NCSHA Letter on IRS Revenue Procedure 2024-21
On June 14, 2024, NCSHA submitted comments to the U.S. Treasury Department on Internal Revenue Service Revenue Procedure 2024-21, which proposes to change the data set used to establish the Mortgage Revenue Bond (MRB) and Mortgage Credit Certificate (MCC) programs’ purchase price safe harbors from the Federal Housing Administration’s loan limits to median home price data collected by the U.S. Department of Housing and Urban Development. NCSHA urged the IRS not to go forward with the proposed change. As IRS acknowledges, and an NCSHA analysis confirmed, the new methodology would cause significant, widespread reductions in the MRB/MCC safe harbors and, consequently, the MRB/MCC purchase price limits for most areas of the country. NCSHA’s letter noted purchase price limits are redundant and unnecessary, because MRBs and MCCs are subject to well-targeted income restrictions; therefore, IRS should ensure purchase price limit decreases don’t needlessly cut off access to MRB and MCC programs.
