"We're ready to file — what actually has to be in the package, when is it due, and how many points do we realistically need to win a 2026 award?"
Two applications, an Authority-run score, and no waiver on the scoring table itself
"Unless otherwise specified, all QAP and Appendix references to 'application' refer to the full application" — the Preliminary Application is a distinct, earlier filing that establishes site control, market position, and initial scoring before the Full Application locks in the underwriting package. SC Housing scores every application itself; there is no self-scoring worksheet for the applicant to complete and submit the way some other states require.
Section III of the QAP governs corrections and disputes on a strict clock measured in business days, not calendar days (with intervening Saturdays, Sundays, and state holidays excluded from the count). SC Housing will notify an applicant in writing of missing or incomplete documents or items needing clarification, and "[t]he applicant must respond by 5:00 p.m. (Eastern) on the third business day" — the same three-business-day window applies separately to a response to posted point scores and to a notice of proposed disqualification. Critically, "[d]ocumentation provided in response to Authority requests will not increase an application's point score," and responses to a point-score notice are limited to "the Applicants' opinions regarding the Authority's determinations," references to material already in the file, and explanations of what was already submitted — new evidence is not permitted at this stage.
A formal reconsideration request is the only avenue beyond that: it must go to reconsiderations@schousing.com within three business days of a disqualification or score determination, requires a fee before it will be processed ($5,000, per the fee schedule), and is decided first by a Hearing/Review Officer and — only if that officer recommends overturning the original decision — by a Review Committee of at least three (an odd number of) Board-appointed members excluding Development Division staff. Ex parte contact with the Hearing/Review Officer by either side is grounds for disqualifying the pending application and suspending every Development Team member from future funding cycles, regardless of who initiated it. Separately, Section II.A of the QAP states outright that "SC Housing will not accept waiver requests on any point scoring or ranking criteria" — a different and narrower carve-out than the Mandatory Site Requirements waiver process described below.
Threshold participation criteria gate every application before scoring begins
Section IV's threshold list has to be cleared before an application is scored at all. Required documentation includes a third-party market study from an Authority-approved analyst (Appendix A), a Persons-with-Disabilities compliance statement, an Affirmative Fair Housing Marketing Plan commitment, and — for rehabilitation deals — a pre-rehab Physical Needs Assessment dated within 12 months of submission, a certified rent roll, and a detailed relocation plan (Form 3 for rehab). Site control must be evidenced by a recorded deed, a dated purchase option or contract, or a ground lease/option of at least 50 years, executed by a Principal; scattered-site (noncontiguous-parcel) developments are categorically ineligible for 9% credits. Zoning approval, a wetlands map (Exhibit W), and a Phase I Environmental Site Assessment dated within six months of the full application deadline are all required, with a Phase II required if the Phase I recommends further examination.
Development-team qualification is concrete, not aspirational: the proposed GP/managing member needs experience on "two (2) LIHTC projects in South Carolina; or four (4) LIHTC projects in other states" within the last ten years, each having reached 8609 issuance, placement in service, and stabilized occupancy, with a controlling stake held from initial application through certificate of occupancy. The proposed management entity needs at least three LIHTC developments "in their current portfolio that it has successfully and continuously managed for the past three (3) years," and its lead contact must hold a recognized LIHTC compliance certification (the QAP names ten qualifying certifying bodies plus SHCM). A commercial appraisal from a South Carolina-licensed, SC Housing-approved appraiser is required for every application, with the Authority reserving the right to write down a purchase price that exceeds appraised value.
Mandatory site requirements can disqualify a site outright — subdividing a development, stacking more than one new-construction phase in the same cycle, unsuitable slope/terrain economics, or an unmitigated National Priorities List/CERCLA site — and a further set of proximity rules (railroads, civil/military airport zones, agricultural processing facilities, hazardous-waste and solid-waste facilities, junkyards, bulk fuel storage, adult entertainment venues, and heavy industrial uses) can disqualify new-construction sites subject to a waiver process requiring documentation "no less than 30 days prior to preliminary application" — a materially earlier deadline than the application itself (the 2026 deadline for this specific waiver was January 13, 2026). Market thresholds require a capture rate at or below 30% and a 12-month-or-shorter absorption period, and unit-mix rules require family developments to run 20–35% three/four-bedroom units (capped at 5% four-bedroom) and at least 10% one-bedroom/studio/SRO units, while elderly developments are capped at studio/one-/two-bedroom units with elevator access above ground level.
Five set-asides, county and team caps, and a scoring table that tops out well above 100 points
| Set-aside | Share of state's 9% ceiling | Notes |
|---|---|---|
| Urban New Construction | 35–40% | Urban counties: Aiken, Anderson, Beaufort, Berkeley, Charleston, Dorchester, Greenville, Horry, Lancaster, Lexington, Richland, Spartanburg, York |
| Rehabilitation | 15–20% (Section II.B.2 body text) — but the Appendix's own Table of Contents lists this set-aside as "20-25%" [UNCONFIRMED — the two figures conflict within the same official document; confirm the governing percentage directly with SC Housing] | Up to $600,000 reserved for one eligible RD project; adaptive reuse and vacant-building redevelopment count as New Construction, not Rehabilitation |
| Suburban New Construction | 25–35% (body) / "25-30%" (Section II.B.3 heading) [UNCONFIRMED — same type of internal figure mismatch] | Suburban counties: Cherokee, Chesterfield, Darlington, Florence, Georgetown, Greenwood, Kershaw, Laurens, Newberry, Oconee, Orangeburg, Pickens, Sumter |
| Rural New Construction | 5–10% | Rural counties: Abbeville, Allendale, Bamberg, Barnwell, Calhoun, Chester, Clarendon, Colleton, Dillon, Edgefield, Fairfield, Hampton, Jasper, Lee, Marlboro, Marion, McCormick, Saluda, Union, Williamsburg |
| Public Housing Authority | One award | Demolition/new-construction replacement of existing public housing; a local PHA (or related entity) must be a GP/managing member; does not count against county limits |
Per-application federal credit caps: Urban $1,450,000; Suburban $1,350,000; Rural $1,250,000; PHA cap set by county. A Development Team may not be associated with more than 4 full/5 preliminary applications, may not win more than 2 awards, and an Urban county receiving 2 awards is capped at 1 award the following cycle.
| Category | Max points | Key mechanic |
|---|---|---|
| Distance to Amenities | 70 | Scaled by driving distance (Google Maps, drivable route as of the preliminary deadline) to grocery, shopping, pharmacy, retail, healthcare, and public-facility amenities; bands tighten for Urban vs. Suburban vs. Rural |
| Public Transportation | 1 | Fixed-location transit stop within 0.3 walking miles, 6 days/week, 10 consecutive weekday hours |
| Area Employment | 10 | Jobs paying $1,251–$3,333/month within a 2/5/10-mile radius (Urban/Suburban/Rural), per Census OnTheMap LEHD data |
| USDA Rural | 5 | Site entirely within a USDA-defined rural area as of the preliminary deadline |
| Land Donation or Ground Lease | 5 | Local-government-owned site donated or ground-leased at ≤$5,000 total or ≤$100/year, held since at least July 31, 2025 |
| Affordability | 10 + 10 | 10 points for meeting a county-tier average-income or original set-aside matrix; 10 more for a notarized Qualified Contract waiver |
| Affordable Housing Shortage | 10 / 7 / 5 / 3 | Scaled to how many prior funding cycles (15/10/5/3) the county went without a new-construction 9% award |
| Sustainable Building | 5 | Commitment to one of five named green-certification programs |
| Leveraging | 6 | See Phase 7 — soft-funding sources meeting the QAP's independence, term, and rate tests |
| Other Credits | 5 | Federal Historic, or SC Certified Historic Structure, Textiles Rehabilitation, Abandoned Building Revitalization, or Brownfields Cleanup credits |
| Supportive Housing | 5 | 10% of units targeted to persons with disabilities at ≤30% AMI/20%-of-income rent, or with project-based rental assistance |
There is no published minimum score to be competitive anywhere in the QAP or its Appendices — awards run in descending rank within each set-aside until that set-aside's dollars are exhausted, so the real benchmark is what the lowest-funded application in your set-aside/county scored in recent cycles, not a stated cutoff. Rehabilitation applications are instead evaluated under a separate comparative scale in Section V (qualified-contract exposure, physical distress by major system, age since last placed-in-service, and a Concerted Community Revitalization Plan bonus).
Tie-breakers run in a fixed sequence: first, whether the award would be a team's only award in that cycle versus a tying competitor's second or third; then the county with fewer 9% awards in the past three cycles; then the highest per-unit Leveraging dollars; then a Concerted Community Revitalization Plan meeting four specific tests; then a tenant-ownership conversion plan for the property; and only then a lottery. A separate nonprofit set-aside can redirect up to roughly 10% of the state's federal ceiling to qualifying 501(c)(3)/501(c)(4) applicants meeting staffing, good-standing, and material-participation tests, with third-party development-consultant fees capped at $35,000.
The bond/4% track: its own cycle, a 5% cost-variance cap, and no HOME eligibility
Tax-Exempt Bond (TEB) applications for the 4% credit run on a schedule "published on the Authority's website" separate from the 9% calendar (2026's preliminary window was April 13–17). At full application, "Total Development Costs, Permanent Financing Sources, State Resource Request and Total Square Footage may not vary more than five percent (5%) from Preliminary Application," and targeting, unit count, and unit mix cannot change at all between the two filings. TEB developments must meet all the same QAP threshold criteria as 9% deals except where Appendix C2 modifies them — most notably, scattered-site and portfolio transactions are explicitly permitted under conditions (single ownership/management/financing plan, same county, minimum 4 units per noncontiguous parcel), unlike 9% deals where scattered sites are categorically barred.
| Item | Rule |
|---|---|
| Size | 70–200 units (achievable via scattered sites or portfolio transactions) |
| Developer fee cap | Lesser of $5,000,000; 15% of TDC less land/consultant/developer fees/overhead/other developer costs/reserves; or $30,000/unit |
| Application/award limits | Up to 3 full / 4 preliminary applications per team per cycle; no more than 2 awards per team; 2 new-construction awards per Urban county, 1 per Rural county |
| Set-asides | New Construction 40%, Rehabilitation 30%, Public Housing Authority 30% |
| Ceiling-allocation request | Section II.B.8.d: a January 9, 2026 QAP clarification states the Development Team must request "the minimum of thirty percent (30%) of the aggregate basis," while Appendix C2's own unrevised body text at the same subsection still reads "the maximum of thirty percent (30%) of the aggregate basis or permanent supportable debt" [UNCONFIRMED — these directly contradict each other within the same official 2026 QAP package; confirm the operative rule with SC Housing before sizing a bond request] |
| HOME eligibility | None — "Tax exempt bond developments are not eligible to apply for Authority HOME funds" |
TEB developments needing State LIHTC must separately clear Appendix C3, and ranking for bond ceiling uses the same four state-resource-efficiency ratios (per square foot, per bedroom, per total cost, per tenant) described in Phase 7, adopted under Act 202 alongside the State Credit ranking system.
Fees due before an application is ever scored
| Fee | 9% LIHTC | TEB/4% LIHTC |
|---|---|---|
| Application Fee | Preliminary $1,500 / Full $4,500 | Preliminary $1,500 / Full $4,500 |
| Market Study Review Fee | $600 | $600 |
| Missing Document Fee | $1,000, reassessed every 5 business days | $1,000, reassessed every 5 business days |
| Reconsideration Fee | $5,000 | $5,000 |
| Bond Issuance Fee | n/a | 0.75% of new issuance; 0.50% of refundings |
| Financial Advisor Fee | n/a | 0.10% of total bond issuance |
Where this goes wrong
- Assuming there is a minimum score needed to be competitive. None is published anywhere in the QAP or Appendix C1 — SC Housing ranks applications in descending order within each of five set-asides until that set-aside's dollars run out, so the real benchmark is the lowest-funded score in your specific set-aside and county in recent cycles.
- Requesting a waiver on any point-scoring or ranking criterion. Section II.A states flatly that "SC Housing will not accept waiver requests on any point scoring or ranking criteria" — this is separate from, and narrower than, the Mandatory Site Requirements waiver process under Section J.3, which has its own much earlier deadline (30 days before the preliminary application, i.e. January 13, 2026 for the 2026 cycle).
- Trusting Appendix C1's Table of Contents percentages for the Rehabilitation and Suburban New Construction set-asides. The Table of Contents lists "REHABILITATION (20-25%)," but Section II.B.2's own body text says "REHABILITATION (15 – 20%)" — a direct conflict within the same official document that this research could not resolve and that should be confirmed with SC Housing before relying on either figure.
- Submitting new evidence in response to a missing-document notice or point-score posting in hopes of raising the score. The QAP states explicitly that "[d]ocumentation provided in response to Authority requests will not increase an application's point score," and a point-score response is limited to opinions on the Authority's determination, references to material already filed, and explanations of prior submissions.
- Measuring amenity distances as the crow flies. Section III(A)(1) of Appendix C1 requires an actual drivable route as of the preliminary application deadline, measured from a single fixed point on the site's road frontage, documented with a satellite-view map, written directions, and a real (non-stock) photograph of each amenity — with driveways and access easements over 500 feet added to the measured distance.
- Counting a hair salon, barber shop, nail salon, or post office as a qualifying "Retail" amenity. The January 27, 2026 QAP clarification excludes all four by name from Appendix C1, Section III(A)(1).
- Treating the 3-business-day response windows in Section III as calendar days. Saturdays, Sundays, and state holidays are excluded from the count, and the deadline for each of the missing-document, point-score, and disqualification responses is 5:00 p.m. Eastern on the third business day — not the third day overall.
- Assuming the 4% TEB ceiling-request rule is settled. The January 9, 2026 clarification to Appendix C2, Section II.B.8.d requires a "minimum" 30% of aggregate basis, while the Appendix's own unrevised body text for the same subsection still says "maximum" 30% of aggregate basis or permanent supportable debt — confirm directly with SC Housing before sizing a bond volume request.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
