"THOMAS shows exactly one Initial Application deadline for the whole year — April 16 at 4:30 PM — what has to be true, dollar-for-dollar and point-for-point, by that moment, and what actually happens if THDA's own review lands on a different score than the one we submitted?"
A single deadline, not a multi-gate calendar
| Date | Event |
|---|---|
| March 20, 2026 | Competitive Cycle opens for Initial Applications |
| April 16, 2026, 4:30 PM CT | 2026 Competitive Cycle deadline for Initial Applications |
The QAP states these dates are "subject to change at THDA's sole discretion," with a full calendar also published on the THOMAS Documents Page. Developments financed through Multifamily Tax-Exempt Bond Authority (MTBA) and applying for noncompetitive Housing Credit follow the separate 2026 MTBA Program Description calendar instead of this table.
| Development size | Fee |
|---|---|
| 1–4 units | $395 |
| 5–50 units | $1,595 |
| 51–100 units | $2,210 |
| 101+ units | $40 per unit |
All fees are wired — no checks — to THDA's clearing account, with the TN ID number(s) entered in the wire's OBI field; the QAP states an Initial Application "is not complete unless and until the required fee is received by THDA." Fees are non-refundable and cannot be applied to a different application or fee type absent circumstances THDA finds beyond the Applicant's control.
Beyond the base filing fee, the same fee schedule prices every later step of the process on a sliding or percentage basis: a Deadline Extension Fee ($500 for 1–5 days, $200/day for 6–30 days, $6,000 for more than 30 days), a Reservation Fee (6.25 percent of the competitive Housing Credit approved, due when the Reservation Notice is accepted), a 42(m) Letter Fee (6.25 percent of noncompetitive Housing Credit requested), a Modification Fee (the greater of $750 or 0.625 percent of the annual Housing Credit in the Reservation Notice), an 8609 Amendment Fee ($50 per form, $250 minimum), and a Monitoring Fee ($600 per Low-Income Unit, due with the Final Application). None of these later fees are optional add-ons — they are how THDA prices every subsequent stage of the same application that starts on April 16.
Threshold and mandatory requirements before scoring ever starts
Section 6 sets six Mandatory Requirements that apply before an Initial Application is even scored: Site Control (one of a recorded deed, eminent-domain evidence, a sale contract, or a purchase/ground-lease option — any ground lease must run at least 50 years unless the development is the subject of an approved PILOT, which the QAP allows to shorten that minimum term); Underlying Seller Authority documentation (a title insurance commitment dated within 60 days of the deadline, with a legal description matching the Site Control documents); Zoning evidence from the local zoning administrator or chief elected official; a Minimum Score under Section 18 (see below); an acceptable, independently prepared Market Study following THDA's own Market Study Guidelines; and, where acquisition costs are part of the deal, an independent Appraisal.
Section 6.B then layers on Threshold Requirements that run alongside the mandatory items: compliance with the Fair Housing Act (including design-and-construction safe harbors for covered multifamily dwellings built after March 13, 1991), the ADA, and applicable building codes; documented availability of electricity, water, sewer, and gas from the local jurisdiction (septic fields are prohibited above four units); demonstrated Financial Feasibility with sources and uses available at application and lender/investor letters showing no construction-period funding shortfall; a 30-year financial pro forma; an election of one Minimum Set-Aside test (20/50, 40/60, or Average Income — with a rehabilitation of a prior Housing Credit development locked into whatever its own prior election was, absent a waiver request); and a full slate of certifications, disclosures, and organizational-ownership breakdowns filed as THOMAS templates.
THDA will not accept a market study, appraisal, physical needs assessment, or cost certification "prepared by parties connected with any person or entity involved with the Development Team or Related Parties, as determined by THDA, in its sole discretion" — and every supporting document filed with the application generally cannot be more than 6 months old as of the deadline unless the QAP specifies otherwise.
Scoring is a 100-point table, but nobody is meant to reach 100
The 2026 QAP scores new construction and rehabilitation of Existing Multifamily Housing on two separate, differently weighted 100-point tables under Section 17, and states outright that "the scoring criteria in this section are not intended to allow an Applicant to claim the maximum 100 points." An application proposing a mix of new construction and Existing Multifamily Housing is scored under whichever type has the majority of Low-Income units — which also determines which of the two tables, and which minimum score, applies.
| Category | Points available |
|---|---|
| Housing Credit Development Location (Regional Housing Needs Score) | up to 4 |
| Meeting Housing Needs (deeper income/rent targeting above the elected minimum set-aside) | up to 6 |
| Development Characteristics (exterior materials, roofing, amenities, community space, etc.) | up to 23 |
| Sponsor Characteristics (prior Tennessee Housing Credit experience; Development Team Track Record) | up to 7 |
| Water & Sewer (availability status) | up to 4 |
| Financial Readiness to Proceed (share of non-equity dollars committed) | up to 4 |
| Design Development (conceptual design completed) | up to 4 |
| Planning & Zoning Process (stage reached) | up to 4 |
| Public Housing Waiting List / Housing Choice Voucher Holder priority | 1 |
| Serving Special Housing Needs OR Serving Populations with Children | 5 |
| Development Intended for Eventual Resident Ownership | 1 |
| Energy Efficiency (ENERGY STAR systems/appliances) | up to 10 |
| Tennessee Growth Policy Act siting | 5 |
| Waiver of the Qualified Contract Process | 9 |
| Extended Recapitalization Waiver | up to 8 |
Rehabilitation of Existing Multifamily Housing (Section 17.B, minimum score 60) uses the same category names but different weights in several places — for example, Location is worth only 2 points and Meeting Housing Needs up to 13 — so a mixed-type application cannot assume identical point values across the two tables.
Several categories are explicitly mutually exclusive with each other: electing the Resident-Ownership point under Section 17.A.11 forfeits eligibility for the Qualified Contract waiver (17.A.14) and the Extended Recapitalization Waiver (17.A.15), and vice versa — an Applicant has to choose one exit-strategy election, not stack all three.
THDA re-derives your score — and cure rights only run one direction
Section 19 is explicit about which direction a discrepancy has to run before an Applicant gets to do anything about it: "If THDA determines that an Initial Application meets all of the eligibility requirements of this QAP and if the score assigned by THDA in each scoring category is the same as or higher than the score assigned by the Applicant..., then no further action by the Applicant or THDA will be taken," and "Applicants shall not submit additional items for the purpose of increasing the score in a particular scoring category" in that situation — "the provisions of the Cure Period do not apply." A Cure Notice issues only when THDA finds an eligibility failure, or when THDA's assigned score in any category is lower than the Applicant's own self-score.
From there, the QAP runs a three-stage escalation: a Cure Period to correct or supply missing items (again, not to chase a higher score than THDA already assigned); if unresolved, a Review Notice and a written Review Appeal request; and, if requested, a Review Meeting before the THDA Board of Directors or its specially appointed body, at which no new documentation may be introduced and any outside contact with the Board between the Review Notice and the Review Meeting is grounds for dismissal. The Board's decision is final, with "no matters with respect to eligibility or scoring...considered after the adjournment of the Review Meeting."
Final ranking then runs in a fixed order: Non-Profit Allocations first, then the Permanent Supportive Housing for Homeless Set-Aside, then the New Construction General Priority Category (ranked within each of six regional housing-needs areas), then Existing Multifamily Housing, then the PHA General Priority Category, with any remaining credit going to the next highest-scoring application statewide regardless of category. A scoring tie among new-construction applications at the award cutoff is broken first by whichever requests the least Housing Credit per unit, then by location wholly inside a QCT covered by a Concerted Community Revitalization Plan.
Where the money actually goes
| Category | Cap |
|---|---|
| Non-Profit Allocations | ≥10% of the Total Credit Ceiling (statutory floor, met through the normal competition) |
| Permanent Supportive Housing for Homeless Set-Aside | up to $1,000,000 |
| Existing Multifamily Housing General Priority Category | no more than $3,600,000 |
| PHA General Priority Category | no more than $3,600,000 |
| New Construction General Priority Category | the balance of the Competitive Total Credit Ceiling after the two $3,600,000 set-asides above, split across six regional housing-needs areas |
| Annual Housing Credit Limit per Initial Application | $1,800,000 |
The six New Construction regional pools (West Tennessee Urban, Middle Tennessee Urban, Southeast Tennessee Urban, East Tennessee Urban, Northeast Tennessee Urban, and Rural/Balance of State) each carry their own cap on the number of developments awarded, from one to two per region.
Development cost and fee limits apply on top of the set-asides: combined developer and consultant fees cannot exceed 15 percent of THDA-determined eligible basis attributable to acquisition, and 15 percent of eligible basis attributable to new construction or rehabilitation — rising to a combined 25 percent of the construction/rehabilitation basis (with contractor profit, overhead, and general requirements folded in) when the developer and contractor are related parties under Section 42(d)(2)(D)(iii). Total contractor fees (profit, overhead, and general requirements together) are capped at 14 percent of site work, accessory buildings, and hard construction or rehabilitation costs. THDA can also award a discretionary Basis Boost of up to 30 percent to any applicant.
Where this goes wrong
- Assuming Tennessee runs multiple 2026 competitive rounds. The 2026 QAP calendar shows exactly one Competitive Cycle — March 20 to April 16, 2026. Anything filed after that deadline is next year's cycle, unless the development instead qualifies for the separate noncompetitive MTBA/bond track.
- Padding a self-score to try to beat THDA's own review. Section 19.A.2 bars submitting additional items to increase a category's score once THDA's assigned score already matches or exceeds the Applicant's self-score in that category — the Cure Period exists to fix a shortfall THDA finds, not to chase a higher number after the fact.
- Using a market study, appraisal, or cost certification from a firm connected to the Development Team. The QAP states THDA will not accept any of those reports, or a physical needs assessment, from a party connected to the Development Team or a Related Party, in THDA's sole discretion.
- Filing supporting documents older than 6 months from the deadline. Section 3.B.1 requires supporting documents to be no more than 6 months old as of the applicable deadline unless the QAP specifically says otherwise — a market study or financing letter drafted early in a long deal cycle can go stale before the April 16 filing.
- Assuming Development Characteristics, Energy Efficiency, and the exit-strategy elections can all be layered without conflict. Several scoring elections are explicitly mutually exclusive — most notably, the Resident-Ownership point (17.A.11), the Qualified Contract Process waiver (17.A.14), and the Extended Recapitalization Waiver (17.A.15) cannot all be claimed on the same application.
- Treating the rehabilitation and new-construction scoring tables as interchangeable. A mixed-type proposal is scored entirely under whichever type has the majority of Low-Income units, and the two tables carry different minimum scores (65 vs. 60) and different point weights for categories that share the same name — Location alone is worth 4 points for new construction but only 2 for rehabilitation.
- Paying the Initial Application fee by check or after the deadline. The QAP requires wire payment only, and states the application "is not complete unless and until the required fee is received by THDA" — a completed THOMAS submission without a cleared wire is not a filed application.
- Assuming a Development Team's eligibility problems are personal to one individual. Major and Minor Significant Adverse Events (Section 5) attach to the whole Development Team as identified in THOMAS, and can make a 2026 Initial Application ineligible — or reduce its Track Record points — based on a team member's history on an unrelated prior Tennessee Housing Credit development.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
