HUD FY 2022 Income Limits. Portland Metro Median Family Increase to $106,500 Bumps Max Rents Up For LIHTC 2 BR 60% MFI Unit By As Much as $132 a Month.

HUD has finally published income limits for FY 2022, which began Oct 1, 2021. The delay this year likely was related to absence of CBO inflation estimates (July 2021 vintage) which caused HUD to switch to an inflation index derived from Bureau of Labor Statistics data " The inflation factor, representing the cumulative change in the CPI from 2019 through February 2022, is 1.1116."

HUD Median Family Income Over $100K for the First Time.

The Portland metro median family income jumped from $96,900 to $106,500, an increase of $9,600/10%. This HUD Median Family Income is more than the $100,400 I  had previously projected primarily because HUD changed it method of calculating income limits using a BLS derived inflation index instead of CBO inflation estimates. 

The Portland metro area 10% HUD MFI increase is also slightly below the national cap on increases: "For FY 2022, an area’s low or very low income limits may not increase by the greater of 5 percent or twice the change in national median family income as measured by the ACS from 2018 to 2019,which is approximately 11.89 percent."

MY LIHTC Maximum Rent Calculation for Portland Metro. 

HUD publishes separate multifamily tax subsidy income limits HERE that are used by states to set maximum incomes and rent levels for LIHTC projects. HUD notes that states, not HUD, set actual income and rent limits for LIHTC projects so the HUD published income and rent limits MAY be subject to further modification by states. 

[Oregon's rent increase policy for LIHTC projects varies and is described in detail HERE].

For this post I calculated the new income and rent limits and compared FY 2022 limits to 2021 limits for the Portland metro area. A subsequent post will provide a statewide snapshot of the changes in LIHTC income and rent limits by county.  

Caveats:

OHCS rent increase policies may limit the max rents that I have calculated for some projects and for some tenants. 

Rounding conventions may also slightly modify my calculations. 

ALLWAYS double check calculations against official government sources, OHCS and HUD.

LIHTC projects built before 1998 may have slightly different rent limits, called HERA rent limits. Those and other official Oregon LIHTC limits will eventually show up on the OHCS website HERE. 

With those caveats , the table pasted below shows my calculations. 

FY 2022 Observations:

50% LIHTC Max Rent and Income Changes

Maximum monthly rent for a 2 bedroom LIHTC unit at 50% MFI jumps $110, from $1,088 to $1,198. 

The 3 person qualifying maximum income at admission (used for 2 Br income qualification) jumps from $43,500 to $47,950 annually. 

60% LIHTC Max Rent and Income Changes 

Maximum monthly rent for a 2 bedroom LIHTC unit at 60% MFI jumps $132, from $1,306 to $1,438. 

The 3 person qualifying maximum income at admission (used for 2 Br income qualification)  jumps from $52,260 to $57,540 annually. 

Because LIHTC Maximum Rents Are Still Below the HUD Fair Market Rent, 100% of the Supply of Portland Metro LIHTC Units Should Be Affordable to HUD Voucher Holders. 

The Portland metro HUD FY 2022 FMR 2 bedroom rent is $1,735 so both 50% MFI rents [$1,198] and 60% MFI 2 bedroom LIHTC FY 2022 rents [$1,438] are below the HUD 2 Bedroom FMR. 

This is also true for all other bedroom sizes-- HUD 2022 Portland FMR's for ALL bedroom sizes are higher than maximum 50% and 60% MFI LIHTC FY 2022 rents.

This means that in the Portland metro area for FY 2022 100% of the supply of  LIHTC units should be affordable to voucher holders, unless the local housing authority adopts a payment standard that is lower then the HUD FMR.

The HUD Picture of Subsided Housing reports about 22,000 voucher units in the Bi-State Portland metro area.

The HUD LIHTC property level database reports a total of more than 26,000 LIHTC units placed in service in the Bi-State Portland metro area, even missing counts of LIHTC units placed in service in 2020 and 2021 in Oregon. 

So, not only are the Portland metro maximum LIHTC rents below housing voucher fair market rents, but the supply of LIHTC units is also more than the number of total HUD housing vouchers in the Portland metro area. 

While some vouchers are project based in LIHTC projects tenant based voucher holders are generally not required to live in specific projects, including LIHTC projects. 

Bottom Line: The supply of LIHTC units is a critical and affordable resource available to voucher holders. 

Originally created and posted on the Oregon Housing Blog.