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One soft-money pipeline runs through the QAP; the state's own fund doesn't reach a typical LP — West Virginia

Phase 7 of 11

"WVHDF folds HOME, HTF, and something called the ERA2 Housing Fund right into my LIHTCP application — but is West Virginia's own housing trust fund one more source I can tap, or is it walled off from a for-profit ownership LP, and does a historic rehab component actually buy me anything beyond scoring points?"

Not yet coveredThere is no single 'capital stack' deadline the way there is for the Reservation Request itself. HOME Program, HTF Program, and ERA2 Housing Fund requests are built into the same WVHDF Form 1040 due with the Reservation Request (Program Calendar: May 1-29, 2026, 4:30 p.m. prevailing Eastern Time, for the 2026 cycle) and are re-underwritten again at Carryover and at Prior to Equity Closing. West Virginia's statutory Affordable Housing Fund (W. Va. Code §31-18-20D) runs on WVHDF's own internal cycle — no LIHTCP-specific calendar for it appears in either the Allocation Plan or the Tax Credit Manual. The state historic rehabilitation tax credit runs on a separate, year-round track through the State Historic Preservation Office's GOapply portal and the National Park Service's three-part federal certification (Parts 1, 2, and 3), independent of the LIHTCP calendar — though the Allocation Plan requires the Park Service's Part 1 evaluation to be no more than six months old as of the Reservation Request due date.

Two soft-money systems under one roof

The financing WVHDF actually lends into a LIHTCP deal — HOME, the National Housing Trust Fund, and a state-created ERA2 Housing Fund — is processed as part of the same LIHTCP application, on the same WVHDF Form 1040, by the same underwriting staff. West Virginia's separate, statutory Affordable Housing Fund is a different program entirely, created outside the LIHTCP framework, with its own eligibility rules that do not track LIHTCP's Ownership Entity structure.

WVHDF-administered soft money vs. West Virginia's statutory Affordable Housing Fund
SourceStatutory / program basisHow it's requestedWho can actually use itPricing
HOME Investment Partnerships ProgramFederal HOME program; WVHDF is the state administering agencyEmbedded in the WVHDF Form 1040 at Reservation Request, re-underwritten at Carryover and Prior to Equity ClosingAny LIHTCP Ownership Entity requesting Fund-provided financingDeferred: 0%. Amortizing: no higher than 1%
National Housing Trust Fund ('HTF Program')Federal National Housing Trust Fund; WVHDF is the state administering agencySame Form 1040 process as HOMEAny LIHTCP Ownership Entity requesting Fund-provided financingSame 0%-1% rule as HOME
ERA2 Housing FundState-held fund built from federal Emergency Rental Assistance (ERA2) allocations, administered by WVHDFSame Form 1040 process as HOME/HTFAny LIHTCP Ownership Entity requesting Fund-provided financingSame 0%-1% rule as HOME/HTF
Affordable Housing FundW. Va. Code §31-18-20D; funded from deposits under §11-15-4c and §11-22-2, plus a matching amount tied to the dissolved Affordable Housing Trust Fund under §31-18-29A separate WVHDF special fund outside the LIHTCP application process; no LIHTCP-specific request procedure appears in the Plan or ManualStatutorily limited to local governments, local government housing authorities, and 501(c)(3) nonprofit organizations §31-18-20D(c) — not a for-profit LIHTC ownership LPLoans or grants on terms set under WVHDF's own program guidelines, not published in the LIHTCP Plan or Manual

Sources: 2025 and 2026 Allocation Plan (WVHDF), pp. 23-25; W. Va. Code §§31-18-20D, 31-18-29; WVHDF, Multifamily Programs and Resources page.

The practical read: a typical for-profit-sponsored LIHTC deal has a real, WVHDF-administered soft-debt path through HOME/HTF/ERA2, but the state's own Affordable Housing Fund is not that path unless the Ownership Entity's general partner is itself a local government, housing authority, or 501(c)(3) — a structure some, but not most, WV LIHTCP deals use.

