"My underwriting has points scored under the QAP's own 'Additional Financial Support' line, plus a piggyback CDBG-DR loan I keep hearing about from a hurricane recovery program -- is that CDBG-DR money actually still open, does it run through the same LHC application as my 9% or 4% request, and where's Louisiana's own housing trust fund or property-tax break in all of this?"
The QAP's own capital-stack scoring line: Additional Financial Support
Appendix A, Section III.C ('Additional Financial Support') is the QAP's only dedicated treatment of outside gap financing. It awards points based on how much a project's development costs are reduced by 'Philanthropic donations not affiliated with any members of the development team, CDBG or HOME funds not provided by LHC, other governmental assistance/funding in the form of loan, grants, rental assistance or a combination of these forms' -- and the QAP lists specific qualifying mechanisms: waiving water and sewer tap fees, waiving building permit fees, foregoing real property taxes during construction, contributing land for project development, providing below-market-rate construction and/or permanent financing, providing an abatement of real estate taxes, and PHA contributions or other governmental contributions.
| Support as % of total project development cost | Points |
|---|---|
| 7% or more | 4 |
| 4% but less than 7% | 3 |
| 2% but less than 4% | 2 |
Only one selection is allowed. The QAP requires the funds be actual 'awarded funds' evidenced by a signed commitment, with supporting documentation and calculations included in the application. Unlike some states' favorable-financing tables, Louisiana's QAP does not award different point values for different source types (a CDBG grant, a fee waiver, and a philanthropic donation all count the same way toward the same percentage threshold), and does not state loan terms (interest rate, amortization, or recourse) for any of the listed sources -- those terms would come from whichever agency actually originates the money, not from the QAP.
Because this is the only place in the QAP where outside financing is scored, a developer assembling a Louisiana capital stack should not expect the QAP text itself to describe how to actually obtain any of HOME, NHTF, CDBG, or a tax abatement -- it only tells you how many points you get for having already obtained one. The actual programs live elsewhere, described below.
HOME and the National Housing Trust Fund: LHC administers both, but neither runs through the QAP
Louisiana Housing Corporation is the state's own HOME Investment Partnerships Program participating jurisdiction and its National Housing Trust Fund (NHTF) State Designated Entity -- LHC's own program materials confirm both roles directly, distributing HOME funds 'through a Notice of Funding Availability' on a non-competitive basis to experienced nonprofit developers. In practice this happens through two small, rolling programs rather than one competitive round: the Nonprofit Open Cycle Affordable Housing Program (NOAH), which funds up to six single-family homeownership units or up to four multifamily rental units per project on a first-come, first-served basis with rents capped at 30% of the adjusted income of a household at 65% AMI (using HOME rent limits); and the Small Project Continuation Program, a $4,000,000 HOME-funded pool capped at $1,000,000 per award, again rolling, prioritizing environmental clearance, preservation of existing housing, 30%-AMI-or-below households, and elderly-serving designs. A separate program, CHAAP (the CHDO Annual Awards Program), reserves 25% of LHC's HOME allocation specifically for state-certified CHDO projects and CHDO operating-cost assistance -- notably above the 15% CHDO set-aside HOME itself requires as a federal floor.
None of this research found a large-scale, competitively sized HOME gap-loan product comparable to what some other states run for a typical 40-to-100-unit 9% LIHTC deal. NOAH's four-unit rental cap and the Small Project Continuation Program's $1,000,000 per-award ceiling both look sized for small nonprofit-sponsored projects, not a project competing in LHC's Urban or Rural 9% pools. A developer assembling a stack for a standard-sized competitive LIHTC deal should confirm directly with LHC's Housing Development division whether a larger HOME allocation is reachable outside these two named programs -- this research could not confirm one exists.
The National Housing Trust Fund is administered the same way: LHC's own NHTF program page describes 'deeper income targeting, lower rent requirements, and a longer minimum affordability period' than HOME, serving extremely low-income and disabled households (including those receiving Title XIX/Medicaid long-term services and supports), operated in connection with the Louisiana Housing Authority and LHC's Permanent Supportive Housing partnership with the Louisiana Department of Health. LHC's own page did not state a specific dollar allocation, eligible-activity list, or application process distinct from the HOME programs above -- this research flags that gap explicitly rather than assuming NHTF in Louisiana works identically to HOME.
Importantly, this research found no evidence of a distinct, state-funded Louisiana Housing Trust Fund separate from the federal NHTF. LHC's own website groups its NHTF materials under a page titled simply 'Housing Trust Fund,' and every description of that program traces back to the federal National Housing Trust Fund statute, not a state appropriation. A developer who hears 'Louisiana's housing trust fund' should assume that means the federal NHTF program LHC administers, not a separate state gap-financing pool -- this research could not find one.
CDBG-DR is live, but it is tied to a specific 2020-2021 storm cycle, not Katrina
Louisiana's 'Piggyback' program lets a developer layer Community Development Block Grant Disaster Recovery (CDBG-DR) funds -- structured as a soft, subordinate mortgage -- underneath a 4% LIHTC deal financed with LHC's own tax-exempt multifamily revenue bonds. The program originated after the August 2016 floods and has run through several iterations since; the most recent, the 2025 Piggyback Resilience Initiative -- Mixed-Income (PRIME-4), is administered by LHC in partnership with the Louisiana Office of Community Development's Disaster Recovery Unit (OCD-DR).
PRIME-4 makes $20,000,000 in CDBG-DR funds available, HUD-allocated specifically for recovery from Hurricane Ida and the May 2021 severe storms/floods and from Hurricanes Laura and Delta in 2020 -- not from Hurricane Katrina (2005). This research found no evidence of an active Katrina-era (Road Home-cycle) CDBG-DR gap-financing program still open to new LIHTC applications; the currently live funding line is tied specifically to the 2020-2021 disaster declarations. The $20,000,000 splits into two geographic set-asides: $10,000,000 for the 21 parishes HUD identified as most-impacted-and-distressed from the Ida/May Floods disasters (FEMA Disasters 4611 and 4606), and $10,000,000 for the 15 parishes tied to the Laura/Delta disasters (FEMA Disasters 4559 and 4570).
| Set-aside | Eligible parishes |
|---|---|
| Ida / May Floods (21 parishes) | Ascension, Assumption, Calcasieu, East Baton Rouge, Iberville (ZIP 70764/70788 only), Jefferson, Lafourche, Livingston, Orleans, Plaquemines, St. Bernard, St. Charles, St. Helena, St. James, St. John the Baptist, St. Mary, St. Tammany, Tangipahoa, Terrebonne, Washington, West Baton Rouge (ZIP 70767 only) |
| Laura / Delta (15 parishes) | Acadia (ZIP 70526/70578 only), Allen, Beauregard, Caddo, Calcasieu, Cameron, Jefferson Davis, Lafayette, Natchitoches, Ouachita, Rapides, St. Landry (ZIP 70570 only), St. Martin (ZIP 70517 only), Vermilion (ZIP 70510 only), Vernon |
Several parishes are eligible only within named ZIP codes, not parish-wide (Iberville, West Baton Rouge, Acadia, St. Landry, St. Martin, Vermilion) -- a project elsewhere in an otherwise-eligible parish does not qualify. Calcasieu appears in both set-asides.
PRIME-4 only pairs with 4% credits: applications 'must combine CDBG-DR with 4% LIHTCs and bond-financed mortgage proceeds' issued through LHC's own tax-exempt Multifamily Revenue Bonds under IRC Section 42(h)(4) -- it is not available to a 9% competitive award. Borrowers must be single-asset LIHTC entities (for-profit LPs or LLCs, though the GP/managing member may be nonprofit or a PHA). A project must also independently clear the QAP's own 40-point Selection Criteria minimum score to qualify for CDBG-DR funding under this NOFA, even though the 4% credit itself is not competitively scored for allocation purposes -- an overlap worth flagging in Phase 8's discussion of the 4%/bond process.
PRIME-4's own application window has already closed as of this research: published December 5, 2025, application deadline May 25, 2026, awards published by August 12, 2026. A developer reading this after that date should check LHC's Piggyback Program page directly for a successor NOFA (a PRIME-5 or similar) rather than assume this specific round is still accepting applications -- the dates above describe the most recently completed round's structure, useful for understanding how the program is built, not a currently open call.
Louisiana's state historic rehabilitation tax credit: real and current, but a different agency and lower QAP points
Louisiana's State Commercial Tax Credit, codified at La. R.S. 47:6019, is administered by the Division of Historic Preservation within the Louisiana Department of Culture, Recreation and Tourism -- not by LHC. It provides a credit against Louisiana income and franchise tax for rehabilitating income-producing historic buildings, following the same three-part process (Part 1 certification of contributing status, Part 2 proposed work description, Part 3 project certification) used for the parallel federal historic credit, requiring compliance with the Secretary of the Interior's Standards for Rehabilitation.
| Parameter | Value |
|---|---|
| Base credit rate | 25% of eligible rehabilitation costs incurred on or after January 1, 2023 |
| Rural enhancement rate | 35% of eligible rehabilitation costs incurred on or after January 1, 2023 and before January 1, 2029, in qualifying rural areas (parishes under 100,000 population, municipalities under 35,000, or qualifying unincorporated areas) |
| Minimum project size | Costs and expenses must exceed $10,000 |
| Annual statewide cap, 2021-2024 applications | $125,000,000 |
| Annual statewide cap, applications received on/after 1/1/2025 | $85,000,000 |
| Sunset | No credit is authorized for expenses incurred on or after January 1, 2029 |
This table is drawn from the Division of Historic Preservation's own program pages and a codification service (FindLaw), not a direct read of the Louisiana Legislature's own official statute text at legis.la.gov -- the underlying figures were consistent across independent sources, but the exact statutory phrasing was not independently confirmed against the primary legislative portal.
The LIHTC QAP itself cross-references this credit but treats it narrowly: Section IV.A.14 requires an approved Part I from the Division of Historic Preservation at application (Part II due at carryover) for any project claiming historic rehabilitation status, and the QAP's resiliency-elevation rules carve out an exception for historic buildings -- if a historic structure would lose its designation by being elevated to meet the flood-elevation threshold, it may remain unelevated provided the historic designation is documented as preserved. Notably, Appendix A's own Selection Criteria score historic preservation lower than generic rehabilitation: 'Preservation of Residential Historic Property' earns only 3 points, versus 7-8 points for 'Existing non-historic Residential Building' or other Existing LIHTC/USDA/federally funded rehab categories in the same Rehabilitation & Preservation subsection -- a developer assuming historic status is a scoring advantage in Louisiana should check this table before counting on it.
Property tax: no dedicated LIHTC exemption, a general housing-authority statute, and a PILOT idea voters rejected
Louisiana has no property-tax exemption program written specifically for LIHTC housing. What exists instead is a general housing-authority exemption, a narrow statewide PILOT mechanism that does not reach residential rental property, and a failed 2019 attempt to create one for New Orleans specifically.
La. R.S. 40:490 exempts a statutorily defined 'housing authority' and its 'housing project' property from parish and municipal ad valorem taxes and other local taxes, while allowing the municipality or parish to negotiate a payment in lieu of taxes with the authority instead -- and separately requires a housing authority in East Baton Rouge Parish specifically to make PILOT payments to local school districts. A related statute, La. R.S. 40:454, authorizes a housing authority to partner with private entities -- accepting private financing, entering contractual arrangements to acquire, manage, or operate housing developments including mixed-income developments -- but this research could not confirm whether Louisiana case law or an Attorney General opinion extends the R.S. 40:490 tax exemption to a privately owned LIHTC limited partnership that merely partners with a housing authority (as opposed to property actually titled to or held by the authority itself). That is an open question worth raising with LHC or local counsel before assuming a housing-authority partnership converts a private deal into a tax-exempt one.
Separately, Louisiana's constitutional cooperative-endeavor-agreement ad valorem exemption (added via a 2020 statewide constitutional amendment) lets a property owner and a taxing authority agree to payments in lieu of ad valorem taxes -- but that mechanism is restricted by its own terms to new manufacturing establishments or additions to existing manufacturing establishments. It does not reach residential rental housing, and this research found no indication LIHTC developments qualify.
A more targeted attempt failed outright: Louisiana Amendment 4 (proposed by Act 448/SB 79, submitted to voters on the October 12, 2019 statewide ballot) would have authorized the City of New Orleans to grant ad valorem tax exemptions to properties of fifteen units or fewer in Orleans Parish specifically to promote affordable housing. Voters rejected it, 442,998 in favor (36.51%) to 770,395 against (63.49%). No comparable New Orleans-specific affordable-housing property-tax exemption exists today as a result.
What remains, in practice, is whatever a developer can negotiate locally -- exactly the pattern the QAP's own Additional Financial Support scoring line anticipates by listing 'foregoing real property taxes during construction' and 'an abatement of real estate taxes' as financing sources a project can claim points for if actually obtained. Louisiana has no defined statutory term or standing state program for this the way some other states' housing-authority statutes do; it is a case-by-case local negotiation, scored if it happens, but not administered or guaranteed by any state agency.
Where this goes wrong
- Assuming the CDBG-DR 'Piggyback' program is a permanent LHC product rather than a series of time-limited NOFAs (PRIME-2, PRIME-3, PRIME-4) tied to specific declared disasters, each with its own funding pool, eligible-parish list, and closing date.
- Assuming Piggyback/PRIME funds pair with 9% competitive credits. PRIME-4 explicitly requires pairing with 4% credits financed through LHC's own tax-exempt bonds, not the competitive 9% pool.
- Treating Hurricane Katrina-era CDBG-DR (Road Home-cycle) funding as still open for new LIHTC gap financing. This research found no evidence of an active Katrina-cycle program; the currently live funding line (PRIME-4) is tied instead to the 2020-2021 disaster cycle (Hurricanes Laura, Delta, Ida, and the May 2021 floods).
- Assuming a project anywhere in one of the 21 Ida/May Floods or 15 Laura/Delta parishes qualifies. Several of those parishes are limited to specific ZIP codes (e.g., Iberville only 70764/70788; West Baton Rouge only 70767; Acadia only 70526/70578), not the full parish.
- Assuming PRIME-4's May 25, 2026 application deadline and August 12, 2026 award date are still open. Both had already passed as of this research (September 2026); confirm with LHC's Piggyback Program page whether a successor NOFA has since been published before assuming CDBG-DR gap funding is currently reachable.
- Assuming 'Housing Trust Fund' on LHC's website refers to a Louisiana-specific state trust fund. This research found only the federal National Housing Trust Fund (NHTF), which LHC administers as the state's designated entity -- no distinct, state-appropriated trust fund program was found.
- Assuming HOME and NHTF funds are awarded through the same competitive LIHTC application process as the QAP. LHC administers both through separate, largely rolling, non-competitive programs (NOAH, Small Project Continuation Program, CHAAP) sized for small projects -- NOAH's rental cap is four units per project -- not through the QAP's 9% or 4% process.
- Assuming Louisiana's state historic rehabilitation tax credit is administered by LHC. It is administered by the Division of Historic Preservation within the Louisiana Department of Culture, Recreation and Tourism, a separate state agency, and the QAP's own Selection Criteria award fewer points (3) for historic preservation of a residential building than for plain non-historic rehabilitation (7-8 points).
- Relying on a $125 million annual cap for the state historic tax credit. That cap fell to $85 million annually for applications received on or after January 1, 2025.
- Assuming Louisiana has a workable statewide PILOT or property-tax-exemption mechanism for LIHTC housing. The state's 2020 cooperative-endeavor ad valorem exemption is restricted to manufacturing property, and a 2019 ballot measure that would have created one for small affordable-housing properties in New Orleans failed at the polls by a nearly two-to-one margin.
- Assuming La. R.S. 40:490's housing-authority property-tax exemption automatically extends to a privately owned LIHTC limited partnership that merely partners with a housing authority under La. R.S. 40:454. This research could not confirm that extension and flags it as an open question rather than assuming it works.
- Treating the QAP's 'Additional Financial Support' scoring category as a defined loan product with stated terms. It is a generic percentage-of-cost point scale (2/3/4 points) that lumps CDBG, HOME, philanthropic donations, fee waivers, and tax abatements together with no per-source differentiation or LHC-stated financing terms.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies