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Christopher Nunn
Commissioner
Brian P. Kemp
Governor
Management Company Approval Policy
Effective date: January 15, 2021
Policy Overview
The Georgia Department of Community Affairs (“DCA”) is responsible for ensuring that owners of
properties funded by the Georgia Housing and Finance Authority’s (“GHFA”) various multifamily
affordable housing programs maintain compliance with all funding programs’ requirements.
These funding programs include but are not limited to: Housing Tax Credit (“HTC”) 9% and/or
4%-Bond funding, 1602 Tax Exchange Funding, HOME, NSP, PSHP, SHTF, and TCAP funding.
This policy comprises the minimum requirements necessary to gain DCA’s approval to manage
a property that currently has affordable housing restrictions imposed on it by GHFA or will have
affordable housing restrictions imposed on it by GHFA due to a submitted application for funding.
DCA will perform a comprehensive review to determine whether a proposed management
company meets minimum qualification requirements related to affordable housing experience,
training, technical skills, and performance history to successfully manage an affordable housing
property community or portfolio in the state of Georgia. DCA reserves the right, to modify this
policy at any time or to waive any of the requirements listed below on a case-by-case basis.
DCA must comply with statutory requirements to consider project team qualifications to own and
operate a DCA or GHFA-funded property. This extends to the management company’s ability to
manage a DCA affordable property. Experience and training are required to manage all DCA
affordable properties, regardless of the funding program. Further, all project teams must include
a management company that agrees to operate properties in accordance with compliance
requirements set forth by DCA, HTC program regulations, HOME Investment Partnership
program (“HOME”) regulations, and/or other funding program regulations.
Properties in the FDIC Program should contact the DCA Compliance Department at
for FDIC specific regulations, requirements, and ownership and
management change requests.
Management companies may seek general approval from DCA in advance of, or without having
a management agreement with a developer/owner for a specific DCA/GHFA funded or monitored
property.
Owners are required to submit all management company approval requests to DCA no less than
30 days in advance of the effective date of the proposed management change or effective date
of management. Failure to provide such advance notice is considered a major finding of non-
compliance and can result in point penalty deductions assessed on Tax Credit applications as
stated in the applicable QAP and may affect the good-standing status of both the management
company and owner with DCA.
DCA will not approve management companies seeking approval to manage affordable properties
funded and/or monitored by DCA/GHFA, if the following conditions exist:
1) Management company is currently barred or suspended or has been barred or suspended
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Christopher Nunn
Commissioner
Brian P. Kemp
Governor
by any state Housing Financing Agency (“HFA”) or equivalent agency within the past two
(2) years from the date that approval is sought. Evidence of reinstatement by the
governing agency must be provided to be considered for DCA’s approval.
2) Management company has, in the five (5) years prior to the submission of an approval
request, received a final decision that a discriminatory housing practice has occurred as
determined by a court, the U.S. Department of Housing and Urban Development (“HUD”)
or has been found guilty of discrimination by any government agency on any affordable
housing property. Management companies under a compliance agreement are eligible for
DCA approval, contingent upon adherence with HUD’s compliance agreement
requirements.
3) Management company is performing third-party management without a licensed
brokerage in Georgia. Georgia Law requires that all third-party property management
companies be a licensed brokerage in Georgia or perform all leasing activity under a
licensed Georgia real estate broker. This license must be current and valid. There are no
exceptions to this requirement. To comply with state law, existing management
companies should forward evidence of the brokerage license or must obtain broker status
no later than June 30, 2021. If DCA discovers management companies providing fee
management that are not licensed in Georgia, DCA will notify the Georgia Real Estate
Commission and the Owner, and the management company’s DCA approval status will
be revoked. DCA may reinstate approval upon receiving evidence of the management
company obtaining a brokerage license.
Discovery of any of the items above, after DCA approval, will cause the management company’s
approval status to be revoked.
Section I. Qualification Requirements
Management companies seeking first-time approval to manage DCA properties that are
subject to the rules and regulations of GHFA’s various affordable multifamily housing
programs must meet and evidence the following minimum qualification requirements:
a. Two or more years managing a minimum of three qualifying affordable properties
in any state. The qualifying affordable properties must be funded by HTC, HOME,
or USDA’s Rural Development program. These qualifying properties must be under
a management contract at the time of request submission.
b. Each management company must always have at least one compliance specialist
or responsible manager with at least one of the following nationally recognized
credentials: HCCP, SCHM, NPCC, C3P or higher. These credentials/certifications
must be current and valid.
c. Good standing status with all applicable state HFAs and/or their equivalents must be
provided to DCA in the form of a Letter of Good Standing or equivalent proof of general
compliance provided by each HFA or their equivalent. DCA will also take into
consideration, any management companies that may be flagged for poor performance
by HUD, or by any other agency. Should DCA become aware of a change in the good
standing status after DCA has provided approval, DCA reserves the right to reconsider
the approval status of the management company, at DCA’s sole discretion.
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Christopher Nunn
Commissioner
Brian P. Kemp
Governor
d. Completion of the Management Change/Approval Request form available on the
DCA website here
.
Management companies, including Public Housing Authorities (“PHAs”), that do not meet
DCA’s minimum experience requirements may have the experience and credentials of
individual management principals and/or officers evaluated to achieve one of the approval
statuses listed in Section VI. Resumes of all management company or PHA officers are
required if minimum qualification requirements have not been met as noted in this policy.
As outlined in Section VI., DCA may impose limitations on the number of Georgia DCA
properties that can be managed. Additionally, DCA may require the management company
to contract with a third-party compliance consultant or professional. These exceptions are
designed to help a management company obtain affordable housing experience in Georgia
in manageable increments.
Section II. Documentation Requirements – Management Companies new to DCA
Management companies seeking, for the first time, to manage Georgia DCA properties that
are subject to the rules and regulations of GHFA’s various affordable multifamily housing
programs must submit a formal request to DCA via the Management Change/Approval
Request on-line form, available on the DCA website here
. On-line submission requests
must include the following items and/or documentation:
i. Applicable Management Company Approval Fee (see fee schedule, Section IV.
herein)
ii. All documentation evidencing the Qualification Requirements as required in
Section I. of this policy, items a. through d.
iii. Copy of the lease template package, which should include the lease application,
lease addenda and other forms, currently in use or proposed for use for low
income units (if applicable)
Section III. Documentation Requirements – Management Companies already
managing Georgia DCA properties
Owners of Georgia DCA properties that are subject to the rules and regulations of GHFA’s
various affordable multifamily housing programs requesting a change in management
company to a management company that already has experience managing Georgia DCA
properties must also submit a formal request to DCA via the Management
Change/Approval Request on-line form, available on the DCA website here
. On-line
submission requests must include the following items and/or documentation:
i. Applicable Management Company Approval Fee (see fee schedule, Section IV.
herein)
ii. Copy of the lease template package, which should include the lease application,
lease addenda and other forms, currently in use or proposed for use for low
income units (if applicable)
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Christopher Nunn
Commissioner
Brian P. Kemp
Governor
Section IV. Multiple Property Requests
Owners and/or Management Companies seeking approval for more than one property may
submit one on-line form requesting approval to manage multiple properties. However, the
properties must all be owned by the same Ownership team. A detailed list of those
properties must be uploaded and attached as part of the on-line submission, and must
include the Property Name, Georgia DCA Property ID Number and the full Property
Address.
DCA reserves the right to limit the number of properties any management company may
receive approval to manage.
Section V. Schedule of Management Company Approval/Change Request Fees
• First property: $500
• Any additional properties: $150 per property, not to exceed $2,000 total
Section VI. Non-Compliance Penalty
All Management Company change approval requests provided less than 30 days in advance
will be issued a finding of administrative non-compliance which can result in the following:
• Point penalties imposed on an HTC application score as indicated in the applicable QAP
Scoring Compliance Performance section
• A $250 penalty fee (per instance) for non-compliance/failure to provide 30 days’ notice
and receive DCA’s approval in advance the management company change
All fees and penalties referenced in this policy are nonrefundable. Check(s) should be
made payable to Georgia Housing and Finance Authority, and mailed to:
Georgia Department of Community Affairs
Attn: DCA Office of Portfolio Management
60 Executive Park Drive S NE
Atlanta, GA 30329
Re: Management Company Approval Request
All applicable fees are due at the time of Management Change/Approval Request online form
completion. DCA will not process any Management Change/Approval requests without the
appropriate fees.
Section VII. Approval Levels
Based upon the review of submission documents, approval levels will be assigned as
outlined below. DCA will publish a list of management companies and their corresponding
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Christopher Nunn
Commissioner
Brian P. Kemp
Governor
approval status to the DCA website no less than twice per year.
DCA Approved – All experience, credentials, and documentation meet DCA requirements.
Conditionally Approved with Limitations – Any of the requirements of Section I of this
policy has not been met. Accordingly, a third-party tax credit and/or HOME compliance
consultant will be required for a period to be determined by DCA, not to exceed three (3)
years. DCA will limit the number of properties that can be managed to no more than five
(5) properties. Management companies with a status of Conditionally Approved with
Limitations will be required to submit to DCA for approval, evidence of the contract with the
third-party consultant and evidence that the consultant meets criteria a and b of the Section
I. Qualification Requirements of this policy. Conditionally Approved with Limitations status
may be reviewed after three (3) years or the first compliance review under the new
management takes place, whichever is sooner. After review, DCA may choose to change
the status to DCA Approved, Probationary Approval, or Not Approved/Approval Revoked.
Probationary Approval – Management companies previously receiving a DCA Approved
or Conditionally Approved with Limitations status may be downgraded to Probationary
Approval. DCA reserves the right to downgrade approval status if it becomes aware of
evidence of systemic noncompliance or operational issues, at DCA’s sole discretion. These
include but are not limited to poor property condition, poor file maintenance, resident
complaints, poor financial performance, and/or low occupancy. Accordingly, a third-party
tax credit and/or HOME compliance consultant will be required for a period to be
determined by DCA, at DCA’s sole discretion. Management companies with a status of
Probationary Approval will be required to submit to DCA for approval, evidence of the
contract with the third-party consultant and evidence that the consultant meets criteria a
and b of the Section I. Qualification Requirements of this policy. Management companies
with a Probationary Approval status will not be allowed to manage any additional properties
until they achieve a DCA Approved status.
Not Approved/Approval Revoked – One or more of DCA’s requirements have not been
met. DCA reserves the right to deny approval or revoke approval to a management
company for any reason, at DCA’s sole discretion.
Management companies shall have an opportunity to appeal a denial by DCA. All
appeals shall be submitted in writing to DCA no later than fourteen (14) business
days following a denial and all appeals decisions shall be final.
Section VIII. Submitting Funding Applications to DCA
Applicants for DCA/GHFA funding must ensure the management company included in all
applications is categorized as DCA Approved or Conditionally Approved with Limitations
by the deadline specified in the applicable QAP. If the management company does not
achieve one of these statuses by the deadline, the applicant will be required to replace the
management company in the application with a management company that is categorized
as one of the approval statuses listed in this section. This applies to all current and future
applications as of the effective date of this policy.
