A clock that starts at the reservation letter, not a fixed post-award calendar — Rhode Island

The reservation letter, not a fixed date, starts every clock

Unlike QAPs that publish a fixed placed-in-service calendar date tied to the award year, Rhode Island's post-award clock runs entirely relative to "an executed reservation letter for LIHTCs." The chain of deadlines comes from the same Readiness to Proceed provision (Section III.A.4) that RIHousing uses to evaluate the application in the first place -- there is no separate post-award chapter or deadline exhibit in this QAP.

RIHousing's own version of the federal 10 percent test

Inside the QAP's Placed-In-Service Requirements section, RIHousing states its own credit-integrity rule this way: RIHousing "will allocate credits only to projects which can be reasonably expected to become eligible for the credits in the year in which the Developer is to be awarded LIHTCs. This means that projects must either be able to be placed-in-service in that year or have incurred more than 10% of their reasonably anticipated project basis within 12 months of the reservation of LIHTCs."

That is Rhode Island's own administrative framing of the concept behind the federal "10 percent test" under IRC Section 42(h)(1)(E)(ii) -- but the QAP text never uses the phrase "10 percent test" and never cites that federal statute directly, and its "12 months of the reservation" framing is not a word-for-word restatement of the federal rule's own timing formula (generally, basis incurred by one year after the calendar year the allocation was made). Developers should confirm the precise federal test and its exact triggering date with tax counsel or their CPA for a given allocation year, rather than rely on RIHousing's QAP paraphrase as a substitute for the federal statute.

The credit amount itself is not locked in at reservation. RIHousing states that it "must evaluate the amount of the credit at 3 specific times: (1) at the time of application, (2) at the time of reservation, and (3) at the time the building is placed-in-service and an IRS Form 8609 is issued" -- meaning a project's final credit amount can still move at the very end of this clock, based on actual costs and other subsidy secured, not just at the beginning.

The Carryover Allocation Agreement: named, but not dated, in the QAP itself

The QAP's own glossary defines "CAA" as "Carryover Allocation Agreement," and its Readiness to Proceed provision lists "a developer's ability to meet the requirements to receive a Carryover Allocation Agreement ('CAA')" as one of several factors RIHousing weighs in judging continued readiness to proceed. Nowhere in the QAP text read for this research does RIHousing state the deadline by which a CAA must actually be executed for a given reservation.

As general background -- not something this QAP itself restates -- the federal default under IRC Section 42(h)(1)(E)(i) is that a Carryover Allocation Agreement, where a project will not be placed in service in the year of allocation, generally must be entered into by the close of the calendar year in which the credit is allocated. Treat that as the applicable federal baseline to confirm directly with RIHousing and with tax counsel for a specific reservation year, not as a date this QAP spells out on its own.

What actually triggers a rescission

The QAP gives RIHousing broad, largely discretionary rescission authority that operates independently of any single missed date. During the review period, "[i]n the event that RIHousing determines that the project is not feasible as proposed or that a change in circumstances has materially altered the proposal as submitted and approved, RIHousing reserves the right to rescind reservations of LIHTCs for projects," with any such rescission required to be in writing.

Separately, once a reservation is in place, RIHousing "reserves the right to adjust aggregate assessments and scores or to rescind a reservation of LIHTCs if there is a material change in the project including, but not limited to, a change in the general partner, the construction start date which adversely affects the achievement of stated goals and/or diminishes the proposal's ability to address documented housing needs or significant changes to the budget." None of these triggers is tied to a specific calendar date -- infeasibility, a GP change, a construction-start slip, or a "significant" budget change are each independently sufficient.

A separate, categorical eligibility bar can also surface post-award if a principal's history only comes to light later: any application "containing a principal that was a principal in an owner that has, in RIHousing's determination, previously participated, on or after January 1, 2019, in a foreclosure in Rhode Island (or instrument in lieu of foreclosure) that was part of an arrangement a purpose of which was to terminate an extended low-income housing commitment... shall be rejected from further consideration for low-income housing tax credits and shall not be eligible for any reservation or allocation of credits." This is framed as an application-eligibility rule rather than a post-award rescission trigger, but it can effectively end an award if the disqualifying history is discovered after reservation.

The fees due on this clock

Two of the three fees described in Phase 8 land specifically on this post-award clock: the tax credit allocation fee (0.5% of the 10-year allocation for 9% credits, 1.0% for 4% credits) is due at closing, and RIHousing's underwriting fee is charged for the review that leads up to it. This research did not find a comparably detailed, itemized schedule of ongoing post-closing compliance-monitoring fees in either the QAP or the 2026 Program Bulletin -- both documents reference RIHousing's separate Compliance Monitoring Manual for compliance requirements generally, and that manual (not analyzed in this research pass) is the actual source to check directly for any recurring monitoring fee schedule, rather than assuming one from the application-stage fee tables alone.

After placed-in-service: Form 8609, a 30-year Declaration, and a waived exit right

Placed-in-service triggers the third and final credit-amount checkpoint above and RIHousing's issuance of IRS Form 8609. At that point the owner must execute a Declaration of Land Use Restrictive Covenants setting an extended-use period of affordability "of at least 30 years" -- the federal minimum 15-year compliance period plus a 15-year extended-use period under IRC Section 42(h)(6)(D), or, for bond-financed deals, "the greater of (i) the period that the tax-exempt bonds remain outstanding or (ii) 30 years."

As part of that Declaration, "[t]he owner must waive the right to seek termination of the Declaration by petitioning RIHousing to find a buyer of the development as provided in IRC Section 42(h)(6)(E)(i)" -- RIHousing does not allow the standard federal 14-year qualified-contract exit route. A Regulatory Agreement must also be recorded ahead of any lien documents, survive foreclosure, and bind any lienholder that subordinates to it.