Report Calls for Improving Property-Level LIHTC Data

The National Low Income Housing Coalition and the Public and Affordable Housing Research Corporation recently released a joint report highlighting the need to improve both the quality of property-level LIHTC data for preservation and public access to these data. The report argues that more useful property-level data and access to this data would greatly aid efforts to preserve the long-term affordability of the LIHTC stock and the housing stability of tenants in LIHTC properties.

The Backdrop: Although LIHTC is an IRS program, HUD collects certain data on LIHTC properties and tenant characteristics from housing finance agencies (HFAs). HFAs, in turn, collect property and tenant data from LIHTC property owners. HUD collects the data using its LIHTC Property Data Collection Form and LIHTC Tenant Data Collection Form. HUD then provides property-level data to the public through the HUD LIHTC Database, which is updated annually. HUD periodically publishes summary tables about LIHTC tenant characteristics.

HUD created the LIHTC Database in the mid-1990s in an effort to “democratize” program data, and the department continues to improve the quality and completeness of the data. The HUD LIHTC Database includes property-level data reflective of when projects were placed in service, including the project name, geographic identifiers, project characteristics, financial characteristics, other subsidy information, and target populations. Because the HUD LIHTC Database incorporates data at the time projects are placed in service, the data can become outdated as property characteristics, such as ownership, change over time.

The collection of tenant data was enabled by the Housing and Economic Recovery Act of 2008 (HERA), which requires HFAs to report demographic and economic data about LIHTC tenants to HUD. While HUD does not make data on individual households publicly available, its summary tables provide a useful, snapshot of LIHTC tenant characteristics for each state. However, reporting rates for certain topics, can vary considerably across states.

One Level Deeper: The authors examined HFA’s LIHTC data practices in two phases from January to June 2022. In the first phase, they scanned HFA websites to determine the availability of property-level LIHTC data on agency websites. In the second phase, they interviewed staff from 25 HFAs about their experiences managing LIHTC data. The key findings include the following:

• 93 percent of HFAs post some form of property-level LIHTC data on their websites.
• The property-level data publicly posted by HFAs is largely limited to what these agencies already report to HUD’s LIHTC Database. Key preservation indicators, such as restriction end dates, the presence of qualified contract (QC) waivers, and up-to-date information on property ownership, are largely absent from HFA websites.
• LIHTC data are often siloed across various teams and systems within HFAs, creating challenges for them in providing comprehensive information to stakeholders about specific LIHTC properties.
• The fact that data are siloed can also complicate the construction of centralized, property-level databases.
• Many HFAs appear to face limitations in their staffing capacity and technology that inhibit their ability to better streamline or automate the collection and reporting of LIHTC data and develop centralized, property-level databases that include key preservation indicators concerning their LIHTC stock.
• Limited oversight power impedes the ability of both HFAs and HUD to collect more timely and robust property-level LIHTC data that can better inform preservation efforts.

The Bottom Line: HUD collects good data on both LIHTC property and tenant characteristics. Yet the report finds that there remain data gaps, especially regarding preservation risks related to expiring affordability restrictions, qualified contracts, and property ownership.