Building ‘Above Average’ and Exceptional LIHTC Average Income Policies

Policies and guidelines regarding the Average Income Test (AIT) for LIHTC properties are a source of confusion for many in the LIHTC industry. This discussion, featuring Scott Michael Dunn, HCCP, CEO/Owner of Costello Compliance and Erica Etterling, HCCP, Rental Compliance Support Manager at Virginia Housing, will help provide the framework to develop and refine good state and owner AIT policy.

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When it was introduced in 2018, the Average Income Test (AIT) for Low-Income Housing Tax Credit (LIHTC) properties was one of the biggest innovations ever introduced to the LIHTC program. It offers significant benefits for both residents of AIT properties and for the properties themselves. Since then, a process to fix some of the problems with federal AIT regulation has been slow to materialize, and as a result preparing good AIT policy is still pending for many states and owners/agents.

This discussion, led by Scott Michael Dunn, HCCP, CEO/Owner of Costello Compliance and Erica Etterling, HCCP, Rental Compliance Support Manager at Virginia Housing, will help provide the framework for developing good state and owner/agent AIT policy.

What You’ll Learn:

• Review a brief history of the AIT to understand what guidelines need to be updated and/or clarified and what policies may be incomplete.
• Understand the recent federal AIT regulation to use to form a basis for good state and owner/agent policy.
• Learn about fundamental state policy matters that affect whether investors will work with the AIT in a state.
• Understand how—building on state policy—owners/agents can create successful AIT procedures.

Speakers:

• Wendy Quackenbush, HCCP (Moderator) – Director of Multifamily Compliance, Texas Department of Housing and Community Affairs
• Scott Michael Dunn, HCCP – CEO/Owner, Costello Compliance
• Erica Etterling, HCCP – Rental Compliance Support Manager, Virginia Housing

CE Credit: NAHB – 1.0 CE hour(s)

Can’t attend but don’t want to miss out? Replays will be available to all registrants throughout 2025.

If you have any questions, please contact nahblearning@nahb.org