Do we file into the one 9% round or catch one of five bond windows this year — and does a check that clears on day eleven instead of day ten sink an otherwise clean application?
The shape of the phase
By application assembly, the deal is underwritten and the site is controlled. Nevada Housing Division (NHD) — part of the Department of Business & Industry — administers the state's entire Low-Income Housing Tax Credit Program directly, as the state's housing credit agency under NRS Chapter 319 and NAC Chapter 319, running both the competitive 9% credit and the tax-exempt bond (4%) track out of the same office against the same annually adopted Qualified Allocation Plan. The 2026 QAP was adopted December 24, 2025, and the Division formally amended Section 2.1 (the 9% schedule) and Table 2 (credit authority) on March 25, 2026 — the figures below reflect that amendment, which is the version currently in force.
| Event | Date |
|---|---|
| 9% Additional LIHTC submission (existing awards only) | March 13, 2026 |
| 9% Tax Credit Project Open | May 1, 2026 |
| 9% Tax Credit Project Application Deadline | June 15, 2026 |
| Posting of applications received | June 30, 2026 |
| Preliminary Scoring Letters sent | July 31, 2026 |
| Issuance of Notice of Reservations | August 31, 2026 |
| Carryover allocation information deadline | September 18, 2026 |
| Carryover allocations issued | November 6, 2026 |
| Estimated 270-Day Deadline (as published) | April 6, 2026 |
| Proof of satisfaction of 10% test | November 5, 2027 |
All deadlines are 5:00 p.m. Pacific Time; the Division may modify this schedule. This table reflects the Division's March 25, 2026 amendment to Section 2.1, which pushed the application deadline six weeks later (from the originally adopted May 1) and every downstream date with it — the December 2025 schedule is superseded, though the section numbers an older citation would point to haven't changed. The 'Estimated 270-Day Deadline' row is discussed under 'Where the QAP disagrees with itself' below — the published date precedes the reservation notice that actually starts that clock.
The 4% bond track runs on a different rhythm, and it changed shape mid-cycle. In 2025 NHD introduced a competitive bond application process. Congress then passed H.R. 1, the One Big Beautiful Bill Act (Pub. L. 119-21, signed July 4, 2025), which lowered the federal tax-exempt-bond financing test from 50% to 25%, which allows the Division to return to a first-come, first-served basis for projects that meet a minimum threshold for scoring, all eligibility and application requirements and can show project readiness and financial feasibility. NHD used the freed-up bond capacity to return to first-come, first-served intake for 2026 — evaluated against the same threshold, financial-feasibility, and readiness standards as before — while layering on its own new limit: starting January 1, 2026, no project may receive more than 30% (up to 40% by exception) of its aggregate basis in new, non-recycled private activity bonds, stretching the state's limited bond cap across more deals now that less bond financing is required per project.
| Bond pre-application deadline | Bond application deadline | Board of Finance meeting |
|---|---|---|
| N/A | January 7, 2026 | February 11, 2026 |
| February 6, 2026 | March 6, 2026 | April 22, 2026 |
| March 26, 2026 | April 23, 2026 | June 24, 2026 |
| May 30, 2026 | June 26, 2026 | August 19, 2026 |
| August 6, 2026 | September 10, 2026 | October 14, 2026 |
December's Board of Finance meeting is not accepting new bond applications in 2026.
Each bond application deadline is followed by a Nevada State Board of Finance meeting roughly five to nine weeks later, where issuance is actually approved — a vote that sits outside NHD. A material change to the financing structure between Board approval and financial close can force a second trip to the Board, with added fees and a timeline dependent on the next scheduled meeting.
One office, one online portal, real fees at every step
There is no second bond-issuer agency and no USB-drive submission. Both tracks file through NHD's designated online platform, using Division-prescribed labeling and the Financial Feasibility Form (Sections 1.1–1.2). NHD will not accept an application, document, or fee submitted after the deadline — but the application fee itself doesn't have to arrive with the application: NHD has up to 10 days after submission to receive it, and a dishonored check is independent grounds for rejection.
| Fee | Amount |
|---|---|
| Application fee, 9% | $4,000 |
| Application fee, 4%/tax-exempt bond (initial and final allocation, each) | $5,000 |
| TEB re-application requiring new Board of Finance approval | additional $10,000 |
| Reservation fee | 10% of the tax credit reservation (5% for standalone nonprofits, payable within 6 months); due within 14 days of the reservation letter |
| Carryover Allocation fee | $4,000 |
| Cancellation / reallocation fee | $6,500 |
| Revised IRS Form 8609 issuance | $1,300 |
| Compliance monitoring fee (annual, per unit) | $60 ($80 for Income Averaging projects) |
| Compliance training fee | $130 per person |
| 45-day extension of the 270-day closing rule | $4,000 |
| Resubmission fee | 75% of the initial application fee |
| Project change approval fee | $1,300 |
| Subsidy Layering Review fee | $2,500 |
| Bond Good Faith Deposit | $75,000, due before closing calls may commence |
| DDA/QCT status preservation application | $5,000 |
Missing documents get a cure window, not an automatic rejection — five business days from NHD's notice, the same window that applies to scoring documentation gaps and Background Disclosure follow-ups. Applicants are directed to raise questions with the Division at least five business days before the deadline, which is the only formal pre-filing consultation the QAP grants (Section 1.3).
What the threshold section actually demands
Section 6, 'Pre-Scoring Threshold Requirements,' is the backbone of the application: market study, entity formation and good-standing documents, site control, environmental review, financial feasibility, background disclosures, security features, and Nevada-based-company commitments all have to clear threshold before anything gets scored.
| Document | Window | Citation |
|---|---|---|
| Market study preparation | No more than 9 months before submission | Appendix A |
| Market analyst's physical site visit | Within 2 years of the application deadline | § 6.1 |
| Capital Needs Assessment (Acquisition/Rehab) | Completed within 12 months of application | § 4.10 |
| Phase I Environmental Study | No more than 2 years old as of the deadline | § 6.10 |
| Entity good-standing / Secretary of State documents | Dated within 30 days of the Submission Date | § 6.7 |
| Utility allowance survey | Conducted within 12 months of application | § 10 |
| Owner / GC / property manager financial statements | Prior 2 full calendar years | § 6.11.1 |
| Background Disclosure lookback (bankruptcies, violations) | 7 years prior to the Submission Date | § 6.11.4 |
The market study carries two independent clocks — a 9-month preparation window and a separate 2-year window on the analyst's own site visit. Satisfying one does not automatically satisfy the other.
Site control has to run through an Initial Term lasting at least to December 31 of the reservation year, and it can't be conditioned on anything requiring seller consent, additional payment, or the LIHTC award itself (Section 6.8) — the same structural trap as an unextended option, just framed forward instead of backward.
| Category | Clark County | Other counties / USDA |
|---|---|---|
| New construction — Rent to Own / Tribal Housing | $530,000 | $540,000 |
| New construction — all other types | $350,000 | $370,000 |
| Acquisition/Rehab — rehab line item only | $120,000 | $130,000 |
| Acquisition/Rehab — total cost per unit | $350,000 | $370,000 |
4% tax-exempt bond projects are explicitly excluded from this threshold cap. Superior Project scoring (Section 7.3.9) applies its own, tighter cost-per-unit bands to award points — a separate mechanism from this ceiling, and easy to conflate with it.
Score is a gate; the tiebreaker is arithmetic, not a fight
9% applications score against a 97-point maximum (Section 7.1.1). NHD's stated Guiding Principle sets a floor: an application must earn at least 60% of available points to be eligible for any award. An item with missing, incomplete, or unclear documentation simply isn't scored — no partial credit, same 5-business-day cure window as elsewhere in the QAP (Section 7.1).
| Category | Max points | Citation |
|---|---|---|
| Project Location | 5 | § 7.3.1 |
| Site Control | 5 | § 7.3.2 |
| Additional / Threshold Project Amenities | 8 | § 7.3.3 |
| Nevada-Based Applicant | 2 | § 7.3.4 |
| Affordability Period (5-yr increments to 50 yrs) | 4 | § 7.3.5 |
| Water Efficiency of Landscape Design | 5 | § 7.3.6 |
| Historical Character | 3 | § 7.3.7 |
| Smart Designs | 16 | § 7.3.8 |
| Superior Project | 21 | § 7.3.9 |
| Low Rent Targeting | 6 | § 7.4.1 |
| Low-Income Targeting | 2 | § 7.4.2 |
| Resident Services | 6 | § 7.4.3 |
| Lowest Developer Fee | 5 | § 7.4.4 |
| Low Contractor Fee | 3 | § 7.4.5 |
| Affordable Housing Incentive | 8 | § 7.4.6 |
The Amenities category alone packages roughly 32 optional menu items (10 development-level, 22 unit-level, several restricted to Tenant Ownership projects) into an 8-point cap, plus a separate mandatory threshold-amenity matrix by project type that earns no points at all.
