Tracey Howard

Recent work & FAQ

What the worklooks like.

Recent work

Current engagement · Detroit · 2026

Management takeover at a Detroit LIHTC and HOME property.

The situation. A Detroit management company took over a tax-credit property carrying HOME funds. The files came from the outgoing manager, and the state agency's first file review was due within months.

The work. An onboarding audit of every tenant file against both tax-credit and HOME rules, a property-level review of the limits in effect, a findings report for each unit, and a shared missing-documents checklist the manager and I both work from. Scans were renamed and ordered the way a monitor reads a file.

What we found. The households appeared income-eligible. The issues were paperwork and dates: stale verifications, unsigned interim certifications and recertifications that needed full HOME verification. Each came with a specific correction and a calendar of upcoming deadlines.

What's next. Monthly compliance support, with recertifications tracked from the 120-day window forward.

Frequently asked questions

If a monitor finds a problem, do we lose our tax credits?

Usually not. When a state agency finds noncompliance it reports it to the IRS on Form 8823, but filing that form does not by itself take credits back. Recapture comes into play only if the building’s qualified basis actually drops, for example when a unit stops qualifying and isn’t corrected. Owners are normally given a correction period, and most file findings can be fixed within it.

Can you guarantee we will have no findings?

No, and nobody honestly can. What a review does is find what a monitor would cite while you still have time to correct it. That reduces risk. It does not eliminate it.

Do you replace our compliance staff?

No. I work alongside your team as an independent reviewer, as overflow capacity, or as the whole tenant-file function for owners without one. Your staff keeps running the property, and the owner and management company make the final compliance decisions.

We just took over a property. Where do we start?

Get every tenant file from the outgoing manager, including move-in certifications, all recertifications and the lease packages, plus the property-level records: the recorded regulatory agreement, the income and rent limits and utility allowance in use, the last Annual Owner Certification and any prior monitoring reports. Then have the files audited before your first state review. I can send you a handoff checklist on our first call.

How do you receive tenant files securely?

Through a secure, access-restricted shared folder. Please don’t email tenant files or Social Security numbers, and don’t send them through the website form. I’ll send you a secure upload link.

Who usually pays for compliance review, the owner or the manager?

Third-party compliance review is commonly treated as a property or owner expense rather than coming out of the management fee. How your property handles it depends on your management agreement and budget, and I’m happy to structure the fee either way.

What if tenants don’t answer our recertification letters?

That’s common, and it’s how files go stale. I can make in-person signature visits in metro Detroit to collect signatures and documents at the household’s home.

Do you work outside Detroit?

Yes. File reviews are done remotely for properties anywhere in Michigan. In-person signature visits are available in metro Detroit.

Do you do physical inspections or set rents?

No. Physical inspections, rent and utility allowance setting, leasing and the management agreement stay with the owner and management company. My scope is the tenant files.

Talk it through

A free 20-minute call. You'll leave knowing what a monitor would look at first in your files.

Book a free 20-minute call

Tracey Howard Consulting Group LLC is not a law firm and is not affiliated with MSHDA, HUD or the IRS. A file review identifies items a monitoring agency may cite. Correcting them reduces compliance risk but does not eliminate it. The owner and management company remain responsible for compliance decisions.