Affordable housing compliance · nationwide
Compliance review that reads the file the way an auditor does.
Provenaut reviews tenant files against every program a property is subject to — LIHTC, tax‑exempt bond, HUD multifamily, Rural Development — in any state, and returns each finding with its severity and its citation. Before it becomes a monitoring letter.
Built by a former state-agency LIHTC compliance auditor — the rules are encoded from the write-up side of the desk, not read off a regulation and hoped for.
Wages annualized at 52 pay periods on a biweekly paystub. Recalculated at 26, household income lands above the applicable 60% MTSP limit for the property’s area by $1,340.
TIC Part IV · 24 CFR 5.609 as modified by HOTMAAsset section: one checking statement on file, current balance above the self‑certification threshold. The current‑balance figure is not carried to the TIC.
HOTMA one‑statement / current‑balance ruleOwner signature dated three days after the effective date — inside the window. Flagged for visibility, no action required.
CTCAC Compliance Manual · signature & date windowsThe problem
A 200-page file, ninety minutes, and one missed pay frequency.
Monitoring is continuous, not seasonal. Every file your staff builds is a file someone else will read line by line — and the errors that get written up are rarely exotic.
Volume
- Initial certifications, annual recerts, and unit transfers all land on the same desk
- A single file runs 150 to 250 pages of scans
- Review quality tracks the day the reviewer was having
The usual write-ups
- Income calculation methods mixed — VOE rate with paystub year-to-date
- Default annualization applied to a non-weekly pay frequency
- Verification outside its window, or the wrong instrument for the program
- Missing signature, wrong effective date, unsigned owner block
The cost of finding it late
- Found at intake, it is a correction
- Found in a monitoring letter, it is an Owner’s Response on a deadline
- Found at 8823, it is on the record
Programs
One review engine. Every program the file is subject to.
Affordable properties rarely sit under a single rulebook. Provenaut runs the layers a file is actually subject to — federal, state and local — and where they conflict, applies the strictest standard.
LIHTC — Section 42
Available nowThe core module, and a federal program: income certifications checked against current MTSP limits for the property’s area and household size, rent limits by bedroom size and set‑aside, the student rule, minimum set‑aside and applicable fraction, annual owner certifications, and signature and effective‑date windows.
Supporting documents are read, not just counted — paystubs, VOEs, bank and asset statements, W‑2s, disclosures — and reconciled against what the household disclosed. Vacant‑unit and 8823‑triggering conditions are called out with the standard that applies, including turn‑key‑ready and documented marketing rather than move‑in date.
The allocating agency’s own manual, form set and verification rules sit on top as configuration. California’s CTCAC is the deepest‑built agency today; additional agencies are onboarded the same way.
IRC §42 · 26 CFR 1.42‑5 · IRS Guide for Completing Form 8823 · agency compliance manualTax-exempt bond & state overlays
Available nowBond‑financed properties carry a second ceiling, and it is not always the one that binds. Provenaut evaluates each ceiling on its own terms — a household can clear one and fail the other, and the report says which.
Built out furthest on California’s welfare‑exemption overlay, where the 100% AMI income limit governing the exemption runs against the 140% AMI bond ceiling with January 1 as the controlling lien date. Paystub‑primary verification hierarchy with VOE as an accepted fallback, per‑asset additive imputation, and source reconciliation against the household’s own disclosures — without the false positives that come from reconciling figures across documents that were never meant to match.
IRC §142(d) · 24 CFR Part 5 · CA R&TC §214(g) · CMFA Charitable Housing ProgramHUD multifamily — 4350.3 & Section 8 PBRA
In developmentPart 5 income, the deductions as moved by HOTMA, recertification and interim timing, EIV discrepancy handling, and the 50059 / 4350.3 form set. The inclusions and exclusions port unchanged from the LIHTC engine; what changes is the verification hierarchy, the windows and the acceptable forms — which is exactly the layer being built.
HUD Handbook 4350.3 REV‑1 · 24 CFR Part 5 · HOTMA final ruleUSDA Rural Development 515
In developmentTenant certification, rental assistance eligibility, and the RD‑specific forms, verification windows and file conventions that rural portfolios run on — including properties layering RD with LIHTC, where the two standards have to be read together.
HB‑2‑3560 · 7 CFR Part 3560HOME, HTF & local layers
On the roadmapHOME and National Housing Trust Fund rules, plus the city and county overlays that attach to local subsidy, inclusionary units and density‑bonus agreements — the layer most often missed on stacked deals because it lives in a regulatory agreement rather than a manual.
