"LHC's site says there's one 9% round a year -- is March 24 my actual application deadline, or is that just a checklist due before the real May 30 underwriting package, and what minimum score actually gets a project funded rather than just ranked?"
One round, eight pools: how LHC divides the 9% ceiling before anyone is scored
Section II.A states plainly there will be 'one (1) funding round for allocating the 2025 Housing Credit Ceilings,' with LHC awarding the highest-scoring application in each pool below until that pool's credits are exhausted, using Appendix A's Selection Criteria. At least 10% of the state's housing credit ceiling is reserved for the Qualified Non-Profit/CHDO pool (requiring a 501(c)(3)/(4) determination letter, articles/bylaws, a CHDO approval letter if applicable, and a Development Services Agreement guaranteeing the non-profit or CHDO at least 51% of the developer fee). Separate Rural Rehabilitation, Rural New Construction, Urban Rehabilitation, and Urban New Construction pools split the remaining credits by geography and project type -- 'Urban' meaning only eight named metropolitan parishes: Caddo, East Baton Rouge, Calcasieu, Jefferson, Lafayette, Orleans, Ouachita, and St. Tammany. A Choice Neighborhood Initiative (CNI) pool caps at $3,000,000 for projects in a designated CNI census tract with an approved local revitalization plan. An Elderly Housing Set-Aside is discretionary rather than dollar-reserved -- the QAP states LIHTCs 'will be funded, one in Rural Areas and one in urban areas, provided that qualifying applications are received,' not a guaranteed pool. Any pool's unused balance shifts first within its Urban/Rural category, then to a statewide remainder pool (except unused Non-Profit/CHDO credits, which are not redistributed this way).
| Pool | Amount |
|---|---|
| Nonprofit/CHDO | $1,500,000 |
| Rural Areas -- Rehab Sub-Pool | $2,250,000 |
| Rural Areas -- New Construction Sub-Pool | $2,250,000 |
| Urban Areas -- Rehab Sub-Pool | $2,000,000 |
| Urban Areas -- New Construction Sub-Pool | $2,000,000 |
| Choice Neighborhood Initiative (CNI) | $3,000,000 |
| Total | $13,000,000 |
A project combining both rehab and new-construction units in a Rural application only lands in the Rural New Construction Pool if new-construction units exceed 50% of total units.
Two caps limit how much any single project or developer can draw from these pools: a per-project cap of $1,000,000 in rural parishes / $1,500,000 in the eight metro parishes, and a per-developer cap (including related persons/entities) of $2,000,000 rural / $3,000,000 metro, with an absolute ceiling of $3,000,000 for any single developer regardless of parish mix. A developer that has never been issued a Form 8609 is limited to exactly one award in the 9% round.
The two-gate submission: a pre-submission packet in March, the real package in May
Section III.B splits the 9% process into two hard deadlines. The pre-submission packet -- a Letter of Intent to Apply, a map plus municipal address or legal description, the Market Study Checklist, Location Characteristics, and the Market Study fee -- was due March 24, 2025 by 4:00 p.m. CDT, and the QAP is explicit that 'No final application will be considered without receipt of a pre-submission packet by the required deadline.' The final submission -- the full underwriting application, application and analysis fees, evidentiary materials supporting the appendices, threshold requirements, and Selection Criteria, the Cost Containment Template, and (for projects requesting LHC soft funds) the Lien Payment Priority Spreadsheet -- was due May 30, 2025, also by 4:00 p.m. CDT.
LHC's post-submission completeness check is narrow: it verifies only whether required materials or threshold items described in Section III.B or Section IV are missing or incomplete. It explicitly does not include review of any scoring item, most environmental items, or anything else not named in that check -- meaning passing the completeness check confirms the file is complete, not that it will score well or meet underwriting feasibility.
| Fee | 1-4 units | 5-32 units | 33-60 units | 61-100 units | Over 100 units |
|---|---|---|---|---|---|
| Application Fee | $100 | $1,000 | $1,500 | $2,500 | $5,000 |
| Analysis Fee | $100 | $1,000 | $1,500 | $2,500 | $5,000 |
| Reprocessing Fee | $50 | $500 | $750 | $1,250 | $2,500 |
Market Study Fee is a flat $4,800 regardless of size. Credit Award fee is 10% of credit reserved; Return/Reallocation fee is 5% of reallocated credits; Subsidy Layering Review is 1/4 of the Analysis Fee; Placed In Service Review is $250 per resubmission; Annual Compliance/Monitoring fee is $40 per unit per year. All fees must be paid by cashier's check, wire transfer, or money order -- any other payment form results in disqualification.
Threshold gates before scoring even starts
Section IV.A lists twenty numbered project-level threshold items that apply before any Selection Criteria points are counted, including: resiliency/flood-elevation construction requirements for structures in the 100-year floodplain (lowest floor, including basement, at least two feet above base flood elevation; no residential structures in a floodway); a 5%-of-units set-aside at or below 30% AMI with a stated preference for Veterans, Disabled, and Elderly persons on the PHA waiting list; site control and appropriate zoning at application; infrastructure evidence (utilities, transportation access, and school-system notification for family projects); an Environmental Restrictions Checklist for any project using existing structures; a half-mile negative-neighborhood-use buffer (junkyards, processing plants, high-voltage substations, prisons, and similar uses) for new construction -- but only within the same eight named urban parishes used for the Urban pools; minimum internet/cable wiring and development-wide Wi-Fi; design features (a 15-year-or-longer maintenance-free exterior, 25-year roof warranty, double-paned windows, and FORTIFIED Roof certification by IBHS or a qualified architect); an Elevation Certificate (and Architect's certification if inside a levee-protected area) for any project in the Special Flood Hazard Area; an approved Part I from the Division of Historic Preservation for historic rehabilitation projects; a 40-point Selection Criteria minimum score; LIHTC compliance training completed within the 12 months before application; and a committed Eviction Prevention Plan plus low-barrier tenant screening.
Acquisition/rehabilitation projects face additional thresholds under Section IV.B: three years of audited seller financials, a sales-price cap at appraised value, a ten-year title history, on-site laundry (or in-unit hookups), a Capital Needs Assessment dated within six months of application by a reviewer qualified in Fair Housing Act/Section 504/ADA accessibility standards, and an appraisal (required whenever the purchase price exceeds $500,000 or acquisition costs are included in eligible basis).
Developer and property-management experience: enforced prerequisites, not aspirational language
Section IV.C requires the Managing Member or General Partner to have served in that same role on a comparable project (in any state, of comparable size and financing complexity) within the last five years that actually received Forms 8609, and to remain responsible for the project's operation for three years after placement in service (removable only for cause, with LHC approval, at an investor's request). A 'New Developer' -- one that has never been allocated tax credits -- is eligible for only one project award under the QAP, and must complete that first LIHTC project (all units occupied) and obtain its Form 8609 from LHC or any other state housing credit agency before submitting another Louisiana application.
The property management company must show at least one similar (size and type) LIHTC project in its portfolio, two years of LIHTC management experience, a staff supervisor certified as an LIHTC compliance specialist within the prior 12 months, and staff records of both Fair Housing and domestic-violence/abuse training; a management change within two years of project completion requires LHC approval.
Section IV.C.3 lists an extensive, dated set of team disqualifiers LHC checks independently of the experience requirements above: within the past ten years, debarment/limited denial of participation or outstanding HUD 2530 flags, bankruptcy, or an adverse fair housing/civil rights settlement; within the past ten years, involvement in a project that received an LIHTC allocation but failed to meet requirements without LHC's express approval; within the past five years, responsibility for uncorrected non-compliance lasting more than three months; current delinquency or default on any LHC obligation; outstanding audit deficiencies or unresolved 8823s; being more than 90 days behind schedule on an existing LHC-funded project; or currently owning/managing an LHC-funded development that had not submitted a compliant Tenant Selection Plan by April 1, 2025. Beyond this explicit list, the QAP adds a catch-all: 'LHC may decide to not fund any application for lack of capacity.'
9% scoring, evaluation, and appeal -- and why 40 points is a floor, not a target
Appendix A's scoring categories cap out well above the 40-point Section IV.A.17 minimum: up to 11 points for Targeted Project Type (Community Redevelopment, Rehabilitation & Preservation, or New Construction, chosen mutually exclusively), up to 6 for Targeted Population Type, up to 13 for Priority Development Areas and Other Preferences (including the Additional Financial Support line discussed in Phase 7 and an optional Extended Affordability Agreement worth 3-5 points for committing to 35-45 years of affordability), up to 5 for Location Characteristics, and several further Project Characteristics categories worth 1-3 points each (community facilities, optional amenities, on-site security, HUD Defensible Space, and hosting a Federally Qualified Health Center on-site). Even accounting for mutually exclusive sub-choices, the realistic maximum score sits well above 40 -- meaning the stated minimum is a threshold for eligibility, not a reliable proxy for what it actually takes to be competitively funded in a given year's ranking, which the QAP itself does not publish.
The QAP gives LHC explicit discretion over the whole process: 'Aggregate rankings or scoring under Appendix A does not guarantee an award of LIHTCs to a particular project... Notwithstanding a Project's score, LHC is not obligated to reserve LIHTCs for a Project.' Ties are broken first by lowest LIHTC amount requested, then by earliest submittal. LHC provided score reconciliations to developers by September 24, 2025; an appeal request was due by September 30, 2025, limited strictly to an applicant's own reconciled score (not another applicant's application, and not underwriting feasibility issues), reviewed by a panel that considers only staff scoring decisions. Unfunded applications meeting the minimum threshold go on a statewide waiting list that remains active until the next QAP is approved. Between initial submission and the end of the appeal period, the QAP treats any contact with LHC staff or Board members about the competitive round as grounds for disqualification.
4% and tax-exempt bonds: no competition, but still gated
Section III.C describes a rolling, non-competitive process for tax-exempt bond-financed 4% deals: a separate bond and underwriting application, the Cost Containment Template, and (if other LHC funds are requested) a Lien Payment Priority Spreadsheet, submitted at least 60 days before the LHC Board meeting at which the project will be considered. A public hearing must follow a notice published at least 14 days beforehand in a newspaper of general circulation in the project's parish; if the project has 50 or more units, that notice must specify the number and percentage of low-income units, or the local governing authority must separately approve that number and percentage. LHC may require a legal opinion on the project's LIHTC eligibility, and while the award itself is not competitively scored, LHC still verifies the full development team, all threshold requirements, and its underwriting requirements before issuing a Section 42(m) letter -- prepared or reviewed by LHC's Program Counsel. A developer or management-company representative must meet with LHC staff within six months of that letter's issuance.
This 'non-competitive' status has a real limit worth flagging: a project layering CDBG-DR gap financing through the PRIME-4 program on top of its 4% credits must still independently clear the QAP's 40-point Selection Criteria minimum score, per PRIME-4's own terms -- so a 4%/bond deal that skips Appendix A's scoring exercise on the theory that 4% isn't competitive may find itself unable to draw CDBG-DR money for exactly that reason.
Where this goes wrong
- Treating March 24 as the application deadline. It is only the pre-submission packet (Letter of Intent, Market Study Checklist and fee, Location Characteristics); the underwriting application, fees, and full evidentiary package are not due until May 30, and LHC will not consider a final application without a timely pre-submission packet.
- Assuming LHC's post-submission completeness check reviews scoring items or environmental compliance. The QAP limits it strictly to checking for missing or incomplete threshold and appendix materials.
- Assuming a first-time (never-8609'd) developer can submit more than one project in a round, or apply again in Louisiana before that first project is fully built and 8609'd by LHC or any other state housing finance agency.
- Assuming the Elderly Housing Set-Aside is a guaranteed, dollar-reserved pool like the others. The QAP funds it only 'provided that qualifying applications are received' -- contingent, with no stated dollar amount.
- Treating the 40-point minimum score as a realistic funding target. Appendix A's category caps sum to well more than 40 points; 40 is an eligibility floor, and the QAP does not publish where the actual competitive cutoff falls in a given year.
- Assuming an appeal can challenge another applicant's score or an underwriting feasibility determination. Appeals are limited to the applicant's own reconciled score and are reviewed only for staff scoring decisions, not feasibility.
- Assuming a 4%/bond application can skip Appendix A's Selection Criteria and 40-point minimum entirely because the credit itself isn't competitively awarded. Threshold requirements, underwriting guidelines, and (if CDBG-DR/PRIME-4 funding is also sought) the 40-point score are all still required.
- Assuming a courtesy check-in with LHC staff or Board members about a pending competitive application is harmless. The QAP treats any contact between submission and the end of the appeal period as grounds for disqualification.
- Assuming the Urban Rehabilitation/New Construction pools and the negative-neighborhood-use buffer rule apply statewide. Both are scoped to the same eight named metropolitan parishes (Caddo, East Baton Rouge, Calcasieu, Jefferson, Lafayette, Orleans, Ouachita, St. Tammany) and do not govern rural-parish projects.
- Missing the different community-notification timing rule for bond deals: standard 9% applications need three newspaper publications within six weeks of submission, while tax-exempt bond applications need proof the notices ran within 60 days prior to submission -- a materially different window.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies