"Which of Florida's three simultaneous RFAs is this parcel even competing in?"
Three RFAs, not one round — and geography decides the pool
FHFC's current 9% Housing Credit architecture runs three geographic RFAs at once rather than one statewide scored round: Small and Medium Counties, an eight-county "large" RFA, and a standalone Miami-Dade RFA with a hard cap of three awards. A county's population band is fixed by the state, not chosen by the developer, and it determines the funding pot, the maximum credit request per deal, and the minimum Extremely Low Income set-aside a project must carry — all before site quality or design enters the picture.
| RFA | Geography | 2026 est. HC available | 2026 applications | 2026 recommended awards |
|---|---|---|---|---|
| 2026-201 | Small (pop. ≤100,000) and Medium (100,001–824,999) Counties | $23,449,270 | 74 | 9 |
| 2026-202 | Broward, Duval, Hillsborough, Lee, Orange, Palm Beach, Pinellas, Polk | $33,633,880 | 44 | 10 |
| 2026-203 | Miami-Dade County alone (hard 3-award cap) | $10,935,850 | 32 | 3 |
Within the small/medium pool, the two sub-pots don't cross-subsidize: Small County funding ($1.94M in 2026) and Medium County funding ($21.5M) are tested completely separately, so a Small County site is never actually competing against a Medium County one for the same dollar — real 2026 data shows 8 of 2026-201's 9 awards went to Medium County. Geography keeps mattering inside the eight-county RFA, too: it guarantees Broward at least 2 awards and six other named counties at least 1 each, and FHFC's own 2026 RFA text states it will alternate a single award between Lee and Polk Counties each year because a Shimberg Center market study found less need there — Polk got that slot in 2026 (1 award), Lee got zero.
Proximity is a real GIS exercise with a hard eligibility gate
Distance to transit, grocery, medical, pharmacy, and school is scored against a defined taxonomy of distance bands, measured from a specific Development Location Point (latitude/longitude) an applicant certifies for the site, to a technical accuracy standard set under Florida's surveying and mapping rule. This is not a scoring nicety — FHFC states directly that a non-LGAO/non-SunRail Medium County application needs at least 7.0 proximity points just to be funding-eligible at all, before any preference or tiebreaker even applies.
Two other geography-driven mechanics belong in the screen: a distinct, narrower funding priority exists for the Florida Keys Area of Critical State Concern and the City of Key West, reflecting how much harder it is to finance and build there; and Florida's 2023 Live Local Act can make a commercial-, industrial-, or mixed-use-zoned parcel eligible for as-of-right multifamily development at the highest density/height/FAR allowed nearby, regardless of what the site's own current residential zoning designation says — meaning the screen has to check Live Local eligibility as a separate question from conventional zoning, not fold it in.
Where the data actually lives, and where the screen stops
The Florida Housing Data Clearinghouse, produced by the University of Florida's Shimberg Center for Housing Studies and jointly funded with FHFC, publishes GIS-queryable housing-inventory and assisted-housing data (CSV/KML/GeoJSON/GeoTIFF, with WMS/WFS API access) — the closest thing Florida has to a centralized public screening layer, though this session did not independently verify its parcel-level zoning coverage or refresh cadence the way the CA guide does for SCAG/LCI.
Rent and income limits are federal, not Florida-specific — HUD's Multifamily Tax Subsidy Project limits set the ceiling the same way they do everywhere else; FHFC does not publish a separate state income-limit schedule. What screening cannot do in Florida is tell a developer whether a specific local government will actually process a Live Local administrative approval the way the statute describes, or which competitors are quietly assembling applications for the same county's tally this cycle — that belongs to the developer's own judgment, dated and recorded, not synthesized as a dataset.
Where this goes wrong
- Screening a Small County site as if it competes on equal footing with Medium County sites in the same RFA — the two funding pots are tested separately, and Small County's much smaller pot supported only 1 of 9 awards in the 2026 cycle.
- Assuming Lee County is "this year's" fundable large county — FHFC's own 2026 RFA text states an explicit Lee/Polk alternation policy, and Lee received zero of the eight-county RFA's 10 awards in 2026 by design.
- Treating the Miami-Dade RFA like the other two — it runs a hard 3-award cap filled by named goal slots (a family/SADDA application, a transit-designated application, an elderly application), not a funding-test tally against a ranked list.
- Conflating Live Local Act administrative zoning approval with an FHFC funding award — a site can gain Live Local's by-right density and height and still receive zero Housing Credits if it doesn't separately win an RFA.
- Certifying an imprecise Development Location Point — proximity scoring is measured from that specific coordinate to a real technical accuracy standard, and a non-LGAO/non-SunRail Medium County application needs at least 7.0 proximity points simply to be funding-eligible.
- Missing the Florida Keys/Key West Area of Critical State Concern priority track — a real, narrower funding lever for sites in an area FHFC itself describes as unusually hard to finance and build in.
- Confusing the small, near-automatic "Local Government Contribution" scoring points with the much harder Local Government Areas of Opportunity cash-contribution threshold — they are different mechanics with very different dollar bars (see Phase 7).
- Assuming Florida runs one annual statewide round the way Texas or California do — the RFA menu, funding amounts, and even which counties are grouped together change from cycle to cycle and must be re-checked against the current year's RFA index, not assumed stable.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies