"Do we actually need to compete for 9% credits, or can this deal get done as-of-right on bonds and 4%?"
What you are actually choosing
New Hampshire Housing Finance Authority — doing business as NH Housing, created by RSA 204-C in 1981 — is the sole allocating agency for both 9% and 4% credits, and it also allocates its own bond volume cap to developers directly under its Conduit Bond Rules (HFA 116). There is no separate bond-issuing agency to coordinate with the way a CTCAC/CDLAC split requires elsewhere. That single-agency structure changes what "picking a program" even means here.
| 9% (competitive) | 4% (bond-financed) | |
|---|---|---|
| Allocating agency | NH Housing | NH Housing — same agency allocates the bond volume cap under HFA 116 |
| 2026 federal ceiling | Greater of $3.416 × state population or $3,953,600 (Rev. Proc. 2025-32 §4.08) | Not separately capped for LIHTC purposes — limited only by available tax-exempt bond volume, which NH Housing does not publish as a fixed annual number |
| Scored for the credit itself? | Yes — every application is scored and ranked under HFA 109.07.A | No. HFA 109.04.G: "Because 4% LIHTCs are not subject to allocation limits, these applications will not be scored for a LIHTC allocation" |
| When 4% IS scored | — | Only if requesting NH Housing capital subsidy or project-based vouchers through a published NOFO (Track 1). Track 2 — bonds and 4% with no capital subsidy request — is non-competitive unless NH Housing's bond capacity becomes constrained |
| Per-project cap | $942,000 general occupancy / $706,000 age-restricted / $470,000 preservation, any single round (HFA 109.04.A, D) | None |
| Most recent completed round | 6 projects funded, $4,835,000 in credits, 207 units (2026 9% reservations) | FY2027 NOFO: ~$24.4M in capital subsidy across Track 1 and Track 2 |
The FY2027 Tax-Exempt Bond NOFO says it directly: "Tax-exempt bond capacity is not currently constrained; however, if at any time NH Housing's remaining available tax-exempt bond capacity becomes constrained, this Scoring Criteria will be used to make bond funding decisions as well." A 4% deal today is effectively as-of-right on the credit. What isn't as-of-right is NH Housing's own money — capital subsidy and project-based vouchers are still rationed and still scored, just through a NOFO rather than the QAP.
One vintage note: the QAP now in effect (HFA 109, effective March 16, 2026, informally the "2027-2028 QAP") supersedes a version dated March 12, 2024. The only published round-by-round scoring data available is from that prior version — treat point categories and thresholds as current, but don't assume a specific project's old self-score would translate unchanged.
Twinning: New Hampshire's version of hybrid
New Hampshire has a direct, scored analog to a hybrid 9%/4% election, and it's more concretely defined than in states where hybrid is a structuring workaround rather than a named program feature. Scoring item 9.c awards 10 points to a 9% application for including "a 4% and a 9% phase being developed concurrently ('twinned')" — provided the 4% phase itself comprises at least 55 total units. A companion phase under 55 units doesn't qualify for the points even if it is genuinely concurrent.
| Path | Requirement |
|---|---|
| Twinned with an existing 9% award | The bond/4% project is paired with a 9% development that already has a reservation or commitment of LIHTCs |
| Twinned with a future 9% award | Paired with a project intending to apply in the current 9% round for the next credit year |
| Subsequent phase | Qualifies as a Phased Project under HFA 109.06.E and represents a later phase of a previously approved or completed development in good standing — prior phases need not have been NH Housing-financed |
Only Track 1 (twinned or phased, seeking capital subsidy) is competitively scored. A stand-alone conduit bond deal with no capital subsidy request can only apply under Track 2 and is excluded from Track 1 entirely.
The calendars don't line up cleanly. For the round now running, the Track 1 tax-exempt bond deadline is September 1, 2026 — three weeks before the 9% final application deadline of September 25, 2026. Twinning a not-yet-decided 9% project into a Track 1 bond application means filing the bond side before the 9% score, or even the threshold determination, is known.
Points are a gate before they're a ranking
9% applications are scored under HFA 109.07.A, but scoring alone doesn't buy eligibility — HFA 109.06.N sets a minimum score floor by project type, and falling short means the project isn't eligible for a reservation regardless of how it ranks against the field.
| Project type | Minimum score to be eligible | Per-round funding minimum |
|---|---|---|
| General occupancy | 106 points | At least 2 funded per round, threshold and funding permitting |
| Age-restricted | 80 points to be eligible; 100 points to be selected over a higher-scoring application | At least 1 funded per round |
| Preservation / recapitalization | 110 points, with at least 8 of those from the Preservation Scoring Matrix (Appendix J) | Competes in the general pool; ties go to the higher Appendix J score |
That score range is from the prior (March 12, 2024) QAP, not the version now in effect, so the specific point values behind each number have since shifted. What carries forward is the shape of the competition: a small, single-digit-to-low-teens applicant pool per round, not the dozens-deep fields seen in larger states — funded projects in the 2026 round drew allocations of $660,000 to $880,000, all under the $942,000 general-occupancy cap.
The tiebreaker rewards unit count, not soft money
New Hampshire's tiebreaker is a two-step ordinal rule, not a computed percentage. HFA 109.07.B: "the project providing the greatest number of net new housing units is favored," and if still tied, "the lowest amount of LIHTCs per rent-restricted unit (most efficient use of LIHTCs) is favored." The FY2027 Tax-Exempt Bond NOFO uses the identical rule for Track 1 4% scoring ties — greatest number of net new units within the proposed project.
There's no leveraged-soft-resources ratio, no eligible-basis-request ratio, and no opportunity-area percentage-point bonus baked into a tiebreaker formula the way some states build it. Location, income targeting, and resource commitments are scored criteria that get you into the threshold and ranking in the first place — the tiebreaker itself only ever resolves an exact score tie, and it resolves toward more net new units per dollar of credit, not toward the deal that brought the most outside money.
Set-asides, and the one-way door out of 9%
| Set-aside | Mechanics |
|---|---|
| Nonprofit | At least 10% of the annual 9% allocation must go to qualified 501(c)(3)/(c)(4) nonprofits holding a controlling interest and materially participating throughout the compliance period (26 U.S.C. §42(h)(5)). Generally satisfied through ordinary scoring, but NH Housing can select a qualifying nonprofit project over a higher scorer if needed to meet the 10%. |
| Supplemental | $90,000 of the annual 9% allocation reserved for projects already holding a reservation that need supplemental credits, capped at $30,000 per project request (though NH Housing may exceed that at its discretion). Unused balance after September 1 can be made generally available. |
The real one-way door isn't a pool you can't leave — it's a door NH Housing can push you through. HFA 109.08.C: "NH Housing reserves the right to remove a project from the 9% LIHTC application round, regardless of potential score, and convert the project to a 4% LIHTC and Tax-Exempt Bond financed project." The same section adds that "once removed from the application round, NH Housing cannot guarantee successful bond financing for the project." A high-scoring 9% applicant can be redirected to 4% on feasibility grounds alone, with the 9% reservation off the table and bond financing not guaranteed to follow.
Preservation/recapitalization projects face a mirror-image requirement going in: HFA 109.04.D requires submitting both a 9% and a 4% application at the preliminary stage specifically to establish the need for 9% credits — a preservation project that skips the 4% filing hasn't built the record NH Housing needs to keep it on the 9% side if a conversion question comes up.
There's also a pipeline cap: HFA 109.04.B blocks a new 9% application from any applicant (principal, general partner, property owner, or development agent) already carrying two or more incomplete LIHTC projects — 4% or 9% — anywhere, defined as not yet holding a municipal Certificate of Occupancy. Bond-financed 4% projects that don't include NH Housing capital subsidy are excluded from that count, which is one more reason a capital-subsidy-free 4% deal is structurally lighter than either a 9% or a subsidized 4% one.
Calendar, cost of entry, and what follows the sponsor
| Milestone | Date |
|---|---|
| Financing application and exhibit list posted | May 8, 2026 |
| QAP / round information session | May 13, 2026 |
| Pre-application period opens | June 3, 2026 |
| Preliminary applications due | July 10, 2026, 5:00 PM |
| Staff preliminary review memos distributed | August 21, 2026 |
| Final applications due | September 25, 2026, 5:00 PM |
| Multifamily Working Group review | November 12, 2026 |
| Multifamily Housing Committee review | December 2, 2026 |
| Board of Directors vote | December 17, 2026 |
NH Housing's own schedule flags every date as subject to change.
| Track 1 (competitive) | Track 2 (non-competitive) | |
|---|---|---|
| Who files | Twinned or phased projects seeking NH Housing capital subsidy | Stand-alone, twinned, or phased projects not seeking capital subsidy; conduit-only deals must use this track |
| Deadline | September 1, 2026, 4:30 PM ET | Rolling by quarter: Oct 1 → Dec 1 response; Dec 31 → Mar 1; Apr 1 → Jun 1 |
| Scored? | Yes, against the NOFO's own point schedule | No, unless bond capacity becomes constrained |
| Funding available | ~$24.4 million in capital subsidy (State Affordable Housing Fund, HOME, national Housing Trust Fund) under the FY2027 Program Plan | — |
| Fee | Amount | Program |
|---|---|---|
| Pre-application / Letter of Intent fee | $1,000, due at submission | 9% LIHTC only |
| Tax-Exempt Bond application fee | $1,200 | Tax-exempt bond / FFB participation |
| Conduit Bond application fee | $5,000 | Conduit bond program |
| Tax-Exempt Bond / Conduit Bond loan fee | 0.75% of loan amount, capped at $250,000 ($25,000 due at commitment, balance at construction closing) | Bond-financed projects |
| Conduit Bond Participation Spread | 0.375% annually on outstanding tax-exempt loan balance | Conduit bond program |
| LIHTC Allocation Fee | 8% of the total LIHTC allocation (1% at application, 7% at final allocation); refundable less $1,000 if withdrawn before reservation, non-refundable after | 4% and 9% LIHTC |
| LURA upfront monitoring fee | $725/unit (30-yr) / $1,085/unit (45-yr) / $1,450/unit (60-yr) / $1,810/unit (75-yr), scaling by LURA term | 4% and 9% LIHTC |
The allocation fee alone runs roughly $70,000 on an $880,000 9% award — larger than the entire flat filing fee some states charge for the whole application.
| Structure | Minimum LURA term |
|---|---|
| 9% LIHTC | 60 years (75 years if the applicant elects the 3-point scoring commitment) |
| 4% LIHTC with tax-exempt bonds and NH Housing capital subsidy | 45 years |
| 4% LIHTC with tax-exempt bonds, no NH Housing capital subsidy | 30 years |
Program election isn't reset each round at the sponsor level. Scoring item 14.a applies a discretionary 1-to-20-point deduction for a development team with outstanding NH Housing arrears, non-compliance history (in New Hampshire or with another state housing finance agency), or previously returned/unused credits. Item 14.b carries an unfulfilled scoring commitment forward as a penalty on the sponsor's next application. Item 14.c applies a flat 5-point penalty to any sponsor that has pursued a qualified contract in New Hampshire within the last five years. All three follow the sponsor and its related parties across rounds and across the 4%/9% line, not just within one application.
Where this goes wrong
- Assuming a 4% deal gets scored and ranked the way a 9% deal does. It isn't scored for the credit at all — HFA 109.04.G says so directly — unless it's also requesting NH Housing capital subsidy or project-based vouchers through a published NOFO, and even then only Track 1 (twinned/phased) applications are competitive by default.
- Treating tax-exempt bond capacity as permanently unconstrained. The FY2027 NOFO says capacity is not currently constrained, but reserves the right to apply scoring criteria to bond decisions the moment that changes — an as-of-right deal today isn't guaranteed to stay that way.
- Assuming a high-scoring 9% application is safe from being redirected. HFA 109.08.C lets NH Housing remove any project from the 9% round, regardless of score, and convert it to 4%/bonds, with no guarantee that bond financing will actually close afterward.
- Filing a preservation/recapitalization project's preliminary application as 9%-only. HFA 109.04.D requires both a 9% and a 4% application at the preliminary stage specifically to establish the need for 9% credits.
- Counting a small companion phase as "twinned" for the 10-point scoring bonus. Item 9.c requires the 4% phase to comprise at least 55 total units — a smaller concurrent phase doesn't qualify even if genuinely simultaneous.
- Filing the FY2027 Track 1 bond application assuming it comes after the 9% decision. The Track 1 deadline (September 1, 2026) falls three weeks before the 9% final application deadline (September 25, 2026) for the same round.
- Comparing this cycle's 106/80/110-point minimum thresholds against the only published score data (the 2025 round, 78-154) as if they're the same scale. That data was scored under the prior QAP (dated March 12, 2024); the current QAP's point categories and values have since changed.
- Treating the LIHTC Allocation Fee like a flat filing fee. It's 8% of the total LIHTC allocation amount — roughly $70,000 on an $880,000 9% award — and once a reservation is made, none of it is refundable.
- Electing the 75-year LURA for its 3 scoring points (HFA 109.07.A item 19, 9% LIHTC only) without pricing the actual fee step-up: a standard 9% deal's default 60-year term already costs $1,450/unit in upfront monitoring fees, so committing to 75 years raises that to $1,810/unit -- a $360/unit increase, not the $725-to-$1,810 span the full fee scale might suggest.
- Requesting a specific source of NH Housing capital subsidy (HOME, AHF, HTF) in the application. Applicants may not request a specific source and must underwrite to the most restrictive one — typically HOME or HTF, which pulls in Build America, Buy America compliance — regardless of what's actually awarded.
- Applying for a second 9% project while an earlier award hasn't reached Certificate of Occupancy. HFA 109.04.B blocks a new 9% application from any applicant already carrying two or more incomplete LIHTC projects, 4% or 9% — though bond-only 4% deals without NH Housing capital subsidy don't count toward that cap.
- Assuming an age-restricted project just needs to clear the 80-point threshold. It needs 100 points to be selected over a higher-scoring application when NH Housing is filling its per-round minimum of at least one age-restricted award.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies