"Does our self-score on Tab 1b actually match what Housing New Mexico's staff will award, and did the bundled PDF land on the file-transfer site before noon?"
One upload, one file-transfer site, one bundled PDF
Housing New Mexico/MFA does not accept a New Mexico 9% Application by email, courier, or in-person delivery. Initial Applications must be uploaded to Housing New Mexico's Secure File Transfer-HD site (https://internal.housingnm.org/SFT_HD/), and "Applications submitted by any other means of delivery will be rejected." The 2026 Housing New Mexico Universal Rental Development Application itself is a single Excel workbook — downloaded from Housing New Mexico's own website — submitted alongside one fully-tabbed, bookmarked PDF containing every item on the Attachments Checklist in numerical order, with each bookmark named to its Tab number ("Tab 1 – Project Information and Application Fees," "Tab 1a – Attachments Checklist," and so on). Four items are the exception and upload as their own stand-alone PDFs instead of living inside that bundle: the market study, the architectural plans and specifications, the Capital Needs Assessment (when required), and the appraisal (when required).
| Milestone | Date |
|---|---|
| Intent to Submit a Tax Credit Application & Development Synopsis | December 20, 2025 |
| Application Round Opens | January 5, 2026 |
| Last Day to Submit FAQs | January 12, 2026 |
| Full Application Deadline | January 20, 2026, 12:00 p.m. MST |
| Deficiency Corrections (if requested) | Late February / early March |
| Preliminary Reservations / Rejections | Late March |
| Appeals Hearing (if needed) | Mid-April |
| Board Videos Due | May 1, 2026 |
| Final Awards | May 2026 Board meeting |
| Reservation Fee Invoice Issued | Day after May 2026 Board meeting |
| Reservation Fee & Reservation Due | Early June 2026 |
Housing New Mexico's own schedule (Section III.A). The Intent to Submit is not a formality — Section IV.G.1 states Housing New Mexico "will not accept an Application prior to receipt of this submission."
"Complete" has a specific, enumerated meaning at the Initial Application stage, and it has to be true on first submission — not after a later fix. Section III.B.4 requires an "omnibus" signature page on which every General Partner certifies the entire Application is accurate and complete; current-year Housing New Mexico forms with no substitutions; redaction of Social Security numbers and board members' home addresses; scanned blue-ink or verified digital signatures everywhere a form calls for one; and, except for the Applicant-eligibility threshold review, a fully self-contained package — Housing New Mexico will not rely on anything submitted in a prior round to fill a gap in this one.
Threshold requirements come first, and two of them can't be fixed
| Requirement | What it takes | Correctable? |
|---|---|---|
| A. Site Control | Fully executed transfer commitment or recorded deed/lease conferring a Qualified Leasehold Interest, initial term to at least June 30 of the allocation year | Yes — 5-business-day deficiency correction (Section III.F.7) |
| B. Zoning | Local zoning official's letter, dated within 6 months of the deadline, confirming multifamily use is not prohibited (or the unzoned/agricultural exemption) | Yes |
| C. Fees | All fees owed to Housing New Mexico on any Project involving the same Principals must be current as of the deadline | Yes |
| D. Market Study | NCHMA Model Content Standards compliance, issued within 180 days, overall Capture Rate ≤ 10% (PSH, Senior, and 100%-farmworker Projects exempt from the Capture Rate test) | Yes — Housing New Mexico may order a second study at the Applicant's cost |
| E. Applicant Eligibility | Development team good standing; related-party affidavits, org charts, compliance affidavits with schedule of experience, resumes | No — rejection regardless of score |
| F. Financial Feasibility | Project meets every standard in the Universal Multifamily Underwriting Supplement | No — rejection regardless of score |
| G. Pre-Application Requirements | Intent to Submit by Dec. 20, 2025; a development-team representative (and, if claiming Criterion A points, a representative of the nonprofit/government entity) attended the most recent QAP training | Not applicable — gates acceptance of the Application itself |
Section III.F.1: threshold review happens after the deadline, and Applicant Eligibility and Financial Feasibility failures are rejected "regardless of the Application's score" — a high-scoring Application is not a shield against either one.
| Fee | Amount | When due |
|---|---|---|
| Application Fee | $750 nonprofit/governmental Applicant; $1,500 for-profit Applicant | With Initial Application |
| Base Portion Design Review | $12,000 (non-refundable, but returned if no Reservation or bond approval results) | With Initial Application |
| Processing Fee | 8.5% of the tax credit allocation amount, rounded down | Before the Reservation Contract |
| Additional Review | $1,500 per review beyond the one included underwriting pass | Per invoice |
| Deadline Extension | $500 per week | Upon invoice |
| Appeal Fee | $5,000 (no appeal considered until paid) | With appeal submission |
Section III.C. The $12,000 Design Review fee buys nine bundled reviews — preliminary Design Standards review, construction drawing and specification review, environmental/HERS review, contract document review, and 33%/66%/100% site inspections — with any additional inspection billed separately at $1,500 each.
Twenty scoring criteria, 115 possible points, 53 to compete
Section V lays out twenty Project Selection Criteria that sum to a maximum of 115 points; a 9% Application needs 53 of them to be ranked at all (fewer only if too few Projects clear 53 and Housing New Mexico chooses to lower the bar). Phase 1 covers Locational Efficiency and Income Levels of Tenants because they gate site selection; the full table below is every criterion in the round.
| Criterion | Points available |
|---|---|
| A. Nonprofit / NM Housing Authority / TDHE / THA / Government Entity Ownership | 5 (net worth ≥ $1M) or 3 (net worth ≥ $250K, or ≥ $2M for a non-local nonprofit) |
| B. Locational Efficiency | Up to 6 (2 for Proximity to Services, 2 or 4 for Access to Public Transportation) |
| C. Rehabilitation Projects | 1–5, scaled to years past the 20-year threshold (21 yrs = 1 pt up to 29+ yrs = 5 pts) |
| D. Sustaining Affordability | 6, 8, or 10, based on existing/anticipated federal rental-assistance coverage |
| E. Income Levels of Tenants | 12, 14, or 16, based on the 40-60/20-50 or Average Income election and Urban/Non-Urban status |
| F. Projects that Incorporate Market Rate Units | 2 (unavailable if Average Income election is used) |
| G. Projects Committed to a Longer Extended Use Period | 5 / 6 / 7 / 8, for a 35 / 40 / 45 / 50-year Affordability Period |
| H. Households with Special Housing Needs Housing Priority | Up to 5 (mutually exclusive with I and J) |
| I. Projects Reserved for Seniors Housing Priority | Up to 5 (mutually exclusive with H and J) |
| J. Households with Children Housing Priority | Up to 4 (mutually exclusive with H and I) |
| K. Leveraging Resources | Up to 10, 1 point per whole percent of Total Development Cost contributed |
| L. Marketing Units to Public/Indian Agency Waiting Lists | 2 |
| M. QCT / Concerted Community Revitalization Plan | 3 for a qualifying CCRP, plus 2 more if also in a QCT (up to 5) |
| N. Projects with Units Intended for Eventual Tenant Ownership | 2 |
| O. Projects with Historic Significance | 2 |
| P. Efficient Use of Tax Credits | 1, 3, or 5, for requesting fewer credits per unit/square foot than published tiers |
| Q. Non-Smoking Properties | 4 (Silver certification) or 6 (Platinum/Gold certification) |
| R. Adaptive Reuse Projects | 2 (unavailable if already claiming Rehabilitation points) |
| S. Underserved Communities | Up to 9, stacking three 3-point tests (small scale, small place, no recent LIHTC activity) |
| T. Other Scoring Points Available | Up to 6 (3 for Deep Affordability, 3 for a Veteran resident preference) |
Points sum to 115 across all twenty criteria (Housing New Mexico's own Tab 1b scoring worksheet totals the same 115). Other than the scaled-point criteria (C, D, E, G, K, P), partial points are not awarded (Section III.F.2).
Scoring is not self-certified in practice, even though the Application asks Applicants to self-score first. Tab 1b of the Application — the LIHTC Project Selection Criteria Scoring Worksheet — has a "Self Score" column the Applicant fills in and a separate "Housing New Mexico Score" column staff fills in independently after reviewing the same documentation. It is staff's score, not the Applicant's, that determines ranking; a mismatch surfaces only after submission, when there's no more room to add the missing exhibit.
