One agency runs the soft money too — except the trust fund nobody ever funded — Idaho

HOME and the federal Housing Trust Fund: one agency, two programs, a NOFA calendar the QAP barely mentions

IHFA is not a pass-through to some separate state housing finance agency for soft money — it is the designated administrator of Idaho's HOME Investment Partnerships Program and, separately, of the federal (“National”) Housing Trust Fund (HTF) for the state. IHFA's own program materials describe HOME funds as awarded “as gap financing to qualified Idaho housing developers to acquire, construct, or rehabilitate affordable rental housing throughout the state,” and describe HTF, targeted at households earning 0–30% of Area Median Income, as a program whose “rules and administrative requirements will closely follow the HOME Program” — both run through IHFA's own HOME Programs Department, not a separate agency.

These funds are awarded through a periodic, competitively scored NOFA process entirely separate from the LIHTC QAP's own application. The 2024 Fall Funding Round NOFA, for example, announced approximately $7 million in HOME funds and $1.7 million in HTF funds for multifamily rental development, with applications due electronically no later than 5:00 p.m. on August 2, 2024 — the identical deadline as that year's LIHTC competitive round, though this research found no QAP or program text guaranteeing the two deadlines will always coincide in future years. That NOFA also states an explicit capacity prerequisite: the owner “must be a non-profit housing development organization, a private rental housing development entity, or a unit of local government with previous experience financing, developing and managing federally-funded multifamily rental housing projects” — and commitment of funds is “contingent on IHFA receiving the [current] annual program allocations from HUD,” meaning the dollar figures reset with each federal appropriation rather than repeating automatically.

The LIHTC QAP's only acknowledgment of this parallel process is a single note in Section 3.1: “If concurrent HOME Investment Program funds or Housing Trust Funds (HTF) are also being requested, a pre-development meeting with the Association's HOME Program Department is required prior to applying.” The QAP does not restate HOME or HTF loan terms, underwriting standards, or scoring anywhere in its own text — a Sponsor layering either source onto a Housing Credit deal is effectively running two separate applications, on two separate timelines, through two functions of the same agency.

A second “Housing Trust Fund” — created by statute in 1992, apparently never funded

Idaho Code Title 67, Chapter 81 establishes a wholly separate “Idaho Housing Trust Fund,” defined in §67-8102 as “the moneys transmitted to the association by state, federal, local or private sources,” with IHFA (the statute's “association”) serving as trustee. §67-8103 requires that at least 75% of the fund's resources assist very low-income households and lists eligible uses — new construction, rehabilitation, or acquisition of housing units, rent subsidies, mortgage assistance, homeless shelters, and related services. §67-8104 lists eligible recipients (local governments, housing authorities, nonprofit community and statewide housing organizations, and for-profit developers), and §67-8106 establishes a seven-member, governor-appointed Housing Trust Fund Advisory Commission required to “review and approve annually an allocation plan and a proposed budget” and hold public hearings before doing so.

None of this machinery appears to have ever operated. Reporting published July 23, 2021 (Idaho Capital Sun, republished by East Idaho News) states that Idaho created this fund in 1992 under Governor Cecil Andrus, modeled on funds then operating in 46 other states, but that the legislature never enacted a dedicated revenue source for it: an early proposal to fund it from interest on real estate broker trust accounts (roughly $150,000 per year) failed to gain legislative support, a later real estate transfer tax proposal was opposed by the Idaho Association of Realtors, and the 1994 elections (in which Idaho Senate Democrats fell from 17 to 8 seats) made new dedicated taxes politically unworkable afterward. IHFA's own president was quoted in that reporting: “At the end of the day, they didn't have the legislative support to get a particular bill through with a specific funding source.” As of that 2021 reporting, the fund had never received a state appropriation and its Advisory Commission had never been formed.

This research found no more recent reporting or IHFA materials confirming whether that status has changed. A developer should not assume the Idaho Housing Trust Fund is a live, disbursing gap-financing source based on the statute's continued presence in the Idaho Code — nor should this research's 2021-vintage confirmation of its dormancy be treated as certainly still current five years later. Either way, current funding status should be confirmed directly with IHFA rather than assumed from either direction.

No Idaho state historic tax credit — the QAP's “historic” point is the federal 20% credit

Selection Criteria item 15 of the QAP awards 1 point to “Developments that utilize Historic Rehabilitation Tax Credits as a funding source,” conditioned on a National Park Service certification that the building is “a certified historic structure (one listed on the National Register of Historic Places or located in a Registered Historic District and determined to be of significance to the Historic District) as defined by IRC Section 47(c)(3)(A),” with the point itself “conditioned upon receipt of written confirmation from the National Park Service that the proposed development meets the Department of Interior's rehabilitation standards.” That IRC citation identifies this as the federal Rehabilitation Tax Credit — a 20% federal income tax credit for certified rehabilitation of income-producing historic buildings, jointly administered by the IRS, the National Park Service, and each state's State Historic Preservation Office (SHPO). This research found no separate Idaho state historic rehabilitation tax credit.

Idaho's SHPO function is carried out by the Idaho State Historical Society, whose own materials describe its role as being “the liaison between you (the applicant) and NPS, providing information and assistance throughout the application process” for the federal credit — an administrative and advisory role, not a source of additional state tax credit dollars. The Historical Society reports that since 1981, 65 Idaho projects have used the federal credit, injecting over $75 million into the state's economy — a track record of the federal program's use in Idaho, not evidence of a distinct state incentive. A Sponsor modeling a “historic tax credit” line in an Idaho capital stack should size it as 20% federal credit proceeds only, subject to that IRS/NPS/SHPO certification process, not as a separate Idaho program.

Property tax: no PILOT program — a mandatory valuation formula instead, and an exemption that starts only after the tax credits end

Idaho has no payment-in-lieu-of-taxes (PILOT) program and no blanket property-tax exemption for LIHTC-financed developments. What exists instead is Idaho Code §63-205A, “Assessment — Market Value for Assessment Purposes of Section 42 Low-Income Properties” (added 2009, amended 2013) — a statute that does not exempt anything, but instead dictates how a county assessor must value a Section 42 property in the first place. It requires the assessor to reconcile three approaches: a sales-comparison approach using “similar rent restricted properties,” a cost approach that must include “an economic obsolescence factor associated with the income and rent restrictions” in the development's tax credit regulatory agreement with IHFA, and an income approach in which “net operating income to be capitalized … shall not include the amount of housing tax credits.” Owners must submit financial statements to the assessor annually by April 1, and the statute directs the Idaho State Tax Commission to gather comparable capitalization-rate data from other Section 42 property sales statewide to support that income approach.

This is a real, generally-applicable protection — it keeps an assessor from valuing a rent-restricted property as though it could charge market rents — but it is a mandated valuation formula that applies automatically to every Section 42 property, not a discretionary exemption, reduction, or negotiated in-lieu payment the way a PILOT is in states that offer one.

A separate statute, Idaho Code §63-602GG, does grant a full property-tax exemption for “low-income housing owned by nonprofit organizations,” conditioned on the nonprofit being organized under Idaho Code chapter 30, holding a 501(c)(3) exemption, and dedicating units as follows: “Fifty-five percent (55%) of the units shall be rented to those earning sixty percent (60%) or less of the median income for the county in which the housing is located; twenty percent (20%) of the units shall be rented to those earning fifty percent (50%) or less of the median income of the county in which the housing is located; and twenty-five percent (25%) of the units shall be rented to those earning thirty percent (30%) or less of the median income for the county in which the housing is located” (§63-602GG(3)(c)). But this exemption carries an explicit carve-out for LIHTC deals: it does not apply “to any property used by a taxpayer to qualify for tax credits under the provisions of 26 U.S.C. chapter 42 or any successor programs until such time as the property is solely owned by a nonprofit organization as defined in this section and is no longer utilized to receive federal tax credits” (§63-602GG(4)(c)).

In practice, that exclusion means a conventional LIHTC ownership structure — a general partner (nonprofit or for-profit) alongside a tax-credit-investor limited partner — cannot claim this exemption during the compliance or extended-use period. It becomes available only if and when a nonprofit acquires full, sole ownership after the property is no longer claiming federal tax credits, for example following a qualified-nonprofit right-of-first-refusal exit at the end of the compliance period (the same ROFR mechanism the QAP requires for its 10% nonprofit set-aside, Section 5.1). Treat this exemption as a possible post-compliance-period benefit, not a day-one capital-stack source.

Bonds: the QAP already runs on the post-OBBBA 25% test, but volume-cap mechanics live in a separate policy document

Section 11.1 governs 4% deals: “developments with 25% or more of its aggregate basis of buildings and land financed with tax-exempt bonds may receive a maximum 30% present value LIHTC (4% LIHTC) calculated against the development's qualified basis without causing a reduction in the state's annual credit ceiling.” Idaho's current (April 30, 2026 Board-approved, May 18, 2026 Governor-approved) QAP already states this 25% figure rather than the older 50% threshold. The One Big Beautiful Bill Act (Pub. L. 119-21) permanently lowered the aggregate-basis bond-financing test under IRC §42(h)(4)(B) from 50% to 25%, for bonds issued after December 31, 2025 (subject to a minimum 5%-of-basis-financed-after-that-date condition) — Idaho's QAP figure aligns with that change, though the QAP's own text does not cite OBBBA or explain why the number is 25% rather than 50%. Confirm with IHFA whether this is meant to track the federal minimum precisely as it may change again, rather than a fixed Idaho-specific policy number.

Volume-cap allocation itself is governed by a document the QAP references but does not reproduce: “the Idaho Housing and Finance Association's Statement of Policy and Rules Concerning Issuance of Bonds for Multifamily Housing Projects” (QAP §11.1, citing that policy's own Exhibit A). This research did not independently obtain that policy document, so bond-issuer eligibility, volume-cap allocation mechanics, and any Idaho-specific bond-sizing rules beyond the 25%/30% figures stated in the QAP itself should be confirmed directly against that separate policy rather than assumed from the QAP alone.

Unlike the 9% competitive track, 4% Conditional Commitment applications run year-round (January 1 through October 31) and are evaluated under the same QAP threshold and Selection Criteria standards without competing in the annual round — unless another development is proposed for tax-exempt bond financing in the same market area at the same time, in which case IHFA will award both only if market studies show sufficient demand for all proposed developments, or will award to the higher-scoring development if not (§11.2; see Phase 8 for the full application-track comparison).