THDA’s Board of Directors approved Tennessee’s 2019-2020 Low Income Housing Credit Qualified Allocation Plan (“2019-2020 QAP”) yesterday afternoon.  The 2019-2020 QAP includes the amended/updated Total Development Cost table as approved by the Tax Credit Committee.  Further changes as housekeeping items have been discussed with developers and owners and will be added in red-line format possibly as early as Friday but no later than next Thursday.  Previously identified housekeeping items discussed with developers include:

  1. Section 3. State Allocation Limits:  Housing Credit Limits for New Construction contains a table which provides per county caps for developments.  The corrected language should identify the per county cap numbers:
  • Urban-2 developments
  • Suburban-1 development
  • Rural-1 development”

Section 12.  New Construction Regional Pool identifies requirements of New Construction Allocations.  The corrected language should read as:

  • A New Construction Initial Application receiving Housing Credits from a Regional Pool is limited to a maximum of one Allocation per county.
  • A New Construction Allocation from the general pool is limited to the per development caps found in Section 3 of this QAP.
  • An Initial Application proposing new construction cannot be located in a QCT unless the Initial Application receives Housing Credits under CNI, the Innovation Round or the PHA Set-Aside.
  • An Initial Application proposing new construction located in a rural urbanicity may be eligible for a Basis Boost.”

Section 14. Initial Application Scoring:  Rehabilitation of Existing Multifamily Housing Only, Project Location and Needs contains the term three year average occupancy rate.  The corrected language should read as “three year average physical occupancy rate”.

  1. Section 14. Initial Application Scoring:  New Construction and Rehabilitation of Existing Multifamily Housing, Recapitalization Waiver contains a table which provides points for deferring the year of recapitalization.  The corrected language will identify the years for recapitalization as:

At least 17 years from Original Allocation                             1 point

At least 18 years from Original Allocation                               4 points

At least 19 years from Original Allocation                              7 points

At least 20 years from Original Allocation                              10 points

Section 14.  Initial Application Scoring:  New Construction and Rehabilitation of Existing Multifamily Housing, Development Characteristics and Populations Served contains a description and table for applicants selecting minimum set-aside federal elections of 20%-50% and 40%-60%.  The corrected language will clarify the income limits of the households being served as:

Applications proposing the minimum set-aside federal election of 40%-60% will serve a percentage of households with incomes no higher than fifty percent (50%) of the area median income with rents maintained at or below the 50% area median income maximums or applications proposing the minimum set-aside federal election of 20%-50% will serve a percentage of households with incomes no higher than forty percent (40%) of the area median income with rents maintained at or below the 40% of area median income maximums (Units occupied by households with Section 8 Housing Choice Vouchers count towards this requirement).  PHA applications and applications proposing the minimum set-aside federal election of 60% Income Averaging are ineligible for these points.

  • Section 14. Initial Application Scoring:  New Construction and Rehabilitation of Existing Multifamily Housing, Development Characteristics and Populations Served will add the following language under Project Location and Need.  The corrected language will identify units fixed by income limits for households being served under the minimum set-aside federal election of 60% Income Averaging as:
  • For applications proposing the minimum set-aside federal election of 60%  Income Averaging up to 10 points
  • A statement from permanent lenders and the equity provider (at Final Application) acknowledging 60% Income Averaging for the proposed unit sizes and percent income limits.  5 points
  • A market study (at Initial Application and updated at Final Application, if necessary) showing current adequate demand for all proposed combinations of unit sizes and percent income limits.  5 points”

These items will appear as red-lined changes along with any additional housekeeping changes which we identify or receive via email to TNAllocation@thda.org using the comments form found on THDA website.  Please provide us with your comments and improvements, including housekeeping clarifications by October 15, 2018.