What it costs to take WVHDF's own soft debt

The Fund is explicit about why this money exists: HOME, HTF, and ERA2 financing are "utilized to fill financing gaps on properties that, due to inadequate cash flow, have an inability to amortize all hard debt at standard mortgage interest rates required to fund property costs." If a portion can be amortized, "the interest rate is typically zero percent, but generally no higher than one percent"; anything deferred carries a zero rate.

Scoring under the Type of Financing criterion requires this financing — combined with any other RD, HUD, or other government financing or guarantee/insurance — to equal or exceed 50% of Total Permanent Financing, with only two exceptions: properties awarded points for a Maturing Mortgage with Expiring Project-Based Rental Assistance, and cases where post-selection underwriting pushes the percentage below 50% through no fault of the Applicant. During underwriting, WVHDF also reserves the right to cut the requested HOME/HTF/ERA2 amount if it determines the property can support more hard debt at standard rates.

Taking HOME, HTF, or ERA2 money comes with a mandatory 20% deferred developer fee requirement, and the Fund requires that any deferred portion of its own financing be preserved by using favorable financing terms elsewhere in the stack — either other Fund financing or outside financing at terms that meet or exceed the Fund's own.

For properties using HOME or HTF financing, the required general contractor cost estimate must also address Build America, Buy America Act (BABA) compliance costs, and new-construction properties using HOME or HTF must additionally build in the energy efficiency standards from HUD/USDA's April 26, 2024 Federal Register determination — both are Reservation Request and Carryover documentation requirements, not just closing conditions.

The state-designated basis boost as a stack lever

Separate from HOME/HTF/ERA2 debt, WVHDF can award a state-designated basis boost of up to 30% under Section 42(d)(5)(B)(v) of the Code to any building it determines needs the boost to be financially feasible — available statewide except where a property already qualifies for a basis boost under Section 42(d)(5)(B)(ii) or (iii). This isn't automatic: the Manual frames it as a judgment call weighed against per-credit equity price, total property costs, the affordability band for 60% units, a vacancy assumption of 5%-7%, other income, operating expenses, replacement reserves, permanent-financing terms, cash flow, and a Debt Service Coverage Ratio normally in the 1.25-1.30 range (lower for properties with 50%+ project-based rental subsidy).

Up to 30% of eligible basis (IRC §42(d)(5)(B)(v))State-designated basis boost ceiling
20% of the total allowed Developer's FeeRequired deferred developer fee tied to a basis boost or HOME/HTF/ERA2 financing
$250,000WVHDF minimum loan size to run the RD 538 guarantee or HUD insurance process
Manual's own worked examples for the required deferred developer fee (Allocation Policies, State-Designated Basis Boost)
ExampleAllowed total developer's fee (A)Property's actual total developer's fee (B)Difference (A − B)Required deferred fee
A$100,000$100,000$0$20,000
B$100,000$90,000$10,000$8,000
C$100,000$80,000$20,000$0

Required deferred fee = greater of [(B x 20%) less the difference], or zero. Source: 2025 and 2026 Tax Credit Manual, 'State-Designated Basis Boost.'

Historic rehabilitation: mandatory once you start, and two different state credits

The Allocation Plan awards 20 scoring points (of the roughly 500-point threshold needed to survive Threshold) for rehabilitating a Certified Historic Structure, provided at least 50% of the property's residential rental units sit inside that structure. But the same section goes further than a scoring incentive: regardless of whether the Applicant even pursues those points, "if existing structures in a property are rehabilitated to historic standards, such property is required to pursue and obtain both federal and state historic tax credit equity." Certification runs through a National Park Service Historic Preservation Certification Application (Part 1 – Evaluation of Significance, currently Form 10-168), which the Plan treats as stale if dated more than six months before the Reservation Request due date.

West Virginia's two state historic rehabilitation tax credits — only one reaches a LIHTC rental deal
Schedule RBIC (income-producing)Schedule RBIC-A (residential, non-income-producing)
Statutory basisW. Va. Code §11-24-23 et seq. (corporate net income tax) with a companion personal income tax credit; WV Tax Division TSD-380W. Va. Code §11-21-8a through 8g (personal income tax only)
Credit rate25% of qualified rehabilitation expenditures for expenditures made after Dec. 31, 2017 (10% before that date)20% of eligible rehabilitation expenses
Applies to a LIHTC rental building?Yes — TSD-380 states this credit "is for income producing properties"No — the statute excludes property that is income-producing or depreciable under 26 U.S.C. §168
Claimed againstWV Personal Income Tax or WV Corporation Net Income TaxWV Personal Income Tax only
Carryforward10 years; excess credit generated after Dec. 31, 2017 cannot offset tax liability before Jan. 1, 2020, and cannot be carried back5 years

Source: WV Tax Division, TSD-380, 'Requirements for Residential Historic and Rehabilitated Buildings Investment Credit,' Rev. January 2025.

Because Schedule RBIC can be claimed against WV Personal Income Tax as well as Corporation Net Income Tax, a partnership-owned LIHTC deal generating this credit has a mechanism to pass the benefit to individual partners' WV personal returns rather than needing a corporate taxpayer in the ownership chain — a structural detail worth confirming with WV tax counsel before assuming a particular investor can actually use the credit. Both federal Part 2 (Description of Rehabilitation) and Part 3 (Request for Certification of Completed Work) review, plus the state credit application itself, run through the State Historic Preservation Office's GOapply portal, separate from anything WVHDF touches.

Property tax relief: not confirmed to exist for a LIHTC owner

This research did not find a West Virginia statute granting a property-tax exemption or a payment-in-lieu-of-taxes (PILOT) arrangement specific to LIHTC-financed rental housing. The state's general property-tax exemption categories (tax.wv.gov) include religious property, educational institutions, government property, and property of 501(c)(3) charitable organizations — but that charitable exemption is expressly limited to property "not held or leased out for profit," language that appears to exclude a rent-restricted but for-profit-owned LIHTC building. WVHDF's own enabling statute (W. Va. Code Chapter 31, Article 18) was also checked and contains no property-tax provision reaching privately owned, Fund-financed developments. Do not assume a WV property-tax abatement exists when underwriting a deal; if a specific municipality or county offers a local abatement, that would be a local, not state, arrangement and should be confirmed directly with that jurisdiction.

Where this goes wrong

  • Assuming WVHDF's 'HTF Program' is a state trust fund. In WVHDF materials, HTF Program means the federal National Housing Trust Fund, administered directly by WVHDF; West Virginia's own state-level pot is the separately created, statutory Affordable Housing Fund (W. Va. Code §31-18-20D), and the two run on entirely different eligibility rules.
  • Assuming the state's Affordable Housing Fund is available to a typical for-profit LIHTC ownership LP. Its enabling statute names only local governments, local government housing authorities, and 501(c)(3) nonprofit organizations as eligible recipients (§31-18-20D(c)) — not a for-profit general partner or developer entity.
  • Modeling HOME/HTF/ERA2 debt at market amortization terms. WVHDF requires no higher than 1% interest if any portion amortizes, and 0% on anything deferred — and reserves the right to reduce the requested amount during underwriting if it determines the property can support additional hard debt.
  • Missing the mandatory 20% deferred-developer-fee condition that comes bundled with any HOME/HTF/ERA2 draw or a state-designated basis boost — it is not optional and is calculated using the Manual's own formula, not a number the Applicant sets.
  • Assuming West Virginia's residential 20% historic credit (Schedule RBIC-A) can be layered onto a LIHTC rental deal. It explicitly excludes income-producing or depreciable property; the credit that actually reaches an income-producing LIHTC building is the separate 25% Schedule RBIC credit under a different statute (Ch. 11, Art. 24).
  • Treating pursuit of the state and federal historic tax credit as optional once a property has claimed WVHDF's 20 historic-rehabilitation scoring points. The Allocation Plan states the pursuit is required for any property rehabilitating existing structures to historic standards, independent of whether the Applicant sought the points.
  • Assuming a West Virginia property-tax exemption or PILOT exists for LIHTC ownership because other states offer one. No such statewide statute was found in WVHDF's enabling act or the general property-tax exemption framework — treat this as an unconfirmed, likely-unavailable source rather than modeling it into a proforma.
  • Overlooking that the required BABA cost documentation and the HUD/USDA April 2024 energy-efficiency standards attach specifically to HOME- and HTF-financed properties (not ERA2-only or non-Fund-financed deals) and must appear in the general contractor's cost estimate at Reservation Request, not just at closing.

At a glance

WVHDF-administered soft-money sources embedded in the LIHTCP application
HOME Investment Partnerships Program, National Housing Trust Fund ('HTF Program'), and the state ERA2 Housing Fund
Pricing on WVHDF soft debt
0% if deferred; no higher than 1% if any portion amortizes
50% financing threshold for Type of Financing scoring points
RD/HUD/other government financing (incl. HOME/HTF/ERA2) must equal or exceed 50% of Total Permanent Financing, with two stated exceptions
Deferred developer fee required when taking HOME/HTF/ERA2 or a basis boost
20% of the total allowed Developer's Fee
State-designated basis boost ceiling
Up to 30% of eligible basis, IRC §42(d)(5)(B)(v)
Affordable Housing Fund statutory basis and funding source
W. Va. Code §31-18-20D; funded via §11-15-4c and §11-22-2, plus a match tied to the dissolved Affordable Housing Trust Fund under §31-18-29
Affordable Housing Fund eligible recipients
Local governments, local government housing authorities, and 501(c)(3) nonprofit organizations only (§31-18-20D(c))
Historic Nature of Property scoring points
20 points; requires at least 50% of residential rental units inside the Certified Historic Structure(s)
Mandatory historic credit pursuit
Any property rehabilitating existing structures to historic standards 'is required to pursue and obtain both federal and state historic tax credit equity' regardless of whether it sought the scoring points
State historic credit for income-producing property (Schedule RBIC)
25% of qualified rehabilitation expenditures after Dec. 31, 2017 (10% before); 10-year carryforward; claimable against WV personal or corporate net income tax
State historic credit for non-income-producing residential property (Schedule RBIC-A)
20% of eligible rehabilitation expenses; 5-year carryforward; personal income tax only; not usable on an income-producing LIHTC building
LIHTC-specific property tax exemption or PILOT in West Virginia
Not confirmed to exist; no such provision found in WVHDF's enabling act or the state's general property-tax exemption statute

Governing authority

  • HOME/HTF/ERA2 Housing Fund as gap financing; 50% financing threshold; deferred developer fee conditionWVHDF, 2025 and 2026 Allocation Plan, Selection and Preference Criteria – Type of Financing, pp. 23-25
  • State-designated basis boost and required deferred developer fee formulaWVHDF, 2025 and 2026 Tax Credit Manual, Allocation Policies – State-Designated Basis Boost
  • Historic Nature of Property scoring criterion and mandatory pursuit of historic credit equityWVHDF, 2025 and 2026 Allocation Plan, Selection and Preference Criteria – Historic Nature of Property (20 points), p. 61
  • Affordable Housing Fund creation, funding sources, and eligible recipientsW. Va. Code §31-18-20D
  • Dissolution of the former West Virginia Affordable Housing Trust Fund into WVHDFW. Va. Code §31-18-29
  • Historic Rehabilitated Buildings Investment Credit (income-producing property), 25% rate and pass-through mechanicsW. Va. Code §11-24-23 et seq.; W. Va. Tax Division, TSD-380, 'Requirements for Residential Historic and Rehabilitated Buildings Investment Credit,' Rev. January 2025
  • Residential Historic Rehabilitated Buildings Investment Credit (non-income-producing only), 20% rateW. Va. Code §11-21-8a through 8g; W. Va. Tax Division, TSD-380
  • General property tax exemption categories in West VirginiaWest Virginia Tax Division, 'Property Tax Exemptions,' tax.wv.gov
  • WVHDF's Multifamily Programs and Resources, listing HOME, National Housing Trust Fund, and Affordable Housing FundWVHDF, 'Multifamily Programs and Resources,' wvhdf.com

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