Housing Finance Agencies sit at the intersection of policy, compliance, and human need. They administer billions in affordable housing dollars through programs that change often and rarely fit neatly into off-the-shelf workflows. And yet, most of the software these agencies rely on can’t keep up.

In our work with Housing Finance Agencies across the country, we’ve seen the same pattern: systems that appear functional on the surface but break down when applied to real regulatory complexity. Staff end up creating side processes, tracking exceptions in spreadsheets, or interpreting rules manually—all while carrying the risk if something goes wrong.

This isn’t just a UX problem. It’s a design failure.

At Emphasys, we’ve built and supported software for public-sector housing programs for over 45 years. Through that experience, we’ve developed a framework we use internally to assess and guide product design for regulated domains. We call it the Three C’s: Competency, Completeness, and Correctness.

Here’s what that means—and why it matters.

Competency: Domain Knowledge Baked into the System

Most enterprise software teams understand their tech stack. Far fewer understand the policy stack their users have to navigate.

Competent software reflects a deep understanding of the programs it supports. For HFAs, that includes everything from LIHTC rent limits and HOME affordability periods to bond cap allocations and layered funding rules.

Competent systems give agencies the flexibility to define AMI categories based on their specific program needs—while still guiding users within clearly defined, policy-aligned parameters. In Emphasys systems like LOTUS, agencies configure AMI ranges according to their funding structure, but the system enforces consistency by restricting selection to predefined options. This strikes the right balance between customization and control—supporting accurate reporting, streamlined workflows, and lower audit risk compared to systems that rely entirely on free-form user input or manual overrides.

Competent systems:

• Enforce HUD Handbook 4350.3 rules for income certification and student status
• Handle program-specific nuances, like IDIS drawdowns or IRS Form 8038 tracking
• Guide users with interfaces built around real workflow

This kind of domain fluency doesn’t come from requirements documents—it comes from building alongside analysts, former agency staff, and compliance teams. And it shows in small ways: field validation that matches IRS income definitions, workflows that guide users through layered funding sources, and UI decisions that reflect the way real programs are structured.

Modern tooling (containerized environments, CI/CD pipelines, test automation) helps—but only if you’re solving the right problem to begin with.

Completeness: The Edge Cases Are the Job

Incomplete software leads to workarounds. We’ve seen agency staff use spreadsheets to handle exceptions like nontraditional household structures, mixed-funding inspections, or post-close monitoring tasks. In housing, that means supporting everything from intake to audit. It also means anticipating edge cases. 

For example:

• A homeownership system that handles commitment, closing, and long-term monitoring
• Multifamily compliance that accounts for move-ins, unit transfers, re-certifications, and noncompliance resolution
• Bond systems that track inducement, carryforward, and arbitrage over a project’s full lifecycle

When any of those are missing, staff are forced to maintain parallel processes. That introduces inconsistency, reduces visibility, and increases audit risk.

The Institute of Electrical and Electronics Engineers (IEEE) defines completeness as the presence of all required functionality. In our world, that means understanding that policies change mid-process, households move between programs, and data rarely arrives perfect.

In affordable housing, edge cases aren’t anomalies—they’re the norm. A system that handles only the “happy path” is one staff will quickly outgrow.

According to the Project Management Institute (PMI), incomplete requirements are consistently listed among the top causes of project failure in both public- and private-sector IT initiatives. Specifically, PMI ranked “Incomplete requirements” fourth in their list of key failure drivers, highlighting how unclear or missing user needs often derail projects.

At Emphasys, we build for completeness by working closely with program staff and compliance experts to surface the full scope of program rules and operational needs—including edge cases. We design systems to support the end-to-end lifecycle of housing programs, from pre-commitment to post-close audit. We also prioritize configurability, so agencies can align the system with their specific funding sources, policy interpretations, and operational workflows—without resorting to spreadsheets or workarounds.

You can’t build a compliant system on an incomplete foundation.

Correctness: Staying in Sync with Policy

Correct software doesn’t just run—it applies the right rules, every time. In the HFA context, that means ensuring income and rent limits are current, program eligibility is enforced correctly, and compliance workflows align with funding source requirements.

We’ve seen otherwise functional systems generate findings because they used outdated AMI thresholds or allowed certifications to proceed without valid documentation. These aren’t edge cases—they’re recurring risks.

Correct systems:

• Apply the latest HUD and IRS guidance for LIHTC, HOME, and bond programs
• Use built-in validations to prevent invalid submissions
• Include role-based approvals, audit logs, and change tracking to support compliance

Correctness also means building the tools to adapt—automated rule updates, regression testing, and user acceptance testing. Because rules change, and the system has to keep pace.

Why This Matters

When software falls short in any of these areas, the consequences ripple outward: more staff time, more audit exposure, more friction for applicants and partners. And when public trust is on the line, those consequences add up quickly.

Software that meets the Three C’s isn’t just efficient. It’s safer. It gives agencies confidence that their systems will hold up under scrutiny, support their teams, and adapt as policies evolve.

At Emphasys, we design with this in mind—because for our clients, software isn’t just a tool. It’s infrastructure for housing equity.

Explore More

Ready to strengthen your agency’s systems for scale, compliance, and policy alignment?
Connect with our team at hfa-sales@emphasys-software.com to learn how Emphasys applies the Three C’s—Competency, Completeness, and Correctness—to help HFAs build software that holds up under real-world conditions.

🔗 Get in Touch