POST-AWARD COMPLIANCE CHECKLIST

Ohio Port Authority Tax Increment Financing: Compliance Requirements

What you must do after you win this award — administered by Ohio Port Authorities (Cleveland, Columbus, Cincinnati) · Ohio.

6
Total requirements
2
Clawback-risk items
6
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to make timely PILOT payments can result in tax lien, foreclosure, and termination of TIF exemption
  • Ongoing Eligibility: Material change in use can terminate the exemption and trigger retroactive tax liability
  • Reporting: Non-reporting may trigger state oversight review or jeopardize future TIF eligibility for the municipality
  • Recordkeeping: Inability to document proper use of PILOT funds may trigger clawback or disallowance of future payments
  • Labor & Wage: Failure to meet CBA requirements can result in withholding or reduction of TIF payments (for projects receiving $250,000+ in Cleveland)
  • Reporting: Non-response may lead to negative compliance findings and potential termination of exemption by municipality

Reporting

  • HighAnnual

    Municipal corporation must submit an annual status report to the Ohio Director of Development by March 31 each year, describing project progress, receipts from PILOTs, public infrastructure improvements financed, and changes in employment and private investment.

    Deadline: by March 31 of each year

    Source: ORC 5709.40(I)

  • MediumEvent Driven

    Developer must respond to information requests from the Tax Incentive Review Council within 10 days of certified mail receipt to support the council's annual compliance review.

    Deadline: within 10 days after receipt of written request

    Source: ORC 5709.85(F)

Financial & Cost Eligibility

  • Clawback riskAnnual

    Property owner must make annual service payments in lieu of taxes (PILOTs) to the county treasurer on or before the final dates for payment of real property taxes, in the same manner and amount as if the improvement were not tax-exempt.

    Deadline: on or before final dates for real property tax payments (typically semi-annual)

    Source: ORC 5709.42(A)

Labor & Wage

  • HighOngoing

    Developer must comply with nondiscriminatory hiring policies adopted by the municipality and any Community Benefits Agreement requirements, including minority- and women-owned business participation and local hiring commitments.

    Deadline: ongoing throughout construction and operations

    Source: Cleveland CBA ordinance practice (referenced in Signal Cleveland coverage); ORC 5709.85(D)

Recordkeeping

  • HighOngoing

    Developer and municipality must maintain records sufficient to document use of PILOT funds for designated public infrastructure improvements as specified in the TIF ordinance.

    Deadline: retain for duration of TIF exemption plus applicable audit period

    Source: ORC 5709.43

Ongoing Eligibility

  • Clawback riskOngoing

    Developer must maintain the improvement in use for the purpose declared in the TIF ordinance (commercial, industrial, housing, etc.) throughout the exemption period.

    Deadline: throughout the exemption period (up to 30 years)

    Source: ORC 5709.40(C)

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This checklist is compiled from official program sources and general grant-management rules for informational purposes. Final compliance obligations are governed by your specific grant agreement and the administering agency — always verify with Ohio Port Authorities (Cleveland, Columbus, Cincinnati).