How a review works
The same checks,every file,every time.
A monitor doesn't read a tenant file front to back. They check whether the household qualified, whether the proof was current, and whether every signature and date is there. My review follows the same order.
What a complete tenant file contains
The eligibility records
- Rental application
- Move-in tenant income certification, the anchor for the whole compliance period
- Income calculation worksheet
- Third-party verifications for every income and asset source
- Asset documentation or a signed asset self-certification
- Student-status certification for the current year
- Signed authorization to verify
- Every annual recertification since move-in, plus any interim changes
The lease package
- Current lease and all renewals, signed by every adult
- Tax-credit lease rider
- HOME lease addendum, where HOME funds are on the property
- Signed lead-based paint disclosure, where required
Property-level records
- Recorded regulatory agreement
- Current income limits, rent limits and utility allowance
- Rent roll with unit-by-unit income designations
- Most recent Annual Owner Certification and prior monitoring reports
The checks I run on every file
- 1
Identify the certification and its effective date
Move-in or annual recertification. Every other check is measured from that date.
- 2
Confirm the certification is fully signed
Every adult household member and the owner's agent, each with a signature and a date, and no blank fields.
- 3
Check every verification's date
Third-party verifications are generally considered current for 120 days before the effective date. Older ones are stale, even when the certification itself was signed on time.
- 4
Recompute the income
Anticipated income for the next twelve months, including overtime, tips and other variable pay, compared with the limit for the unit's set-aside.
- 5
Check assets
Verified or self-certified according to the rules that apply to the property, with any imputed asset income included.
- 6
Verify student status
Certified for the current year. A household made up entirely of full-time students must meet one of the program's exceptions.
- 7
Review the lease package
Signed lease, tax-credit rider, HOME addendum and required disclosures all present and signed.
- 8
Confirm rent is within the limit
Tenant rent plus the utility allowance, compared with the rent limit for the unit.
- 9
Confirm the recertification chain
The move-in certification is present and no year is missing between move-in and today.
- 10
Write it up
What's clean, what a monitor would flag, and the specific fix, in plain English.
The findings monitors cite most
Most of what turns up in a file review is paperwork and dates, and most of it can be corrected before a monitor arrives.
| Finding | How it's caught |
|---|---|
| Verification older than 120 days | Each verification date compared with the effective date |
| Missing signature or date on the certification | Every adult and the agent checked for both |
| Variable income left out of the projection | Income recomputed from the verifications |
| Missing annual student certification | Current-year certification confirmed for every household |
| Income over the limit or miscalculated | Recomputed against the set-aside limit |
| Missing move-in certification | Eligibility anchor confirmed in every file |
| Gross rent over the limit | Tenant rent plus current utility allowance compared with the limit |
| HOME recertification skipped | Annual full recertification confirmed on HOME units |
| Missing rider, addendum or disclosure | Lease package checked for every required piece |
| A year missing from the recertification chain | Recertifications lined up year by year from move-in |
Layered properties need layered reviews
Many Michigan tax-credit properties also carry HOME funds, project-based Section 8 or other money, and each program adds its own rules. HOME, for example, requires full annual recertifications with third-party verification, a HOME lease addendum, lead-based paint disclosures and a current Affirmative Fair Housing Marketing Plan. Where HOME and tax-credit limits overlap, the more restrictive one applies.
A review that assumes tax-credit rules alone will miss these. Mine checks every program on the property.
HOTMA is coming for HUD properties
HUD has set January 1, 2027 as the date HUD Multifamily owners must be fully compliant with the HOTMA income and asset rules. For 2026, households with net assets under $52,787 can self-certify their assets, and the figure is adjusted each year. If your property carries project-based Section 8, now is the time to check that your certification forms and procedures are ready.
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.