The Multifamily Finance Division of the Texas Department of Housing and Community Affairs (TDHCA) has posted on their website a memorandum regarding clarifications the allocation process for the 2012 Competitive (9%) Housing Tax Credits. The purpose of the memorandum is to convey to the public two challenges that may need to be considered and addressed during the staff’s award recommendations at the July 26th, 2012 Board meeting. The two challenges that have been identified as topics for further discussion are:
Non-profit set-aside: Due to an insufficient number of qualified nonprofit-sponsored applications in the 2012 9% cycle to meet the 10% set-aside, the staff seeks to clarify how this will be met without further reducing the overall amount of credits that can be awarded.
100% Underfunded Subregions: The 2012 QAP includes a provision that the most underserved regions be prioritized for the use of any remaining funds, which are combined from all subregions into one “pot” for allocation. Currently, there is not a step described in the QAP that explicitly instructs staff on how to prioritize applications in the event that two or more subregions are 100% underfunded and there are insufficient funds to reach all of the 100% underfunded areas. The staff believes that this situation will be encountered and that a resolution of the situation at the July 26th Board meeting may be necessary.
The staff recognizes that this tax credit cycle has been extremely challenging for all participants and wishes to provide the public the opportunity to consider and prepare to address the aforementioned issues. Should proceedings continue without additional measures, it seems likely that several regions may not receive 2012 awards.
The memorandum can be found on TDHCA’s website.
If you have questions or concerns about the memorandum or the tax credit program, please contact Cameron Dorsey at cameron.dorsey@tdhca.state.tx.us.
