On April 14, 2017, HUD published the 2017 income limits for HUD programs as well as for the Low-Income Housing Tax Credit and Tax-Exempt Bond programs. The limits for the LIHTC and Bond projects are published separately from the limits for HUD programs. Now that we have had a chance to review the new limits, a significant error has been discovered in the “Determination of Maximum Income Limits” section of the MTSP limits for the “ on or before 12/31/08” tab.
The referenced section is showing FY 2017 as the income limit to use even if 2017 is lower than earlier years. There are also errors regarding which HERA Special Income Limit to use.
HERA 2008, Title I, Part III, §3009(a)(E)(i) states that any determination of Area Median Gross Income for any project after 2008 will not be less than the AMGI used for the project in the prior year. In other words, LIHTC projects never have to reduce income limits below the highest limit in use since the project began operating.
HUD is aware of the problem and will hopefully correct the problem shortly.