"I just received my Carryover or LOD — where in this QAP is the federal 10 percent test spelled out, is my placed-in-service deadline a fixed date or X months from now, and what exactly would make DCA rescind this award?"
The QAP's own Post-Award section — and what it doesn't restate
Core Plan Section V.F, "Post-Award," is the entirety of the QAP's narrative treatment of what happens after an award: DCA will provide its Carryover or Letter of Determination within seventy-five days of receiving a complete Threshold submission (longer if clarifications are needed); following Threshold approval, DCA issues the LOD or Carryover, with a work scope/plan review conference required first for rehabilitation deals; after issuance, DCA must approve any significant change in financing structure, syndicator, or scope of work; "Applicants must meet all deadlines indicated in the LOD. DCA reserves the right to rescind award for failure to meet deadlines in the LOD"; and DCA will not issue a Carryover, LOD, or Form(s) 8609 to Applicants showing a continual pattern of noncompliance or unwillingness to resolve it.
Notably absent: the phrase "10 percent test" does not appear anywhere in the 2026-2027 QAP's text, nor does the QAP restate IRC §42(h)(1)(E)'s reasonably-expected-basis rule (the federal requirement that more than 10% of a project's reasonably expected basis be incurred by the close of the calendar year following the year of allocation, to keep a Carryover Allocation valid). This QAP appears to rely on that federal rule by reference through DCA's separate Carryover Allocation Agreement form, which is not part of this document and which this research did not independently obtain — Applicants should not assume Georgia's carryover mechanics diverge from federal law just because this QAP is silent on the test, but should also not assume the QAP itself restates or modifies it.
Similarly, this QAP's Definitions section defines "Letter of Determination (LOD)" but does not separately define "Reservation" or "Binding Commitment" as distinct LIHTC allocation terms — it simply uses "Carryover," "Carryover Allocation Agreement," and "LOD" in their ordinary federal-practice sense. A related state statute — O.C.G.A. Title 36, Chapter 82, Article 8, the "Georgia Allocation System" governing private-activity-bond volume cap — could plausibly use "Reservation"/"Binding Commitment"-type terminology for bond volume specifically, but this research could not confirm that exact phrasing in that statute's own definitions section (§ 36-82-182) due to access limitations on Georgia's official annotated code. Treat any "Reservation vs. Binding Commitment" framing for Georgia as unconfirmed until checked directly against that statute or GHFA/state bond counsel — it is not terminology this QAP itself uses.
A fixed calendar, not a rolling clock
| 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 |
| DCA Review Submission (HOME Loans only) | 45 days prior to Construction Loan Closing (must include Front End Cost Review) | Same |
| HOME Construction Loan Closing Submission | 10 days prior to DCA Construction Loan Closing | Same |
| Construction Loan / Bond Finance Closing (tax credit-only projects) | Within 180 days of Carryover issuance | Within 180 days of LOD issuance |
| Front-End Cost Review | 45 days prior to Construction Loan Closing | 45 days prior to Construction Loan Closing |
| Commencement Submission | 30 days prior to construction commencement | Same |
| Place in Service (DCA PIS Notification within 30 days of first building's PIS date) | December 31, 2029 | December 31, 2029 |
| 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, 2030 |
| Completion of Work Scope | December 31, 2029 | December 31, 2029 |
| 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, 2030 |
| 8609s with Part II completed and signed | 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 |
The 2027-round column of the same exhibit shifts every one of these dates forward exactly one year (e.g., Place in Service becomes December 31, 2030). Georgia states these as fixed calendar dates rather than "X months/years from Carryover" — a genuinely distinctive design choice worth modeling explicitly, since it means the effective runway an award gets depends on how early or late in its round DCA actually issues the Carryover or LOD.
One specific, easy-to-miss detail: the Completion of Work Scope deadline (December 31, 2029/2030) is identical to the Place in Service deadline in Exhibit B — the QAP does not stage these as sequential milestones the way some states separate substantial completion from placed-in-service certification.
The two gates that actually control near-term timing: 180 days and 45 days
For tax-credit-only projects, the 180-day Construction Loan/Bond Finance Closing window (from Carryover or LOD issuance) is a materially shorter and harder gate than the multi-year placed-in-service date — miss it and there is no stated automatic extension in this QAP's text. For HOME-financed deals, two 45-day-lead-time requirements run in parallel ahead of that same closing: the DCA Review Submission (which "must include Front End Cost Review") and the Front-End Cost Review itself, both due 45 days before Construction Loan Closing — while the separate HOME Construction Loan Closing Submission is due only 10 days before closing. These are easy to conflate because they cluster around the same closing event but carry different lead times and different document sets.
The Front-End Cost Review carries its own disclosed cost-control mechanism: Tax Credit Administration §VI.C.1 requires a Third-Party Front-End Cost Review, and "if costs increase more than 10% between Competitive Application and submission of Front-End Cost Review, owners must submit a written explanation to DCA." DCA then has 45 days to respond, plus any additional days for questions or clarifications, and "Owners may not close equity until after the earlier of this time period expiring or DCA's approval" — meaning an unexplained cost overrun can directly delay equity closing, not just trigger a paperwork request.
What actually terminates a Reservation, Carryover, or LOD
The QAP names exactly two explicit termination-adjacent triggers. First, the missed-LOD-deadline rule from Section V.F: "Applicants must meet all deadlines indicated in the LOD. DCA reserves the right to rescind award for failure to meet deadlines in the LOD." Read literally, this sentence names only the LOD (the 4% bond track's determination letter) — but Exhibit B's Post-Award Checklist applies a parallel set of deadlines to both the 9% Carryover track and the 4% LOD track under one combined table. This research could not confirm whether DCA treats the rescission language as reaching missed Carryover deadlines on the 9% side as well, or whether it is genuinely narrower by design; Applicants relying on either reading should confirm directly with DCA rather than assume.
Second, an ongoing-conduct trigger, not tied to any single deadline: "DCA will not issue a Carryover or 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" (Core Plan §V.F). This is a discretionary, conduct-based bar rather than a single-event rescission trigger, and it can block issuance at any of three separate documents (Carryover, LOD, or the final 8609) rather than only at the initial award stage.
Post-Carryover flexibility is also constrained by Project Reconfiguration/Application Modification (Core Plan §VIII): after award, tenancy, real estate purchase prices, and scope of work cannot change, and "the number of units may not be reduced"; a construction budget increase over 10% from the Application needs DCA approval; the utility allowance source used cannot change until eighteen months after placing in service; and — a catch-all — "any change after award will not be accepted if the change would have reduced Application score," regardless of category. This provision runs for the entire Extended Use Period or Period of Affordability, whichever is longer, not just through the initial post-award window.
The fees due on this clock
| Fee | Amount | Due |
|---|---|---|
| Allocation/Credit Processing Fee | 8% of annual Federal Credit amount | 5th day of the month following the Carryover Allocation Date (non-profit sole general partners may request an extension), or 5th day of the month following tax-exempt bond issuance |
| Post-Award Project Concept Change Fee | $2,500 per request | Invoice deadline |
| Construction Monitoring Inspection Fee | $8,000 per development | At time of 60 Day Submission |
| Credit Compliance Monitoring Fee | Per DCA's published Compliance Monitoring Fee table | Placed-in-service date |
| Final Allocation Application Re-Submission Fee | $1,500 per request | At time of request |
| Non-Compliance Fee | Per DCA's published non-compliance fee list | Within 15 days of DCA invoicing |
The Allocation/Credit Processing Fee — 8% of the full annual Federal Credit amount, not a flat administrative charge — is one of the largest single post-award cash requirements in the entire process and is easy to under-budget if treated as a minor line item.
Failure to pay any fee when due "may delay processing (e.g., Form 8609) and/or adversely affect the ability to compete in future funding rounds," and all fees remitted to GHFA are non-refundable (Core Plan §IX).
Where this goes wrong
- Assuming Georgia's QAP restates the federal 10 percent test / "reasonably expected basis" carryover rule. The phrase never appears in the 2026-2027 QAP text — that timing rule has to come from DCA's separate Carryover Allocation Agreement form or IRC §42(h)(1)(E) directly, not this document.
- Reading "Applicants must meet all deadlines indicated in the LOD. DCA reserves the right to rescind award for failure to meet deadlines in the LOD" as covering only 4% bond deals because it literally names "LOD." The adjacent Post-Award Checklist (Exhibit B) applies parallel deadlines to both the 9% Carryover and 4% LOD tracks in one table — this research could not confirm whether the rescission language reaches Carryover deadlines equally; confirm directly with DCA.
- Treating the placed-in-service deadline as "X months from award." It is a fixed calendar date printed in Exhibit B (December 31, 2029 for 2026-round awards, December 31, 2030 for 2027-round awards) — an award issued early in a round's review window gets meaningfully more effective runway than one issued near the round's own Threshold deadline.
- Missing the 180-day Construction Loan/Bond Finance Closing clock for tax-credit-only projects. It is a separate, much shorter gate than the placed-in-service date, running from Carryover or LOD issuance, with no stated automatic extension in this QAP's text.
- For HOME-financed deals, not sequencing the Front-End Cost Review and DCA Review Submission (both due 45 days before Construction Loan Closing) ahead of the HOME Construction Loan Closing Submission (due only 10 days before closing) — these cluster around one event but run on different lead times.
- Assuming a cost increase can be absorbed without DCA involvement. Tax Credit Administration §VI.C.1 requires written explanation to DCA for any Front-End Cost Review increase over 10% versus the Competitive Application, and equity cannot close until the earlier of DCA's response or 45 days passing.
- Assuming post-Carryover flexibility to fix a shortfall by trimming units, changing tenancy, or adjusting the purchase price. Project Reconfiguration/Application Modification (Core Plan §VIII.B) bars all of these outright after award, and separately bars any change that would have reduced the Application's original score, regardless of category.
- Treating the 8% Allocation/Credit Processing Fee as a minor administrative charge. It is sized off the full annual Federal Credit amount, due the 5th day of the month after Carryover Allocation (or bond issuance), and is one of the largest single post-award cash requirements in the process.
- Assuming a late or corrected Final Allocation Application is simply a scheduling slip. DCA charges a separate $1,500 Final Allocation Application Re-Submission Fee — it is a paid event, not just a deadline extension.
- Assuming "Reservation" and "Binding Commitment" are QAP-defined Georgia LIHTC terms. The 2026-2027 QAP's Definitions section defines "Letter of Determination (LOD)" but not either of those terms; this research also could not confirm that exact phrasing in Georgia's private-activity-bond volume-cap statute (O.C.G.A. Title 36, Ch. 82, Art. 8) — treat any such framing as unconfirmed for Georgia specifically.
- Missing that the Completion of Work Scope deadline is identical to the Place in Service deadline in Exhibit B — Georgia does not stage these as sequential milestones the way some states separate substantial completion from placed-in-service certification.
- Relying on the 50%-of-aggregate-basis federal bond test as still governing 4% deal timing. The One Big Beautiful Bill Act permanently lowered it to 25% for bonds issued after December 31, 2025 — relevant to how much bond volume actually needs to close within the 180-day window, though this QAP does not itself restate the federal test (see Phase 7).
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies