Certified payroll for affordable housing, mapped to the funding stack.

LIHTC deals rarely close on tax credits alone — HOME funds, CDBG, public housing dollars, and state soft loans stack on top, and each source can carry its own labor-standards trigger. We map the stack, confirm what applies, and run certified payroll to whichever wage requirement is highest, for developers and general contractors building affordable housing anywhere in the country.

Request a compliance review See the certified payroll service

Why it matters

A labor-standards miss on an affordable housing deal doesn’t just risk a penalty — it risks the funding. HUD and state housing finance agencies can withhold disbursements, and a state tax-credit allocation can carry its own compliance conditions tied to the same closing binder your lender and syndicator are reviewing.

How we do the work

Method

Map the capital stack

Every funding source in the deal — LIHTC, HOME, CDBG, public housing, state soft loans, tax-exempt bonds — is checked against its own labor-standards trigger before payroll starts.

Confirm the HOME threshold

Under 24 CFR 92.354, federal Davis-Bacon generally attaches to HOME-assisted construction contracts covering 12 or more HOME-assisted units under one contract; we confirm unit count and contract structure rather than assume.

Check the state overlay

If the project sits in one of the states that runs its own prevailing-wage law — see our state-by-state coverage — or the state ties a tax-credit allocation to prevailing wage, that requirement is confirmed and applied too.

Run certified payroll

WH-347 or the awarding agency’s required format, verified against the governing wage determination before the payroll is finalized.

Build the closing file

A dated compliance record organized for your lender, syndicator, and the housing finance agency’s own monitoring review.

What you receive

Deliverables

Funding-source-by-funding-source labor-standards determination
HOME 12-unit / Davis-Bacon coverage confirmation
State prevailing-wage or tax-credit-conditioned wage check
Certified payroll prepared and verified weekly
Pre-submission exception review
Dated compliance file for lender, syndicator, and agency review

Scope, plainly statedWe run the labor-compliance recordkeeping, wage verification, and filing. We do not underwrite the deal, allocate tax credits, or provide tax or legal advice, and we hold no contractor license in any state. Confirm credit and compliance conditions with your syndicator, housing finance agency, and counsel.

Scoped and quoted per development once we’ve mapped the funding stack and unit count — email hello@aeternusdynamics.com with the sources of funds involved.

Pricing & scope

Questions developers ask

Common questions

Does the Low-Income Housing Tax Credit (LIHTC) itself require prevailing wage?

Not by itself in most states. LIHTC (Section 42) does not federally require Davis-Bacon on its own. Federal Davis-Bacon labor standards attach when the deal also layers in HOME, CDBG, public housing, or another covered federal funding source, and a growing number of states now tie some LIHTC allocations or scoring to state prevailing wage. We confirm the actual funding stack rather than assume either way.

When does HOME trigger Davis-Bacon?

Under HUD’s HOME regulations (24 CFR 92.354), federal Davis-Bacon labor standards generally apply to HOME-assisted construction contracts that include 12 or more HOME-assisted units under a single contract. Rehabilitation and smaller-unit-count HOME deals may fall outside Davis-Bacon but can still carry other federal labor-standards provisions.

What if the project has HOME, CDBG, and a state tax-credit allocation all at once?

Layered federal sources each carry their own labor-standards trigger, and the project’s state may add its own prevailing-wage requirement on top. We map every source in the capital stack to its trigger before payroll starts, and apply the highest wage requirement that governs.

Aeternus Dynamics uses AI-assisted tools to help prepare and check compliance documents; all deliverables are reviewed by a qualified human before submission or use. Aeternus Dynamics is not a law firm and does not provide legal or tax advice. See our Terms & Disclosures.

Start an engagement

Tell us the funding sources and unit count; we’ll confirm what applies and scope the filing.

Request a compliance review