Reservation &

Carryover

Gross Rent Floor

Election

Commitment

10% Certification

PLACED IN SERVICE (PIS)

PLACED IN SERVICE

Housing Authorities evaluate the project following the date all of the buildings in a project are PIS, including a site visit if deemed necessary, to ensure all program requirements have been met and to review the project prior to the issuance of IRS Form 8609.

Applications are available through the Public Housing Authorities

Michigan State Housing Development Authority (MSHDA)

www.Michigan.gov/mshda

Indiana Housing & Community Development Authority (IHCDA)

http://www.in.gov/ihcda/

PLACED IN SERVICE

A project must be PIS by December 31 of the second calendar year following the issuance of the Carryover Allocation Agreement or the credit will be lost to the project.

If you are claiming credit for any project for the Current Year:

PIS request to issue Regulatory Agreement

Due Date…………………..any time during the year, but no later than: November 1 of Current Year

Regulatory Agreement recorded in the county in which the project is located……………………..any time during the year, but no later than:

December 31 of the Current Year

Owner’s/Contractor’s Final Cost

Certifications Due Date:…any time during the year, but no later than:

February 1 of the Following Year

If you are not claiming credit for the Current Year:

It is not necessary to submit any placed-in –service documentation prior to the end of the year.

REMINDERS You are able to submit a placed-in-service application and final cost certifications at any

time during the year.

A Regulatory Agreement must be recorded in the county in which the project is

placed in service

All Exhibits must be tabbed in accordance with the PIS Exhibit Checklist, and placed at the end of the application

The PIS date(s) shown on the 8609(s) will be taken from the Building-by-Building page of the LIHTC application. The PIS date(s) must be on or after the date(s) shown on the temporary or final Certificate(s) of Occupancy. If the date of the temporary Certificate(s) of Occupancy. If the date of the temporary Certificate(s) of Occupancy is used, a copy of the temporary and final Certificate(s) of Occupancy must be submitted.

8609(s) will only be released upon receipt of the recorded original Regulatory Agreement and all required exhibits, including payment of all fees. Cost Certifications must be completed in accordance with LIHTC guidelines.

Please thoroughly read the PIS Instructions prior to submitting the Application and Exhibits.

PLACED IN SERVICE

What Do I Need To Include With My Application Copy of Executed and Recorded Deed to Property

Entity Formation Documentation

First Year Credit Statement

Original Owner’s and Contractor’s Final Cost Certification

Certificates of Occupancy

Executed Limited Partnership Agreement

Copy of Executed and Recorded Permanent Mortgage and Note

Color Photograph of the Project

IRS Form 8821

Compliance Monitoring Fees

Documentation for Rental Subsidy (if applicable)

Project’s Latest Financial Audit

Green or Leed Certifications

Environmental and/or Marketing Updates

PLACED IN SERVICE

There are certain sections of the Primary Application that frequently changes from the time a Placed in Service application is submitted to the time 8609s are issued.

Housing Units

Distribution of Rents

Low Income Tenant Targeting

Construction/Permanent Financing

Project Costs

Annual Project Expense Information

Any changes to a LIHTC project that require a re-scoring or re-evaluation of the application, in which the score falls below the category minimum threshold in which they were funded, will not be allowed from time of initial application to placed-in-service. Important to check consult your local Housing Authority.

Placed in Service

Cost Certification

There are two types of Cost Certifications

Owner’s Cost Certification

Contractor’s Cost Certification

The purpose of the cost certification is to establish the total costs incurred by the owner and contractor in the development of a project. These reports enable the Authority to determine certain developments costs and the amount of tax credit to be allocated to the project. All costs are included in the calculation of the total development costs; however, not all such costs are necessarily recognizable in determining the eligible basis and the amount of credit to be allocated.

The Authority reserves the right to exclude from eligible basis part or any line item of expense when the amount is so high as to be out-of-line with reasonable and necessary costs for the services performed or the item supplied. In such cases, the amount allowed will be the Authority’s estimate of the “reasonable and necessary” amount as compared with comparable projects in similar areas. All expenditures must be reduced by the amounts of any kickbacks, rebates, allowances, trade discounts or other sums that the owner or the sponsor has received or is to receive.

Authority reserves the right to determine whether or not the certifications of actual costs received are satisfactory to the Authority.

Cost Certifications must be prepared and contain an Opinion of a Certified Public Accountant

Owner’s must certify the gross and net syndication proceeds applicable to the project.

Syndicators require that drafts of the Cost Certifications be submitted for review prior to submitting to the authority.

PLACED IN SERVICE

What Are Some of the Pitfalls of Placed In Service No familiarity with the Qualified Allocation Plan, Housing Authorities Forms and

due dates related to the Placed In Service process

Submission of incomplete packages

Updates on application not completed

Submission of wrong PIS Dates

Missing documents related to financing and subsidy

Missing certifications related to Green and Leed initiatives

Not working close enough with Accountants in capturing and qualifying costs

Securing proper signoff related to third party reports (i.e. appraisals and environmentals)