"GHURA's QAP timeline shows a single Application-Open-to-Application-Closes window instead of the staged Pre-Application/Competitive-Application/Threshold sequence some mainland agencies run — does that mean my entire package has to be complete and final the day the window closes, is the published 77-out-of-111 minimum score actually a hard cutoff, and can I verify how GHURA picked its most recent award from a public record?"
A single application window, not a sequence of gated deadlines
| Milestone | 2025 abbreviated cycle | 2024 cycle |
|---|---|---|
| Public Comment Period | Oct. 1–16, 2025 | June 24–July 5, 2024 |
| Presentation to GHURA BOC for approval | Oct. 21, 2025 | July 23, 2024 |
| Application Open to the Public | Oct. 22–Nov. 26, 2025 | July 25–Oct. 25, 2024 |
| Application Closes/Final Submissions | Nov. 26, 2025 | Oct. 25, 2024 |
| Evaluation Panel Review/Final Scoring | Nov. 28–Dec. 7, 2025 | Oct. 28–Nov. 8, 2024 |
| Final Recommendation to GHURA BOC | Dec. 9, 2025 | Nov. 12, 2024 (combined with Award Decision) |
| Award Decision | Dec. 11, 2025 | Nov. 12, 2024 |
| Final day, Carryover Allocation Submission | Dec. 31, 2025 | Dec. 31, 2024 |
The 2025 cycle is explicitly labeled an "Abbreviated QAP Application Process," run in a single year rather than GHURA's more typical two-allocation-cycle timeline, because the CY2024 credits went unawarded in the 2024 cycle and needed a home before the two-year federal use-it-or-lose-it clock on those specific credits ran out (2025 LIHTC QAP, Section I.C).
There is no Pre-Application gate, no separate Waiver Requests deadline, and no Threshold Submission date that falls weeks or months after the scored Competitive Application — all of it, scoring documentation and threshold documentation together, is due once, at Application Closes. The Application Fee is $1,500 per application, "the same for all applicants," payable by Cashier's Check at submission (2025 LIHTC QAP, Section V).
Threshold documentation: what has to be in the package the day it's due
| Item | Requirement | Applies to |
|---|---|---|
| Set-Aside election | Applicant designates 9% Credits Set Aside or Income Averaging Set Aside | All applications |
| Market Study | Comprehensive, disinterested third-party study dated within 6 months of submission, at owner's expense | All applications — no cure if missing or stale |
| Site Control | Fee simple deed, executed land lease, or sale option acceptable to GHURA; all lease terms must extend at least 5 years past the minimum affordability period | All applications |
| Capital Needs Assessment | Qualified third-party assessment of physical condition and deferred maintenance | Acquisition/rehabilitation projects only |
| Public Housing Waitlist / Homeless Services letters | Copy of letter to the local PHA administering public housing waiting lists, and a copy of letter to the Guam Homeless Coalition | All applications |
| Smoke-Free certification | Prohibits smoking in indoor common areas, individual living areas (incl. balconies/carports), and within 20 feet of entries/vents; non-smoking lease clause required | All applications |
| Phase I Environmental Assessment | Required for every application; must address lead-based paint and asbestos for acquisition/rehab | All applications |
| Proof of Non-Profit Status | Articles of Incorporation and current 501(c)(3) letter | Only if applying under the federal non-profit set-aside |
| Minimum Affordability Period commitment | 45 years for a 9% award; for acquisition/rehab of an existing affordable building, must exceed any pre-existing affordability period by at least 30 years | All applications |
| Good Standing / Disqualification check | GHURA may disqualify based on unresolved GHURA debt, documented property-management issues, program noncompliance with a GHURA-administered program or federal grant, federal debarment-list inclusion of any principal/agent/consultant/affiliate, or a pattern of mismanagement | All applications |
The Market Study rule is explicit and has no stated cure: "Any applicant failing to submit a Market Study or submits a Market Study with a date older than 6 months before the date of Application submission will not be considered for an award of tax credits" (2025 LIHTC QAP, Section II.B.2.b).
The Good Faith Deposit is a separate, later financial commitment, not a submission-day cost: "A good faith deposit of ten percent (10%) of the first year's federal tax credits reserved shall be payable at the time the executed binding agreement is submitted to GHURA." What happens to it is worth planning around before an applicant treats it as a refundable hold: "Upon allocation and issuance of the IRS Form 8609, eighty percent (80%) of the good faith deposit shall be retained by GHURA as an administrative fee. The remainder of the good faith deposit may be refunded to the applicant in the sole discretion of GHURA" (2025 LIHTC QAP, Section V). GHURA also states that failing to meet elections made in the scoring criteria or requesting additional credits after the fact "may result in the retention of the entire good faith deposit."
Scoring: a published minimum score, and fifteen criteria worth 111 points
| # | Criteria | Points |
|---|---|---|
| 1 | Project Location and Proximity | 20 |
| 2 | Project Financial Feasibility/Viability | 18 |
| 3 | Project Characteristics | 12 |
| 4 | Populations Served by the Project | 15 |
| 5 | Developer, Owner, and Management Team Experience and Capacity | 12 |
| 6 | Community Support and Involvement / Impact on the Neighborhood | 5 |
| 7 | Affordability of the Rents and Length of the Affordability Period | 8 |
| 8 | Increase in the Extended Use Period / Conversion to Homeownership | 6 |
| 9 | Local/Federal Government Support | 2 |
| 10 | Qualified Non-Profit Organization | 1 |
| 11 | Qualified Census Tract | 2 |
| 12 | Public Housing Waiting Lists | 1 |
| 13 | Project will Receive Project-Based Rental Assistance | 1 |
| 14 | Historic Nature of the Project | 1 |
| 15 | Developer Fee | 7 |
"Application must have a minimum score of 77 out of 111 points to be considered for award" (2025 LIHTC QAP, Section III, intro) — a published floor, unlike allocating agencies that rank purely on relative score with no stated minimum. Meeting 77 points makes an Application eligible to be considered, not entitled to an award.
The QAP does not state a maximum number of applications a single Developer may submit per round, and does not describe a self-scoring mechanism for resolving an over-limit Developer's applications the way some mainland QAPs do — this research found the QAP simply silent on a per-developer cap. That silence should not be read either as confirmation that no cap exists or as confirmation that one does; it should be confirmed directly with GHURA before an applicant plans a multi-project round. Where the QAP is explicit is on ties: "In the event of a tie in the scores, Applications will be ranked according to tax credits per unit favoring the development that requires the fewest tax credits per unit" (2025 LIHTC QAP, Section IV).
GHURA's discretion survives a passing score. Section IV states GHURA "reserves the right to disapprove any Application or project for any tax credit reservation or allocation, regardless of ranking under the criteria and point system," and separately that GHURA "in no way represents or warrants to any interested party... that the project is, in fact, feasible or viable." An applicant should treat 77 points as a threshold to clear, not a guarantee.
The Flores Rosa Gardens reservation, the $5,021,880 balance, and what could not be confirmed about Summer Vista II
The 2025 QAP text itself states: "The Board of Directors has approved the issuance of an allocation reservation of 2025 tax credits in an amount not to exceed $1,793,120 to Flores Rosa Gardens LLC for the Flores Rosa Gardens development... A total of $5,021,880 in credits is available for award net of this reservation" (2025 LIHTC QAP, Section II). This research independently corroborated the Flores Rosa Gardens reservation: a document filed with the Office of Public Accountability, Guam references a "2025 GHURA Low Income Housing Tax Credit Carryover Allocation Agreement with Flores Rosa, LLC" dated February 3, 2025, and Flores Rosa Gardens is a real, since-built affordable community in Tamuning with units rent-restricted at or below 60% of Guam's area median income.
This research could not confirm, from any GHURA board packet, meeting minutes, press release, or news report located, that Core Tech Development's "Summer Vista II" was the entity that received the remaining $5,021,880 at the December 11, 2025 Award Decision. What is confirmed independently: Core Tech Development has an active, multi-project affordable-housing pipeline on Guam under the "Summer" name (Summer Vista I in Dos Amantes, Dededo; Summer Breeze I in Barrigada; Summer Town Estates and Summer Homes elsewhere), and Summer Vista I itself broke ground in February 2025 — which is before this abbreviated 2025 QAP cycle's own Award Decision date, meaning Summer Vista I was necessarily funded from an earlier allocation cycle, not from the $5,021,880 balance described in this QAP. A specific project called "Summer Vista II" tied to the December 2025 award could not be located in a searchable GHURA board record as of this research. Anyone using this example to illustrate GHURA's review process should verify the recipient and amount directly against GHURA's own December 2025 board minutes or a subsequent Carryover Allocation Agreement filing, rather than citing the Summer Vista II connection as established fact.
Appeal Review: a fast, paper-heavy process for a non-selected applicant
An applicant who receives a Non-Selection Letter has seven calendar days to submit a written request for an Appeal Review to GHURA's Executive Director, delivered to GHURA's main office at 117 Bien Venida Avenue, Sinajana. "The Appeal process shall conclude within ten (10) calendar days from the receipt of the Appeal request" (2025 LIHTC QAP, Appendix 3, Administrative Procedure for LIHTC Program Appeal Review). GHURA identifies a 3-to-5-member Appeal Review panel, drawn from outside the Research, Planning and Evaluation Division, before awards are even announced, and a separate Appeal Review Committee of at least three employees appointed by the Executive Director. Both GHURA and the Applicant must submit a written summary capped at ten pages (exclusive of attachments) at least five days before the meeting; each side's initial presentation is capped at one hour, with GHURA's response capped at 20 minutes, and any follow-up question the Committee needs answered after the meeting must get a response from both sides within 48 hours. The Committee "will only consider documents of record" — GHURA's own scoring documentation, the Application as submitted, and correspondence during the scoring process — and an Applicant "may not clarify... a 'scoring' category... during scoring or during the Appeal process," which makes the quality of the original submission, not a later explanation, the decisive factor.
Where this goes wrong
- Treating the Application Open date as a soft target because there is no separate Pre-Application gate. There is exactly one Application Closes date; threshold and scoring documentation are both due there, together.
- Submitting a Market Study older than 6 months, or none at all. The QAP states plainly that the applicant "will not be considered for an award of tax credits" — no cure period is described.
- Treating the Good Faith Deposit as a fully refundable hold. Eighty percent is retained by GHURA as an administrative fee automatically upon IRS Form 8609 issuance; only the remaining 20% "may" be refunded, at GHURA's sole discretion.
- Assuming a site-control lease only needs to cover the construction and compliance period. Lease terms must extend at least 5 years past the full minimum affordability period (45 years for a 9% award) — a term most standard ground leases don't default to.
- Assuming a 77-of-111 score guarantees an award. The QAP states it only as the minimum to be "considered," and separately reserves GHURA's right to disapprove any Application "regardless of ranking."
- Citing "Core Tech Development's Summer Vista II" as a confirmed example of the December 2025 award. This research found no public GHURA board record naming it as the recipient of the $5,021,880 balance — verify against GHURA's own board minutes before relying on it.
- Preparing a Capital Needs Assessment for a new-construction application, or skipping it on an acquisition/rehabilitation deal. It is required only for the latter.
- Assuming Phase I Environmental Assessment is only for acquisition/rehab projects. The QAP requires it "for all applications," new construction included.
- Assuming the QAP's silence on a per-developer application cap means no cap exists (or that one does). The text simply does not address it — confirm directly with GHURA.
- Missing that a principal, management agent, consultant, or affiliate's presence on the federal debarment list is, by itself, a stated Good Standing disqualifier — not just a red flag to be explained away.
- Assuming a scoring dispute can be fixed with a better explanation during the Appeal Review. The Committee considers only documents of record, and an Applicant "may not clarify" a scoring category during the Appeal process.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
