TDHCA’s proposed Housing Finance Corporation compliance monitoring rule will establish statewide standards for how tax-exempt developments are audited, documented, and publicly reported. Because HB 21 is prescriptive, the rule leaves limited discretion and places real weight on implementation details. For owners, auditors, and compliance teams, small drafting decisions will directly affect cost, risk, and day-to-day operations. Against that backdrop, early and coordinated engagement has been essential.
How TAAHP Organized Member Input
Recognizing the pace and complexity of HFC rulemaking, TAAHP’s Compliance Committee moved quickly to stand up the Tax Exemption Compliance Reporting Subcommittee this fall. Chaired by Stephanie Naquin of Novogradac, the subcommittee was launched on an accelerated timeline to ensure member expertise could be organized while the rule remained flexible.
In just a few weeks, the group held three working meetings, conducted a structured member survey, and consolidated feedback into a clear issues matrix. This rapid response effort reflects the strength of the Compliance Committee and the leadership of Stephanie in creating a focused forum where technical issues could be identified, tested, and refined before formal engagement with TDHCA.
TDHCA Roundtable on HFC Compliance Implementation
The groundwork laid by TAAHP members directly informed the November TDHCA roundtable on HFC compliance implementation, the first of its kind between TAAHP and the agency in several years. TAAHP appreciates TDHCA’s willingness to reopen this forum and engage in direct, solution-oriented dialogue with the industry. The tone of the discussion reflected strong working relationships with TDHCA’s Compliance Department and a shared interest in identifying implementation issues early, before they become compliance challenges in the field.
We also extend our thanks to Esme Thoman of Butler Snow for generously hosting the roundtable at her office, which made this in-person discussion possible.
Where the HFC Rule Stands Now
TDHCA has confirmed the proposed rule will return to the Board after identifying a discrepancy between the version approved by the Board and the version published in the Texas Register. The rule will be reposted with an additional 30-day public comment period, and final adoption is not expected before February.
Several stakeholder-driven revisions have already been incorporated. Other issues remain under discussion and will continue to be a focus of coordinated member feedback.
What Comes Next
TDHCA will host a live HFC Audit Workbook Roundtable on December 16, focused on audit standards and documentation requirements. This discussion will shape how compliance is monitored in practice, particularly where changes to rule text may be limited.
The Tax Exemption Compliance Reporting Subcommittee will remain active through the reopened comment period, workbook development, and final Board consideration of the rule.