Ranking itself runs in two separate pools — new construction/Adaptive Reuse Projects compete against each other, rehabilitation Projects against each other — and Housing New Mexico awards in a fixed pattern of two new-construction Projects for every one rehabilitation Project until credits run out (Section III.D.2). Within either pool, a tie is broken in favor of the lower Total Development Cost per Unit, not the higher score (Section III.F.2).
Elections that lock in on the application itself
Several of the highest-value choices in the Application are binary elections made once, at submission, with no do-over. The Households with Special Housing Needs, Seniors, and Households with Children Housing Priorities (Criteria H, I, and J) are drafted as mutually exclusive — each one's own QAP text disqualifies the Application from points under the other two. A Project claiming the Average Income election under §42(g)(1)(C) for Income Levels of Tenants scoring cannot also claim points for Market Rate Units (Criterion F); the QAP states this exclusion in both directions (Sections V.E and V.F).
The Underserved Populations set-aside works differently from the Nonprofit set-aside Phase 1 already covers. The Nonprofit set-aside is structural — Housing New Mexico simply funds the highest-scoring Qualified Nonprofit Organization Eligible Project first. The Underserved Populations set-aside is an opt-in: "The Application must indicate the desire for the Project to participate in the Underserved Populations set-aside, otherwise the Project will compete within the general round" (Section II.C.2). Even after electing in, a Project's score must fall within 20% of the round's highest-scoring Project to actually be awarded credits through that set-aside — a real eligibility gate on top of the election, not just a label. The two qualifying categories carry their own separate submission requirements: a Permanent Supportive Housing election requires 25%+ of units set aside, Project-Based Vouchers or another federal operating subsidy secured for at least 75% of those units, a preliminary Memorandum of Understanding with a service provider, and a PSH Commitment to Quality checklist at Tab 15c; a Tribal Projects election requires the sponsor or developer to be a Tribally Designated Housing Entity or other Tribal Entity, plus a map showing the site inside a Tribal Trust Lands boundary at Tab 15e.
The per-project and per-developer caps compound that scarcity. No single 9% Project may receive a Reservation over $1,700,000, and no Applicant, General Partner, Affiliate, or anyone entitled to any part of a Developer fee may receive more than one Reservation in the same round (Section II.B). A developer filing more than one Application in the same year isn't scored differently for it, but has to say in the Project Narrative which Project it wants funded if more than one clears the minimum score — Housing New Mexico will not decide that preference on its own.
What happens to the file after it lands
Submission is the start of a fixed sequence, not the end of one. Housing New Mexico runs threshold review first (Section III.F.1); Applications with correctable defects get a 5-business-day deficiency correction window, opened by email and U.S. mail notice, with corrected materials due back through the same Secure File Transfer-HD site by 5:00 p.m. MST on the fifth business day (Section III.F.7). Within 10 days of the deadline, Housing New Mexico sends a "Local Notice" to the chief executive of the site's jurisdiction — municipality, county, or tribal government — opening a 30-day comment window (Section III.F.5). Site visits follow for the highest-ranking Projects, alongside a separate financial-feasibility review and an initial design review against the Design Standards.
A "Quiet Period" begins the moment the Initial Application is submitted, not at Reservation, and runs until the Board approves awards. During it, no one on the development team may contact Housing New Mexico's management, Board, Allocation Review Committee, or their proxies about a pending Application except through channels Housing New Mexico itself initiates (Sections III.B.5 and III.B.6); a violation is grounds for outright rejection of the Application, independent of its score.
Staff's rating and ranking then goes to an Allocation Review Committee (ARC) appointed by the Board Chairman, which can trigger preliminary Reservation, waitlist, or rejection letters before any appeal is heard. An Applicant has 10 calendar days from that letter's email date to appeal, for a $5,000 fee, and only the General Partner (or proposed General Partner) may file it — one appeal per Application (Section III.F.8.c). Final awards happen only at the Board's May 2026 meeting; Applicants must deliver a roughly three-minute MP4 video about the Project (Housing New Mexico's marketing staff helps produce it) and attend that meeting in person to answer Board questions before a Reservation Letter is issued.
