Best Practices

Document Retention

Various documents are standard and critical to compliance oversight. Certain duplicate project records may be required in the event of IRS proceedings, such as an audit. Asset Management must have adequate procedures and systems to ensure long-term retention of key documents for 21 years from the start of the compliance period, i.e., through the 15–year holding period and expected disposition in year 16, plus 5 additional years for IRS statutory compliance.

  • All legal documents including partnership agreements and related documents.
  • All permanent loan agreements and other closing documents.
  • Qualified Allocation Plan.
  • Tax credit application.
  • Reservation letter from tax credit allocating agency.
  • 10% carryover cost certification, if applicable.
  • Carryover allocation letter from the tax credit allocation agency, if applicable.
  • Final cost certification.
  • Extended Use Agreement.
  • Certificate(s) of Occupancy.
  • First year IRS Forms 8609, with Part II completed indicating owner’s irrevocable elections.
  • Rent roll reporting every restricted unit, initial eligible tenant and date each was initially qualified.
  • Complete lease files for all initial qualifying tenants.
  • Tenant selection plan.
  • All annual partnership tax returns, particularly K-1s.
  • All partnership audited financials.
  • Annual reports to State HFA.
  • Annual income limits and rent increase documentation.
  • Annual utility allowance documentation.
  • Record of unit transfers.
  • Any 8823s or other notices of noncompliance and documentation of corrections, if applicable.