Affordable Housing & Compliance

5 Takeaways on E-Signatures, TRACS, and NAHMA’s Winter Meeting

Content Team

In this episode of “Cocktails and Compliance” – ResMan’s podcast about the affordable housing industry – ResMan SVP of Marketing Dennis Behrman speaks with RightSource’s Vice President of Compliance Janel Ganim. Ganim attended NAHMA‘s Winter Meeting, a biannual conference for the affordable industry to gather together and talk about the most pressing issues. 

In case you missed the meeting, here are Ganim’s top takeaways about the fast-approaching future of affordable: 


Ganim and her colleagues have been working on a draft notice that recommends policy on how to implement electronic signatures in the affordable housing sector. HUD is close to releasing the draft notice to the public for comments, which will then stay up for a two-week comment period.  

“I coached to develop this working notice and co-authored it with a colleague, Mary Ross, who is very hands-on in the industry,” Ganim said. “We did have a lot of input from owners and agents and contract administrators who are very anxious to see this take place.” 


The TRACS 203A update is delayed because the Office of Management and Budget is playing catch up on form approvals.  

“We are hearing from HUD that they expect to start implementation sometime summer of 2019,” Ganim said. “I do anticipate there will be a four to six-month transition period as with any big TRACS release.” 

Stay tuned. 


HUD has a concern that properties are able to pass their inspections and still have poor unit conditions. So, it decided that it will only give a 14-day notice of an on-site inspection. If a property management company were to cancel or reschedule, the company would receive an automatic score of zero. This went into effect on March 20, 2019. When HUD was asked about negotiating, it said there was no changing the 14 days.

Carbon Monoxide Detectors in Units

HUD’s short-term plan is to make all carbon monoxide detectors mandatory in units with gas appliances. It is also changing how inspections are conducted. Previously, unit inspections made up 35% of your inspection score. Now, that has increased to 50% because HUD is more concerned about the quality of the actual unit as opposed to the building exterior. HUD is starting a two-year trial of this new policy in Pennsylvania, Virginia, D.C., Maryland, and Delaware.   

Income Averaging

Affordable professionals are used to minimum set-asides for units at 50% median income or 40% of units at 60% median income. This is due to the Consolidated Appropriations Act of 2018. The bill allowed for affordable housing companies to move in residents at 20% through 80% median income. The goal was that any combination of units can be identified as intended to satisfy your minimum set-aside, as long as the average affordability of the units is 60%.  

With the change, if you have a higher applicant pool to choose from, instead of being limited at a 60% income, now you can move someone in at an 80% income. That means that when you have market renters in your units, who really qualify at 80%, the market renters’ units can qualify for tax credit units because you are still going to serve the lower income population as well.  

“[Income averaging] increases your applicant pool and it also allows you to charge higher rents for the 80 percenters because of the tax credit rent calculated off the income limit,” Ganim said. It makes a property overall more viable and is a great option for tax credit developers.” 

About Janel Ganim  

Janel Ganim is the Vice President of Compliance at RightSource. She has worked in the affordable housing industry for more than 20 years. She is actively involved in multiple affordable housing organizations, including serving as vice chair of the NAHMA Affiliates Committee and participating in HUD working groups to create TRACS industry specifications. 

Listen to the entire podcast our YouTube Channel: Make-Ready – A Property Management Podcast

Conquer compliance with ResMan’s comprehensive Compliance Analytics Center. It’s modern design and easy-to-use interface awards you the confidence you deserve. 

request a demo

Subscribe to Our Blog


Stay In The Know

Subscribe to Blog