24 CFR Part 92 · 24 CFR Part 93 · local regulatory agreementsStacked funding: where a property carries more than one layer, the strictest standard governs — and the finding names which layer produced it, so you know what you are answering to.
Coverage
The income rules are federal. What changes at the state line is narrower than it looks.
This is why one engine covers a national portfolio. Inclusions, exclusions and asset treatment come from Part 5 as modified by HOTMA and are the same in every state. What actually varies is the layer around them — and that layer is configuration, not a rewrite.
The federal core
- Income inclusions and exclusions under 24 CFR 5.609 as modified by HOTMA
- Asset treatment, imputation and the current-balance rule
- Section 42 set-asides, applicable fraction and the student rule
- Next-available-unit and vacant-unit standards
- The 8823 categories themselves
The agency layer
- Verification hierarchy — which instrument is primary, what falls back
- Verification windows and self-certification thresholds
- The agency’s own form set, checklists and required signatures
- State overlays such as welfare exemption or state credits
- Monitoring practice and correction-period conventions
How the review runs
Three agents. One answer you can defend.
Compliance calls are not a single judgment. Provenaut separates the work the way a review actually separates it, and writes down where the parts disagreed.
Triage
Identifies every document in the packet and maps it to the file — paystubs, VOEs, bank statements, W‑2s, TICs, checklists, disclosures — then flags what needs a compliance call and what does not.
Compliance
Runs flagged items against the program rules, income limits and rent restrictions. Calculation methods are held apart on purpose — rate×hours and year‑to‑date annualization are never fed each other’s inputs.
Arbitration
Where the first two passes disagree, arbitration resolves it and records the reasoning. Every finding arrives with its basis attached, so you can accept it, override it, or take it back to the file.
Every finding is a recommendation to a human reviewer. Provenaut does not certify a file — your compliance staff do, with the reasoning in front of them.
Coverage
Everything the file is judged on. Nothing you have to configure.
Limits, forms and thresholds are kept current per program and per jurisdiction. You pick the property; the standards it is actually subject to come with it.
Income
- Wages by rate, hours and pay frequency
- Year-to-date annualization, held separate from rate-based methods
- Self-employment, seasonal and variable hours
- Social Security, pension, unemployment, child support
- Inclusions and exclusions under Part 5 as modified by HOTMA
Assets
- Current-balance rule and self-certification thresholds
- Per-asset additive imputation
- Disposed assets and below-market transfers
- Statement completeness and date windows
Limits & rent
- MTSP and Section 8 income limits by area and household size
- Rent limits by bedroom size and set-aside
- Utility allowance applied to the gross rent test
- Bond and state-overlay ceilings evaluated separately
Forms & signatures
- TIC and TICQ completeness, part by part
- Owner certification blocks and initialed checklist items
- Every required signature and date, against its window
- Program-correct form versions
Household
- Composition against the disclosed household
- Student status and the exceptions
- Live-in aides, minors, and unborn children
- Additions, removals and unit transfers
Unit & property events
- Vacant unit rule — turn-key ready plus documented marketing
- Move-in, move-out and recertification timing
- Set-aside and applicable fraction consistency
- Conditions that trigger an 8823
How it works
Drop in the file. Get back a report you can act on.
No form-by-form data entry, no template mapping, no integration project. The sequence is the same every time.
Drop in the file
One combined PDF or a folder of scans, in whatever order your staff assembled it. Provenaut does not need the packet pre‑sorted.
Documents identified and read
Every page is classified, the figures are pulled with their source page recorded, and identifying information is scrubbed before any model sees the content.
Reviewed against the applicable programs
Each flagged item is checked against the rules, limits and forms for the programs the property carries — with disagreements resolved and recorded rather than averaged away.
Report out
Findings by severity, each with the page it came from and the standard it rests on. Hand it to staff as a correction list, or keep it as your own record of review.
Privacy & security
Your tenant files stay under your control.
Provenaut processes files where they already are. There is no upload step, no third‑party document service, and no tenant data sitting in someone else’s bucket. Deployment is your choice, including fully on your own systems.
Identifying information is scrubbed before the review layer ever reads a document, and nothing about a file is retained once the report is written.
Now scheduling demos
See Provenaut review a real file.
Twenty minutes, live. Bring a file type you find slow — a bond household near the ceiling, a variable‑hours income calculation, a recert with a mid‑year addition — and watch it run.