ProLinkHFA Average Income Regulatory Updates

As the industry continues to grapple with the Average Income Test (AIT), ProLink is making changes to the Tenant Portal in order to better support average income properties. These updates reflect our commitment to inclusivity and responsiveness to the unique needs of different property types. This quarter, the ProLinkHFA release includes updates to support average income set-asides.


What is the Average Income Test?

October of 2022 marked the release of the newest temporary guidelines regarding the Average Income Test. These regulations bring clarity to the criteria for designating a unit as low-income according to Internal Revenue Code (IRC) Section 42. In general, for a unit to be considered low-income under Section 42, it must be suitable for occupancy and occupied by a household who is income- and rent-restricted at the applicable area median income (AMI) for the unit. These regulations broadened the scope of what a low-income unit is under the AIT to now include that the unit as part of a qualified group of units.


What is the minimum set-aside?

The minimum set-aside establishes the essential baseline for both the required number of tax credit units and the corresponding income limits that pertain to the property. Up until 2018, there existed three alternatives: 20-50, 25-60, and 40-60. Commencing from 2018 onwards, two supplementary “average test” options were introduced, thereby expanding the total potential minimum set-aside configurations to five.


How is Average Income Supported in ProLinkHFA?

The new ProLinkHFA update includes the following new average income data views:

  • AIT Unit Designations—Includes fields specific to the AIT Unit Designation record, as well as fields related to the property, building, and unit.
  • AIT Qualified Group of Units—Includes fields specific to the AIT Qualified Group of Units record, as well as fields related to the property and building.
  • AIT Applicable Fraction Group—Includes fields specific to the AIT Applicable Fraction Group record, as well as fields related to the property and building.

ProLink is also updating the XML importer to accept NAHMA XML version 7, which includes new attributes for average income properties. The imported records will include both tenant event records and AIT Unit Designation, Qualified Group of Units, and Applicable Fraction Group records.

We highly recommend using Version 7 for average income properties to ensure efficient compliance evaluation. Otherwise, beginning in 2024, owner/agents will need to enter the designations manually.


Kelly Encinias, HFA Senior Product Manager at ProLink, will also be speaking on a panel at Housing Colorado titled “Average Income Test Policies and Reporting” on Wednesday, October 11 at 10:45 a.m. MST. Click here to learn more about the event and register.

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