Post-award readiness clock — Mississippi

The chain of dates, in order, from Reservation to Form 8609

Extensions exist but are narrow: a deadline extension request must be submitted in writing at least 10 days before the deadline, for good cause, and cannot exceed 30 days; at the end of that 30-day extension, credits are recaptured absent further good cause, and any granted extension still triggers the late fee schedule in Chart 3 (§7.3).

The 10% test has no cure — and three separate certifications have to back it up

The Carryover Allocation Agreement is what starts the federal 10% test clock: per IRC §42(h)(1)(E)(ii) and 26 CFR §1.42-6, the owner must incur costs exceeding 10% of the development's reasonably expected basis within one year of the Carryover date. The QAP states the consequence in one sentence, with no cure period attached: “Failure to meet the 10% Test by the deadline date will result in the loss of credits” (§7.4(4)).

Proving the test requires three separate, original-signature documents — an Owner certification (Exhibit C), a certified public accountant's certification (Exhibit C-1), and an Owner Certification of Cost Incurred (Exhibit C-2) — all due by the deadline stated in MHC's Carryover letter. Missing that paperwork deadline (as distinct from missing the 10% threshold itself) triggers a late fee under §2.3(4) rather than automatic credit loss, but the underlying 10% shortfall itself is not curable.

The Carryover package also locks in two other elections the owner cannot revisit casually: Building Identification Numbers (Exhibit A) and a Gross Rent Floor election (Exhibit B) under Revenue Procedure 94-57, which determines whether the gross rent floor is set as of the initial allocation date or the placed-in-service date. Owners have only 10 days to flag any errors in MHC's Carryover paperwork itself before a correction penalty applies (§7.4).

Bond-financed (4%) deals run on a completely different clock — and the QAP contradicts itself on the financing threshold that gets you there

A tax-exempt bond development has no Carryover Allocation Agreement and no 10% test at all — the QAP explicitly excuses it: “the development does not have to meet the ten percent (10%) requirements for a carryover allocation” (§1.5(8)(f)). Instead, the clock runs from Bond Inducement: 12 months to Bond Issuance (one 6-month extension available at MHC's discretion for good cause), then 24 months from Bond Issuance to placed-in-service (again, one 6-month extension available) (§1.5(8)(h)). Missing either deadline can revoke eligibility for the 4% credits and jeopardize future bond or credit allocations.

The QAP's own text does not agree with itself about what triggers 100% credit eligibility for a bond deal. Section 1.5(8)(f) states the current federal standard directly: “If twenty-five percent (25%) or more of a development's basis...is financed with tax-exempt bonds, one hundred percent (100%) of the development qualifies for the tax credit.” That 25% figure matches the federal bond-financing test as reduced by the One Big Beautiful Bill Act (Pub. L. 119-21, amending IRC §42(h)(4)(B)) for bonds issued after December 31, 2025. But Addendum C's Required Documents list still asks for “an opinion letter from a Certified Public Accountant certifying that fifty percent (50%) or greater of aggregate basis will be financed by tax-exempt bonds” — the old, pre-2026 federal threshold. The QAP does not reconcile the two anywhere in its text. Get MHC's written confirmation of which percentage it will actually apply to a specific bond issuance before relying on either number, particularly for a deal issuing bonds close to the turn of the year.

Hurricane and wind risk: a scoring choice at application, not an insurance mandate at closing

The QAP contains no separate, freestanding insurance requirement tied to closing — no mandated minimum windstorm or flood coverage, and no Gulf Coast-specific closing condition anywhere in the document. The permanent lender's firm commitment letter must specify “losing and funding conditions” and “loan security requirements,” but the QAP leaves those terms generic (§4.5(1)); any specific insurance line item is a matter for the permanent lender's own underwriting, not an MHC-mandated gate. This research could not confirm whether MHC's Minimum Design Quality Standards (Addendum B) or its site-inspection process impose an implicit wind-resistance construction standard beyond the optional Building Standards scoring item described below — that addendum's construction specifications were not fully reviewed as part of this research.

The state's most direct answer to hurricane and severe-storm risk is a Selection Criteria scoring choice, not a threshold or closing requirement: Addendum A's “Building Standards” item awards up to 7 points to a development that commits to either a green building standard (ICC 700 National Green Building Standard, Silver Level, or Enterprise Green Communities) or the Insurance Institute for Business & Home Safety's (IBHS) FORTIFIED Multifamily™ standard (Gold level), which “addresses specific natural hazard risks… to resist wind, water, and hail damage from tropical cyclones or convective storms.” Earning the points requires a signed letter of intent at application and a written proposal from a FORTIFIED evaluator; the final IBHS certification is not due until Form 8609 is requested — well after placed-in-service, not before closing.

In practice, that means a developer choosing FORTIFIED for the scoring points is making a construction-specification commitment enforced at the back end of the process (8609 request), not a closing-stage insurance requirement enforced by MHC. Whatever windstorm, flood, or named-storm insurance a Gulf Coast or coastal-county deal actually needs to close is a lender- and insurer-driven underwriting question, not something this QAP specifies — confirm actual coverage requirements with the permanent lender and insurer, not the QAP.

What actually revokes an award, and the fee schedule enforcing every deadline above

Section 1.8(8) lists MHC's grounds for denying or revoking a reservation or carryover allocation at its sole discretion: fraudulent application information; failure to pay fees (including late fees); failure to promptly notify MHC of a material or adverse change; any material change made without MHC's written approval; changes to unit design, square footage, unit mix, unit count, or building count without written approval; failure to comply with federal or state Fair Housing law; failure to meet (or falsifying the ability to meet) any timeline MHC has established for the award cycle; or “other cause demonstrating the failure of the Applicant or the Development to be qualified.” No score-reducing change is ever approved, regardless of the reason given (§7.6).

Before Forms 8609 are issued, MHC verifies seven things beyond the cost certification: full development completion matching everything represented in the application (regardless of whether points were awarded for it); a site inspection; no outstanding fees; a final feasibility analysis; an independent third-party CPA cost certification; a Minimum Design Quality Standards certification from the architect/engineer; and a third-party accessibility certification (§7.9(1)-(7)).