individual properties during which the following aspects of the properties are analyzed:
1. Physical inspection, including grounds, building exteriors, and unit interiors. The interiors of 2-4 units are normally inspected.
2. Review of on site administration (personnel, marketing, and occupancy status);
3. Review of maintenance program (preventative maintenance, work order procedures, capital improvements, etc.);
4. Review of social programs (if any); and
5. Overview of the local community and economic conditions.
Tax Credit (Section 42) Reviews
Section 42 Procedural Reviews
Section 42 procedural reviews examine all aspects of tax credit operations on a property, and will cover the following areas:
1. Confirmation of minimum set aside;
2. Examination of in service date relative to lease up deadlines;
3. Review of special set asides;
4. Examine Extended Use Agreement and ensure that requirements of the Agreement are met;
5. If multiple financing programs are used, ensure that site complies with requirements of those programs;
6. If there are mixed income buildings, analyze the applicable fraction requirements of the buildings;
7. Examine Deep Rent Skewing requirements (if applicable);
8. Review the property for compliance with the accessibility and adaptability requirements of the Fair Housing Act of 1988 (if applicable);
9. Determine if non profit partner is materially participating (if applicable);
10.Examine issues relating to model units, employee units, and courtesy officer units;
11.Review any optional fees charged to residents for appropriateness under Section 42;
12.Determine if rent and utility allowance levels are appropriate;
13.Ensure that correct income limits are being used on site;
14.Analyze site policies relative to rental to Section 8 recipients;
15.Analyze methodology for tracking units under the Next Available Unit rule;
16.Determine how original resident files are being secured and whether copies of such files have been made for off site storage; and
17.Review of 15 resident files to determine if procedures are adequate to ensure that tenant qualification and documentation requirements are being met.
Tax Credit Eligibility Review
An eligibility review is designed only to determine the eligibility of the residents. Basically, income and student status issues are reviewed and an opinion regarding the eligibility of each household is given. Each file is examined for eligibility (e.g., recertifications, file organization, document dating, etc. are not examined). This level of review is normally requested by investors concerned with resident eligibility issues.
Full Tax Credit Compliance Review
A full tax credit compliance review will examine all elements of tax credit compliance, including a review of set-aside requirements, rent levels, utility allowance documentation, income limits, employee units, optional fees, file storage policies, available unit tracking compliance, and fair housing accessibility compliance. Resident files from each property will be reviewed for procedural compliance with the tenant certification and verification requirements of the Section 42 program. Each file is reviewed for the purpose of determining whether the property meets the compliance requirements of the Section 42 Program. This is a very detailed audit of all resident files that basically examines every document in each file in order to make the most complete assessment possible regarding the status of the unit. This review is designed to identify both eligibility and compliance issues.
Asset Management and Limited Compliance
This review includes all information listed under the asset management review section, plus a procedural review designed to determine if the site staff’s procedures are in conformance with the requirements of the Section 42 Program. The compliance portion of the review is limited to a confirmation of correct income and rental levels, and a review of five (5) resident files to determine if tenant qualification procedures are adequate.
Asset Management and Full Procedural Review
Following each review (except desk audits), we conduct an exit interview with site staff during which we make recommendations relative to improving on site practices in whatever areas we have reviewed.
For each of the services listed above (except desk audits), a written report will be provided to the client within 21 days after completion of the review.
We have the ability to tailor our review services to the needs of individual clients (e.g., desk audits, pre-concurrence reviews, fair housing reviews, etc.), but our experience has shown that most clients benefit from the review levels outlined above.
We also offer comprehensive training in a variety of areas relating to multi-family housing. The following is a description of the most common training we provide.
Training Services
Basics of Tax Credit Site Management
This training is designed primarily for new site manager and supervisory property managers, and is especially beneficial to those personnel who are relatively inexperienced in the tax credit program. It covers all aspects of credit relating to on site management, including the application process, rental calculation, income and eligibility verification requirements, requirements relating to tenant assets, and a full discussion of student issues. There are multiple workshop programs and an optional comprehensive exam at the end of the training. This is a full day course.
Intermediate Tax Credit Management
Designed for more experienced managers, supervisory personnel, investment asset managers, and compliance specialists, this program expands on the information covered in the Basics of Tax Credit Site Management. A more in-depth discussion of income verification issues is included as well as a detailed review of minimum set-aside issues, optional fees and use of common areas. The Available Unit and Vacant Unit rules are covered in great detail, as are the requirements for units occupied by employees. This course contains some practice problems, but is more discussion oriented than the Basic course. This is a full day course.
Advanced Tax Credit Issues
This full day training is intended for senior management staff, developers, corporate finance officers, and others involved in decision-making with regard to how credit deals are structured. This training covers complex issues such as eligible and qualified basis, applicable fraction, credit calculation (including first year calculation), placed in service issues, rehab projects, tax exempt bonds, projects with HOME funds, Next Available Unit Rule, employee units, mixed income properties, vacant unit rule, and dealing effectively with State Agencies.
Fair Housing
This course offers a complete discussion of the requirements of the Fair Housing Act of 1988, including detailed analysis of elements relating to each protected class. Examples of how to handle specific situations for each group are covered. Appropriate areas of Section 504 and ADA requirements are also covered. Both half and full day courses are offered.
Tax Exempt Bonds
This is a half-day course that covers the basic requirements of the bond program, especially with regard to on site compliance. It is recommended primarily for senior management and development personnel, and is often combined with a discussion of rehabilitation issues on Section 42 properties.
HOME Program Requirements
This half-day course outlines the basic requirements of the HOME Investment Partnership Program, with particular emphasis on combining HOME funds with the federal Low-Income Housing Tax Credit. The training provides an overview of HOME Program regulations, including rent rules, unit designations, income restrictions, and recertification requirements. The course concludes with a detailed discussion of combining HOME and tax credits, focusing on occupancy requirements and rents, tenant eligibility differences, handling over-income residents, and monitoring requirements.
HOPE VI Program
Offered in both half-day or full day options, the training focuses on the tenant eligibility and selection challenges of the HOPE VI program. Beginning with a program overview, the session concentrates on income limits and rent payments, economic and social mix options, selection preferences, and waiting list requirements. A detailed discussion of assistance to non-citizens is included. In the full day session, training is provided in income verification and calculation requirements, including the handling of household assets.
Marketing of LIHTC Properties
This full day training is designed to provide an outline of effective marketing techniques for LIHTC properties. It covers proven marketing strategies for tax credit projects and provides tips in how to avoid non-compliance during the marketing of such properties. Issues covered include desired amenities, energy efficiency measures, elements involved in a successful marketing program, and fair housing concerns in the development of a marketing program.
Rural Housing Section 515 Program
This full day course outlines the basic requirements of the Rural Development Section 515 Program, with particular emphasis on combining the Section 515 program with federal Low-Income Housing Tax Credit. The training provides an overview of Section 515 Program regulations, including rent rules, resident eligibility, income restrictions, and recertification requirements. The course includes a detailed discussion of combining Section 515 and tax credits, focusing on occupancy requirements and rents, tenant eligibility differences, handling over-income residents, and monitoring requirements.
Dealing with Tenant Assets
This half-day course is one of our most requested by management companies. It features a detailed discussion of requirements related to the determination of asset value and income, and is applicable to all federal housing programs, including the low-income housing tax credit program, tax-exempt bonds, Section 8, Section 515, HOME, and HOPE VI. Multiple types of assets are covered, both in terms of what constitutes an asset and how they must be verified. The course concludes with an extensive series of problems, designed to test the ability of the attendee to determine the value of an asset and calculate the income from that asset.
Income Verification and Calculation
This course provides concentrated instruction over half a day on the required methodology for calculating and verifying income. A comprehensive discussion of employment income is a major part of the training, along with military pay, pensions/social security, self-employment income and child support. A basic discussion of asset verification and calculation is included and the course concludes with multiple workshop problems. These problems test what the student has learned during the discussion phase of the training and serve to reinforce HUD & IRS required techniques for the determination of income.
We also offer specialized training designed to meet the unique needs of our clients. In addition, we are one of the few organizations approved to offer the Housing Credit Certified Professional (HCCP) Review and Examination by the National Association of Homebuilders (NAHB). This is the most prestigious professional designation in the credit industry, and we are authorized to administer that exam in conjunction with our training. In addition to industry training, we provide a good deal of training for State Housing Finance Agencies, and since 2007, have been the primary trainer for the Virginia Housing Development Authority (VHDA).
A. J. Johnson personally does all the training, and brings over 30 years of experience to every training session, having developed and managed tax credit properties since the creation of the program. Each of the offered courses was designed by A. J. Johnson based on experience in both the field and classroom (the feedback of previous students is an important element in determining future changes to our training). All courses are updated on a regular basis on technical changes, new laws, and changes in industry procedures and practices.
Regardless of the training or asset management services a client selects, our services are always adjusted to meet the specific needs of the individual client. We believe it is critical that all services be individually suited to the client. Click here to make a private training inquiry.
We represent many of the major real estate investor in the United States, such as SunAmerica, MMA Financial, Red Capital Markets, and SunTrust in the performance of on site management reviews. We also work with individual management companies and developers to assist them in ensuring that their properties are properly structured and well managed.
If you feel that any of these services would benefit your organization, please give us a call and we will develop a program specifically for your needs. If you would like to speak to any of our existing clients, please let us know and we will provide you with a contact list. Please feel free to contact us at (757) 259-9920 or ajjcs@cox.net.
© 2009-2010 A. J. Johnson Consulting Services, Inc.
This is the most comprehensive review we offer on a regular basis. It includes all elements of the asset management review and full procedural review.
The desk audit or, “pre-concurrence” service is one of the most popular services we offer. This is a straightforward process during which we review tenant or applicant files that are sent to us either by email or overnight mail service. We then provide a report to the client, normally within two to three days, outlining any issues noted with the file and recommending corrections. We guarantee consistency in methodology and findings by having the same two people review all files and prepare the final report; those two people are Marie Peace, our Senior Compliance Consultant, and A. J. Johnson. Ms. Peace performs the detailed review of the file, noting discrepancies and recommending corrections. Her report is then reviewed by Mr. Johnson, at which time final recommendations are made and credit risk is assessed. This very affordable service provides our clients with a rapid way to meet the IRS requirement of demonstrating due diligence in the tenant approval process.
Desk Audit