Bond/4% applications score on a different baseline: every project clearing the Section 6 threshold starts at 60 of a possible 100 points, can add up to 40 more (capped) across AMI weighting, site location, public-land donation, leverage of outside pricing or financing, and nonprofit/housing-authority ownership, and needs 70 to be considered for Division funding resources (Section 8.2) — a stricter effective floor than the 60% stated for the 9% track.
Ties within the same set-aside account are broken by dividing the gross 10-year LIHTC amount by Total Project Cost; the lowest ratio wins. An application that received a QAP waiver automatically loses any tie it's part of. If the ratio still ties, NHD runs a lottery under NAC 319.990 (Section 7.5).
Negative consequences layer on top of scoring rather than replacing it. NHD may reject an application or cut up to 10 points for 11 enumerated grounds — incomplete materials, late responses, a controlling person tied to a prior project failure or misrepresentation, bond or HOME/NHTF default, foreclosure history, felony fraud investigation, and more (Section 16). A QAP waiver request costs a flat 3-point deduction regardless of what's waived. Unresolved compliance violations beyond the 90-day cure period cost 5 points instead of making the application ineligible outright (Section 7.6). An application on a HUD, USDA, or other federal/state/local debarred list skips scoring entirely: it's rejected, and every fee paid is forfeited.
Elections that lock at filing
| Election | What locks | Citation |
|---|---|---|
| Project category | Determines which Section 7.2 project-type priority scoring applies; only one category per application | § 4, § 7.2 |
| Category / geographic set-aside boxes | Only the boxes checked at filing are scored — nothing is retroactively added | § 1.1 |
| AMI / rent-restriction election (40% at ≤60% AMI, 20% at ≤50% AMI, or Average Income Test) | Binds for the compliance / extended-use period, up to 50 years | § 6.3 |
| Qualified Contract waiver | Every 9% and 4% applicant waives the federal Qualified Contract right at application — no opt-out | § 6.2; IRC § 42(h)(6)(E) |
| Extended affordability period | Locks in 5-year increments to a 50-year maximum; scored 1 point per increment | § 7.3.5 |
| Nevada Transferable State Tax Credit request | Separate Certificate-of-Eligibility application with its own threshold-point floor (8 or 12 points, by unit count) | Appendix C, § D3 |
Losing a box you didn't check isn't recoverable inside the round — an application is only scored for the categories and geographies it elected.
Where the QAP disagrees with itself
The Section 2.1 schedule lists an 'Estimated 270 Day Deadline' of April 6, 2026 — a date that falls before the August 31, 2026 Notice of Reservations that actually starts the 270-day closing clock under Section 12.5 and NAC 319.981. Running the math forward from August 31, 2026 lands the 270th day on May 28, 2027 — over a year after the published row. (Under the originally adopted December 2025 schedule, the Notice of Reservations was set for July 10, 2026, which would have made the 270th day April 6, 2027 — a tidy one-year-off typo; the March 25, 2026 amendment pushed the Notice of Reservations back seven more weeks without touching this row, so the gap no longer even resolves to a clean year.) The reservation letter's own notice date, not the schedule table, is what actually starts the clock.
Section 7.2.6 (Mixed Use scoring) points readers to 'the Tie Breakers Section (Section 7.15)' for resolving equal scores. There is no Section 7.15 in the QAP — the Tie Breakers section is Section 7.5. It's a mislabeled cross-reference, not a separate rule.
The General Information section states a 60% minimum score to be eligible for an award, with no track distinction. Section 8.2 then sets a specific, numerically higher 70-of-100 floor for bond/4% applications. The more specific bond-scoring section should control for that track under ordinary reading, but the QAP never states the relationship explicitly — worth confirming with NHD rather than assuming which governs.
After you file
A reservation triggers the Carryover Allocation requirements: a $4,000 fee, an executed Declaration of Restricted Covenants recorded within 30 days of the Carryover Letter (or later if NHD approves, but no later than closing), the physical address or legal description for each building, and the Federal Tax ID of the owning entity — all due to NHD by September 18, 2026 for the 2026 round (Section 12.4). The 10% test itself is due by November 5, 2027, and NHD can require quarterly construction-status reports in the meantime.
| Affordable units | Maximum TSTC |
|---|---|
| 50–100 | up to $1,000,000 |
| 101–150 | up to $2,000,000 |
| 151–200 | up to $3,000,000 |
| 201 or more | up to $4,000,000 |
| Supportive Housing at/below 30% AMI (min. 30 units or 20% of total) | up to $3,000,000, separate provision |
TSTCs run a second, independent 270-day proof-of-progress clock (§ D5) and their own threshold-point scoring — a minimum of 8 points for projects under 200 units or 12 points above that, before the sliding scale even applies.
Final 8609 issuance requires a fully updated sources-and-uses application, CPA cost certification, a final energy analysis confirming every pre-construction energy measure was actually installed, and an ADA/Fair Housing accessibility letter — and NHD's compliance team runs a 100% compliance review before releasing the 8609s (Section 13). Ongoing compliance carries its own annual fee ($60 per unit, $80 for Income Averaging projects) and a $130-per-person annual training requirement (Section 15).
Post-award changes are not a formality. A cost swing over 5% of total development cost, a financing-source change of 10% or more, new ownership parties, or a unit-mix change all require prior written NHD approval and a $1,300 fee (Section 19); failure to notify can mean rejection of a pending application or termination of an existing reservation.
Where this goes wrong
- Missing the 10-day application-fee window. Section 1.1 lets the fee arrive up to 10 days after the application itself, but a check that bounces or a wire that's late past that window is independent grounds for rejection — separate from the application deadline itself.
- Treating the 60% score floor as a soft target. It's a hard eligibility cutoff on a 97-point (9%) scale, and the bond track's own Section 8.2 floor is a stricter 70 of 100 — falling short doesn't lower your rank, it removes you from consideration.
- Planning around 2025's competitive bond scoring after NHD returned to first-come, first-served for 2026. H.R. 1's cut of the federal 50% test to 25% (IRC § 42(h)(4)(B)) is why the Board of Finance queue reopened as intake windows rather than a scored round — a 4% deal that clears threshold moves on the calendar in Table 3, not on a comparative score.
- Assuming the $1,500,000 per-developer 9% cap is per-project. It aggregates across every project where the same Applicant, Co-Applicant, or affiliate holds an interest in the current allocation year, and NHD's determination also looks at how the developer fee is split and who's paid consulting fees.
- Building a market study that's fresh on one clock but stale on the other. The 9-month preparation window (Appendix A) and the analyst's 2-year site-visit window (Section 6.1) are independent — satisfying one doesn't satisfy the other.
- Skipping the Qualified Contract waiver on the theory it's optional. Section 6.2 requires every 9% and 4% applicant to waive the federal Qualified Contract process (IRC § 42(h)(6)(E)) at application — there's no scoring election, only compliance.
- Following the Section 7.2.6 cross-reference to 'Section 7.15' for Mixed Use tie-breaking. That section doesn't exist; the QAP's actual Tie Breakers section is 7.5.
- Planning the carryover or closing calendar off the 'Estimated 270 Day Deadline: April 6, 2026' row in the Section 2.1 schedule. That date precedes the August 31, 2026 Notice of Reservations that actually starts the 270-day clock — the arithmetic points to roughly May 2027, not 2026.
- Underestimating the debarment provision. Section 16 doesn't cost points for a debarred applicant — it rejects the application outright and forfeits every fee already paid, before scoring even happens.
- Dating entity good-standing documents to the application deadline instead of the Submission Date. Section 6.7 requires Secretary of State documents dated within 30 days of the actual date of submission, which can be earlier than the deadline.
- Assuming the Nevada Transferable State Tax Credit rides along automatically with a LIHTC award. Appendix C runs its own threshold-point scoring, its own sliding-scale cap, and its own 270-day proof-of-progress clock — separate paperwork, separate deadline, separate risk of losing the reservation.
- Building a closing budget around only the two headline application fees. The Subsidy Layering Review fee ($2,500) and the bond Good Faith Deposit ($75,000, due before closing calls commence) land at specific process points and are easy to leave out of an early pro forma.
- Working from an un-amended copy of the 2026 QAP. The Division's March 25, 2026 Program Notice replaced the Section 2.1 schedule and Table 2 credit-authority figures wholesale — the 9% application deadline moved six weeks later (May 1 to June 15) and total 9% credit authority grew by roughly $2.1 million — without changing any section numbers an older citation or draft would still point to.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies