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Grand Rapids Housing Commission

From Fragmented Files to Audit-Ready: Restoring LIHTC Compliance at Grand Rapids

Client Snapshot

Organization Type: Public Housing Authority

Location: Grand Rapids, Michigan

Engagement Type: LIHTC Compliance Review, Internal Controls & Quality Assurance

Programs Supported: Low-Income Housing Tax Credit (LIHTC) Program

The Challenge

Compliance breakdowns in tax credit programs represent significant risk for public housing agencies, particularly when internal controls and program responsibilities overlap across funding streams.

The Grand Rapids Housing Commission entered a critical period in which leadership identified warning signs that LIHTC compliance was slipping. An initial process mapping exercise confirmed those concerns: tenant files were disorganized and incomplete, staff often relied on HUD 50058 requirements instead of LIHTC standards, and internal controls were weak with significant overlap between Section 8 and LIHTC responsibilities.

As a result, more than 320 tenant files were overdue for review, leading to mounting documentation gaps, declining confidence in compliance accuracy, unresolved program errors, and elevated funding and investor risk.

AMA’s Approach

Grand Rapids partnered with AMA Consulting Group to provide project management, on-site compliance support, and internal controls development during this high-risk period.

AMA’s role focused on stabilizing compliance integrity while maintaining operational continuity. By embedding a project manager and compliance specialists on site, enforcing review discipline, and separating LIHTC responsibilities from HUD program duties, AMA guided the agency from fragmented processes toward a structured, audit-ready compliance environment.

Key Actions Implemented

  • Conducted comprehensive quality control review and file purging across all LIHTC tenant files
  • Implemented LIHTC-specific internal controls and policy documentation aligned with state requirements
  • Provided on-site partnership with a project manager and two compliance specialists working alongside agency staff
  • Developed guide sheets, checklists, and sample applications, with one-on-one training and live tenant appointment coaching

Results & Outcomes

  • 100% of tenant files reviewed with issues flagged and tracked
  • Creston Plaza closed its compliance audit with zero findings
  • Hands-on staff training delivered immediate improvements and built internal capacity
  • Internal controls implemented and integrated into agency policy systems
  • Operational blind spots exposed, enabling stronger leadership oversight and accountability
  • Established clear separation of duties between Section 8 processing and LIHTC compliance

Long-Term Impact

Beyond completing the file review, AMA helped Grand Rapids establish a governed, sustainable compliance environment. The agency is now positioned to maintain reliable LIHTC operations, protect funding streams, and operate with strengthened internal controls and accountability across properties.

Before & After Snapshot

Before

• Disorganized and incomplete tenant files
• Overlapping Section 8 and LIHTC responsibilities
• Weak internal controls and declining compliance accuracy

After

• Reviewed, organized, and tracked LIHTC tenant files
• Clear separation of duties between Section 8 and LIHTC
• Strengthened internal controls and audit-ready operations

Closing

Compliance challenges are governance issues as much as they are technical ones. AMA Consulting Group partnered with the Grand Rapids agency to clear the file backlog, establish sustainable internal controls, and equip staff with the tools and training needed to maintain LIHTC compliance long after the engagement ended.

Ready to Transform Your Agency?

Every agency’s situation is just as unique, but the path forward doesn’t have to be unclear. AMA brings the expertise, structure, and hands-on support your team needs to move forward with confidence.