"Are the preliminary and full application fees actually two different charges, or is NCHFA billing us twice for the same thing?"
Two fees, two stages, and a specific one-week revision window
| Date | Milestone |
|---|---|
| January 23 (12:00 noon) | Preliminary application deadline |
| March 13 | Market analysts submit studies to Agency and Applicants |
| March 20 | Notification of final site scores |
| March 27 (5:00 p.m.) | Deadline for market-related project revisions |
| April 10 | Deadline for revised market study, if applicable |
| May 15 (12:00 noon) | Full application deadline |
| August | Notification of tax credit awards |
The Agency reserves the right to change this schedule 'to accommodate unforeseen circumstances,' so the published dates should be treated as the current plan rather than a guarantee.
On fees, the QAP text resolves the ambiguity directly: 'All Applicants are required to pay a nonrefundable fee of $6,200 at the submission of the preliminary application. This fee covers the cost of the market study or physical needs assessment and a $1,500 preliminary application processing fee (which will be assessed for every electronic application submitted).' That $1,500 is bundled into the $6,200 — it is not billed separately at the preliminary stage. A second, genuinely separate $1,500 nonrefundable processing fee is then due 'upon submission of the full application.' The Agency may also charge additional fees to cover direct contracting costs, such as appraisers, on top of these two base fees.
What has to be locked before the preliminary deadline, versus what can wait for full application
Site control is a threshold requirement, not a scoring factor: the Applicant or a Principal must hold site control — evidenced by an option, contract, or deed, plus a plot plan — as of the preliminary application deadline. Every preliminary application must also include the Agency's 'Notice of Real Property Acquisition' form, executed by all parties at or before the option or contract date. Zoning works on a different clock: required zoning, including any special or conditional use permits and other discretionary land use approvals, only has to be in place by the full application deadline in May — so a project can compete for a site score in January with entitlements still in process, but must have them resolved by May 15.
Site scoring runs up to 68 points across neighborhood characteristics (10), amenities (46), and site suitability (12), net of up to 3 negative points, but the scoring package only matters if the site clears a 50-point minimum threshold — and the Agency can remove an application for being 'sufficiently inadequate' in a single category regardless of the total score. Only one active application is allowed per site, and no Principal or Applicant can be in the ownership entity of more than 5 new-construction 9% preliminary or full applications in the same cycle.
The 4%/bond track: a rolling window and an Order of Priority instead of a scoring package
Tax-exempt bond volume and 4% Tax Credit applications aren't tied to the 9% round's fixed dates — the Agency accepts them any time between May 1 and October 1, and once a preliminary application is filed in that window, NCHFA sets a project-specific milestone schedule keyed off the submission date, following a timeframe 'similar to' the 9% round. Full applications for that cycle are accepted no later than January 15, 2027, and the Agency determines whether the deal draws 2026 or 2027 volume cap. An inducement resolution must be submitted with the full application — not the preliminary — for a bond deal.
Instead of point-scoring, bond volume is allocated by a strict Order of Priority: (1) projects that are a component of an overall public housing revitalization effort, (2) rehabilitation of existing rent-restricted housing, (3) rehabilitation of projects consisting entirely of market-rate units, (4) adaptive re-use projects, and (5) other new construction. A tier is only reached if bond authority remains after every eligible application in the tiers above it is funded, and within a tier, priority goes to the application requesting the least bond authority per low-income unit — there's no score to maximize, only a rank to beat within your own tier.
Rehabilitation applications carry their own eligibility bar: the property must have been placed in service on or before December 31, 2010, require rehab expenses over $30,000 per unit, carry an acquisition cost no more than 70% of total replacement cost, show no Mark-to-Market (or similar HUD) debt restructuring in the last five years, and not be so deteriorated that it requires demolition. Separately, every bond deal needs at least one Principal who has successfully placed a 9% Tax Credit project (in NC) or a tax-exempt bond project (in any state) in service between January 1, 2017 and January 1, 2025 — that Principal must be named as the Applicant in the preliminary application, become a general partner or managing member, and stay responsible for the project for two years after it's placed in service.
Where this goes wrong
- Treating the $6,200 preliminary fee and $1,500 full application fee as duplicate billing — they're sequential, both nonrefundable, and both due; total pre-award cost is $7,700 minimum.
- Submitting a preliminary application without evidenced site control (option/contract/deed plus plot plan) — this is a hard threshold at the preliminary deadline, not something to firm up before full application.
- Missing the narrow window between final site score notification (March 20) and the market-revision deadline (March 27) — about one week to react.
- Assuming zoning can wait until closer to construction — required zoning and special-use approvals must be locked by the full application deadline in May, months before award notification.
- Losing eligibility by falling below the 50-point site score threshold, or getting removed outright for being 'sufficiently inadequate' in one scoring category even with a strong overall total.
- Filing more than 5 new-construction 9% applications for the same Principal in one cycle — the excess applications become ineligible.
- For bond/4% deals, submitting the full application without the inducement resolution, or relying on a Principal whose only qualifying prior deal falls outside the January 2017–January 2025 placed-in-service window.
- Approaching the Order of Priority like a scoring matrix to optimize — within a priority tier the only lever is requesting less bond authority per low-income unit, not accumulating points.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
