OHFA sincerely appreciates the input that was provided at the 2019 QAP Training session. Following the 2019 QAP Training session that was held on October 22nd, OHFA consulted with Rural Development to arrive at the following conclusions in regards to how Capital Needs Assessments will be accepted moving forward.
OHFA will continue to accept Capital Needs Assessments that are performed by Housing Consultants of Oklahoma (Ivan Graves and Tim Henderson). We believe that Housing Consultants of Oklahoma satisfies OHFA’s definition of an independent third party contractor.
Furthermore, beginning in 2019, OHFA will not accept Capital Needs Assessments that are performed by the architect, contractor, or engineer who is involved with the rehabilitation of the proposed property. OHFA believes that if an architectural firm who performs a Capital Needs Assessment on a property for which they are involved in the rehabilitation constitutes an Identity of Interest. For example: the Architect that performs the Capital Needs Assessment could overstate the conditions of the property in order to inflate the rehabilitation scope, because they will receive further compensation in the event that the property were to be awarded tax credits. By overstating the conditions of the property, the property itself could then qualify for an unnecessary excess amount of tax credits. One of OHFA’s priorities is cost containment and the limitation of any excessive award of tax credits. We apologize for any inconvenience that this may cause. However, simply because we have accepted Capital Needs Assessments such as this in the past, does not mean we will continue to do so moving forward if we do not believe that it is in the best interest of all AHTC Applicants.