"Does every window, door, shutter, and roof assembly on this job actually carry a Miami-Dade NOA or equivalent — before the inspector asks?"
HVHZ certification has to hold through substitutions, not just the original spec
In Miami-Dade and Broward Counties, every window, door, shutter, and roof assembly needs a Miami-Dade Notice of Acceptance or equivalent certification, verified at inspection — a real, common field failure point is a mid-construction product substitution (a different window or roofing line than originally specified) that isn't re-confirmed against HVHZ certification before installation.
Reserve funding and draw timing are rule-set, not deal-negotiated
Up to 50% of two years' required replacement reserves may be pre-funded or escrowed at closing with Corporation/Credit Underwriter approval, but draws are restricted afterward: new construction and redevelopment reserves can't be drawn for the first 5 years (or until a 5-year accumulated balance exists), and rehab/preservation reserves can't be drawn before year 3. The required third-party Capital Needs Assessment cadence — due by year 10, again by year 15, then every 5 years after — runs from the date the first building is placed in service, not from construction completion.
Cost certification and the operating deficit guarantee
For a 4%/bond deal, release of the mandatory operating deficit guarantee is not a single post-completion snapshot — it requires reaching 1.15x DSC together with 90% occupancy and 90% of gross potential rental income, and sustaining all three for 12 consecutive months, with a further floor that release cannot happen before 3 years after final certificate of occupancy or bond repayment, whichever comes first. Lease-up and construction scheduling has to plan around that full holding period explicitly, not assume the guarantee releases as soon as stabilized occupancy is first reached.
Where this goes wrong
- Substituting a product mid-construction (a different window/door/roofing line) in an HVHZ county without re-confirming Miami-Dade NOA or equivalent certification for the substitute product.
- Drawing replacement reserves before the restriction period ends — 5 years (new construction/redevelopment) or 3 years (rehab/preservation), a rule-set restriction, not a lender-negotiated one.
- Underestimating the post-completion holding period for a 4%/bond deal's operating deficit guarantee release — 12 consecutive months at 1.15x DSC and 90%/90% occupancy/income, not a one-time snapshot.
- Assuming the Capital Needs Assessment cadence starts at construction completion rather than from the date the first building is placed in service.
- Assuming a specific FHFC construction-inspection or draw-administration process without independently confirming it against current rule text or FHFC's own construction consultant guidance — not verified this session.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies