"Does this deal chase a lottery number across three separate RFAs, or take the non-competitive bond/4% path where the real competition is for the SAIL gap dollars instead?"
9% is competitive by geography and sorting chain, not by a single score
FHFC's 9% RFAs award only 10–15 additive points total, almost entirely for administrative compliance (a timely-stamped Principals Disclosure Form, bookmarked attachments, a small Local Government Contribution item). Real 2026 data shows 144 of 149 applicants across all three geographic RFAs tied at the maximum score. What actually allocates credits is a sorting chain of non-scored preferences applied in order — Development Category, Leveraging Classification, Proximity, Permit Ready Tier status, Developer Experience, Florida Job Creation — ending in a random lottery number. This exact chain, including the Permit Ready Tier and Developer Experience steps, is new for the 2026 cycle; FHFC's own 2026 workshop materials show both were added this cycle and were not tiebreakers in the 2024/2025 RFA generations. The membership and order of that chain is not fixed: it changes depending on which named Goal (general pool, Local Government Areas of Opportunity, SunRail) is being filled within the same RFA.
4%/bonds are close to as-of-right — the SAIL gap money is where the real competition moved
Non-Competitive (4%) Housing Credits paired with tax-exempt bonds are not scored or ranked against other applications at all — a development that clears the federal basis test and Credit Underwriting is essentially entitled to its 4% allocation. That basis test has two versions since the One Big Beautiful Bill Act (Pub. L. 119-21, §70422(b)(1), signed July 4, 2025): the longstanding 50% test (at least half the aggregate basis of the buildings and land financed by volume-cap tax-exempt bonds) still applies, but for bonds issued after Dec. 31, 2025 that finance at least 5% of aggregate basis, a much more favorable 25% test now qualifies instead — for virtually every 2026-vintage bond issuance, the 25% test is the relevant one, not 50%. Florida's own rule restates the (still-current) 50% version three separate ways depending on who is issuing the bonds — FHFC's own Multifamily Mortgage Revenue Bond program, a county Housing Finance Authority, or any other issuer — each under its own rule subsection; this session did not confirm whether FHFC's rule has yet been updated to also restate the newer federal 25% alternative. But the SAIL gap financing that usually makes a 4%/bond deal actually feasible is competitively scored, using a shorter, differently-ordered preference chain than the 9% RFAs: the most recent confirmed SAIL/4%/bond RFA text (RFA 2025-205, the direct predecessor of the not-yet-issued RFA 2026-205) runs Leveraging Classification, then Proximity Funding Preference, then a Florida Job Creation Funding Preference, ending in a lottery number — a shorter chain than the 9% RFAs', without a Developer Experience tiebreaker step (Developer Experience is a pass/fail eligibility item in this RFA family, not a scored preference).
The hybrid question is really "which bond issuer"
Several Florida counties operate their own Housing Finance Authorities as alternative bond issuers to FHFC's own program — a real choice affecting process, fees, and which local relationships matter, distinct from the state-level 9%-vs-4% election itself. This session did not independently research the comparative mechanics of county HFA-issued bonds versus FHFC-issued MMRB in enough depth to generalize a recommendation; treat the issuer choice as needing deal-specific confirmation rather than a fixed rule.
Where this goes wrong
- Treating FHFC's RFA score as the competitive lever for a 9% deal — 96% of real 2026 applicants tied at the maximum possible score; the sorting chain below the score is what actually allocates credits.
- Assuming the sorting-chain order and membership is fixed across programs — the confirmed SAIL/4%/bond RFA chain (Leveraging Classification → Proximity → Job Creation → lottery) is shorter than, and ordered differently from, the 9% geographic RFAs' chain, and has no Developer Experience tiebreaker step at all.
- Assuming a 4%/bond deal automatically has enough soft money once the bonds close — the credits and bonds are close to as-of-right, but the SAIL gap dollars that typically make the deal pencil are themselves competitively awarded on their own RFA cycle.
- Applying only the federal 50% test to a 2026-vintage bond deal — bonds issued after Dec. 31, 2025 financing ≥5% of basis can qualify under a new, more favorable 25% test instead (One Big Beautiful Bill Act, 2025); and even the 50% test is restated three separate ways in Florida rule depending on whether FHFC, a county HFA, or another issuer is issuing the bonds.
- Filing more than 3 related Priority 1 applications across the shared small/medium + eight-county + Miami-Dade pool — the cap is shared across all three RFAs at once, and exceeding it risks downgrade to Priority 2 or, post-award, rescission with a misrepresentation finding against every affiliated Principal.
- Assuming a Rehabilitation deal competes on equal footing in the general geographic RFAs — FHFC's own rule defines "Preservation" narrowly (20+ years old, an active HUD/RD contract) and funnels genuine preservation deals toward dedicated tracks instead.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies