The 2024 Rental Compliance Manual is now published and may be downloaded by clicking on the link below. The update to the manual introduces the Boulder Regional Affordable Rental Housing Program, incorporates the new HOTMA rules and HUD guidance. In our ongoing efforts to seek out opportunities to reduce the administrative burden on property management, the City adopted the following new rules regarding income and asset determinations:
- Owners/Managers may accept Rental Subsidy Provider’s Income Determination for all households receiving rental assistance payments instead of conducting third party income verification.
- Owners/Managers may accept Safe Harbor Income Determination which allows property management to accept income determinations from TANF, Medicaid, SNAP, LIHTC and WIC instead of conducting third party income verification. This new rule will drastically reduce the administrative burden since there are many more applicants/residents that receive these types of benefits that may not receive rental assistance payments.
- Increase Asset Limit to 100,000 from 55,000 which aligns with the new HOTMA rule.
As we embark on 2025, we wanted to let you know how the 2024 Monitoring Season went and what to expect for 2025. While your property may not have been on the city's monitoring schedule for 2024, valuable observations were made that we’d like to pass on that ALL properties can benefit from. Below are some items which you will want to keep in mind, items that are often found missing, things that are required, and helpful tips which might allow future monitorings to flow smoothly.
Permanently Affordable Unit Addendum: The RCM 5.4 requires households to sign the Permanently Affordable Rental Unit Addendum at initial occupancy. The Permanently Affordable Rental Unit Addendum must be signed by all households at move-in, and only then, and maintained in the tenant file. HOWEVER, when the city monitors, we like to see the signed Addendum, regardless of when it was signed, so we know it was signed. It should be part of the file that we ask for.
Placed in Service (PIS) Date (reminder if 2025): The PIS date is very important to the City of Boulder and the monitoring process. The PIS date originates from one of the following - whichever is latest - Certificate of Occupancy (new construction) or Date of Original Covenant. The Owner/Manager must calculate annual income using third party income verification at initial occupancy and EVERY 6th year of the Placed In Service (PIS) Date of the PROPERTY. If you are unsure of your property’s PIS Date, please contact the city and we will be happy to let you know.
Monitoring schedule for 2025: While the 2025 schedule is being determined, we are expecting the next year to be quite busy. In February, we expect to have our list completed and will send introduction emails to the scheduled properties. Our monitoring season traditionally runs from February through October. We will do our very best to schedule a monitoring that works best with your schedule. Monitorings will be a mix of remote or hybrid visits.
AMI Limits (old/new): The City of Boulder, Department of Housing & Human Services published the 2024 HUD Area Median Income (AMI) limits. Please be sure to use these income limits to determine income eligibility and rent limits to determine maximum rent for all applicants prior to initial occupancy and annual recertification of eligibility to maintain compliance with your permanently affordable rental housing properties under Covenant with the City. The AMI limits for 2025 should be released in mid-May. We will send them to you via email as well as update our website.
Utility Schedule: The City of Boulder, Department of Housing & Human Services published the 2024 Utility Schedule. Please be sure to reference the schedule when determining maximum rents (as applicable). These can also be found on our website.
Offer Technical Assistance: The city incorporates technical assistance into the overall monitoring plan in an effort to help Owners/Managers understand and comply with all compliance requirements. Technical assistance is not intended to replace formal monitoring but rather serves as a supplemental tool for monitoring to ensure long-term compliance. Technical assistance is offered prior to initial lease-up, based on need as identified in the monitoring process, staff turnover and is available upon request.
Update Contact Information: If your organization has had any key management or property staff changes in the last year, please be sure to provide updated information to us. This will ensure communication is maintained. Please submit any updates you may have to Cindy Spence, Compliance & Monitoring Administrator at spencec@bouldercolorado.gov.