One agency, four HUD grants, no property tax to exempt: CNMI's capital stack — Northern Mariana Islands

NMHC is the entire federal pipeline -- CDBG, HOME, ESG, and HTF, all under one roof

NMHC's own HUD Consolidated Plan states its role in one sentence: "NMHC is the Grantee of these HUD funds. NMHC administers CDBG, HOME, ESG, and HTF programs on behalf of the CNMI" (Amended NMHC Consolidated Plan PY2025-PY2029 and PY2025 Annual Action Plan, p.16-17). That is the same agency, the same Garapan office, and in practice several of the same staff who run the LIHTC program under this QAP. For PY2025, NMHC's combined CDBG, HOME, and ESG budget totaled $1,469,058.00, of which $407,723.00 was HOME funding specifically -- split between a $346,564.55 Rehabilitation/Homebuyer New Construction Program line and $61,158.45 for HOME Administration.

The National Housing Trust Fund (HTF) runs on the same grantee relationship but at a scale that cannot function as multifamily gap financing: NMHC's own RFP for the HTF program (dated June 3, 2026) reports Program Year 2021 through 2024 allocations of $17,893.88, $4,575.99, $5,000.00, and $19,268.89 -- a four-year cumulative total of $46,535.80 -- solicited for "the acquisition and/or rehabilitation of a housing unit to convert into a rental unit" for a household at 30% AMI or less, on a first-come, first-served basis. That is consistent with the national pattern for insular-area HTF allocations, which are formula-driven off each insular area's share of national renter households and have historically been small enough that insular areas have in some years declined the grant outright; CNMI's own four-year total confirms the program exists and has been used here, but at a scale that covers roughly one unit, not a LIHTC-scale multifamily deal.

CDBG-DR is the one federal source with a confirmed LIHTC gap-financing track record -- and it is disaster money, not a standing program

HUD allocated $254,324,000 in Community Development Block Grant-Disaster Recovery (CDBG-DR) funds to CNMI following the presidentially declared disasters of Typhoon Yutu (DR-4404) and Typhoon Mangkhut (DR-4386), with NMHC designated as the administering agency and running a dedicated CDBG-DR Office. Within that program, the Affordable Rental Housing Program includes a specific "Gap Filler to LIHTC" track, separate from its 1-to-4-unit and 5-plus-unit (non-LIHTC) tracks. Two completed projects document that this track is real, not aspirational: Isa Villa II (a multifamily/apartment project) used approximately $6.3 million in CDBG-DR gap financing structured as LIHTC gap financing, and Lotus Homes received $8,000,000.00 in CDBG-DR gap financing through the same housing program.

This is disaster-recovery money tied to specific 2018 declared disasters, administered under a HUD grant agreement (Action Plan approved October 14, 2020; grant agreements executed November 24, 2020) that carries its own federally mandated expenditure timeline -- this research did not independently confirm CDBG-DR's current unspent balance or firm expenditure deadline for CNMI as of this writing. A developer should not assume the Gap Filler to LIHTC track remains open on the same terms indefinitely; confirm current fund availability directly with NMHC's CDBG-DR Office before underwriting a deal to it.

No property tax to exempt: the Qualifying Certificate, not a PILOT, is CNMI's soft-money analog

Every source checked in this research -- CNMI's Division of Revenue and Taxation, NMHC's own Consolidated Plan (which never mentions a property tax anywhere in its roughly 9,400 lines of program detail), and the CNMI Department of Public Lands' investor guidance -- is consistent in listing CNMI's local taxes as the territorial income tax (NMTIT), wage and salary tax, earnings tax, business gross revenue tax (BGRT), and general excise tax, with no real property tax among them. This research did not find a codified real property tax anywhere in CNMI law; the mainland question of negotiating a property-tax exemption or PILOT with a local taxing authority does not appear to have an equivalent in CNMI because there is no ongoing property tax to abate in the first place. Confirm this directly with CNMI's Division of Revenue and Taxation before assuming it -- the absence of any reference to a real property tax across every primary source checked here is strong but not a substitute for an explicit statutory confirmation, which this research could not locate.

CNMI's actual soft-money tax tool is the Qualifying Certificate (QC) program, administered by the Commonwealth Economic Development Authority (CEDA, the successor to CDA) under 4 CMC Section 50204 (Public Law 12-32, the Investment Incentive Act of 2000, as amended, most recently by PL 19-22 in 2015). The statute's text is direct: the Governor may issue a QC "abating the following taxes...(a) Abatement of taxes of whatever nature, except taxes under the NMTIT and developer infrastructure tax for the Third Senatorial District...of up to 100 percent for a period of up to 25 years," or alternatively "(b) Rebate of taxes of whatever nature, except for developer infrastructure tax for the Third Senatorial District...of up to 100 percent for a period of up to 25 years." Read literally, the territorial income tax (NMTIT) is excluded from the abatement mechanism in (a) but not from the rebate mechanism in (b) -- meaning a QC can rebate income tax already paid, even though it cannot let a beneficiary skip paying it in the first place.

A secondary source describes affordable-housing builders, alongside insurance underwriters, as a category eligible for a 100% income-tax rebate under this program -- this research could not independently verify that specific eligibility category against CEDA's own current regulations (Title 25, Chapter 30 of the CNMI Administrative Code) or against the underlying Public Laws, so treat it as an unconfirmed lead worth checking directly with CEDA, not a confirmed program feature. What is confirmed is the mechanism itself (up to 100% abatement or rebate, up to 25 years, of most CNMI taxes other than NMTIT-by-abatement and the Third Senatorial District's developer infrastructure tax) and that it runs through CEDA's own public hearing process -- a September 2026 news report on a $77.7 million QC applicant describes a public hearing before the CEDA board, illustrating that QC approval is a separate, negotiated administrative process, not a QAP scoring item with published terms.

This QAP's own Criterion 10 (Local Government Support) treats a "qualifying certificate" as explicitly distinct from a below-market loan or grant: a project relying on financing types other than a qualifying certificate gets up to 5 points if that financing reaches 10% or more of total development cost, but the QC path itself is carved out of that scoring path entirely (Section III.2, Criterion 10 note). In other words, NMHC's own scoring treats a QC as a tax-cost reduction, not as capital the project can point to for Local Government Support points.

Article XII land tenure: how long can a typical LIHTC ownership entity actually hold the ground?

Article XII of the CNMI Constitution, "Restrictions on Alienation of Land," restricts fee-simple ownership and any leasehold exceeding 55 years (the constitutional definition of "long-term leasehold," per a 1985 amendment) to persons of Northern Marianas descent (NMD) -- defined as persons of at least one-quarter Northern Marianas Chamorro or Carolinian descent. A sale of a freehold, or a leasehold exceeding that 55-year threshold, to a person not of NMD is void ab initio. A corporation counts as a person of NMD, and so may hold land on the same terms as an individual, only if it is incorporated in the Commonwealth, has its principal place of business there, and has at least 51% of both its directors and its voting shares held by persons of NMD.

In practice, per the CNMI Department of Public Lands' own investor guidance, public land is available for lease to non-NMD lessees for a term of 25 years with an extension of not more than 15 years (40 years total), while private land can be negotiated directly with an NMD landowner for a term of up to 55 years. Both figures sit inside Article XII's 55-year ceiling for non-NMD lessees. A typical LIHTC ownership entity -- an LLC with a for-profit or nonprofit developer as managing member and a tax-credit investor as the limited member, neither of which is likely to be majority-NMD-owned -- cannot itself hold CNMI land in fee, and cannot hold a lease longer than 55 years (or 40, if the parcel is public land), without either partnering into a majority-NMD-controlled entity to hold title, or structuring the deal to fit inside that ceiling.

This matters directly for capital-stack sizing and investor underwriting: this QAP's own Criterion 1 lets an applicant earn up to 10 scoring points by electing an Additional/Extended Use Period of 30 years or more on top of the base 15-year compliance period -- a combined 45-year (or longer) affordability commitment. That fits comfortably inside a 55-year private-land lease, but leaves little to no margin against a 40-year public-land lease if the compliance clock, extended-use election, and any post-award delay in reaching Placed-in-Service are all counted from site control forward. This research found no public record of how CNMI's existing LIHTC-financed projects have actually structured site control against Article XII -- that is a live structuring question for any new CNMI deal, not one this research can resolve generically.

Developer fee: the one capital-stack limit the QAP states directly

Both caps are stated in the QAP's Minimum Thresholds section (III.1.D) and are written for "the 9% (volume cap) LIHTC" specifically; the QAP text does not separately state a developer fee cap for a 4% or bond-financed CNMI deal, and this research found no separate bond-deal cost certification exhibit to check that against. "Developer Fee" in this QAP is itself a bundled term -- "developer fee, developer overhead, management fee, consultant fee, etc." -- so the cap constrains more line items than its name alone suggests.