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Compliance & Reporting

Why Does Affordable Housing Ask for Bank Statements?

Providers require affordable housing bank statements to verify income and assets at application and at recertification. LIHTC and HUD Section 8 compliance standards require that evidence.

September 15, 20265 min readBy DIMOV Audit

Affordable housing bank statement rules

  1. Providers require bank statements to verify what a household earns and holds, at application and at each recertification, because LIHTC and HUD Section 8 rules demand third-party evidence.
  2. Below HUD’s self-certification figure a household supplies none, above it at least one current statement per banking or financial account, and a state agency that has not adopted HOTMA may ask for more.
  3. When the reviewer finds a statement missing, the unit can be out of tax credit compliance, the owner can lose subsidy payments, and the agency can flag noncompliance on the project’s record.

What auditors look for in affordable housing bank statements

During an affordable housing audit, the reviewer reads bank statements to:

  • Confirm that the deposits match declared sources of income
  • Locate recurring deposits from employment or benefits the household did not declare
  • Assess the household’s total assets against the program’s asset rules
  • Evaluate interest income or transfer patterns across multiple accounts

Employment verification letters and pay stubs do not show gig work or cash payments. Those appear only as deposits.

What Happens if the Bank Statements Are Missing?

When the reviewer finds a missing bank statement, the whole project is at risk, not only that file:

  • Temporary disqualification of the unit from tax credit compliance
  • Loss of subsidy payments
  • A flagged noncompliance issue on the project’s record

How Many Bank Statements Does a Household Have to Supply?

How many affordable housing bank statements a household has to supply depends on its net family assets, under the Housing Opportunity Through Modernization Act (HOTMA) rules:

  • Below the self-certification figure: none. The household self-certifies its assets. Owners may decline to allow self-certification, but only in a written policy.
  • Above it: at least one statement showing the current balance of each banking or financial account, dated within 120 days of the day the owner receives it.
  • Under a state agency that has not adopted HOTMA or that sets stricter standards: possibly more, so check your agency’s requirements.

The owner has to have implemented the HOTMA rules first. HUD’s Office of Multifamily Housing moved the full compliance date to January 1, 2027 in Notice H 2025-07, the same day the 2027 figures take effect. For LIHTC units the state allocating agency sets its own date.

HUD bank statement requirements: the 2026 and 2027 figures

HUD publishes each year’s amounts the previous August, effective January 1. Owners who have not implemented HOTMA do not use either table. The 2026 amounts (HUD table), with the 2027 amounts in brackets:

  • Self-certification of net family assets
    $52,787 or less ($54,898 from January 1, 2027)
  • Asset limit for Section 8 and public housing eligibility: $105,574 ($109,797 from January 1, 2027). It does not apply to LIHTC, HOME, HTF or Rural Development households.
  • Passbook rate used to calculate imputed income, the notional return HUD assigns to net family assets above the self-certification figure: 0.40% (0.38% from January 1, 2027)

What If the Tenant Has No Bank Account?

Some households have no bank account. Then the reviewer asks for other income and asset documentation: money order receipts, a letter explaining cash on hand, or a sworn statement. Providers accept these only when they are complete and consistent with the rest of the file.

How a LIHTC file review finds a missing statement

A missing or incomplete statement is found at the file review stage. In a LIHTC file review we read tenant files the way the state agency will, before the visit.

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Reviewed by George Dimov, CPA. Dimov Audit audits affordable housing and HUD-assisted projects for owners, managers and agents across all 50 states.

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