Income eligibility
Household income at move-in must not exceed the applicable income limit (50% or 60% AMGI). All sources verified and calculated per HUD 4350.3/HOTMA.
The most rigorous §42 tenant file a property manager can deliver.
The LIHTC Income Certification & File-Compliance Engine assembles a documentation-complete tenant income certification — every statutory element, every required verification, the income/asset calculation, the student-rule check, and the utility-allowance reconciliation — checked against the letter of IRC §42 and HUD 4350.3/HOTMA before a certified analyst releases it.
Every subsection of IRC §42 and HUD 4350.3/HOTMAFive statutory income elements, gate-checkedIncome · asset · student · utility · household-composition verificationsCertified analyst release on every file5-business-day SLA
Why files fail
A single miscalculation can trigger 8823 findings and recapture.
Every LIHTC unit must have a correctly documented, correctly calculated tenant income certification on file — at move-in and annually. Miss an income source, miscalculate assets under HOTMA, overlook a full-time-student household, or misapply a utility allowance — and the state Housing Credit Agency files IRS Form 8823, which can trigger recapture of previously claimed tax credits (Form 8611), plus interest and penalties.
Most property managers run this by hand, from memory, across dozens of files. The rules change (HOTMA, OBBBA expansion) and certified staff are scarce. That is exactly where compliance gaps hide.
The LIHTC Income Certification & File-Compliance Engine exists to close that gap with a single, exhaustive standard applied identically to every file.
1 of 5
missing income elements is enough to jeopardize a certification
The benchmark
Measured against the letter of the statute — subsection by subsection.
We do not summarize the law and hope. Every file is scored against a versioned rule pack tied to the exact text of IRC §42, HUD 4350.3, and HOTMA. These are the provisions each file is held to.
Full-time student rule
All adult household members must be checked for full-time student status; exceptions (single parent, disabled, etc.) documented or the unit is disqualified.
Gross rent floor
Gross rent (tenant rent + utility allowance) must not exceed 30% of 50% or 60% AMGI, adjusted for bedroom count. Utility allowance sourced correctly.
Asset calculation (HOTMA)
Assets over $50,000 (HOTMA threshold) require imputed income calculation; assets under may use self-certification. All bank statements and asset documents verified.
Qualified allocation plan (QAP)
State-specific QAP requirements (e.g., targeting, preference, waiting list) are checked and documented for each file.
Annual recertification
Annual income recertification completed within 12 months of last certification, with updated verifications and student-rule check. Late or missing recerts flagged.
How a file is built
Intake to certified analyst release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A certified analyst reviews only flagged exceptions and signs every release. That order is never reversed.
01
Compliance Gap Scan
Upload tenant documents and property parameters. We return a free completeness read: which statutory elements and verifications you already have, and which are missing.
02
Document intake & extraction
As your authorized clerical agent, we intake paystubs, benefit letters, bank statements, self-certifications, and prior TICs. AI extracts income and asset data.
03
Grounded calculation
Income and assets are calculated under the applicable HUD 4350.3/HOTMA framework using field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Income totals reconcile to source documents; asset threshold checked; student-rule applied; utility allowance matched; recert deadline verified. Any failure blocks release.
05
Certified analyst review
A COS/HCCP-credentialed analyst reviews the exception queue and signs the certification. High-value or complex files route to senior review first.
06
Delivery
You receive the certified tenant file: completed TIC, verification packet, eligibility determination, exception notes, and analyst sign-off — ready for your records and state agency review.
The bar we hold
Rigor you can measure.
100%
Analyst-signed
No file ships without a certified human signature.
5 days
Standard SLA
From complete intake to released file.
<1%
Critical-defect target
Tracked against a gold-standard file library.
4
Verification sources
Income · assets · student status · utility allowance, every applicable file.
Why the Engine
Built to be the most thorough option a property manager has.
Documentation-complete, by design
The deliverable is completeness itself — every statutory element and verification accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A calculation error cannot slip past a statutory requirement.
In its lane, on purpose
We prepare documentation and run calculations as your clerical agent. We never contact the tenant, give legal advice, or make eligibility decisions.
Engagement
Flat fee, per certified file. No hourly billing, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any credit.
- A free Compliance Gap Scan before you commit — see exactly what is missing.
- One flat fee per certified tenant file; disclosed pass-through verification costs.
- Optional fixed-fee senior analyst review for complex or high-value files.
- Optional Annual Recertification Subscription for portfolio-wide coverage.
FAQ
Questions, answered precisely.
Is the Engine a law firm?
No. The LIHTC Income Certification & File-Compliance Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or contested matters.
Do you contact the tenant or make eligibility decisions?
Never. The Engine is not a property manager and does not contact tenants or make leasing decisions. The property manager remains the party responsible for all tenant communications and eligibility determinations.
What makes a file 'complete'?
Completeness is defined by the statute: income eligibility verified, full-time student rule applied, gross rent floor checked, asset calculation correct, QAP requirements met, and annual recertification current. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a certified analyst-released file. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per certified file, plus disclosed pass-through verification costs. No hourly billing and no percentage of any tax credits or proceeds.
See what's missing before it costs you a credit.
Start with a free Compliance Gap Scan. Send your tenant documents and property parameters and we'll return a completeness read against every subsection of IRC §42 and HUD 4350.3/HOTMA.
Documentation-completeness service · not legal advice · the property manager makes all eligibility decisions.