Application assembly and submission — Connecticut

The real first gate is DOH and CHFA's joint Development Engagement Process

Before any LIHTC application is filed, CHFA's own LIHTC Program Guideline (effective 11/1/2025) requires every applicant to "indicate their intent to submit an application for LIHTC by submitting a Preliminary Application in accordance with CHFA Procedures through the Development Engagement Process (DEP) by the date specified." DEP windows are published "on a bi-annual basis, generally in the spring and in the fall," and a Pre-Application Conference with both CHFA and DOH staff follows -- scheduled "within 30 days from the DEP due date," and available "anytime up to 45 days before an application due date for a funding round." DOH's own Fall 2025 DEP notice is explicit about what this stage is not: "The DEP Fall 2025 is not a competitive funding round. It is intended to provide an early assessment of development proposals," and "participation in the DEP does not constitute a commitment of any DOH or CHFA financing or other assistance."

A 9% LIHTC applicant still has to clear this intent step, but does not need DOH's separate blessing to proceed to the competitive round: the same DOH notice states "a specific Invite to Apply from DOH is not required for 9% candidates," because 9% credits are "awarded only through a highly competitive application process based on program set asides, the point scoring system, and the ranking process outlined in the approved LIHTC Qualified Allocation Plan." An applicant seeking DOH money alongside the credit, by contrast, generally needs an actual Invite to Apply before submitting full DOH application materials -- required within 120 days of that invitation, per the same notice, including architectural drawings at a minimum of 90% completion.

Twenty Basic Threshold Requirements gate every application -- and the QAP states no minimum score

Section III(A) of the 2027 and 2028 QAP lists twenty numbered "Basic Threshold Requirements" that every Application -- 9% or 4% -- has to satisfy before it is eligible to be evaluated at all, on top of the New Construction Classification's separate competitive scoring. They run from a credible financing plan and site control/Phase I environmental assessment, through zoning approval, a qualified development team, no-displacement and 40-year affordability commitments (with at least 20% of units at or below 50% AMI), 90%-complete plans and specifications for 9% deals, a qualified-contract waiver, and a market-study acknowledgment, to more specific items like a 20-year re-syndication gap for prior credit recipients and Preservation Classification's $35,000-per-unit minimum hard-cost threshold. The Guideline's own instructions are blunt about timing: "All Basic Threshold Requirement items set forth in the QAP must be secured by the applicant before the application deadline. Basic Threshold Requirement items obtained by the applicant and submitted after the application deadline will not be accepted."

That last point is worth stating plainly because it is easy to assume otherwise: the 2027 and 2028 QAP does not publish a minimum score an application must clear to be eligible for a 9% award. New Construction Classification applications are simply scored on the 100-point table below and ranked against each other; the Authority awards down the ranked list until the annual Credit Ceiling is exhausted. Preservation Classification applications are not scored on points at all -- they are ranked instead against nine declining-priority factors (largest rehabilitation scope first, then risk of losing affordability, re-syndication, phased-development status, cost efficiencies, sponsor track record, and so on) listed in Section III(D).

New Construction scoring: a flat 100-point table across five categories

Two mechanics inside the scoring table deserve particular attention when modeling a deal. First, the deferred developer fee is capped by rule, not just by underwriting judgment: the QAP states a Deferred Developer Allowance/Fee "may not exceed the lesser of fifty percent (50%) of the total paid DAF, or the amount that may be fully recovered by the mortgagor, without interest, from CHFA-approved annual distributions during the first fifteen (15) years of operations." Second, a hybrid 9%/4% structure has a hard filing rule: "an applicant must submit both the 9% LIHTC application and a concurrent 4% LIHTC application at the time the 9% LIHTC application is due," and if the 9% application fails, "CHFA will not complete its review of the 4% application" -- the 4% piece cannot be salvaged as a fallback once the 9% competition is lost.

Fees, the market study, and what "complete at submission" actually means

A market study is a hard prerequisite, not an optional exhibit: the Guideline requires one "for developments awarded LIHTC without CHFA-issued TEB or CHFA financing prior to the issuance of the 42(m) letter or the Carryover Allocation Agreement," prepared and paid for by the applicant, non-refundably, in advance. There is no general cure window described for an incomplete application. The QAP's own Section III states CHFA "may seek clarification of any Application submissions in its sole discretion at any time" -- discretionary, not a guaranteed process -- and the Guideline is direct about the consequence of filing short: "Incomplete applications may mean a loss of points or a failure to meet application Basic Threshold Requirements criteria... and the application can be rejected. CHFA will not process incomplete applications." Section VIII(A) closes the loop for Basic Threshold failures specifically: "There is no appeal of the determination that Basic Threshold Requirements were not met."

Past performance follows the applicant into the review, not just the application on the table. The Guideline directs CHFA to evaluate "past performance and compliance in transactions with CHFA, DOH, U.S. Department of Housing and Urban Development (HUD) and/or other government funding agencies," covering timeline adherence, cost deviation, execution fidelity to what was originally proposed, and satisfactory operation of existing properties -- and CHFA may contact other funders or lenders the applicant has worked with over the past three years to check.

After a loss: CHFA's reassessment process, and what it can and cannot undo

Connecticut does provide a limited path to challenge a scoring or ranking decision, distinct from the QAP's flat statement that there is no appeal of a Basic Threshold determination. Following the CHFA Board's adoption of the 9% ranking resolutions, an applicant may request a reassessment, but on a tight and narrow track: written notice of intent to the Chief Executive Officer-Executive Director within two weeks of Board approval, then a formal written request -- accompanied by the $10,000 fee -- within 60 days of that initial notice. The request "must specifically identify in detail each issue that the applicant is challenging," based only on "documents filed with the original application," with "no changes from the original submission... permitted," and no applicant may challenge another applicant's scoring. CHFA will refund the fee only "if a change results in an allocation or forward commitment of 9% LIHTCs" -- and even a successful reassessment "will not result in the cancellation of previously approved reservations," so a later-corrected score adds to the round rather than displacing an already-awarded competitor.

The 2026 round shows what the competition actually looks like in practice: CHFA received 11 applications requesting more than $20 million in annual 9% credits, proposing 640 rental units statewide, and funded six developments -- $11.5 million in 9% credits, three of them structured as hybrid 9%/4% deals -- for a combined 475 apartments (438 affordable) once the hybrid-financed units are included.