POST-AWARD COMPLIANCE CHECKLIST

Ohio TMUD Tax Credit: Compliance Requirements

What you must do after you win this award — administered by Ohio Department of Development · Ohio.

10
Total requirements
4
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Reporting: Rescission of entire tax credit certification
  • Financial & Cost Eligibility: Pre-application expenditures (except A&E) are ineligible; costs may be disallowed if not properly documented
  • Financial & Cost Eligibility: Automatic rescission of entire tax credit award if deadline missed
  • Financial & Cost Eligibility: Ineligible costs are disallowed and reduce tax credit value or trigger clawback
  • Recordkeeping: Inability to verify costs may result in disallowed expenditures and tax credit recapture
  • Financial & Cost Eligibility: Unauthorized material changes may result in credit disallowance or rescission
  • Financial & Cost Eligibility: Failure to demonstrate 10% increase in tax collections results in reduced or no tax credits
  • Financial & Cost Eligibility: Use of unauthorized financing sources results in ineligible costs and potential credit clawback
  • Reporting: Failure to report transfers may result in credit invalidation
  • Other Obligations: Non-cooperation with inspections or failure to provide access may result in credit denial

Reporting

  • Clawback riskEvent Driven

    Submit required reports identified in the program guidelines to the Ohio Department of Development. Failure to submit any identified report may result in rescission of tax credit certification by the Authority.

    Deadline: As specified in grant agreement and guidelines

    Source: FY25 Program Guidelines; OAC 122:29-1-07

  • MediumEvent Driven

    If tax credit is sold or transferred to another person, submit a transfer form to the Ohio Department of Development identifying the transferee, transfer date, and credit amount transferred.

    Deadline: Form must be submitted at time of credit transfer or sale

    Source: FY24 Program Guidelines; ORC 122.09

Financial & Cost Eligibility

  • Clawback riskOngoing

    Track and document all project expenditures and verify that costs comply with tax credit eligible expenditure requirements. Only costs paid or incurred after final application submission qualify, except for architecture and engineering fees incurred before submission.

    Deadline: Costs must be incurred after final application submission date

    Source: ORC 122.09(A); FY25 Program Guidelines Section 3

  • Clawback riskOne Time

    Begin construction within twelve months from project certification date. Failure to begin construction within this deadline results in automatic rescission of tax credit certification.

    Deadline: Construction must commence within 12 months of certification date

    Source: ORC 122.09; FY25 Program Guidelines

  • Clawback riskOngoing

    Ensure that eligible expenditures are limited to development costs specific to the certified project only, excluding expenditures for other phases of multi-phased development or pre-application costs (except A&E).

    Deadline: Cost eligibility determined from application submission forward

    Source: ORC 122.09(A); FY25 Program Guidelines Section 3

  • HighEvent Driven

    Project must not be amended in any material way once the Authority determines it is reasonably certain of the required increase in tax collections. Material amendments require Authority approval.

    Deadline: No material amendments permitted after tax collections determination

    Source: FY23/FY24 Program Guidelines

  • HighOne Time

    Calculate and document the increase in tax collections using an input/output economic impact model acceptable to the Authority. This determination must be made within one year after project completion.

    Deadline: Determination must be completed within one year of project completion

    Source: FY24/FY25 Program Guidelines; ORC 122.09(D)

  • HighOngoing

    Ensure that only financing sources committed at the time of application are used to pay for Tax Credit Eligible Expenditures. Financing sources cannot be used for ineligible expenditures.

    Deadline: Financing restrictions apply from application date through project completion

    Source: FY25 Program Guidelines Section 3; ORC 122.09

Recordkeeping

  • HighOngoing

    Maintain records documenting project expenditures, project completion, and cost verification. Make records available for review and inspection by the Ohio Department of Development upon request.

    Deadline: Records must be maintained and available for inspection at all times post-award

    Source: FY24 Program Guidelines; ORC 122.09(D)

Other Obligations

  • MediumEvent Driven

    Allow the Director of the Ohio Department of Development to conduct site visits to inspect and evaluate project progress at any time prior to issuance of tax credit certificate.

    Deadline: Site visits may occur with 3 business days notice

    Source: FY24 Program Guidelines

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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 Department of Development.