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One annual round, five threshold gates, and a rolling line for bonds — Rhode Island

Phase 8 of 11

"RIHousing runs one submission deadline a year for 9% credits, not a multi-gate calendar with separate pre-application, competitive-application, and threshold-submission dates -- so what exactly has to be true about my development team, my budget, and my site before RIHousing will even score the application, and does any of that threshold review apply the same way if I'm applying for 4% credits and bonds instead?"

Not yet coveredFor the round that produced 2026 9% reservations: RFP issuance on or about October 1, 2025, proposals due on or about the third Friday in December 2025, and reservation decisions rendered at the April 2026 Board of Commissioners meeting -- roughly six months from RFP to award, with RIHousing free to add additional rounds if credits remain unallocated or are returned. Tax-exempt bond Volume Cap applications for 4% deals run on a different, rolling basis, "subject to availability," with no fixed annual deadline. RIHousing has no formal pre-application process, though staff consultation before filing is "strongly encouraged."

The funding-round calendar: one RFP, one deadline, one Board vote

First funding round schedule for 2026 9% reservations (2026 QAP, Section II.A)
MilestoneDate
RFP issuanceOn or about October 1, 2025
Proposals submission deadlineOn or about the third Friday in December 2025
Reservation decisions renderedAt the April 2026 Board of Commissioners meeting

RIHousing may run additional funding rounds to allocate remaining or returned credits, and may limit a later round to applicants who already applied in the first or second round.

RIHousing has no formal pre-application process, but the QAP tells applicants that they are "strongly encouraged to review potential applications with RIHousing staff prior to submission" -- and makes clear it is "solely the applicant's responsibility to select a preferred plan of action." RIHousing may also build a public, inspectable waiting list for strong-but-unfunded proposals within a given LIHTC program year.

After submission, RIHousing staff can request written clarification of "discrepancies or incomplete items," giving the applicant 10 days to respond in writing -- but the QAP draws a hard line around what that clarification window can fix: "Only clarifications or missing information will be accepted, no substantive changes may be made by the applicant after the application is submitted. A substantive change may include, but is not limited to, modifying the LIHTC request, changing unit count, and adding or removing specific locations from the application."

Five Threshold Criteria gate everything before scoring starts

"Only proposals that satisfy the Threshold Criteria review will be further considered under the Scoring Criteria," and Threshold determinations are explicitly final: "Threshold determinations are not appealable." The five criteria, as the QAP itself lists them at the top of Section III.A, are development team experience, 15-year financial feasibility, a reasonable likelihood of 95% occupancy within 6 months of construction completion, a construction-timing test, and a per-unit total development cost ceiling.

The five Threshold Criteria (2026 QAP, Section III.A)
CriterionWhat it requires
1. Development Team CapacityExperience developing and operating affordable housing of similar scope; audited financials for the prior 3 years; joint venture required if the developer lacks LIHTC experience
2. Financial FeasibilityRealistic development budget; 15-year operating feasibility; funding sources available within 9 months of reservation; municipal tax-treatment documentation for mixed-income deals
3. MarketabilityReasonable likelihood of 95% occupancy within 6 months of construction completion; third-party market study for qualifying mixed-income proposals
4. Readiness to ProceedConstruction reasonably likely to commence within 12 months and complete within 30 months (see anchor-milestone note below); 9-month readiness checklist after the reservation letter
5. Total Development Cost ceilingPer-unit TDC (excluding capitalized reserves) must not exceed RIHousing's cap -- stated as a flat $500,000/unit figure in the 2026 QAP itself

That fifth criterion is worth reading literally rather than assuming it tracks RIHousing's separate building-type cost table. The currently governing 2026 QAP states the ceiling in dollars, directly in the Threshold list: "The per unit TDC of the project does not exceed $500,000 per unit, not including capitalized reserves." RIHousing's 2027 QAP draft -- posted for public comment, not yet adopted as of this research -- rewrites that same criterion to instead reference "RIHousing's established project type related cost caps per unit," i.e., the separate, building-type-specific Overall TDC table RIHousing publishes by Program Bulletin (currently ranging from $266,000/unit for LIHTC preservation up to $470,000/unit for a 4-story elevator building, per the 2026 Program Bulletin, Section 9). If the 2027 draft is adopted as written, RIHousing would be able to move this cap administratively through a Program Bulletin update rather than through a QAP amendment -- a real change worth tracking once the 2027 QAP is finalized.

Development Team Capacity and Financial Feasibility: three years of audited financials and a municipal tax-treatment letter

Team review looks at "the quality and quantity of previous development, design, construction and property management efforts, as well as affirmative action records," plus a full creditworthiness review: "a thorough review of the developer's audited financial statements for the previous 3 years," and a credit report for all principals of for-profit developers. A developer without satisfactory LIHTC experience must either joint-venture with an experienced entity or demonstrate to RIHousing's "sole satisfaction" how the gap will be covered. RIHousing can deny an award outright if any team member is not creditworthy, is on the HUD or RIHousing debarment list, or is not in good standing on compliance monitoring elsewhere in RIHousing's portfolio.

Financial Feasibility review requires funding sources to be realistically achievable even though they need not be secured at application: "the applicant must be able to demonstrate to RIHousing's satisfaction that the sources identified will be available to the developer within 9 months of the reservation of credit." For mixed-income proposals, it also requires "documentation... demonstrating that the municipality has agreed to limit taxes on the affordable units to 8% of the gross scheduled rental income for the real estate tax calculation or lesser percentage determined by the municipality" -- the same 8%-of-rent benchmark discussed in Phase 7, tying this Threshold criterion directly to whatever local PILOT or tax-stabilization agreement (under R.I. Gen. Laws § 44-3-9 or § 44-3-13.4) the developer has negotiated.

The 2027 draft QAP would add a rule not present in the currently governing 2026 QAP: "A developer who has received a previous allocation of 9% LIHTC credits and has not closed on financing and begun construction on that project as of the application deadline date may not apply for additional 9% credits." That is a meaningful new gate on repeat applicants with unclosed prior awards -- but it is a draft provision only as of this research, not yet governing.

Marketability and Readiness to Proceed: the clock that becomes Phase 9's clock

Marketability review centers on the same 95%-occupancy-within-6-months standard as the Threshold summary, backed for qualifying mixed-income deals by a third-party market study with "an absorption schedule, lease-up reserve" and a stated timeline for reaching 95% occupancy, plus comparables, supply/demand, and outreach-strategy documentation.

Readiness to Proceed's initial test is a fixed 9-month sprint from the reservation letter: an applicant must, "within 9 months of an executed reservation letter for LIHTCs," achieve five things -- "(i) receive all written land use and zoning approvals and building permits; (ii) complete all regulatory, environmental, and historical reviews; (iii) maintenance of site control; (iv) secure all funding commitments; and (v) demonstrated financial feasibility." This 9-month test is the exact clock Phase 9 picks up as the first milestone of the post-award period.

Continued readiness runs on RIHousing's discretionary judgment against factors including a developer's ability to meet the requirements for a Carryover Allocation Agreement, finalize design development, secure an investor commitment letter, and "close on all financing and commence construction within 12 months of reservation." Flag a real internal inconsistency in the 2026 QAP's own wording: the Threshold Criteria summary at the top of Section III.A ties construction to "12 months of preliminary commitment" for commencement and "30 months of firm commitment" for completion, while the detailed Readiness to Proceed provision a few pages later ties both the same 12- and 30-month figures instead to "reservation of credits." The QAP does not itself reconcile whether "reservation," "preliminary commitment," and "firm commitment" are meant to be the same event -- treat them as the same milestone unless RIHousing staff confirms otherwise in writing for a given deal.

Scoring: a 60-point Financing category inside 133 total points across four categories

2026 QAP Scoring/Point Allocation Summary, Section III.B
CategoryPoints
Financing60
Incomes/Populations Served44
Promoting RI Workforce/Permitting16
Community13

These four category subtotals, as stated in the QAP's own summary table, add to 133 total points. See Phase 7 for the Financing category's own sub-parts (TDC, LIHTC efficiency, leveraged operating subsidy, leveraged hard debt/other resources).

The remaining three categories reward new three-bedroom-or-larger units, service to homeless/special-needs populations, and units above 80% AMI (Incomes/Populations Served); use of Rhode Island-based firms, MBE/WBE participation, and fully-permitted status at application (RI Workforce/Permitting); and siting in communities with less than 10% existing affordable housing, job-rich or strategic-growth areas, or HUD-designated Areas of Opportunity (Community).

This QAP states no published minimum competitive score anywhere in its text. An application can clear every Threshold Criterion, be fully scored, and still not be funded, because RIHousing separately reserves "sole and absolute discretion" to decline a reservation regardless of score if it finds the award wouldn't further the Plan's goals, available resources are insufficient, or there is an over-concentration of projects by geography or production type.

4% Credits/Bonds and Hybrid Developments: a different track entirely

Section IV of the QAP, Tax Exempt Financing with 4% Credit, states plainly that 4%/bond deals are not evaluated the 9% way: "Proposals utilizing tax-exempt bond financing with 4% LIHTC are not scored based on the 9% scoring criteria outlined in the QAP. These projects typically need subsidy funding and will be scored for the other competitive sources developers may be seeking (e.g. HOME, Housing Production Fund, Building Homes RI, etc.)." Every 4%/bond deal must still independently satisfy Section 42 and Section 142 of the Internal Revenue Code and the Threshold Criteria/Developer's Handbook. The bond side of the transaction is its own separate filing: "Applications for Volume Cap are currently received on a rolling basis and will be subject to availability" -- no fixed annual deadline the way the 9% round has one.

A Hybrid Development -- one seeking both a 9% award and a simultaneous 4%/bond allocation -- must conform to RIHousing Program Bulletin 2022-2 and Section 12 of the Developer's Handbook, on top of the ordinary 9% and 4% requirements. RIHousing evaluates a proposed hybrid on scale (it must be large enough that the added execution complexity is worth it), the applicant's demonstrated capacity to run two simultaneous financing tranches, and documented cost savings or unit gains from the hybrid structure. The 2027 draft QAP -- not yet adopted -- would raise the bar further, requiring the developer to "also submit an alternate proposal that would utilize 4% for the entire development" specifically "to demonstrate that a hybrid structure is the most efficient use of state resources." That competing-proposal requirement does not exist in the currently governing 2026 QAP.

What's actually a regulation, not just a QAP policy

RIHousing's LIHTC allocation authority is separately codified at 825-RICR-30-00-4 (effective January 4, 2022, most recently refiled without substantive change, under R.I. Gen. Laws §§ 42-55-5(5) and 42-55-24.1). That regulation is what legally designates RIHousing "the housing credit agency for the State of Rhode Island," backs the QAP's reservation-and-allocation mechanics and its non-profit set-aside, and is the source of RIHousing's authority to charge application, underwriting, and allocation fees -- authority the QAP itself exercises but does not independently create.

LIHTC fees due through application and closing (RIHousing 2026 Program Bulletin, Section 9)
FeeAmountWhen due
Application fee$1,500, non-refundableAt submission
Underwriting fee$20,000 (combined loan up to $1M) / $25,000 (up to $3M) / $35,000 (over $3M)Review of the LIHTC proposal
Tax credit allocation fee0.5% of the 10-year allocation (9% credits) / 1.0% (4% credits)At closing

Where this goes wrong

  • Assuming Rhode Island runs a multi-gate calendar with separate Pre-Application, Competitive Application, and Threshold Submission dates. RI's 9% process has one RFP and one submission deadline; Threshold review and scoring both happen after that single filing.
  • Treating the post-submission 10-day clarification window as an opportunity to fix substantive problems. The QAP explicitly bars changing the LIHTC request amount, the unit count, or the site list during that window -- only clarifications and missing information are accepted.
  • Assuming a Threshold denial can be appealed. The QAP states Threshold determinations "are not appealable" -- only the numeric score can be contested, and only before the Funding Committee meeting.
  • Reading the $500,000-per-unit TDC ceiling as fixed and permanent. It is a flat dollar figure in the currently governing 2026 QAP, but the 2027 draft would tie the same Threshold criterion to RIHousing's own separately adjustable Program Bulletin cost-cap table instead.
  • Assuming 4%/bond deals get scored the same way as 9% deals. QAP Section IV states plainly they are not scored under the 9% criteria and instead lean on other competitive-source scoring and RIHousing's own underwriting standards.
  • Missing that a Hybrid Development has its own separate compliance document -- Program Bulletin 2022-2 plus Developer's Handbook Section 12 -- not just a combination of the ordinary 9% and 4% rules.
  • Treating the two "30 months" construction-completion clocks in the 2026 QAP as obviously the same date. One QAP passage ties it to "firm commitment," another to "reservation of credits," and the document never reconciles the two.
  • Forgetting that 825-RICR-30-00-4 and the RIHousing Developer's Handbook are independently binding, not just background color for the QAP. RIHousing's legal designation as the state's housing credit agency, and its fee authority, both come from the regulation, not the QAP text.
  • Assuming the currently posted 2027 QAP draft is already governing. As of this research it remained a public-comment draft -- the comment period closed August 31, 2026, and the Executive Office of Housing's own QAP page had not marked it adopted.

At a glance

Application fee
$1,500, non-refundable, due at submission (2026 Program Bulletin, Section 9)
Underwriting fee tiers
$20,000 (combined loan up to $1M) / $25,000 (up to $3M) / $35,000 (over $3M)
Tax credit allocation fee
0.5% of the 10-year allocation (9%) or 1.0% (4%), due at closing
2026 round timeline
RFP ~10/1/2025 -> submission ~3rd Friday of December 2025 -> Board decision at the April 2026 meeting
Minimum new-production size
30 new units; preservation deals need 30% of total units, or 20 units, whichever is greater, newly created
Per-development award cap
No single development may be awarded more than 40% of Rhode Island's annual small-state minimum allocation
Preservation limit per round
RIHousing approves no more than one 9%-credit transaction with a preservation component per funding round
Total scoring points
133 across Financing (60), Incomes/Populations Served (44), RI Workforce/Permitting (16), and Community (13)
Governing allocation regulation
825-RICR-30-00-4 (effective 1/4/2022), authority R.I. Gen. Laws §§ 42-55-5(5) and 42-55-24.1
2027 QAP status
Public-comment draft only as of this research; comment period closed 8/31/2026, not confirmed adopted

Governing authority

  • Funding round schedule and process2026 QAP, Section II, Application Process and Ranking Method for 9% Credits
  • Five Threshold Criteria2026 QAP, Section III.A, Threshold Criteria
  • 8%-of-gross-rent municipal tax documentation requirement2026 QAP, Section III.A.2, Financial Feasibility
  • Readiness to Proceed 9/12/30-month tests2026 QAP, Section III.A.4, Readiness to Proceed
  • Scoring/point allocation summary2026 QAP, Section III.B
  • 4% Credits/Bonds not scored under 9% criteria; rolling Volume Cap applications2026 QAP, Section IV, Tax Exempt Financing with 4% Credit
  • Hybrid Development requirements2026 QAP, Section III.A.4 (Hybrid Development provision); RIHousing Program Bulletin 2022-2; Developer's Handbook, Section 12
  • 2027 draft QAP changes (TDC cap language, repeat-applicant bar, hybrid alternate-proposal requirement)State of Rhode Island 2027 Qualified Allocation Plan, Draft (posted for public comment, Executive Office of Housing, housing.ri.gov)
  • Application, underwriting, and allocation feesRIHousing 2026 Program Bulletin, Section 9 (Developer Fee Policy / Fee Schedule)
  • RIHousing's designation as housing credit agency; regulatory basis for fees and allocation process825-RICR-30-00-4, Allocation of Low Income Housing Tax Credits

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