Asset Management > Program Compliance Accounting

> TCAP/TCR Program

MHDC’s Asset Management Department is responsible for monitoring the compliance for the Tax Credit Assistance Program (TCAP) and Tax Credit Replacement Program (TCR) as created by the American Recovery and Reinvestment Act of 2009. Outlined below are procedures on how MHDC will be implementing the program for compliance purposes. These requirements are for all properties receiving gap financing from these two programs.

TCAP/TCR Program Compliance Requirements Effective May 1, 2011

 

1. All TCAP/TCR funded properties are required to submit the previous months internal balance sheet, income statement, and accounts payable aging report through MHDC’s Asset Management Reporting System (AMRS) https://amrs.mhdc.com by the 25th of each month. A user name and password is required to access this system. Note: All financial information must follow MHDC’s Chart of Accounts.
    

2. The TCAP affordability period is the same as the term of the loan. The affordability period for TCR is 30 years.
    

3. An Asset Management fee of $45,000 is required to be funded at conversion and be held in an account held by MHDC. MHDC’s Asset Management Department will release 1/15th of the fee annually as payment to MHDC for its asset management responsibilities.
    

4. TCAP and TCR programs are subject to the following additional MHDC Asset Management risk review requirements:
   • Monitoring of established reserves
   • Authorization of management and adjustment of management fees
   • Annual inspections
   • Budget Based rent increases
   • Reporting of annual household characteristics through COL
   • TCR Only: 25percent of cash flow needs to be deposited annually into a reserve account of MHDC’s choice.
    

5. TCAP funded properties only: In accordance with HUD requirements, the owner agrees to establish an affirmative fair housing marketing plan (AFMP) to be followed when marketing TCAP units. AFMP steps consist of actions to provide information and otherwise attract eligible persons in the housing market to the available housing without regard to race, color, national origin, sex, religion, familial status or disability.
    

6. TCR funded properties only: The owner must engage a qualified compliance professional, unrelated to both the owner and management agent, to verify qualified occupancy at initial tenant move-in. Qualified occupancy refers to the first households to occupy 100percent of the units.
    

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