Note: RAC compliance reporting in this section only applies to rental projects.
System Development Charges Exemption
About SDC Exemptions for Rentals | No administrative rules.*
*SDC Exemptions for Rentals does not have a specific set of program-specific administrative rules. Current admin rules apply only to Home Ownership, a different branch of the SDC program.
Part 1: Prior to Lease-up
Your first step in understanding compliance for a DI program is to familiarize yourself with your:
- Extended Use Waiver
- Covenant and/or Regulatory Agreement
This is where you will find how many units are restricted, unit mix, Median Family Income % (MFI %), and other compliance requirements for your specific project.
Don’t have a copy of your property’s agreements? Ask the property owner.
Prior to lease up, you will receive a Welcome Letter from the RAC (Risk Analysis and Compliance) team. There will be helpful information in this letter, as well as required action items. Please complete all action items to help the RAC team get your projects set up and ready for compliance!
IMPORTANT: If you are within 30-60 days of leasing up, and you have NOT received a welcome letter or communication from the RAC Team, please contact us.
It is imperative that we are in communication with you prior to moving in the first tenant!
Part 2: At Lease-up
The questionnaire will identify all sources of income for the applicant or tenant. This ensures you are considering all sources of income when determining eligibility.
This tool will guide you in determining if the applicant’s income is at or below the required MFI%.
Income Verification: You will verify all income of adults in the home by obtaining 3rd Party Verification of this income.
Income verification is required for any move in certification.
Part 3: Annual Recertifications
Every year, it is required that you recertify tenants. This will occur on or before the anniversary of their initial move in.
Required at Recertification
This tool will guide you in determining if the applicant’s income is at or below the required MFI% at recertification. This form will be completed by the tenant/household and eligibility is based on self reported income.
NOTE: 3rd Party Verification is NOT required at recertification.
Example: Tenant moved in on 5/6/2019, you will recertify them on or before 5/6 every year.
When to complete. Recertifications may be completed and signed up to 120 days before the recertification is due. In the above example, you can complete the recertification as early as 1/7 (120 days prior to 5/6).
Changes in the size of household (Example: a baby is born; new adult moving into the home; adult moves out) can be captured:
- At the time they report it, or
- At the family’s recertification date.
Adding new adult. When an adult is being added either at time of report or at recertification, the new adult is required to fill out the Applicant Tenant Questionnaire. 3rd party verification of the new income is required as well.
How do I count income?
Now that you have determined all sources of income at initial move in, and at recertification, you will need to determine HOW to count the income.
You will refer to Chapter 5 of the HUD Handbook for guidance on calculating income.
Keep in mind, the following special cases:
STUDENTS: There are specific rules around student eligibility, and how to count their income if they are eligible.
- Student eligibility (scroll to section 3 13B, PDF page 162).
- How to count student income, if eligible (scroll to Figure 5 2, PDF page 6).
MINORS: There are specific rules around how to count children’s income.
- Minors with income (scroll to section 5 6A, PDF pages 315 316).
Reporting and Email Reminders
Now that you have moved tenants into restricted units, it is time to report this data to PHB.
The next sections will take you through WHEN, HOW, and WHAT you will report.
Get reporting reminders
The RAC team will send reporting reminders to the contacts on file. Sign up through the link below to stay in the loop about all important updates and reminders.
Is your contact info up to date? If not, use this form to let us know.
Email contact update form to email@example.com
The deadline for reporting tenant data is based on the project’s Fiscal Year End (FYE).
|Fiscal Year End||Reporting Due to PHB||Reporting Period|
|June 30||October 1||7/1 - 6/30 (of previous year)|
|December 31||April 1||1/1 - 12/31 (of previous year)|
Example: The project’s fiscal year end is 12/31. By 4/1/2021, all tenant data must be entered into WCMS for the reporting period of 1/1/2020 12/31/2020.
Your Welcome Letter will include additional details about when to report!
What is WCMS?
The Web Compliance Management System (WCMS) is a user-friendly, web-based program that you will use to submit tenant data. The RAC team will use this tenant data to run compliance testing on income eligibility and rent amounts. The RAC team will help with error messages and other issues you may have with WCMS.
How does it work and what will I be entering into WCMS?
The information that will be entered into WCMS is found on the TICs that have you have completed.
How do I register?
You will receive instruction in your Welcome Letter prior to lease up. Please do not register for WCMS until you have received a letter instructing you to do so.
Ready to log in!
WCMS User Guide, with step-by-step instructions and screenshots.
All information you will enter into WCMS will be found on the TICs that you completed at certification or recertification. Once PHB receives this information (by your deadline), the following will occur:
- The RAC Team will conduct compliance testing on the data that you have provided.
- The RAC Team will compile the results, with action items, into the Annual Compliance Test workbook (ACT).
- The RAC Team will send you the ACT workbook.
- You will respond within the ACT, and by the deadline given in the ACT. There will be a section titled "partner response". This is where you will provide information on the numbered action items.
- With your responses, the RAC Team will finalize the ACT for that reporting year, give a compliance score, and send the finalized ACT to you and the owner of the project.
Compliance is a collaborative process. We are here to help!
Start your data entry early and enter regularly. You are able to enter certifications and recertifications in real time (when you have completed the TIC) and not wait until your reporting deadline to enter all tenant data for all units at once.
You cannot edit an old certification if you have already entered/submitted a newer certification in WCMS for that unit. Contact the RAC team, we can help with this!
Example : I have submitted a certification for 5/6/19, and also for 5/6/20 for a specific unit. WCMS will not allow you to edit/change the 5/6/19 certification unless the 5/6/20 certification is ‘unsubmitted’.
Send us your questions. When reaching out to the RAC team or submitting your ACT, please email firstname.lastname@example.org.
Contact info changes. If there is a change in who the RAC team should be communicating with about the property, please use this form to update contacts, and send it to email@example.com.
Lease up strategy. In many agreements, it states to consult with PHB regarding their lease up strategy. Currently, PHB does not have a lease up strategy. Please disregard this section of your agreement.
Utility Allowances for DI projects. You must use the Energy Consumption Model or Public Housing Authority (PHA) Schedule.