Building the capital stack and closing the gap — New Hampshire

What actually happens: one agency, a thin pool, and a fast clock

Structurally this still runs as three interleaved workstreams — structuring, soft-money assembly, debt/equity procurement — but New Hampshire compresses them because one agency, NH Housing (formerly New Hampshire Housing Finance Authority), is both the state's sole LIHTC allocating agency under its Qualified Allocation Plan (HFA 109) and, through the Multi-Family Bond Financing Program (HFA 114) and its Conduit Bond Rules (HFA 116), one of its own primary bond issuers and permanent lenders. There is no separate CDLAC-style bond committee to coordinate with and no Texas-style three-way issuer split to shop between.

The pool is small. For the 2026 9% round (the most recently completed, evaluated under the prior 2025–2026 QAP), NH Housing received nine 9% LIHTC project applications requesting a total of approximately $6.99 million in credits and $12.57 million in capital subsidy; the Board of Directors approved six of the nine for a reservation, awarding $4.84 million in 2026 LIHTCs. The current 2027-2028 QAP (effective March 16, 2026) sets minimum scoring thresholds of 106 points for a general occupancy project, 80 for age-restricted, and 110 for preservation/recapitalization (HFA 109.06.N) — and separately guarantees that at least one age-restricted and two general occupancy projects will be funded per round as long as they clear threshold, even over higher-scoring competitors.

What actually gates a New Hampshire deal is neither credit scarcity nor bond volume. NH Housing's own April 2026 bond-allocation guidance states plainly that it is "not currently constrained" by private activity bond cap. The forcing function is calendar, not competition: within 120 days of a reservation of LIHTCs (9% round) or a Track 1 bond award (4%/bond NOFO), the sponsor must submit commitment letters, with terms and conditions specified, for the construction loan, every long-term or subordinate loan, and the equity investment — all at once, not staged evidence of partial commitments the way CDLAC's 50% threshold works (HFA 109 Appendix A; FY 2027 Tax-Exempt Bond NOFO, Exhibit D).

Bonds and the 25% test: the same federal law, a fresh NH policy, no scarcity

This is the identical nationwide statutory change every state is working through in 2026. NH Housing's own guidance — Attachment B to the Underwriting Standards, "25% Test Policy for Tax-Exempt Private Activity Bonds and Conduit Bond Financing," effective April 17, 2026 — states the two-condition version unambiguously: both the bond issuance date and the placed-in-service date must fall after December 31, 2025. A refunding of pre-2026 paper, or a project placed in service before 2026, still needs the 50% test.

NH Housing's own allocation practice sits above the bare federal floor. For its own Multi-Family Bond Financing Program deals, it allocates PAB volume cap equal to the greater of 30% of aggregate eligible basis or whatever amount is actually needed to cover the project's maximum construction/permanent debt plus reserves, cost of issuance, and other financing costs. For conduit transactions under HFA 116, it targets a flat 30% of aggregate eligible basis, fixed at loan closing regardless of how the number moves at final cost certification. A deal modeled to the bare 25% federal minimum will typically be undersized against NH Housing's own practice.

Because that ceiling is a statewide number shared across every private-activity-bond category (housing, exempt facility, student loan, and more) and NH Housing describes itself as unconstrained by it, bond volume simply has not been the binding resource here the way it periodically is in California.

One underwriting rulebook: a year-12 DSCR floor, not a 15-year residual-receipts calendar

There is no CTCAC/HCD-style two-agency reconciliation to work through here — one lender, one rulebook, no gap to bridge between an allocating agency's DSCR test and a soft-money agency's separate one, because in New Hampshire they are usually the same desk.

One gap worth flagging rather than guessing at: unlike CTCAC's published (if stale) operating expense minimums that HCD imports as a binding floor, NH Housing's Underwriting Standards do not publish an equivalent minimum-expense schedule at all. Reasonableness is judged case-by-case against "operating expense data of similar properties" NH Housing holds internally (§ 5.03.D). A pro forma here has no public floor to check itself against — own the expense number from market data, not from an agency table, because there isn't one.

Developer fee: a tiered per-unit dollar schedule, not a percentage-of-basis cap

Applying that schedule to a fully-populated 100-unit deal (illustrative arithmetic on the published tiers, not a quoted agency example): a general occupancy project totals $23,760×10 + $19,440×30 + $16,200×60 = $1,792,800; the equivalent age-restricted project totals $21,600×10 + $17,280×30 + $14,580×60 = $1,609,200 — both still capped by the 15%-of-TDC ceiling if development cost is low relative to unit count.

4% LIHTC/tax-exempt bond deals get a different, more generous mechanic: developer fee up to 15% of total development cost, uncapped by the per-unit schedule above — but the difference between what the per-unit schedule would have allowed and the full 15%-of-TDC figure must be loaned back into the project as a mandatory, non-interest-bearing developer fee loan, not taken in cash.

Where the builder and developer share an identity of interest and construction costs exceed $2.5 million, developer fee plus the builder's overhead/profit/general-conditions (CM fee) together may not exceed 18% of total development cost (20% where construction costs are $2.5 million or less).

Two mechanics that trip up modelers moving from other states: for LIHTC projects, NH Housing follows the partnership's own development-services or operating agreement for the fee pay-in schedule — the general "up to 33% at construction closing, balance held to completion" rule applies only to non-LIHTC deals. And developer fee loans are generally expected not to exceed 50% of the maximum allowed fee, carry 0% interest, must be projected to fully amortize within the 15-year compliance period, and are repaid from surplus cash ahead of NH Housing's own deferred payment loan.

The New Hampshire soft-money map: smaller, more flexible, capped per unit

AHF's terms are deliberately undefined rather than codified the way California's MHP fixes a 0.42% annual payment. NH Housing's own rule states loan terms are flexible "based on the ability of the project to support debt" and explicitly permits 0% interest, deferred payment, cash-flow-only, or outright grants — and that "no Application shall be rejected solely or primarily because of the level of assistance requested" (HFA 113.07(d)).

The FY 2027 Tax-Exempt Bond Program NOFO (released July 8, 2026) is the current live mechanism for 4% deals seeking capital subsidy: roughly $24.4 million in AHF/HOME/HTF capital subsidy is available. Track 1 is competitive and scored, restricted to projects twinned with a 9% award (existing or applied-for) or a subsequent phase of a prior development, with applications due September 1, 2026. Track 2 is non-competitive, open to stand-alone 4%/bond deals without capital subsidy, and runs on a fixed quarterly-style schedule (October 1, 2026 / December 31, 2026 / April 1, 2027) rather than a rolling basis.

Track 1's own scoring directly rewards asking for less, mirroring the shape (if not the formula) of California's MHP Gap NOFA funding-priorities points: against a $100,000/unit ceiling, requesting 5% below ($95,000 or less) earns 2 points, 10% below ($90,000) earns 3, 15% below ($85,000) earns 4, and more than 15% below earns 5 — with a documented penalty on the developer's next application if the committed subsidy level is later exceeded.

The calendar: one round a year, and the 120-day clock that actually kills deals

One annual round, roughly five months from preliminary application to Board vote. The real deadline pressure lands after the vote: within 120 days of notification of a reservation (9% round, Appendix A) or a Track 1 bond award (NOFO Exhibit D), the sponsor must submit an updated financing application plus commitment letters — with terms and conditions specified — for every long-term loan (first mortgage, all subordinate loans, all grants), the construction loan, and the equity investment, along with continued evidence of site control and an appraisal. Miss it, and the reservation is subject to rescission at NH Housing's sole discretion. This is a materially harder bar than CDLAC's "evidence of commitments for at least 50%" standard — New Hampshire wants the whole stack, signed, inside four months.

As in California, there is no live exit: waiving the right to submit a qualified contract is a condition of receiving a LIHTC allocation, built into Section 9 of the standard LURA (HFA 109.10.A). Any year-15 qualified-contract cash-out assumption is foreclosed here too — administratively, through the recorded LURA, rather than by a standalone statute the way California does it.

Equity pricing is the same unsourceable input it is everywhere else — NH Housing's underwriting standards direct sponsors to project pricing themselves and reserve the right to test it "for reasonableness and consistency with the market," without publishing a pricing series of their own. Treat it, as in every other state, as a sensitivity input, not a constant — and note that New Hampshire's small, secondary-market deal sizes mean national LIHTC equity pricing series (themselves paywalled) may not reflect local pricing at all; no NH-specific public pricing series was located in this pass.