SERVICE

Inclusionary Below Market Rate (BMR) renter recertification

Below Market Rate renter recertification information for Inclusionary Property Managers and Leasing Agents

What to know

What is recertification?

Every year, property owners in the BMR program must collect current income and asset information and verify household size and occupancy status for BMR renters. This process is called recertification.

You can read more about re-certification and it's requirements on page 65-66 of our Inclusionary Affordable Housing Program Monitoring and Procedures Manual (2024)

When to start the process

MOHCD recommends starting the process 120 days prior to the previous re-certification or initial lease-up. This allows enough time to complete the recertification process, and provide the required noticing time for any rent increases.

Compliance

You must be in compliance with annual recertifications in order to re-rent BMR vacancies and you must be in compliance with the recertifications to do rent increases.

What to do

1. Send households required documentation

Send households a Recertification Letter (this is an example document, please be sure to send your own re-certification letter) and Recertification - BMR Rental Application Form A.

2. Review applications

  • Review all submitted documents.
  • Complete the Review and Analysis (R&A) worksheet, based only on the most recent tax return form.
    • If the income based on the tax return is 175% AMI or below, the household has completed the income portion of recertification.
  • If the income exceeds 175% AMI or if the household does not have a valid reason for having to not file tax returns:

3. Process disqualifications and appeals

  • If renters are disqualified, you must notify them by mail, email, text, and a phone call. You will need to prepare and provide the renter with the following form: MOHCD-Disqualification Recertification
    • You must offer a disqualified household 5 calendar days to appeal. An appeal must include a Letter of Explanation, along with all supporting documents.
    • If renters are disqualified for missing documents, you must issue a letter listing the missing documents. You must allow the renter another 5 calendar days to send in the missing paperwork.
  • Submit appeals to MOHCD for review. MOHCD will make the final decision on all appeals.
  • You must allow 10 business days for MOHCD to review the appeal.
  • If the recertification or the appeal is denied by MOHCD, you must give the household a 90-day non-renewal notice.
  • The household must vacate by the end of the 90-day period.