"PHFA's QAP mentions an Intent to Submit, a portal-opening fee, several different developer's-fee caps, and two different minimum-score figures in the same document — what's actually due, when, and which minimum score governs my application?"
One Intent to Submit, one hard deadline, one portal — for 9%; a rolling process for 4%
Before submitting a Competitive 9% Tax Credit application, an applicant must first submit an "Intent to Submit a Tax Credit Application - Fact Sheet and Development Synopsis"; for the 2025 round this was due December 5, 2024, roughly ten weeks ahead of the full application. The full Application package, "including all exhibits," then had to be received — as both an electronic submission and a hard copy — no later than 3:00 p.m. on February 11, 2025. The QAP is explicit that Applications not received by the closing date "will not be considered," and equally explicit that it is not committing to a fixed second-year date: further 2025/2026 deadlines "may be announced by the Agency on its website... if a second round is coordinated under this QAP." PHFA's own news page shows 2025 9% awards were announced October 9, 2025, and shows no separate Competitive 9% round opened for calendar year 2026 as of this research — the next visible QAP-related milestone is the draft 2027-2028 QAP, board-approved as a draft on July 13, 2026.
| 9% Competitive | 4% with Tax-Exempt Bonds | |
|---|---|---|
| Competitive? | Yes — Intent to Submits and full applications accepted once a year | No — accepted on a rolling basis; PHFA may reject any application based on feasibility, scoring, inability to close within 180 days, or volume cap availability |
| Application limit per developer | Four | Two (a waiver may be available for a prior HUD Choice Neighborhood Implementation Grant development) |
| Does the project need to meet the 50% Bond Test? | No | Yes |
| Does the project need to meet the 10% Test (for expenditures)? | Yes | No |
See Phase 9 for what the 10% Test and the Bond Test actually require, and for a federal change to the Bond Test's percentage that this QAP does not itself reflect.
Application fees escalate with volume rather than staying flat. The 9% Application Electronic Portal Opening Fee is $5,000, due at the Intent to Submit stage for a developer's first application; a second application submitted the same year adds $2,500 (a $7,500 total), a third adds $5,000 more (a $10,000 total), and a fourth adds $10,000 more (a $15,000 total) — so a developer filing all four applications the cap allows pays $15,000 in application fees alone before underwriting begins, not $5,000 times four.
Good standing and delinquency checks happen before you're even allowed to submit
PHFA screens for "Good Standing" ahead of a full application, and can bar submission outright. Grounds include failing to close a prior-year Tax Credit deal before the 2022/2023 round, repeated delinquent Agency billings gone unanswered, unresolved property-management concerns, uncorrected noncompliance on an existing PHFA property (in either the initial 15-year compliance period or the extended use period), and losing or reducing the number of affordable units still in the extended use period. PHFA makes "a good-faith effort to notify applicants within approximately three weeks of the receipt of the Intent to Submit" if they will not be permitted to submit a full application — but the QAP also reserves the right to raise a good-standing issue at any later point in the process, including asking an applicant to withdraw.
These checks reach beyond the named Applicant entity: the QAP defines a "related entity" broadly (significant common purposes and substantial common membership, or substantial common directors/officers) and applies application caps across related entities and consultants alike — four 9% applications per year per entity serving as general partner or managing member (solely or as co-GP/co-managing member), two 4% applications per year per such entity, and twelve 9% and 4% applications combined per year per consultant. Unclosed prior-year applications count toward these caps unless a waiver documenting circumstances beyond the developer's control is approved.
Threshold Criteria: 21 general items, plus design criteria — and a minimum score the QAP states two different ways
| Item | What it requires |
|---|---|
| Compliance & delinquency history (§3.2.1-3.2.2) | No uncorrected IRS-reported noncompliance in an active 15-year compliance period; no unresolved Agency delinquency/default, or a rejection follows |
| Financial and organizational capacity (§3.2.7) | Evidence of capacity to complete the development; audited financials may be required before closing even if not at application |
| 40-year affordability or homeownership conversion (§3.2.8) | Commitment to serve low-income residents at least 40 years, or a financially viable homeownership-conversion plan with at least $3,000/unit set aside for residents after the compliance period |
| Affordability of units at deep AMI (§3.2.12) | At least 10% of low-income units in Urban Areas (5% in Suburban/Rural Areas) affordable to households at or below 20% AMI, with a viable rent plan for the full compliance period |
| Financial feasibility (§3.2.20) | Any development funding gap (including unsecured sources) must be less than 50% of the developer fee; the operating budget cannot show negative cash flow before year 11 |
| Cybersecurity attestation (§3.2.17) | Multifactor authentication, password policies, security software and staff training must be attested to for all principals and accounting-team members |
This is a selection, not the complete list — the QAP's General Threshold Criteria run 21 numbered items (§3.2.1 through §3.2.21), plus separate Development Design Threshold Criteria (§3.3) covering physical building requirements.
The QAP states its minimum competitive score two different ways in two different sections, and this research could not reconcile them. Section 3.2.21 ("Minimum Score," within General Threshold Criteria) states: "For 9% LIHTC developments, the minimum score needed to meet threshold and continue through the competitive process is at least 125 points. For 4% LIHTC developments, the minimum threshold score needed is at least 110 points." Sections 4.3 and 4.5 (within Selection Criteria and Process) instead state a minimum point threshold of "one hundred and twenty (120) points for all developments except for those qualifying for the Preservation Preference, which shall be one hundred ten (110) points" — repeated in §4.5 as "score at least 120 points... for new construction and/or rehab developments and 110 points for preservation developments." The 4% figure (110) is consistent across both sections; the general 9% figure is not (125 vs. 120). Both sections purport to describe the same qualifying threshold for the same 9% competition. Confirm directly with PHFA which number actually governs before treating a scored application as above or below threshold.
Separately, PHFA caps eligible basis at $320,000 per unit for Competitive 9% developments and $380,000 per unit for 4% developments with tax-exempt bonds (excluding developer fee and acquisition cost), and caps the developer's fee itself at 15% of the first $10 million of replacement cost (less acquisition costs) plus 10% of every dollar above that — subject to per-project ceilings of $1.7-$2.0 million for 9% deals (depending on unit mix/supportive-housing criteria) and $2.55 million for 4% deals, with a further 5% add-on available for a supportive-services escrow on 9% deals only.
Selection Criteria: 232 live points across five categories (a sixth is suspended)
| Category | Maximum points | Notable subcategories |
|---|---|---|
| A. Community and Economic Impact | 37 | A.1 Underserved Areas (15); A.2 Community Revitalization Plan (16 new/rehab, 17 preservation); A.3 Social Inequities & Community Disparities (5) |
| B. Resident Population & Services | 62 | B.1 Income & Rent Targeting (20); B.2 Designated Population & Supportive Services (12); B.3 Accessible Units (10); B.4 Affordable Units for Large Families (10); B.5 Broadband Internet Access (5); B.6 Section 811 Program Participation (5) |
| C. Development Characteristics | 35 | C.1 Smart Site Selection (10); C.2 Green Certification (10); C.3 Energy Efficiency (10); C.4 Build America Buy America (5) |
| D. Development Team and Process | 93 | D.1 Development Team Experience (41); D.2 MBE/WBE Material Participation (15); D.3 Zoning (10); D.4 Commitment of Funds (27); D.5 Noncompliance (negative 10) |
| E. Development Cost Savings | 0 | Scoring suspended for 2025/2026 |
| F. Complete Application Package | 5 | — |
37 + 62 + 35 + 93 + 5 = 232 live points (Category E contributes zero for this cycle).
Zoning scoring (D.3) is a useful, concrete illustration of how PHFA's point system rewards documented readiness over intent: ten points go to a development that has secured "all zoning approvals... for all sites included in the Application, to the satisfaction of the Agency, including all variances and special exceptions," while only five points go to a development that instead provides "a letter from a qualified attorney or local zoning official which articulates and identifies a realistic and timely path forward to secure final zoning approval."
Competitive 9% Tax Credits are divided roughly 50/50 between an Urban Pool and a Suburban/Rural Pool, with at least 25% of the Urban Pool initially set aside for municipalities other than Philadelphia. Separately, the Code's own 10% statutory nonprofit floor is exceeded by PHFA's own target of 25% of Competitive 9% credits going to qualified-nonprofit-sponsored developments, with up to an additional 5% preference layered on for PHFA-certified Community Housing Development Organizations. Where two applications tie within the same Set-Aside, Pool or Preference and only one can be funded, PHFA breaks the tie by favoring the application with the higher percentage of units at or below 50% AMI, then by its own judgment of fit with affordable-housing priorities and geographic distribution, and ultimately by "an ability to proceed."
Waivers and the market-study requirement PHFA doesn't fold into the point system
PHFA's Section 5 waiver process covers several caps described above: a waiver of the Maximum Basis per Unit limit, a waiver to exceed the 30% acquisition-cost cap in certain circumstances, a waiver of the 40%-of-Replacement-Value construction/rehabilitation threshold, and a waiver of the 130% State Designated Basis Boost (available only to Competitive 9% applications, and only where an applicant can show excess costs from one of several named causes — location in an under-resourced area, siting in an "area of opportunity," supportive housing, community impact, or another demonstrable justification). Developments already automatically qualifying for the federal 30% Qualified Census Tract/Difficult Development Area basis boost are not additionally eligible for the state boost, and 4% Tax-Exempt Bond deals are ineligible for the state boost entirely. Developer's fee waivers, by contrast, are capped at a $500,000 request generally — but the QAP is explicit that "waivers of the developer's fee cap for projects that request Competitive 9% Tax Credits... will not be granted by the Agency" regardless of that $500,000 figure.
PHFA's QAP does not state a blanket market-study Threshold requirement applicable to every application the way some states' plans do. The QAP itself ties an independent market study to two specific circumstances: an Income Averaging election ("Applications must provide a market study evidencing demand for proposed targeted incomes") and a preservation deal claiming a likelihood of conversion to market-rate housing (which "must be supported by a current market study in a form and substance acceptable to the Agency"). PHFA also reserves a general right to require "additional independent market studies" of any applicant during processing. Whether the separately-published 2025/2026 Multifamily Housing Application Package imposes a broader market-study requirement for every submission is not something this research confirmed from the QAP text alone — check that document before assuming a market study is optional outside these two named cases.
Where this goes wrong
- Treating "2025/2026" as two guaranteed annual 9% competitive rounds. PHFA does not appear to have run a separate Competitive 9% round for calendar year 2026 as of this research; the QAP itself only commits to announcing a further round "if uncommitted resources are available."
- Missing the Good Standing bar's reach. It can block submission of a full application entirely — not just cost points — and applies across related entities and consultants, not only the named Applicant.
- Underbudgeting the application fee. A developer filing all four allowed 9% applications in one year pays $15,000 cumulative in portal/application fees ($5,000 + $2,500 + $5,000 + $10,000), not $5,000 times four.
- Relying on a single "minimum score" figure without checking which QAP section you're reading. Section 3.2.21 states 125 points (9%) / 110 points (4%); Sections 4.3 and 4.5 state 120 points (new construction/rehab 9%) / 110 points (preservation 9% and all 4%) for the same competition. Confirm with PHFA which governs before treating an application as above or below threshold.
- Assuming Selection Criteria Category E ("Development Cost Savings") still carries points. It is listed at 0 points, scoring suspended for 2025/2026, in the QAP's own Exhibit SC.
- Assuming a market study is a blanket Threshold requirement for every application. The QAP text ties it specifically to Income Averaging elections and to preservation deals claiming conversion risk — confirm the separate Application Guidelines don't impose a broader requirement before skipping one for another deal type.
- Assuming developer-fee waivers are available for Competitive 9% deals because the waiver section states a general $500,000 request cap. The QAP separately states waivers of the 9% developer's fee cap itself "will not be granted by the Agency" — the $500,000 figure applies elsewhere (subsequent-phase and 4%/bond fee waiver contexts).
- Overlooking the 40%-of-Replacement-Value threshold. Both 9% and 4%-with-bonds deals must show construction/rehabilitation costs exceeding 40% of replacement value or submit and win approval of a waiver — relevant to light-touch acquisition-heavy preservation deals.
- Assuming the Urban/Suburban-Rural pool split and the 25% non-Philadelphia Urban Pool carve-out are fixed percentages rather than targets. The QAP states these as amounts PHFA "may be adjusted... to ensure adequate and appropriate funding," not hard caps.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies