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Capital stack and soft money — New York

Phase 7 of 11

"Which of HCR's dozen soft-funding programs can actually stack on this unit — and which ones cancel each other out?"

Not yet coveredAssembled inside the same multi-week window as the 9% LIHTC application itself, since most soft sources share one combined RFP — but locking down ESSHI/OPWDD coordination or an HPD/HDC-paired NYC stack realistically starts months before that RFP window opens

One RFP, a dozen funding lines, and a rule that blocks doubling up per unit

HCR's annual Multifamily Finance 9% LIHTC RFP is a single combined solicitation for the 9% federal credit, the parallel New York State Low-Income Housing Tax Credit (SLIHC), and every major HCR/HTFC soft-money program at once: the Housing Trust Fund (HTF), the Rural and Urban Community Investment Fund (CIF), the Supportive Housing Opportunity Program (SHOP), the Public Housing Preservation Program (PHP), the Middle Income Housing Program (MIHP), the Senior Housing Program (SENR), and the HOME American Rescue Plan Program (HOME-ARP). A sponsor requests all of it on one Project Detail Application and one Underwriting Application — there is no separate RFP cycle to chase for these gap sources when the deal is going through DHCR's 9% competition.

2025 9% LIHTC RFP: anticipated statewide funding by program
Program2025 Anticipated FundingAdministered by
9% LIHTC$50 millionDHCR
SLIHC (state credit)$10 millionDHCR
Housing Trust Fund (HTF)$43 millionHTFC
Supportive Housing Opportunity Program (SHOP)$65 millionHTFC
Community Investment Fund (CIF)$10 millionHTFC
Middle Income Housing Program (MIHP)$10 millionHTFC
HOME-ARP$10 millionHTFC
Public Housing Preservation (PHP)$10 millionHTFC
Senior Housing Program (SENR)$22 millionHTFC
New Construction Program (NCP)$26 millionHTFC — automatic, not directly requested

The RFP's 'Subsidy Gap Financing Source per Residential Unit' rule then narrows what any one unit can actually carry: HTF, SHOP, SENR and PHP cannot be combined — a project may draw from only one of those four. HOME-ARP can sit alongside other HCR financing at the project level but must be the only HCR subsidy source in any single unit (except CEI and SFA, the sustainability add-ons). MIHP must likewise be the sole HCR financing source in its unit, cannot combine with a PHP or SENR project, and — critically — no unit that receives MIHP money may also carry federal or state LIHTC. CIF can only be requested as a standalone source for non-residential space or the non-residential component of a mixed-use project. NCP isn't requested on the application at all; projects that meet its criteria are automatically considered for it at HCR's discretion, at the same per-unit limits as whatever subsidy program was actually requested.

Financial leveraging is a scored category, and NYC's stack runs at a different order of magnitude

Financial Leveraging is worth up to 10 of the QAP's competitive-scoring points, and it rewards the capital stack itself, not just underwriting feasibility: the extent to which sources other than HCR/HTFC permanent funding — donated land or buildings, nominal long-term ground leases, net syndication proceeds as a share of the credit requested, and credit requested per unit adjusted for unit size — finance total development cost. Deferred developer fee is explicitly excluded from the calculation, so a sponsor who plans to lean on fee deferral to hit a leverage target is scoring against a number that doesn't count it.

Per-unit subsidy ceilings by program and geography (2025 term sheets)
ProgramNYC/Westchester/Nassau/Suffolk/RocklandRest of State
HTFup to $125,000/unit ($9M/project)up to $100,000/unit ($6.5M/project)
SHOP — 9% LIHTC track, ESSHI unit, no other subsidyup to $140,000/unitup to $115,000/unit
SHOP — HFA bond track, supportive unitup to $200,000/unitup to $150,000/unit
MIHPup to $200,000/unitup to $150,000/unit
$160,000–$205,000/unitHPD subsidy, 4% LIHTC deal
$380,000–$420,000/unitHPD subsidy, ≥120-unit 9% LIHTC deal
$100,000–$125,000/unitStatewide HTF ceiling (comparison)

Those HPD figures aren't a DHCR/HFA program at all — they're NYC HPD's own New Construction Finance (NCF) term sheet, which pairs HPD subsidy loans with HDC tax-exempt bonds (HDC's own New Construction Program), HFA bonds, or 9% credits, running a per-unit economics roughly two to three times the state's HTF or SHOP ceilings. For a NYC-sited project, that means the real capital-stack question isn't just which HCR soft sources to request — it's whether the deal is a state DHCR/HFA transaction at all, or a city HPD/HDC transaction layered on top of (or instead of) it, because the two stacks are not interchangeable and don't share an application.

The ESSHI/SHOP pipeline is a real capital-stack lever, not just a scoring checkbox

SHOP's own term sheet names its priorities explicitly: projects with an Empire State Supportive Housing Initiative (ESSHI) award, projects comprised of at least 50% supportive-housing units, and projects targeting at least 10% of income-restricted units to 30% AMI or below all receive priority in SHOP funding decisions. On the QAP side, the Special Housing Needs and Supportive Housing scoring criterion is worth up to 5 points on a tiered scale — 5 points for a preference covering at least 50% of LIHTC-assisted units, 3 points at 30%, 2 points at 15%, all requiring a narrative, a comprehensive service plan, and a written provider commitment, or 1 point for a 55+/62+ senior project with an aging-in-place plan. The populations underlying that scoring tier track the 2025 ESSHI RFP's own population definitions, run by the Office of Mental Health (OMH), not HCR.

For projects proposing an intellectual/developmental-disability tenant preference, HCR's 2025 RFP adds a hard gate: the project will only be considered if it either holds an ESSHI conditional award letter and doesn't require OPWDD capital, or has a current Integrated Supportive Housing (ISH) letter of support from OPWDD issued after July 1, 2025 (under which OPWDD will consider funding up to 50% of total project costs for the OPWDD units). Because OMH's ESSHI RFP runs on its own separate award cycle, a sponsor pursuing this lever has to have that OMH pipeline underway — ideally with a conditional award in hand — well before HCR's own application deadline; it can't be assembled reactively in the weeks before submission.

Where this goes wrong

  • Assuming HTF, SHOP, SENR and PHP can be layered together to cover a single unit's gap — the RFP explicitly limits a project to only one of those four sources.
  • Treating MIHP as a LIHTC subsidy — a MIHP-financed unit may carry no other HCR subsidy and no federal or state LIHTC at all; it's a genuinely separate, non-credit unit type layered into the same building.
  • Proposing an I/DD tenant preference without either an ESSHI conditional award letter or a post-7/1/2025 OPWDD ISH letter in hand — HCR won't consider the preference without one of the two.
  • Treating the OMH ESSHI RFP as something to pursue after the HCR application is submitted — it runs on its own separate cycle and needs to be well underway (ideally awarded) before HCR's deadline.
  • Budgeting a NYC-sited deal off statewide HTF or SHOP per-unit ceilings instead of HPD's NCF term sheet — HPD's subsidy runs at roughly two to three times HTF's per-unit scale and is a separate city process.
  • Counting deferred developer fee toward the Financial Leveraging score — the QAP explicitly excludes it from the leverage calculation.
  • Assuming HOME-ARP can sit in the same unit as HTF, SHOP, PHP or SENR — it can combine with other HCR sources at the project level, but must be the sole HCR subsidy in any one unit (aside from the CEI/SFA sustainability add-ons).
  • Requesting CIF to subsidize residential units in a mixed-use project — CIF is a standalone source limited to non-residential space or the non-residential component of a mixed-use deal.

At a glance

2025 RFP combined programs
9% LIHTC, SLIHC, HTF, CIF, SHOP, PHP, MIHP, SENR, HOME-ARP, NCP, CEI, SFA — one application
2025 anticipated 9% LIHTC / SHOP funding
$50 million / $65 million statewide
HTF per-unit / per-project cap
$125,000/unit, $9M/project (NYC-adjacent); $100,000/unit, $6.5M/project (rest of state)
MIHP per-unit cap
$200,000/unit (NYC/Westchester/Nassau/Suffolk); $150,000/unit elsewhere — sole HCR source, no LIHTC in that unit
SHOP priority criteria
ESSHI award, ≥50% supportive units, or ≥10% units at ≤30% AMI
Financial Leveraging scoring weight
up to 10 of the QAP's competitive points
Special Housing Needs/Supportive Housing scoring
up to 5 points, tiered at 50%/30%/15% of units with a supportive-housing preference
OPWDD ISH letter funding ceiling
up to 50% of total project costs for OPWDD units

Governing authority

  • Combined RFP program list and 2025 funding table2025 HCR Multifamily Finance 9% LIHTC RFP (released July 17, 2025), Section I.A
  • Subsidy Gap Financing Source per Residential Unit rule2025 HCR Multifamily Finance 9% LIHTC RFP, Section III
  • SHOP per-unit caps, priorities and ESSHI population definitions2025 HCR Supportive Housing Opportunity Program Term Sheet (July 2025)
  • HTF per-unit and per-project caps2025 HCR Low-Income Housing Trust Fund Term Sheet (July 2025)
  • MIHP per-unit caps and sole-source rule2025 HCR Middle Income Housing Program Term Sheet (Rev. August 2025)
  • HPD NCF per-unit subsidy by LIHTC trackNYC HPD New Construction Finance (NCF) Program Term Sheet (July 2025), Table 2
  • OPWDD coordination and ESSHI conditional award gate2025 HCR Multifamily Finance 9% LIHTC RFP, Section III ("OPWDD Coordination")

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