"Is the property-tax line in this pro forma using the pre-existing nonprofit exemption or the 2023 Live Local 'Missing Middle' exemption — because they have different owners, different percentages, and different unit-count floors?"
SAIL and HOME ride FHFC's RFA machinery; SHIP is the entitlement layer underneath it
Florida's State Apartment Incentive Loan program is FHFC's own primary gap-financing tool, awarded through the same competitive RFA machinery discussed in Phase 4. This session could not independently confirm a reliable total or demographic/county-size breakdown for the current SAIL/4%/bond RFA's anticipated funding — a figure this session previously assumed (≈$139.6 million) does not check out against Florida's total statewide FY2026-27 SAIL appropriation (≈$70.8 million, per the state budget), so pull the actual issued RFA's stated funding amount directly rather than relying on any total quoted here. Federal HOME funds flow through the same RFA machinery in some cycles, paired with Live Local SAIL for specific goals such as Rural Areas of Opportunity. Underneath both sits the State Housing Initiatives Partnership (SHIP) program, created by the 1992 William E. Sadowski Affordable Housing Act and funded by documentary stamp tax revenue — distributed on an entitlement basis to all 67 counties and 52 CDBG entitlement cities for local gap financing, impact-fee assistance, and construction financing. SHIP is not competitive at the state level; where competition exists, it's inside each local government's own local housing assistance plan.
Two real, distinct property-tax exemptions — do not conflate them
| §196.1978(1) — the longstanding exemption | §196.1978(3) — the 2023 "Missing Middle" exemption | |
|---|---|---|
| Who qualifies | 501(c)(3) nonprofit owner, recorded LURA | For-profit sponsors eligible too |
| Exemption amount | Set by the nonprofit-ownership statute's own terms | 100% of assessed value for units ≤80% AMI; 75% for units 80–120% AMI |
| Unit-count floor | None stated | More than 70 units (more than 10 in an Area of Critical State Concern) |
| Duration | Tied to the recorded LURA | First applies to the 2024 tax roll; sunsets December 31, 2059 |
| Local opt-out | N/A | A local taxing authority may opt out only of the 75% (80–120% AMI) tier, by a two-thirds ordinance vote, and only where a Shimberg Center report shows the county's affordable-unit supply already exceeds demand in that band |
Large-county local surtax layers
Some of Florida's largest counties layer a dedicated local gap source on top of SHIP. Miami-Dade's Documentary Surtax (Affordable Housing Surtax) Program has funded more than 15,000 affordable multifamily units and is administered jointly with SHIP and HOME through the county's own combined RFA — a real, easy-to-miss source if a capital stack is modeled only against the state-level RFA menu.
Where this goes wrong
- Applying the §196.1978(1) nonprofit exemption's terms to a for-profit sponsor's deal — the for-profit path is a separate subsection (§196.1978(3)) with different percentage tiers and a real unit-count floor.
- Missing the >70-unit threshold (or >10 in an Area of Critical State Concern) for the Missing Middle exemption — smaller deals don't qualify under that subsection at all.
- Assuming the Missing Middle exemption runs for the life of the deal — it sunsets December 31, 2059, by its own statutory text; a deal placed in service late in the exemption's life needs its long-term pro forma to model the exemption's actual remaining term.
- Assuming a local taxing authority can opt entirely out of the Missing Middle exemption — it can opt out only of the 75% (80–120% AMI) tier, only by a two-thirds ordinance vote, and only where a Shimberg Center report supports it.
- Treating SHIP as a competitive state program — it's distributed on an entitlement basis to all 67 counties and 52 CDBG entitlement cities; any competition happens inside each local government's own allocation plan.
- Not checking whether the target county runs its own dedicated local gap program on top of SHIP (e.g., Miami-Dade's Documentary Surtax) — a real source easy to miss modeling only the state-level RFA menu.
- Confusing SAIL (Florida's own state gap loan program) with HOME (federal) — both can ride the same RFA in a given cycle but are legally and administratively distinct sources with different compliance regimes.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies