"We're moving from Carryover into vertical construction — what does DCA actually require while we build, and what has to happen before it issues our 8609s?"
Quarterly DCA-assigned inspections, not lender draw inspections
Once an Application is awarded, the QAP's Construction Monitoring provisions take over from the application-stage rules. DCA assigns a contracted inspector to the development, and that inspector performs quarterly increment inspections, completing a DCA inspection checklist and report form each time (Core Plan §XI.A.2). The owner is not a passive party here: this QAP cycle added an explicit duty requiring owners to notify DCA construction services proactively if construction has begun and the assigned inspection company has not yet made contact — DCA's own board-approved substantive-changes log confirms this was a new addition, not a carryover from prior cycles. Beyond the scheduled quarterly visits, DCA and/or the assigned inspector may perform monthly or unannounced visits for any instance of non-compliance, and any property that also carries a DCA loan or grant gets monthly inspections as a matter of course, regardless of tax-credit-only inspection frequency.
| Inspection type | Who is billed | Citation |
|---|---|---|
| Scheduled quarterly increment inspections | Billed directly to DCA | Core Plan §XI.A.2; Exhibit A |
| Additional inspections required due to non-compliance | Billed to the Owner | Core Plan §XI.A.2 |
| All properties with a DCA loan and/or grant | Monthly inspections by the contracted inspector (in addition to the above) | Core Plan §XI.A.2 |
DCA's non-compliance determinations during construction split into two tracks with different clocks. Quality-and-safety non-compliance is measured by how quickly the Project Team resolves issues an inspection report identifies — a DCA inspector must return to confirm resolution within 48 hours for site safety, resident safety, or treatment of resident belongings, and within three months for construction quality more broadly. Progress non-compliance, by contrast, is tied to whether the project ends up needing an exchange of 9% Credits or an extension of a statutory placed-in-service deadline — a slower-moving, deal-level determination rather than a punch-list item. On either track, DCA's available penalties reach well past the single project: it can require a cease of construction activity for safety findings, cease reviewing any pending Application on which the same Project Team member appears, and impose award limitations on the Project Team, General Contractor, or architect — though the QAP commits DCA to engaging with the Project Team before imposing those broader restrictions.
The Post-Award calendar: fixed dates by competitive round, not a rolling clock from your own award
DCA's Post-Award Checklist (Core Plan, Exhibits to Core Plan) lays out every deadline from Carryover/LOD issuance through Final Allocation as a specific requirement-and-deadline pair, with two dates listed wherever a deadline differs by competitive round: the first date applies to the 2026 Competitive Round and the second to the 2027 Competitive Round. That convention matters because it means the operative placed-in-service and Final Allocation dates are keyed to which year's round a deal was awarded in, not to a fixed number of months counted from that deal's own Carryover or LOD date.
| Requirement | 9% Credits deadline | 4% Credits/Bonds deadline |
|---|---|---|
| 60 Day Submission | No later than 60 days after receiving Carryover from DCA | No later than 60 days after receiving LOD from DCA |
| Front-End Cost Review | 45 days prior to Construction Loan Closing | 45 days prior to Construction Loan Closing |
| Construction Loan/Bond Financing Closing (Tax Credit only) | Within 180 days of Carryover issuance | Within 180 days of LOD issuance |
| Commencement Submission | 30 days prior to construction commencement | 30 days prior to construction commencement |
| Placed in Service (DCA PIS Notification) | Within 30 days of first building's PIS date; calendar target Dec. 31, 2029 / Dec. 31, 2030 | Same |
| Final Inspection Submission (Tax Credits only) | Within 30 days of final retainage draw certified date | Same |
| Construction Clearance Submission (Tax Credits only) | March 30, 2030 / March 30, 2031 | Same |
| Completion of Work Scope | December 31, 2029 / December 31, 2030 | Same |
| LURC Execution | Prior to submission of Final Allocation Application | Same |
| Affirmative Fair Housing Marketing Plan (AFHMP) | Prior to lease-up; no later than 30 days after first building placed in service | Same |
| Final Allocation Application Submission | September 30, 2030 / September 30, 2031 | Same |
| 8609s with Part II completed and signed, sent to DCA | Within 30 days of DCA's issuance of IRS Form 8609 Part I | Within 30 days of DCA's issuance of IRS Form 8609 Part I |
This QAP cycle shortened the 8609 Part II return window from 60 days (prior cycles) to 30 days, per DCA's own Board-Approved QAP Substantive Changes memo — a compliance calendar built against an older cycle's figure will be wrong.
Cost certification: DCA borrows HUD's HOME standard — a full CPA audit, not a review or compilation
Before the Front-End Cost Review even happens, DCA requires a Third-Party Front-End Cost Review (FECR). If costs increase more than 10% between Competitive Application and the FECR submission, the owner must submit a written explanation to DCA, which then has 45 days to respond (plus any additional days consumed by DCA's own questions or clarifications) — and the owner may not close equity until either DCA approves or that response period expires, whichever comes first (Core Plan §VI.C.1). At the back end of construction, the QAP's cost-certification requirement is a single sentence: owners must submit a "Contractor Cost Certification prepared in accordance with the standards for a HOME contractor cost certification" (Core Plan §VI.C.2) — Georgia does not write its own independent cost-certification standard for the Housing Credit program; it incorporates HUD's HOME rule by reference.
DCA's own Construction Services forms make clear what that borrowed standard actually requires. Exhibit B, "Certification of Independent Certified Public Accountant," states that the certifying CPA's opinion "is supported by an audit report and an opinion letter prepared in accordance with auditing standards generally accepted in the United States of America and the government auditing standards issued by the Comptroller General of the United States." That is a materially higher bar than a plain GAAS-only audit: it layers in Generally Accepted Government Auditing Standards (the "Yellow Book"), the standard normally associated with federal-award compliance audits, onto every Housing Credit deal's contractor cost certification — not just HOME-funded ones. DCA's companion Contractor Cost Certification Guidelines (CCC) checklist requires the auditor's opinion letter, the General Contractor's Certification, the Multifamily Loan Contractor's Cost Certification of Actual Project Costs, and the Contractor's Cost Certification (Exhibit E) schedule of values, which must reconcile to the contractor's AIA G702/G703 pay applications; any line-item swing between budgeted and actual cost exceeding both 10% and $10,000 requires a written explanation and a completed DCA Executed Change Order Log.
What this research could not confirm is whether DCA additionally requires a separate accountant's certification of the entire development budget or eligible-basis calculation, the way some other states' agencies do. The QAP's own text (§VI.C.2) and DCA's Construction Services exhibits name only the "Contractor's" or "General Contractor's" certification of actual costs — a hard-cost audit, not a certification that on its face covers total project sources and uses. Confirm directly with DCA's Office of Housing Finance whether a separate, broader cost certification is expected as part of the Final Allocation Application before assuming the Contractor Cost Certification is the only accountant sign-off DCA will accept.
8609 issuance: not building-by-building, and the fee that funds it
Georgia's Core Plan is explicit on a point that trips up teams used to other states' practice: "DCA will not issue Form(s) 8609 as buildings are placed in service" (Core Plan §V.F). Read against the Post-Award Checklist, that means 8609 issuance waits for the full Final Allocation Application — cost certification included — rather than releasing incrementally as each building in a multi-building project reaches its own placed-in-service date. The same subsection warns that DCA will not issue a Carryover, LOD, or Form(s) 8609 to Applicants "exhibiting a continual pattern of noncompliance or demonstrating an inability or unwillingness to resolve noncompliance matters in a timely manner" — tying 8609 issuance directly to the same compliance-history tracking that follows a Project Team into future competitive rounds (see Phase 11).
The processing fee behind all of this is substantial and easy to underbudget: an Allocation/Credit Processing Fee equal to 8% of the annual Federal Credit amount, due the 5th day of the month following the Carryover Allocation Date (non-profit sole general partners may request an extension) — or, for 4% Credits/Bonds deals, the 5th day of the month following issuance of the tax-exempt bonds. The QAP's Fees section warns plainly that failure to pay fees when due "may delay processing (e.g., Form 8609) and/or adversely affect the ability to compete in future funding rounds" (Core Plan §IX).
Post-award change control: a locked scope, and a Project Concept Change process that runs the entire extended-use tail
Once an award is made, tenancy, real estate purchase prices, and scope of work cannot change, and the number of units may not be reduced (Core Plan §VIII.B) — construction-cost pressure is not, on the QAP's own terms, a basis for shrinking a deal's unit count. A construction budget that rises more than 10% above the Application figure requires DCA approval, and the utility allowance source elected at Application may not change until eighteen months after placing in service. Separately, after LOD or Carryover issuance, "DCA must approve any significant changes in the financing structure, syndicator, or scope of work" (Core Plan §V.F) — a broader, ongoing approval requirement layered on top of the specific unit-count and UA-source locks.
Changes that do fall inside the allowed lane — amenities, services, or a direct or indirect transfer of a General Partner's or Developer's interest — go through DCA's Project Concept Change (PCC) Form, and the QAP is explicit that this obligation "applies to any changes throughout the project's Extended Use Period or Period of Affordability, whichever is longer" (Core Plan §VIII.B) — meaning the change-notification duty doesn't end at 8609 issuance or even at Year 15; it runs for as long as the LURC or HOME restriction is in effect. The Post-Award Project Concept Change Fee is $2,500 per request generally; for a property already placed in service, the fee was $1,500 and rose to $2,500 as of July 1, 2024.
Where this goes wrong
- Assuming 8609s are issued building-by-building as each is placed in service. DCA's own Core Plan text says the opposite — "DCA will not issue Form(s) 8609 as buildings are placed in service" — and issuance instead follows the full Final Allocation Application process.
- Treating the Contractor Cost Certification as a compilation- or review-level engagement. DCA's own Exhibit B requires a full audit opinion prepared under both GAAS and the Comptroller General's government auditing standards (the "Yellow Book") — a materially higher bar than a plain GAAS audit.
- Assuming DCA's cost-certification audit necessarily covers the entire development budget the way some other states' does. The QAP and Construction Services exhibits name only the General Contractor's certification of actual (hard) costs; this research could not confirm whether a separate, broader accountant certification is also required for the Final Allocation Application — confirm directly with DCA's Office of Housing Finance.
- Waiting for the DCA-assigned inspector to make first contact before flagging construction start. The QAP places the notification burden on the owner: if construction has begun and the assigned inspection company hasn't been in touch, the owner must notify DCA construction services (Core Plan §XI.A.2) — this duty was added in this QAP cycle.
- Assuming inspection costs are always DCA's to pay. Scheduled quarterly increment inspections are billed to DCA, but any additional inspection required because of non-compliance is billed to the Owner.
- Treating the placed-in-service deadline as a fixed "two years from my award" rule rather than checking DCA's own Post-Award Checklist. The operative calendar dates are tied to the competitive round (December 31, 2029 for 2026 awards; December 31, 2030 for 2027 awards), not to each deal's individual Carryover or LOD date.
- Using a prior QAP cycle's 60-day figure for returning the completed 8609 Part II to DCA. The 2026-2027 QAP shortened that window to 30 days after DCA's issuance of Form 8609 Part I, per DCA's own Board-Approved QAP Substantive Changes memo.
- Assuming a construction budget increase above 10% of the Application figure is simply absorbed into the deal. The QAP requires DCA approval for it, and separately requires a written explanation if costs rise more than 10% between Competitive Application and the Front-End Cost Review, with equity closing barred until DCA responds or 45 days pass.
- Changing the utility allowance methodology or source within 18 months of placed in service. The QAP locks it for that period regardless of an owner's operating rationale for wanting to change it sooner.
- Not budgeting for the Allocation/Credit Processing Fee — 8% of the annual Federal Credit amount, due the 5th of the month following the Carryover Allocation Date (or bond issuance for 4% deals). The QAP warns that late payment can delay Form 8609 processing and hurt competitiveness in future funding rounds.
- Assuming a reduced unit count, changed tenancy, or altered scope of work is negotiable after award for cost reasons. Core Plan §VIII.B flatly prohibits all three regardless of construction-cost pressure, and any change that would have reduced the Application's score will not be accepted.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies