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Rental Housing Compliance


Our Compliance regional teams monitor a property’s occupancy requirements under the federal Housing Tax Credit Program, Tax Exempt Bonds, HUD regulations and Virginia Housing specific requirements. This includes a review of property records and the physical condition of all monitored properties.

Guidance

We strongly encourage owners to review all documentation such as Internal Revenue Code Section 42 and Section 142, the Extended Use Agreement (EUA), Loan Agreement and any other statutory and regulatory requirements for their property.


Average Income Test (AIT) Written and Video Guidance

Virginia Housing will monitor the AIT according to the IRS Average Income Test Final Rule, property-specific occupancy requirements in the Extended Use Agreement, Regulatory Agreement, and IRS 8609 form. Virginia Housing may amend its AIT written guidance to conform with the regulations and IRS guidance or as may otherwise be appropriate, as determined by Virginia Housing.

 

Noncompliance discovered and corrected before receiving notice of a Virginia Housing compliance monitoring audit is not reportable to the IRS and shows due diligence in managing the program requirements.


    See our Compliance Forms and Documents page to view:
    • Rental Loan Forms and Documents
    • Federal Housing Credit Program Compliance Forms and Guidelines

    Compliance Forms and Documents

Additional Tools and Resources

  • Online Tenant Portal - Procorem

    In 2024, Virginia Housing transitioned our online Tenant Portal to a new vendor, Procorem.

    Property managers must regularly update and maintain accurate and complete tenant information in the online Tenant Portal for all occupied units, including low, moderate, and market households. Certification updates include move-in, move-out, unit transfer, required annual income recertifications, and change in unit designation.

    Virginia Housing relies on the project and tenant data in the online Tenant Portal to review and confirm program requirements for audits, to assist properties, and for required annual Agency program reporting of occupancy and compliance requirements for our rental portfolio.

    We appreciate your cooperation and our continued partnership in meeting the shared mission of providing affordable housing throughout Virginia.

    To access the Procorem online Tenant Portal, complete and submit the required access form located within the property’s Procorem Work Center or email the Tenant Portal Admin at TenantPortalAdmin@VirginiaHousing.com. Include your property name, VHDA #, and Procorem Access Request in the email subject line.



    Training Replays
  • Compliance Monitoring and Annual Reporting

    Immediate Action Required:
    Report all changes and anticipated changes in on-site property staff contacts to your assigned Compliance Officer so we may update our records. Complete the Request for Change in Ownership and/or Management Agent to immediately report ownership and management agent changes. For more information, visit the Change of Business Relationship webpage.

    Email questions to your regional team. Not sure which region your property is in? Use the Compliance & Asset Management Regional Team Map to identify and contact your regional team and to share changes.


    Important Year-End Reporting Dates to Remember:
    Date 2025 Year-end reporting Activity
    December 5, 2025 Tax Credit Compliance Monitoring Fee Invoices are sent from VHDAProLinkAlerts@ProLinkSolutions.com.
    January 9, 2026 Annual Owner's Certifications for all tax credit properties in the Compliance Period and Extended Use Period, Tax-Exempt Bond properties, Alternative Monitoring (formerly known as ES-01), state-required Decontrol Period, and Virginia Housing-financed properties will be distributed to the primary owner and management contacts using Adobe.
    March 1, 2026 Deadline - Tax Credit Compliance Monitoring Fee payments & Annual Owner's Certifications, and Average Income Test Annual Reporting, as applicable, are due.
    March 2, 2026 Tax Credit Compliance Monitoring Late Fees are assessed.
    March 31, 2026 Deadline - Validate all 2025 tenant certification events in the online Tenant Portal and correct all errors.


    Virginia Housing-Financed Only Reporting Date Reminders:

    • Monthly Operating Summary (MOS) Reports are due 20 days following the end of the reporting month.
    • Budget submission package is due 60 days prior to the beginning of the fiscal year.
    • Annual financial statements are due 90 days after the end of the fiscal year.

     

    Tax Credit Compliance Monitoring Fees

    All Tax Credit compliance monitoring fees and annual reports are due by March 1, 2026.

    Annual compliance monitoring fee invoices will be sent to each property from “VHDAProLinkAlerts@ProLinkSolutions.com”, on December 5, 2025, with the calculated compliance monitoring fees. Check your spam folder if you do not receive your invoice.

    Tax Credit properties with all buildings placed in service as of December 31, 2025, must pay annual compliance monitoring fees. Ownership/Management entity in place as of December 31, 2025, is responsible for the assessed fees.

    • Do not pay the compliance monitoring fee payment until the invoice has been received.
    • Pay the total fee amount on the invoice, including past-due balances.
    • Pay the invoiced compliance fees using the Rental Housing Invoice Portal.


    Late fees will be assessed on all unpaid balances starting March 2, 2026.

    Any outstanding invoices will be assessed a late fee per the following schedule.

    The greater of:

    • $100 or 10% of the total monitoring fee if paid 3/2/2026 through 3/31/2026.
    • $200 or 15% of the total monitoring fee if paid 4/1/2026 through 4/30/2026.
    • $300 or 20% of the total monitoring fee if paid 5/1/2026 or later.


    Tax Credit properties that have not placed all buildings in service     by December 31, 2025, are not required to pay compliance monitoring fees; however, properties must complete the Property Information Report (PIR), page one of the Owner’s Certification, and the management agent and owner must sign and submit the report by March 1, 2026.

    Electronic Invoice Payment Portal


    We strongly encourage electronic payment of all fees, where possible, as this will help reduce processing time.

    The Rental Housing Invoice Portal is used to collect compliance monitoring fees. The payment portal provides options to set up a free, one-time direct draft from a banking account or charge to a credit card (for an additional 3% transaction fee). Virginia Housing uses a banking provider; no account information will be stored after the transaction is complete. The payment portal can accept invoices for multiple projects in one transaction and provides an immediate email confirmation.

    To access the Rental Housing Invoice Portal, scroll to the top of this webpage, click "Login" in the top right corner, and select "Rental Housing Invoice Portal." Review the Rental Housing Invoice Portal Instructions or watch the Rental Housing Invoice Portal Tutorial video for guidance.


    Tax Credit Annual Owner's Certification


    On January 9, 2026, the Project Information Report (PIR) and the annual Owner’s Certification report will be distributed to the property's owner and management contacts. The reports will be sent from the Virginia Housing regional email accounts using Adobe Sign. Review the instructions in the Annual Tax Credit Reporting User Instructions for guidance.


    Average Income Test (AIT) Annual Reporting


    On September 30, 2025, the IRS published the Final Average Income Test Regulations in the Federal Register, requiring project owners to annually report as of December 31:

    • that all low-income units are assigned income limitation designations at 20% up to 80% AMI,
    • are rent-restricted at the unit designation,
    • at least 40% of the units are occupied or previously occupied by qualified households,
    • all low-income unit designations collectively average 60% AMI or less, and
    • all low-income residential units are habitable without uncorrected noncompliance, confirming the minimum set-aside test and applicable fraction.


    Tax Credit properties with Average Income where all buildings are placed in service by December 31, 2025, must satisfy the annual AIT reporting requirement. AIT reporting for properties that selected AIT as their minimum set-aside is satisfied in the online Tenant Portal when the “Validate” function is used for all tenant certification events and errors are corrected.

    For guidance on the AIT annual reporting requirements, review the following:



    State-Required Decontrol Period Owner's Certification Report


    Tax credit properties in the Extended Use Agreement-required three-year Decontrol Period must complete an Owner Certification report. The Owner Certification report will be sent to the owner and management agent from Virginia Housing regional email accounts using Adobe Sign. The annual report certifies compliance with the tenant protections for existing tenants.

    All Decontrol projects have been notified in writing of their Decontrol start and end dates. Contact your assigned Compliance Officer if you have questions about your project’s Decontrol status.

    Alternative Monitoring Annual Compliance Report
    (formerly known as ES-01)


    The Alternative Monitoring Annual Compliance Report will be sent from Virginia Housing regional email accounts using Adobe Sign. The report will be sent to the primary owner contact of properties financed by Virginia Housing. Property owners are required to certify tenant eligibility as determined by Virginia Housing’s regulatory documents.

    Virginia Housing-Financed Annual Owner Certification


    All properties financed by Virginia Housing that do not have tax credits must complete the Virginia Housing-Financed Annual Owner Certification report to certify tenant eligibility as determined by Virginia Housing’s regulatory documents. The report will be sent to the owner contact from Virginia Housing regional email accounts using Adobe Sign.

    Procorem Online Tenant Portal – Required Validation and Submission of Tenant Events for the 2025 Program Compliance Year


    By March 31, 2026:

    • Evaluate all property unit information, including market units and tenant  events for all low- and moderate-income units, and
    • Correct all errors.

    Please do not use the “Submit” feature in the online Tenant Portal. This is a change from the 2024 reporting year, in which properties were instructed to “Validate” and “Submit” all tenant certification activities. The “Submit” process is no longer required for annual reporting.

    Procorem training resources are available here under the Online Tenant Portal – Procorem section on this web page.

    After April 1, 2026, the 2025 Procorem compliance year and tenant events will be closed.

    Questions?


    Email property-specific questions to your assigned Compliance Officer or email program-related questions to Compliance-AssetManagement@VirginiaHousing.com. Include your property name and details in the subject line of the email.

     

  • Target Population Leasing Preference

    Through the Housing Credits Qualified Allocation Plan (QAP), Virginia Housing partners with Referring Agents to provide a leasing preference within the Virginia Housing Portfolio to persons with disabilities, known as the Target Population. The Referring Agent determines eligibility of the Target Population and refers them to properties in our portfolio.


    Properties with the Target Population leasing preference are required to complete the training course annually in the Virginia Housing Partner Portal Learning Management System to learn how to manage the leasing preference requirements in Tax Credit properties. The Target Population Leasing Preference Overview course will cover the Memorandum of Understanding first leasing preference, compliance monitoring for the leasing preference, and the partnership between Virginia Housing, the approved Referring Agents, and property management professionals. Review the Virginia Housing Partner Portal User Guide for instructions on how to create an account, log in, and enroll in the Target Population Leasing Preference Overview course.


    For more information about property requirements, refer to the Target Population Leasing Preference Guidance and the documents linked below.

  • Utility Allowance

    Housing Credit property owners must include the cost of all resident-paid utilities, excluding phone, cable TV and internet, in the gross rent charged to residents. To do this, owners must obtain a utility cost allowance for Housing Credit units. The utility allowance must be deducted from the applicable Maximum Tax Credit Rent Limit to determine the maximum rent that can be paid by a resident.

  • Training
    External Training Resources

If you have any questions, please contact your assigned Compliance Officer or email: Compliance-AssetManagement@VirginiaHousing.com

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