"MHC runs the 9% competitive round and the 4% tax-exempt bond round through the same QAP, and the QAP itself gives two different numbers for the federal bond test depending on which page I read — so which is it, who actually issues the bonds if I go that route, and is there a Mississippi state credit I should be stacking on top of the federal one?"
A document quietly still labeled 2024, describing itself as the 2026 QAP
The file MHC posted to its own website as the "Approved 2026 Qualified Allocation Plan" (posted December 18, 2025, at mshomecorp.com) is titled, in its filename, "2026 QAP_FINAL_Addendum L." The document's own narrative text confirms it is describing the 2026 cycle: "On November 5, 2025, MHC... held a public hearing... for the purpose of receiving comments on a draft of Mississippi's 2026 Qualified Allocation Plan," and its Important Dates chart runs entirely on 2026 calendar dates (Application Cycle Closes April 3, 2026). Yet every single page footer throughout the roughly 150-page document reads "2024 QUALIFIED ALLOCATION PLAN │ Mississippi Home Corporation" — not 2025, not 2026. This is the base-document-carried-forward pattern seen in several other states researched for this library: MHC appears to have amended a 2024-vintage master file in place across at least three annual cycles without updating the running footer, even as the substantive dates, set-aside dollar amounts, and (as described below) at least one federal-test percentage were updated for 2026.
The document's own introduction adds a second, harder-to-explain wrinkle: it states the plan "was presented to the Governor of the State of Mississippi, who formally approved its terms by Resolution received by MHC on December 27, 2024" — a date that precedes the November 5, 2025 public hearing described one sentence earlier in the same paragraph. This research could not resolve that sequencing directly with MHC and treats it as further evidence that the introduction's boilerplate was carried forward from an earlier year's QAP without full revision, not as a claim that the 2026 QAP was somehow approved before its own public hearing. A developer relying on this document should independently confirm with MHC's Allocation staff that no further board action postdates the "3022026" file date embedded in the PDF's own filename.
One QAP, two federal tracks — and a real point-score floor on both
Unlike states that run the 4% bond credit as a pure as-of-right queue, Mississippi requires every application — 9% or 4% — to clear a minimum score under the Selection Criteria. Addendum A states this directly: "Competitive Applications must score a minimum of eighty-five (85) points to be considered for a reservation of housing tax credits. Tax Exempt Bond Applications must score a minimum of 80 points to be considered for housing tax credits." The 4% track is not scored competitively against other 4% applications for a fixed pool the way the 9% round is, but it is still a genuine threshold a bond deal must clear on Mississippi's own point scale (site location, building standards, development type, deeper targeting, and the rest of Addendum A) — not merely a feasibility or Mandatory-Components review.
| 9% Credits | 4% Tax-Exempt Bond Credits | |
|---|---|---|
| Timing | One annual competitive cycle (2026: Application Cycle March 30–April 3) | Rolling; accepted "anytime outside of the 9% cycle" and reviewed before/after it |
| Minimum score to be considered | 85 points (Addendum A) | 80 points (Addendum A) |
| Rationing mechanism | Ranked competition within Set-Asides (Non-Profit, Smaller Credit, Rehabilitation, New Construction) | Sized by eligible basis / bond volume actually issued, not a separate fixed dollar pool |
| Bond issuer | N/A | MHC itself, as conduit issuer (bonds are not MHC's or the state's indebtedness) |
| Application fee | $1,500 | $3,500 (Tax-Exempt Bond Inducement Fee) |
| 10% carryover test | Applies | Does not apply — bond-financed deals are exempted from the Section 7.4(4) 10%-cost test |
2026 QAP (as MHC's own text describes it; page footers read "2024"), Section 1.5(8)(f), Section 2.3, Addendum A introduction.
The federal bond test: MHC's own document gives two different numbers
The operative eligibility clause, Section 1.5(8)(f), states: "If twenty-five percent (25%) or more of a development's basis (total development cost including land) is financed with tax-exempt bonds, one hundred percent (100%) of the development qualifies for the tax credit without a decrease in the state's allocation." That 25% figure tracks the federal One Big Beautiful Bill Act (OBBBA, Pub. L. 119-21, §70422 (2025)), which lowered the longstanding 50%-of-aggregate-basis test under IRC §42(h)(4)(B) to a 25% alternative for buildings placed in service after December 31, 2025, conditioned on at least 5% of aggregate basis being financed by bonds issued after that date. MHC's own restatement in Section 1.5(8)(f) does not mention that 5%-of-post-2025-bonds condition, OBBBA, the One Big Beautiful Bill Act, or Pub. L. 119-21 anywhere — a direct text search of the full document turns up none of those terms. A bond deal should confirm with bond counsel that its specific bond-issuance timing actually satisfies the full federal test, not just MHC's flat, unconditioned 25% restatement.
But the very next required-document instruction elsewhere in the same QAP was not updated to match. Addendum C's Required Documents list, item 16, still reads: "Tax Exempt Bond Financed Developments 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." This is not a typo isolated to one draft — MHC's own published "Executive Summary, 2026 QAP Proposed Revisions" (dated October 2, 2025) shows the redline that updated Section 1.5(8)(f) from "fifty percent (50%)" to "twenty five percent (25%)," including the CPA-opinion-letter sentence that sits inside that same section. That redline never touches Addendum C's separate copy of the same CPA-certification requirement, which is why the final, board-adopted document still shows 50% there. A developer preparing the CPA opinion letter for a bond application should follow the operative 25% standard in Section 1.5(8)(f) — confirmed current by the Executive Summary's own redline — and flag the Addendum C discrepancy with MHC's Allocation staff directly rather than assume either number silently controls.
All bond-financed developments including 4% credits must still "score a minimum of 80 points under the selection criteria requirements outlined in Addendum A," but do not have to meet the 10% carryover-allocation cost test in Section 7.4(4). An opinion letter from a CPA must accompany the application, and tax-exempt bond applications should be submitted at least 60 days before the scheduled bond closing; applicants get 18 months from Bond Inducement to submit the tax credit application package, or face a second $3,500 application fee.
Who actually issues the bonds: MHC as mandatory conduit issuer, MDA behind the statewide cap
The QAP is unambiguous on this point: "MHC can act as a conduit issuer of tax-exempt bonds; however, the bonds do not constitute an indebtedness of MHC or the State of Mississippi. For all developments utilizing the Housing Tax Credit Program, MHC must act as a conduit issuer of the tax-exempt bonds." That last sentence forecloses routing an HTC-linked bond deal through a different issuer of record — MHC is the mandatory conduit issuer whenever the tax credit program itself is in play, not one option among several. Developers who select non-Mississippi bond counsel trigger an added requirement: MHC engages its own general counsel, at the applicant's cost, to confirm conformity with Mississippi bond law. Fees are a $3,500 non-refundable inducement fee plus a servicing fee of 20 basis points (minimum $10,000) on principal under $15 million, or 15 basis points or $30,000 — whichever is higher — on principal at or above $15 million.
This research separately confirmed that the Mississippi Business Finance Corporation (MBFC) operates its own Industrial Development Revenue Bond program — but that program is aimed at companies locating or expanding operations in the state, not multifamily rental housing, and this research found no documentation of MBFC issuing bonds for LIHTC-linked multifamily deals. Given the QAP's own unconditional requirement that MHC be the conduit issuer for any development using the Housing Tax Credit Program, MBFC does not appear to be an alternate path for a Mississippi HTC bond deal. Confirm this directly with MBFC and MHC before assuming otherwise, since this research could not review MBFC's own bond documents directly.
A separate agency sits behind the state's overall tax-exempt bond math. Under the Mississippi Private Activity Bonds Allocation Act (Miss. Code §§ 31-23-51 through 31-23-69), the entity that determines and administers the state's annual private-activity-bond ceiling — dividing it into a "threshold portion" and an "undesignated portion" and issuing the notices of allocation that let any issuer, MHC included, actually draw bond volume — is statutorily defined as "the Mississippi Board of Economic Development, or its successor." Separately, Miss. Code § 57-1-54 establishes the Mississippi Development Authority (MDA) as that successor body (formerly the Department of Economic and Community Development). In practice this means two different state entities touch a Mississippi HTC bond deal: MDA administers the statewide volume-cap ceiling and allocation system that all Mississippi bond issuers draw from, while MHC is the actual conduit issuer of the housing bonds themselves once an allocation is secured. This research did not confirm the exact administrative mechanics MHC and MDA use to coordinate a housing-bond allocation request — confirm the current process directly with MHC's bond counsel contact.
No Mississippi state tax credit for affordable housing — confirmed, not assumed
Search engines return confident-sounding references to both a "Mississippi Workforce Housing Tax Credit Act" and a "Mississippi Affordable Housing Tax Credit Act," each described as a state income/franchise/insurance-premium tax credit for LIHTC investors, administered by MHC, capped at $4,000,000 per year. Tracing this directly to the Mississippi Legislature's own bill-history records shows why that description is misleading: both names refer to the same recurring bill, introduced and killed in committee every session for which records were checked — SB 2494 (2021), SB 2485 (2022), SB 3057 (2023), HB 1717 (2024, "Died In Committee" 3/27/24 per the Legislature's own bill-history record), and SB 2253 (2025, "Died In Committee" 2/26/25, also per the Legislature's own record). None of these bills was ever enacted. As of this research, Mississippi has no state tax credit that pairs with the federal LIHTC to boost investor equity, unlike Georgia's, Missouri's, or Illinois's state credit mechanisms.
| Session | Bill | Result |
|---|---|---|
| 2021 Regular Session | SB 2494 | Introduced; not enacted |
| 2022 Regular Session | SB 2485 | Introduced; not enacted |
| 2023 Regular Session | SB 3057 | Introduced; not enacted |
| 2024 Regular Session | HB 1717 ("Mississippi Affordable Housing Tax Credit Act") | Died in committee, March 27, 2024 |
| 2025 Regular Session | SB 2253 ("Mississippi Workforce Housing Tax Credit Act") | Died in committee, February 26, 2025 |
Mississippi Legislature, official bill history records (billstatus.ls.state.ms.us) for each session cited. This research did not independently confirm whether a further bill was introduced in the 2026 Regular Session; the pattern above runs through 2025.
The bill text itself (SB 2253, as introduced, 2025 Regular Session) is worth knowing even though it never passed, since it is likely to resurface in a future session in similar form: it would have capped total state credits certificated to all qualified projects at $4,000,000 per year, limited each project's state credit to no more than its federal housing tax credit amount, and run on the same 10-year credit period as the federal LIHTC. A developer should not build a 2026-vintage Mississippi capital stack around this credit existing — it does not, as of this research — but should watch for its reintroduction.
Set-Asides: how MHC actually rations the 9% pool
| Set-Aside | Share of Annual Credit Authority (ACA) | Per-development cap | Key conditions |
|---|---|---|---|
| Non-Profit | ≥10% of ACA (IRC §42(h)(5) floor) | $900,000 (<60 units) / $1,800,000 (≥60 units) | Ranked by score; unfunded eligible non-profits get priority in the general pool if the 10% floor isn't otherwise met |
| Smaller Credit Amount | 25% of ACA | $330,000 | New construction must be ≥24 units, no waivers below 24; multiphase developments ineligible |
| Rehabilitation | 65% of ACA remaining after Non-Profit + Smaller Credit | $900,000 (<60 units) / $1,800,000 (≥60 units) | — |
| New Construction | 35% of ACA remaining after Non-Profit + Smaller Credit | $900,000 | — |
2026 QAP, Section 3 (Set-Asides). MHC also caps funding to a single development type (single-family vs. multifamily) at 65% of the relevant credit pool, with a partial-award formula if an eligible award would otherwise exceed that share.
Two award-level limits apply across every Set-Aside. First, an owner/developer/GP/affiliate/guarantor/principal cannot receive more than 25% of total credits reserved or allocated for the round, absent an MHC waiver for undersubscription, geographic concentration, or a similar stated reason. Second, applicants electing the Smaller Credit Amount Set-Aside are locked out of the waiver process available elsewhere for the 24-unit minimum — a stricter rule than the general 24-unit development-size floor in Section 1.2(2), which does allow a waiver request.
Where this goes wrong
- Citing the Required Documents checklist's 50% bond-financing figure (Addendum C, item 16) as MHC's current standard — the operative eligibility clause (Section 1.5(8)(f)) was updated to 25% for the 2026 QAP, per MHC's own published redline, but the Addendum C cross-reference was never brought into line with it.
- Assuming MHC's flat 25% aggregate-basis figure is the complete federal test — OBBBA's actual 25% alternative under IRC §42(h)(4)(B) is conditioned on at least 5% of aggregate basis being financed by bonds issued after December 31, 2025, a condition MHC's own restated clause omits entirely.
- Treating the document's "2024 QUALIFIED ALLOCATION PLAN" page-footer label as evidence you're looking at a stale plan — the document's own text and 2026-dated Important Dates chart confirm it is the adopted 2026 QAP; the footer itself was simply never updated across at least three annual cycles.
- Assuming a Mississippi state housing tax credit exists because search results describe one confidently — the "Mississippi Workforce/Affordable Housing Tax Credit Act" has been introduced and died in committee every session checked (2021 through 2025); none was enacted.
- Assuming the 4% Tax-Exempt Bond track is an as-of-right queue — Mississippi requires bond-financed applications to score a minimum of 80 points under Addendum A's Selection Criteria, a real point-score floor most as-of-right bond states don't impose.
- Assuming a local development authority, county, or MBFC can serve as an alternate bond issuer for an HTC-linked deal — the QAP requires MHC itself to act as conduit issuer for "all developments utilizing the Housing Tax Credit Program," with no stated exception.
- Confusing MHC's own conduit-issuer role with the separate statewide private-activity-bond ceiling administered under Miss. Code §§ 31-23-51–69 by the Mississippi Development Authority (the statutory successor to the "Mississippi Board of Economic Development") — these are two different agencies performing two different functions in the same bond deal.
- Filing a 4% application during the 9% competitive cycle window expecting it to be reviewed — MHC states 4% applications are accepted "anytime outside of the 9% cycle" and reviewed only before or after that window, not during it.
- Missing the Smaller Credit Amount Set-Aside's stricter no-waiver rule — unlike the general 24-unit minimum in Section 1.2(2) (which allows a waiver request), new construction competing in the Smaller Credit Set-Aside cannot waive below 24 units at all.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies