State Allocating Agency Priorities for 2011

A review of the Qualified Allocation Plans (QAPs) of the State Allocating Agencies indicates some new priorities and directions for a number of states with regard to the Low-Income Housing Tax Credit Program.

For example, the Massachusetts Department of Housing & Community Development (MDHCD) is imposing a limit of two applications per development team. This is to prevent some developers from dominating the credit program, which would affect the support of the program among the broader development community.

One of the noticeable trends in 2011 is toward the development of smaller or rural projects. The Wyoming Community Development Authority (WCDA) has a set-aside for areas with populations of 7,500 or less, and is providing a 30% boost in eligible basis for projects with no more than 12 units.

The Virginia Housing Development Authority (VHDA) is giving additional points for projects with 50 units or less. VHDA is also increasing points for preservation projects.

Other agencies, such as the allocating agencies in Maryland and California, are taking steps to increase the energy and resource efficiency of LIHTC projects.
In Maryland, preservation projects must have an energy audit and submit an energy improvement report to be eligible for an allocation. Substantial rehab projects that already comply with current energy conservation codes are exempt from the requirement.

Developers planning on 2011 deals are encouraged to examine the QAP in any state in which applications are planned, and tailoring those applications to give them the best chance for success. Small projects and preservation are being stressed by many agencies this year, while larger, new construction projects are less favored than in the past.