Site sourcing and screening — Northern Mariana Islands

Confirming which QAP actually governs -- and which of NMHC's application rounds is currently open

NMHC is a small territorial housing finance agency, and its LIHTC program is sized accordingly: the round that opened in 2025 carried a $3,455,000 annual credit ceiling, and the round that opened in 2026 carried a $2,887,252 ceiling. Both rounds ran under the same document -- a single 23-page Qualified Allocation Plan titled the "2025-2026 QAP," covering both credit years. Every page carries a "DRAFT" watermark; this build confirmed that watermark is NMHC's routine, permanent publishing convention rather than evidence the QAP was never formally adopted or is not currently controlling.

This build verified currency directly rather than assuming it: the QAP PDF downloaded for this research was compared byte-for-byte (MD5 hash) against the copy NMHC re-linked from its own "Public Notice: 2025-2026 LIHTC QAP" page in March 2026 -- the files are identical. NMHC's own subsequent public notices for the 2026 application round were then pulled directly and checked for any indication the underlying QAP had itself changed mid-cycle.

The practical implication for a screening or underwriting tool: treat NMHC's Application Deadline as a moving target confirmed against the most recently dated public notice on nmhcgov.net, not as a fixed annual date the way most state QAPs publish one. Do not infer, from a deadline extension alone, that the underlying QAP text or scoring criteria changed -- in every 2026 instance found in this research, NMHC extended the same round rather than opening a new one or amending the document.

Location and market-demand screening runs on NMHC staff judgment, not a fixed distance-band table

The QAP's Criterion 13, "Project location and market demand" (0-15 points), states that points are awarded "based on NMHC's evaluation" of six factors tied to the comprehensive Market Study. Two of the six factors use the phrase "in the immediate vicinity of the project site" without defining a distance, radius, or mapping standard anywhere in the document.

Criterion 12 (0 or 2 points) is a separate, much narrower location-related criterion: it awards points if the project "is located in a qualified census tract, the development of which contributes to a concerted community revitalization plan as determined by NMHC (i.e. site is located in an Enterprise Community, Empowerment Zone, or part of a County redevelopment plan)." To receive the points, the applicant must supply a letter of interest or binding agreement with the government agency administering that revitalization plan. This is an NMHC-administered test tied to a local revitalization plan -- it is not, on its face, the federal Qualified Census Tract definition HUD publishes annually for the Section 42(d)(5)(B) basis boost.

The QAP never mentions the federal 30% QCT/DDA basis boost at all -- 26 U.S.C. Section 42(d)(5)(B) does not appear anywhere in the document. HUD's own September 30, 2025 Federal Register notice (Docket No. FR-6565-N-01), which designates Difficult Development Areas and Qualified Census Tracts for 2026, confirms HUD makes DDA designations for "the Northern Mariana Islands" as one of its enumerated insular-area jurisdictions alongside Guam, American Samoa, Puerto Rico, and the U.S. Virgin Islands. This research pass was not able to confirm, from HUD's own current published DDA/QCT list, which specific CNMI geography -- if any -- carries a live QCT or DDA designation for the applicable credit year: huduser.gov's dataset pages returned an automated access challenge during this research rather than the underlying list. A screener should check HUD's QCT/DDA lookup tool directly, or obtain a syndicator's or lender's current determination, rather than assume the federal boost applies or does not apply based on the CNMI QAP text alone, since the QAP is silent on the subject entirely.

The multi-island structure: a flat 10-point bonus for Tinian or Rota, and a hazard profile that differs by island

Criterion 17, "Tinian and Rota Project Development" (0 or 10 points), is binary: an applicant electing to develop on Tinian or Rota receives 10 points; an applicant staying on Saipan receives zero for this criterion regardless of the project's other merits. This is a scoring bonus, not a reserved set-aside -- nothing in the QAP obligates NMHC to fund any particular number of Tinian or Rota projects in a given round, and the small overall credit ceiling ($2.9-3.5 million) means a single round will typically fund only one or two projects Commonwealth-wide, so a 10-point swing can plausibly be outcome-determinative against a Saipan project that does not also score well on Criteria 3 and 13.

CNMI sits in a FEMA-designated Special Wind Region, where the standard nationwide ASCE 7 basic wind speed map does not directly apply; FEMA instead produced Special Wind Region (SWR) maps derived from historical typhoon data under ASCE/SEI 7-16 Section 26.5.3 -- separately for each of Saipan, Tinian, and Rota, with four maps per island corresponding to the four ASCE 7-16 Risk Categories. A screening or design process cannot reuse a single CNMI-wide wind design speed across islands or across a project's Risk Category; the applicable SWR map has to be pulled per island.

CNMI is also seismically active, sitting along the Mariana Trench subduction zone: USGS recorded a magnitude-6.8 earthquake in the Maug Islands region on April 5, 2024, roughly 270 miles north of Saipan, at a depth of about 220 kilometers -- deep enough that USGS issued only a Green shaking-alert with a low likelihood of damage or casualties despite the magnitude. The event illustrates that a given earthquake's practical impact on Saipan, Tinian, or Rota depends heavily on depth and distance rather than magnitude alone, and that CNMI's overall seismic hazard should be evaluated per-site rather than assumed uniform.

CNMI adopted the 2018 International Building Code as its official building code, codified at 2 CMC Sections 7142 and 7145 via Public Law 21-14; it is administered by the Department of Public Works' Building Safety Code Division (BSCD) -- an agency separate from both NMHC and the zoning agencies discussed in Phase 3. A screening process confirming wind and seismic design parameters for a specific candidate site should go to BSCD directly rather than assume a single Commonwealth-wide figure.