Scored in the QAP, funded outside it: Georgia's capital stack — Georgia

Favorable Financing: the QAP's own scored list of gap sources, and the one it quietly excludes from itself

Scoring Criteria Section IV, "Favorable Financing," is worth up to 5 points and is the QAP's most direct treatment of the capital stack. Subsection A lists eleven "Qualifying Sources for Favorable Financing": Federal Home Loan Bank Affordable Housing Program (AHP) funds; Replacement Housing Factor (RHF) or other HUD public housing improvement funds; HOME funds; HOME-ARP funds; Beltline Grant/Loan; historic tax credit proceeds; Community Development Block Grant (CDBG) program funds; Special Purpose Local Option Sales Tax (SPLOST) funds; National Housing Trust Fund (NHTF) funds; qualifying foundation grants or loans; and "other Federal, State, or Local Government grant funds or loans" (excluding anything originated by a conventional bank). Every dollar claimed must be binding and unconditional, actually utilized if awarded, and — for loans — carry a minimum ten-year term at or below the long-term monthly Applicable Federal Rate.

The QAP is explicit, in the same breath, that scoring these sources is not the same as DCA administering them: "When paired with the Housing Credit program, DCA administers HUD funding such as HOME through Notices of Funding Availability (NOFAs) outside of the competitive review processes detailed in the QAP" (Exhibits to Threshold Criteria, §B). In other words, an Applicant claims Favorable Financing points on the strength of a HOME commitment, but wins the HOME dollars themselves through a separate DCA NOFA process this QAP does not describe in detail.

The fine print DCA does spell out: HOME (and TCAP) loan terms, once you actually have one

Georgia's QAP defines "TCAP" narrowly as "program income from the Tax Credit Assistance Program" — recycled repayments from the original 2009 ARRA-era program, not a live federal funding line. Both HOME and this recycled TCAP income function as direct GHFA loan products layered onto Housing Credit deals, and Exhibits to Threshold Criteria §B ("Additional DCA Policies Related to the Funding of DCA HOME Loans") lays out the servicing terms in real detail, even though the award itself happens outside the QAP's competitive process.

HOME Loan proceeds are restricted to construction hard costs, General Requirements (excluding payment/performance bonds), Builder's Overhead, and Builder's Profit; other sources must cover soft costs and acquisition unless DCA expressly approves otherwise. Rural deals can use a non-fully-amortizing balloon structure with an excess-cash-flow reserve that sweeps half of post-debt-service cash flow annually toward principal reduction. None of this loan-servicing detail is stated for the other ten Favorable Financing categories (Beltline, SPLOST, foundation grants, etc.) — the QAP's underwriting specificity is concentrated on the DCA-originated HOME/TCAP product, not the broader list of qualifying sources.

Property tax relief: a local housing-authority tool, not a DCA program

Scoring Criteria §IV.B, "Property Cost Reduction," awards one point if "a Private Enterprise Agreement will reduce property taxes," documented at Competitive Application with a preliminary agreement and a legal opinion confirming the relevant authority may lawfully engage in the agreement and that it will in fact reduce property taxes. The QAP does not define what a Private Enterprise Agreement is or cap its size — it only scores the fact that one exists.

The mechanism itself lives in Georgia's Housing Authorities Law, not the QAP: O.C.G.A. § 8-3-8 exempts housing authority property from ad valorem taxes as "public property used for essential public and governmental purposes," and — per O.C.G.A. § 8-3-3(13.1)(C), which this research could not independently verify in full verbatim text due to access restrictions on Georgia's official annotated code — extends that exemption to units under a qualifying Private Enterprise Agreement with a for-profit entity, limited to units occupied or reserved for persons of low income. In lieu of taxes, the statute allows the authority to negotiate payments to the city or county capped at the estimated cost of services actually provided. This is a tool any local housing authority in Georgia can use, not a DCA-administered program; DCA's role begins and ends at the one scoring point.

Atlanta is the only well-documented statewide example: the Atlanta Urban Development Corporation (AUDC), created in 2023, uses the Private Enterprise Agreement mechanism to offer negotiable-length tax exemptions (commonly tied to a 20-year-or-longer affordability term) to projects reserving at least 20% of units at 50% AMI, 10% at 80% AMI, and the remainder at 140% AMI or below, structured as a ground lease under which AUDC holds title. This is a local Atlanta program, not evidence of a statewide DCA product — an Applicant elsewhere in Georgia would need to negotiate a comparable agreement directly with their own local housing authority, and this research found no indication that most Georgia jurisdictions currently offer one.

Bond financing: local issuers, DCA's own aggregate-basis ceiling, and a federal test that just got easier

The QAP does not restrict who may serve as the tax-exempt bond "issuing authority" for a 4% Credits/Bonds deal — Threshold Criteria requires only a bond inducement resolution from that issuing authority at Threshold Submission (moved there from Competitive Application in the drafting process, with Readiness to Proceed points now available for having it early). Local development authorities (O.C.G.A. Title 36, Ch. 62), housing authorities (O.C.G.A. Title 8, Ch. 3), and urban residential finance authorities (O.C.G.A. Title 36, Ch. 82, Art. 8) are the general categories of Georgia public bodies empowered to issue this kind of housing bond; the QAP itself references only the last of these by name.

One such issuer gets a defined carve-out: the QAP states that "DCA will set aside sufficient bonds to comply with GA Code § 36-82-190 which reserves a percentage of bonds for urban residential finance authorities," calling this set-aside the "Urban Housing Reservation" (Core Plan §V.B.3.i). The local urban residential finance authority — in practice, Atlanta's — determines its own awards under that reservation, and (per the August 2026 amendment) Applications selected under it are excluded from DCA's own geographic-balancing and New-Affordability/Preservation math entirely.

On sizing: DCA caps its own bond deals at "no more than 30% of a development's aggregate basis" financed by tax-exempt bonds (Exhibits to Threshold Criteria §A.19.b) — a DCA volume-cap-conservation policy, not the federal minimum-financing test. That federal test itself changed materially and recently: the One Big Beautiful Bill Act (Pub. L. 119-21) permanently lowered the long-standing 50%-of-aggregate-basis bond-financing threshold under IRC §42(h)(4)(B) to 25%, for bonds issued after December 31, 2025 (subject to a minimum 5%-of-basis-financed-after-that-date condition). DCA's own 30% ceiling sits comfortably above that new 25% federal floor, meaning a Georgia deal has room to use less bond volume than the federal minimum required under the old rule while still qualifying for 4% credits — but this QAP text does not itself restate the federal 25% test, so the interaction should be confirmed against DCA's separate underwriting guidance rather than assumed from the 30% figure alone.

What sits outside the capital stack entirely — and a brand-new statewide credit ceiling

Georgia's State Housing Trust Fund for the Homeless (SHTF), established via a 1988 constitutional amendment and administered by DCA, never appears anywhere in the 2026-2027 QAP's text. Its FY2025 funding (approximately $4.6 million, per DCA's own public materials) supports homeless services, non-congregate shelter, and permanent housing opportunities through programs like Georgia Rehoused — a genuinely separate DCA mission from competitive Housing Credit rental production, the same way Missouri's and other states' homeless trust funds sit outside their LIHTC programs. This research could not independently verify SHTF's precise enabling statute section (secondary sources point to O.C.G.A. § 8-3-3 et seq., but exact section boundaries were not confirmed against primary text).

A distinct new constraint on the whole capital stack arrived via this QAP's own August 2026 amendment memorandum: House Bill 1199 "amended O.C.G.A. § 48-7-29.6 to limit the aggregate annual amount of 9% and 4% Georgia Housing Tax Credits awarded to no more than $100 million per year for taxable years 2026 through 2028." That is Georgia's own State Credit — defined in the QAP as "the Housing Tax Credit as set forth in O.C.G.A. §48-7-29 and §33-1-18" — not the federal 9%/4% credit ceiling, but it is the same State Credit equity that gets layered into Georgia deals' capital stacks, and its new statewide annual cap is the direct cause of the amendment's Atlanta/geographic-distribution restrictions (see Phase 8).