Compliance Challenges in Affordable Hsng
- May 20, 2010
Riverstone Residential Group recently hired 25-year industry veteran, Patricia Bowen as executive vice president of Compliance Services. In this new role, she will oversee the Tax Credit Compliance program, HUD Bond programs, and other Affordable Housing programs. In addition, she will manage Riverstone’s internal audit programs in the company’s Quality Assurance Group.
Bowen talks to MHN about her prime responsibilities and the major challenges when it comes to compliance.
MHN: What will be your prime responsibilities in this new role?
Bowen: Riverstone is committed to providing quality management for both their affordable and conventional portfolio. Right now, we have a well-established compliance team across the country and they support the needs of our clients by periodically visiting the properties, doing training and monitoring and making sure documentation is complete. My role in leading the group is oversight of the Low Income Housing Tax Credit and bond financing program and the management of our internal audit and quality assurance group. Right now the group does routine visits to various sites for training and development. Riverstone will continue to do that to make sure they are up to date on compliance knowledge. This in turn will be passed on to our clients. We will continue to enhance our residential services, seek funding and third part partnerships to manage onsite programs for the residents and conduct satisfaction surveys. The department that I lead, the quality assurance department, will continue to do that and gauge how well the company is doing. We are also looking at improving technology and the plan is to enhance how we manage the communities through automating and streamlining the processes, for which we are looking at operating platforms to improve the effectiveness and efficiencies of our managing operations.
MHN: How big is the team?
Bowen: There are currently between 35 to 40 associates within three groups.
MHN: What are some of the biggest challenges facing the Tax Credit Compliance program and other programs you are in charge of?
Bowen: Affordable housing is critical to the country’s housing needs. Time and resources are required to market and manage tax credit properties and ensure compliance with government agencies. Record keeping and documentation is essential to ensure that units are filled with income-qualified residents. Sometimes it’s a bit difficult to find that in some markets. Multiple agencies monitor these programs and that requires different reports, which can be frustrating for managers and onsite staff.
But collaboration between owners and managers- is critical to reduce liability and manage the assets under federally regulated guidelines. Education is another challenge, because you need to gain residents’ cooperation when the management team needs to verify their income and validate if they are still eligible for the program. Annual certifications are sometimes difficult for residents and it’s a challenge for us as well. We have to woo them into the office to get them to do the paperwork.
MHN: How do you woo them?
Bowen: Usually it’s a series of reminders— 60 or 90 days out—that they need to come in and get the paperwork done. That’s one of the biggest challenges in this industry. If something changes in their financial status, they need to inform the management office of the change. If that isn’t done, we might lose the tax credit for that unit.
MHN: If they don’t, why not ask the resident to leave?
Bowen: It’s difficult to evict people living in tax credit housing. What you can do is change the tax credit to another unit. Sometimes those are fixed and sometimes you can move them but once you fill out the paperwork for IRS, you have to maintain the number of low-income units in that community. So if someone becomes unqualified for it, you can move them to another unit or make another unit qualify for low-income. In certain cases, we have to offer incentives or one month free rent etc., in order to maintain the right number of low-income units.
MHN: What are your key compliance goals?
Bowen: I plan on meeting owners and agencies and identify any compliance issues that need to be addressed. Riverstone’s record has been good, but there’s always room for improvement, Riverstone has made a significant investment in key talent, to provide good management and I’d like to continue to streamline processes and enhance programs that we offer today. From what I hear from the team Riverstone has very few notices from IRS notifying that we are out of compliance. We are in good standing with the agencies and my goal is to keep it that way.