Three-of-eight, not a point score: how OHCS actually ranks a 9% application — Oregon

ORCA is the application: five steps, one WorkCenter, two different cure windows

Every OHCS resource — LIHTC included — runs through the Oregon Centralized Application (ORCA). Organizations first complete Prequalification, evaluated on portfolio performance, development track record, legal standing, and diversity/equity/inclusion goals, renewed annually 12 months after approval. Every project then begins at Intake, a web-based form covering project basics, site and build plan, unit mix, financial plan, and team/timeline. Approved projects receive access to a project-specific Procorem WorkCenter to work through Impact Assessment, Financial Eligibility, and Commitment — each step gated by its own checklist of evaluation standards the applicant and OHCS both check off.

Two different cure windows apply depending on where a deficiency is found, and conflating them risks a missed deadline: a missing document at the Impact Assessment step gives the applicant 3 business days to respond before the step must be restarted from scratch, while the ORCA Manual's general Cure Process — for a standard not otherwise met — allows 10 business days, with the applicant's original submission date preserved through a successful cure.

Where resources are oversubscribed, OHCS maintains a published ORCA Pipeline Waitlist ordered by date of final, correct Impact Assessment completion. There is no maximum time a project may sit on the waitlist, but a material change (as defined at the Financial Eligibility step) requires a new application and removal from the waitlist, and OHCS may periodically require waitlisted projects to recertify their submissions to keep their place.

No point table: mandatory criteria, three-of-eight supplemental criteria, then a fixed tiebreaker order

For new-construction 9% LIHTC projects specifically, the 2025 QAP's Project Criteria section sets a three-stage filter with no numeric scoring anywhere in it. First, a project must meet all mandatory criteria. Second, it must meet at least three of eight supplemental criteria — meeting more than three is encouraged but earns no additional priority. Third, only if the total resources requested by threshold-qualifying projects exceed what's available does OHCS apply a fixed, ordered tiebreaker sequence. A screening tool that assigns point values to any of these items is fabricating a rubric OHCS does not publish.

Preservation projects skip this framework entirely. They're instead evaluated against the OHCS Preservation Funding Framework's own risk categories — Risk of Loss (Physical or Financial Challenges), Risk of Loss (Federal Project-Based Rent Assistance), and Risk of Loss (Expiration and Conversion to Market-Rate) — sorted into Critical, High, and Medium priority tiers. OHCS works down from Critical only as far as funding allows, and only applies its own four-step tiebreaker (Federal PBRA projects first, then soonest-expiring restrictions, then highest-market-rent census tracts, then greatest number of units preserved) within a priority tier if it's oversubscribed.

Set-asides carve up the annual 9% ceiling before any project-level criteria apply

Ahead of the criteria above, the QAP reserves 10 percent of the annual 9% credit ceiling for qualified nonprofits — organizations under IRC §501(c)(3) or (c)(4) with a stated exempt purpose of fostering low-income housing, per IRC §42(h)(5), which must also satisfy the material-participation test at IRC §469(h). Beyond that, the QAP sets three further targets for the annual ceiling: 25 percent for preservation projects, 10 percent for developments serving Native Nations on tribal trust land, and the remaining 65 percent allocated per percentages set out in the ORCA itself (not restated as numbers in the QAP text).

For 4% LIHTC and Private Activity Bonds, there is no set-aside table or competitive round at all: OHCS tracks and allocates PAB on a first-completed, first-reviewed basis keyed to each project's own estimated closing date, maintaining a waitlist when volume cap runs short. A separate Housing Authority Owned (HAO) PAB set-aside is negotiated annually with the Housing Authorities of Oregon, and Housing Authority-sponsored projects that instead request gap funding through the standard ORCA path do not count against that set-aside.

What actually has to be in the package, and what it costs

A comprehensive market study is required by federal law before any credit allocation — IRC §42(m)(1)(A)(iii) — conducted at the developer's expense by an OHCS-approved analyst from OHCS's own Approved Market Analyst List, per its published LIHTC Market Analysis Guidelines. The submission deadline is set within the Financial Eligibility step for each project, not a fixed date in the QAP itself. At Impact Assessment, new-construction projects submit an Affirmative Fair Housing Marketing Plan, a completed New Construction narrative and Form NC-1, Accessibility Form AD-1, Sustainability Form SD-1, and a conceptual site plan; rehabilitation/preservation projects submit the RH-series equivalents. Each of these is a distinct, OHCS-templated form inside the project's Procorem WorkCenter — the QAP text itself does not enumerate them.

Threshold discipline that applies before and after the award: 60-year affordability, a 20-year resyndication lockout, and a mandatory qualified-contract waiver

All 9% LIHTC projects must remain affordable for 60 years. 4% LIHTC projects must also commit to 60 years unless the deal pairs LIHTC with another OHCS resource offered for at least 30 years, in which case the LIHTC affordability period drops to match that paired resource's term (minimum 30 years, or longer if the paired resource's own term exceeds 30) — the exact mechanic that sets LIFT's own loan-term rules in Phase 7. Projects awarded LIHTC in 2025 or later cannot apply for another 4% or 9% award within 20 years of that project's placed-in-service date, absent a narrow OHCS exception for risk of physical, affordability, or other loss.

By submitting an application at all, every LIHTC applicant waives the right to request a qualified contract under IRC §42(h)(6)(E)(i) — this is not a negotiated term but a blanket condition of applying, and it locks in the same 60-year (or paired-resource) extended-use commitment described above rather than letting the extended-use period terminate at the end of the standard 15-year compliance period. Every awarded project must also be owned by a single-asset entity organized (or authorized to do business) in Oregon, and must execute a Reservation and Extended Use Agreement (REUA) — a recorded declaration of restrictive covenants — as a condition of the award.