Capital stack and soft money — Mississippi

MHC runs HOME and the National Housing Trust Fund itself, inside the QAP

Unlike states that route HUD formula money through a separate NOFA process outside the tax credit competition, Mississippi's QAP folds both programs directly into itself. Section 1.5(8)(g), titled “Housing Trust Fund (HTF) and HOME,” sets aside $1,500,000 in HOME funds for developments to apply for up to $750,000 per development, and a further $1,500,000 in Housing Trust Fund money — reserved specifically “for deeper targeting units” — also capped at $750,000 per development. The QAP text never spells out that “HTF” means the federal National Housing Trust Fund rather than a state-created fund; that identification comes from MHC's own Developer Guide, which lists “Housing Trust Fund (HTF)” as a federal program MHC administers, with an annual allocation of about $3 million (versus roughly $9.5 million for HOME in 2024).

The QAP's timing rule is a genuine gate, not a formality: “Developments that intend to use HOME and/or HTF must apply for those funds either before submission of the HTC Application or twelve (12) months after the original HTC Award. A non-binding Preliminary Award letter must be provided with the application. The expected HOME/HTF funds should be included as a source on the tax credit application” (§1.5(8)(g); see also §1.5(8), item 8, “Other Sources of Financing”). Evidence of the actual award is then due by whatever date MHC's reservation package specifies. Note also that “all federal grants will be reduced from eligible basis” — a HOME or HTF award is real gap money, but it shrinks the credit basis it sits alongside.

A state-level gap loan fund exists too: the Mississippi Affordable Housing Development Fund

Mississippi has its own state-created revolving loan fund for affordable housing gap financing, separate from HOME and NHTF: the Mississippi Affordable Housing Development Fund (MAHDF), established in 1989 and codified at MS Code § 43-33-759. The statute creates the fund “as a revolving fund for the provision of affordable housing to very low income, low income, and moderate income persons,” to be used “exclusively to support programs created or administered by the Mississippi Home Corporation.” It is funded by loan repayments, fees, and any appropriations or gifts the Legislature directs to it — not by a dedicated recurring tax or fee, so its size can vary year to year.

MHC's own Developer Guide describes MAHDF as usable for “construction, rehabilitation, pre-development, site control, and site development,” at below-market rates with negotiable amortization, open to nonprofits, for-profit developers, public housing authorities, planning and development districts, and limited equity cooperatives. Its stated advantage over HOME or HTF is that it can fund pre-development and site-control costs — the cash a developer needs before there is a deal to attach HOME or LIHTC financing to.

This research could not confirm MAHDF's current fund balance, interest rate, or per-development cap from any primary source — the statute itself sets none, and MHC's public materials describe the loan terms only in general terms (“below market,” “negotiable”). A developer should get MAHDF's current terms directly from MHC rather than assume a specific rate or amount.

Historic rehab money is two separate benefits from two separate agencies

The QAP itself offers two historic-preservation-linked benefits, both administered by MHC: 10 Selection Criteria points for a “Historic Development” (a property individually listed, or contributing to, the National Register), and a “State Discretionary Basis Boost” MHC may grant to a development that has actually received historic tax credits, on top of the QCT/DDA discretionary boost criteria (2026 QAP §5.3, Discretionary Basis Boost criteria). Both require a letter from the Mississippi Department of Archives and History (MDAH) confirming preliminary eligibility, submitted with the application, and Parts 1 and 2 of the federal Historic Preservation Certification Application submitted to MHC within 90 days of the reservation letter (§4.5(5)).

The actual money — Mississippi's state historic rehabilitation income tax credit — is a completely separate program administered by MDAH under MS Code § 27-7-22.31, with its own application filed directly with MDAH's Historic Preservation Division, not through the QAP. It provides a state income tax credit equal to 25% of qualified rehabilitation expenditures on a certified historic structure (income-producing property must exceed 50% of adjusted basis in qualified expenditures; owner-occupied property has a lower $5,000 threshold and only qualifies for expenditures after January 1, 2021). Any rehabilitation that qualifies for the federal 20% historic rehabilitation credit automatically qualifies for the state credit as well, and the two combined are commonly described as reducing rehab costs by roughly 45% for income-producing structures.

Property tax relief: one confirmed, narrow exemption — and one statute this research could not read

Mississippi does not offer a general PILOT or ad valorem exemption to LIHTC properties as such. The one exemption this research could confirm in the actual statutory text is MS Code § 27-31-1(dd), which exempts “all property, real or personal, used exclusively for the housing of and provision of services to elderly persons, disabled persons, mentally impaired persons or as a nursing home, which is owned, operated and managed by a not-for-profit corporation, qualified under Section 501(c)(3) of the Internal Revenue Code.” That is real, but narrow: it only reaches nonprofit-owned senior, disabled, or mentally-impaired housing — not a general family LIHTC deal, and not a for-profit ownership structure, even one with a nonprofit co-general-partner.

Search results repeatedly surfaced a second, potentially broader statute — MS Code § 43-33-37, titled “Tax exemption and payments in lieu of taxes,” inside the Housing Authorities Law (Title 43, Chapter 33). If that title accurately describes the section's content, it would be the closest thing Mississippi has to a PILOT mechanism for housing-authority-affiliated developments, similar in concept to Atlanta's Private Enterprise Agreement structure in Georgia. This research could not retrieve the section's operative text: both Justia and FindLaw blocked automated access with a Cloudflare bot challenge on every attempt, and no other free source of the current Mississippi Code text was found. Do not assume this statute extends PILOT treatment to a conventional LIHTC limited partnership — confirm the actual text, and whether it requires the housing authority itself to hold title (rather than merely partner with the developer), directly with Mississippi Code counsel or MHC before structuring a deal around it.

CDBG-DR in 2026: real money, but tornado recovery in six counties — not a Katrina-era gap-financing well

Mississippi's largest-ever CDBG-DR allocation followed Hurricane Katrina in 2005–06 and was used for years afterward, including as gap financing layered under Gulf Coast LIHTC deals. That money closed out long ago. It is not a live source for a 2026 application, and this research found no evidence of any currently active CDBG-DR allocation tied to a hurricane.

The CDBG-DR money that is currently active is unrelated to storms of any kind on the Gulf Coast: HUD approved a $134.95 million action plan for the Mississippi Development Authority (MDA — not MHC) on July 31, 2025, responding to severe storms and tornadoes that struck Mississippi in 2023 and 2024 (including the devastating March 2023 tornado that hit Rolling Fork and Silver City, in Sharkey and Humphreys Counties). The plan targets six named counties — Hinds, Humphreys, Jackson, Monroe, Scott, and Sharkey — and allocates $29.32 million to owner-occupied housing recovery, $19.55 million to “affordable rental housing repairs,” $38 million to infrastructure, $21.72 million to economic revitalization, and $17.6 million to mitigation, with 93% of housing funds required to serve low- and moderate-income households.

That $19.55 million rental-housing line is worth noting for a developer with an existing affordable property in one of the six named counties that suffered storm damage, but it is described as funding for repairs to existing affordable rental housing, not as new-construction gap financing, and it is administered by MDA on MDA's own timeline — the MHC QAP does not reference it at all. Do not assume CDBG-DR gap money is available for a new 2026 LIHTC application outside those six counties, or for new construction rather than storm repair, without confirming current program guidelines directly with MDA.