Where the checklist stops, and what EZFeasi doesn't do yet
The Application's own Attachments Checklist (Tab 1a) runs to at least 57 line items in Section I — required of every Applicant, covering the omnibus signature page, project narrative, related-party affidavits, site control evidence, site-specific maps and photos, resumes, market study, and financing commitments — before a single scoring point is claimed. Applicants pursuing scoring points add roughly another 118 line items in Section II, one set per criterion, several of them (Tabs 16a–16n) duplicated wholesale for a Qualified Nonprofit path versus a Government/Housing-Authority path claiming the same Criterion A points. That's before Tabs 33 through 40g, which apply only to Applicants also seeking Housing New Mexico gap financing (HOME, National Housing Trust Fund, Risk Share, and similar loan products) alongside the LIHTC award.
None of this is specific to the 9% competitive round by accident. Tax-exempt bond (4%) Projects file the same Universal Rental Development Application on a continuous, non-competitive basis; the 2026 4% QAP's own Section V is titled "Selection Criteria" and imposes mandatory eligibility tests rather than the point-scored ranking this phase describes — there is no self-score worksheet, no 53-point floor, and no fixed January deadline for a 4% filing.
EZFeasi has no New Mexico application-filler, no self-scoring calculator that checks an Applicant's Tab 1b math, and no checklist tracker built for any of this today. For a New Mexico 9% deal, this phase is currently pure manual assembly against a printed checklist and a spreadsheet workbook, with the deadline itself as the only thing enforcing completeness.
Where this goes wrong
- Treating the January 20 Application Deadline as the first hard date on the calendar. The Intent to Submit a Tax Credit Application & Development Synopsis is due December 20, 2025, and Section IV.G.1 states Housing New Mexico "will not accept an Application" without it already on file.
- Assuming the Applicant's own self-score on Tab 1b of the Application is the score that determines ranking. Housing New Mexico staff completes a separate "Housing New Mexico Score" column on the same worksheet after independently reviewing the documentation, and it is staff's number that controls (Section III.F.2).
- Assuming every threshold defect gets a second chance. Only Site Control, Zoning, Fees, and Market Study defects get the 5-business-day deficiency correction window (Section III.F.7); Applicant Eligibility and Financial Feasibility failures (Sections IV.E and IV.F) are rejected outright, regardless of the Application's score.
- Submitting the Application by email, courier, or hand delivery. Section III.B.2 requires upload to Housing New Mexico's Secure File Transfer-HD site specifically; any other means of delivery results in rejection.
- Treating the Underserved Populations set-aside as automatic for a qualifying PSH or Tribal Project. Section II.C.2 requires the Application to affirmatively indicate the desire to participate, and even then the Project's score must fall within 20% of the round's highest-scoring Project to actually receive an award through that set-aside.
- Layering more than one Housing Priority election to stack points. Special Housing Needs (Criterion H), Seniors (Criterion I), and Households with Children (Criterion J) are mutually exclusive — claiming one explicitly forfeits points under the other two.
- Combining the Average Income minimum-set-aside election with Market Rate Units scoring. Sections V.E and V.F both state that a Project using the §42(g)(1)(C) Average Income election cannot also claim the 2 points available for incorporating Market Rate Units.
- Filing multiple Applications from the same developer without naming a preference. No Applicant, General Partner, Affiliate, or anyone entitled to a Developer fee may receive more than one Reservation per round (Section II.B), and Housing New Mexico will only pick among a developer's own competing Applications if the Project Narrative says which one to prefer.
- Underestimating how little room the round has. Housing New Mexico's own pre-round estimate put the 2026 Annual Credit Ceiling at roughly $3.7 million, against a $1,700,000 per-project cap (Section II.A n.4 and Section II.B) — two full-size awards can consume nearly the entire year's competitive pool.
- Assembling the PDF bundle out of numerical or bookmark order. Section III.B.3 requires the Application, Schedules, and every attachment (except the market study, plans/specs, CNA, and appraisal) in a single PDF, in numerical Tab order, with bookmarks named to match — a disordered or unbookmarked file risks failing the "complete Application" standard in Section III.B.4.
- Treating the Quiet Period as boilerplate that starts at Reservation. It begins the moment the Initial Application is submitted (Section III.B.5) and bars unsolicited development-team contact with Housing New Mexico's Board, ARC, or leadership; a violation (Section III.B.6) is grounds for rejection independent of score.
- Assuming a preliminary Reservation Letter is the finish line. The Board doesn't vote until its May 2026 meeting, Applicants must deliver a roughly three-minute video and attend that meeting, and the 10-calendar-day, $5,000 appeal window can still re-rank Projects before a Final Reservation Letter issues (Section III.F.8).
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies