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New Inclusionary Zoning Lottery Consultant Information

Why do I have to provide Proof of Custody of my child?

Program guidelines require you to provide proof of custody of all household members under the age of 18. You can proof custody of the minor(s) by claiming he/she as a dependent on your most recent tax transcripts, separation agreement that confirms you have full or joint custody, proof of legal guardianship, a court order or a birth certificate – this last document will only suffice if the child is a newborn and was born after you filed your taxes.

If you don’t have legal custody of the minor, he/she cannot be part of the household.

My Child is in College, he/she is a FT Student and won’t be living at home year around, (not living at home year-round) – How should I count him/her in my household size?
Depends on the monitoring agent, they will ultimately decide – 100% grey area!

We are in the process of rolling off of some MHP properties where the on-site staffs think they can handle the recertification process themselves, and I had a few questions and ideas about the annual reporting requirements that I would like to discuss with MHP, and I figured you two would be the best to contact.

I understand that MHP doesn’t do as many on-site audits as they used to, and I think this may give some properties a false sense of confidence/competency. But I also know your time and scope is limited, and those audits are time consuming, and I’d like to know more about the annual financial reporting requirements (the “Annual Limited Dividend Financial Report” in section13(b) of the Reg Agreement) as if a CPA has to provide those reports, I think there is a fairly elegant way to get the CPAs involved to do a cursory review of the health of the certifications the property is doing (or not doing, in some cases). Such a review wouldn’t require any more bandwidth from MHP, wouldn’t require you to offload any fees, and some CPAs would do that work as part of their report without any change in their costs to the developer (as some like Kevin Martin Associates already do this). I think it would just require an annual memo from MHP to the CPAs that clarified what the expectations are for the full scope of those reports.

And that could go hand in hand with the reporting required in section 13(a) of the Reg Agreements.

The goal of all these programs is to not just build the units, but to also to ensure the proper households are moving into the units, and the right households are getting to stay in the units. MHP has historically been more diligent about ensuring that, but I think in recent years you may not have had enough bandwidth, and as your portfolio grows I think it will become even more important to figure out a way to properly enforce these requirements to help meet some of the most important goals of the program.

In any event, let me know if or when you’d like to discuss.