Site sourcing and screening — Mississippi

Confirming which document actually governs -- MHC replaced its own file mid-cycle without a visible amendment notice

MHC's HTC News page dates its "Approved 2026 Qualified Allocation Plan" post to December 18, 2025, following an October 15, 2025 proposed-revisions post and a November 5, 2025 public hearing referenced in MHC's own Executive Summary of proposed revisions. That would ordinarily settle the currency question. It doesn't, quite: the PDF the "CLICK HERE to view 2026 QAP" link on that same page actually serves today is named "2026 QAP_FINAL_Addendum L" and its own embedded Adobe metadata gives a creation date of March 2, 2026 -- roughly two and a half months after the board-approval announcement, and about four weeks before the 2026 Application Cycle itself opened. No separate dated amendment notice for that March 2026 file was found on MHC's HTC News page in this research pass. The most plausible explanation, based on MHC's own Executive Summary of proposed revisions (which describes a then-still-pending "Addendum L: Approved Housing Service Providers" and its "Deeper Targeting" referral requirement), is that MHC finalized and re-attached Addendum L's provider directory after the December board approval and re-posted the merged file under the same link -- but this research could not obtain a copy of the file exactly as it stood on December 18, 2025 to diff against the March 2, 2026 version, so it cannot confirm whether anything in Sections 1-9 or Addendum A's Selection Criteria changed between the two dates. Any Mississippi build-out should treat March 2, 2026 as the confirmed vintage of record and verify directly with MHC whether Selection Criteria or Threshold Factors moved between the board-approved and currently-served files.

One internal artifact is worth naming so it isn't mistaken for evidence of staleness: every page of the QAP carries a running footer reading "2024 QUALIFIED ALLOCATION PLAN | Mississippi Home Corporation" -- appearing 58 times through the document. That is a leftover template header, not a sign the rules are actually two cycles old: Chart 2's dated milestones run January through August 2026, and the Executive Summary independently documents a November 5, 2025 public hearing for "Mississippi's 2026 Qualified Allocation Plan (QAP)" (the source text visibly shows a struck-through "2025" replaced with "2026" -- itself a redlining artifact carried into the final text). The QAP is currently the operative 2026-cycle document; the footer is simply uncorrected copy from an earlier year's template.

There is no Delta pool or Gulf Coast pool -- Mississippi allocates by applicant and development type, not by region

This was checked directly against the QAP's own Set-Asides section (Section 3) and it does not split competitive credits geographically the way some states divide a metro pool from a rural pool. MHC's four set-asides are defined entirely by who the applicant is and what kind of development it is: a Non-Profit Set-Aside (a floor, not a pool, driven by the federal 10% requirement), a Smaller Credit Amount Set-Aside, a Rehabilitation Set-Aside, and a New Construction Set-Aside. None of the four carries a regional definition, a regional target percentage, or a regional cost-limit adjustment. "Delta" and "Gulf Coast" do appear in the QAP, but only inside Addendum L's directory of MHC-approved housing service providers (organized by the counties each provider serves, for the Deeper Targeting referral requirement) -- a services-referral network, not a competitive allocation pool. A Mississippi screen should not import a Georgia- or Texas-style regional-pool mental model; the geography that matters here is market area (for the Market Study, see Phase 2) and county (for building-code and zoning purposes, see Phase 3), not a QAP-defined region.

Site Location scoring: four non-geographic categories, hard-capped at 10 points

Addendum A's Selection Criteria open with a Site Location item worth up to 10 points, built from four categories a site may qualify under. Read literally, the chart lets an applicant claim "up to two of the four categories," but the category values themselves (5, 5, 10, and 10 points) don't fit inside a 10-point ceiling if two 10-point categories were meant to stack -- the chart's own "Maximum Points: 10 pts" line caps the section regardless of how many qualifying categories a site claims. Practically, that means pairing a 5-point category with another 5-point category can reach the 10-point ceiling, but claiming two 10-point categories (or a 10 plus a 5) still tops out at 10, not 15 or 20. This wasn't stated as an explicit stacking rule anywhere else in the document, so a Mississippi screen should confirm the intended mechanics with MHC's Technical Assistance staff before assuming any particular combination adds up the way it looks on paper.

The federal 30% QCT/DDA basis boost (IRC §42(d)(5)(B)) runs on an entirely separate track from Site Location scoring: it is automatic for any site HUD designates a Qualified Census Tract or Difficult Development Area, requires no MHC action, and earns no direct Site Location points of its own. Its only appearance inside Addendum A's competitive scoring is as the fourth and final tiebreaker (after lowest soft-cost percentage, lowest cost per unit, and fewest credits per unit): "a development to be located in a qualified census tract shall take precedence over one that is not," quoted directly from the QAP's own tiebreaker list. A screener should not conflate High Opportunity Area (an MHC-defined, income/growth-based designation carrying 10 Site Location points and eligibility for the state's own discretionary boost) with federal QCT/DDA status (a HUD designation carrying an automatic federal boost and, at most, a tiebreak).

What MHC actually screens for on site -- and what its own QAP is silent on

MHC's review process (Section 6.3(1)) makes site acceptability a discretionary, in-person call, not a checklist: "Site visits will be conducted for each application submitted... MHC reserves the right to deny an application due to site location. MHC also has the right to require a buffer for sites that are deemed unacceptable (ex. adjacent to railroad tracks or graveyards). Site acceptability is determined by the MHC." That is quoted directly from the QAP, and it is the closest thing Mississippi has to a site-suitability standard -- two illustrative examples, then unrestricted agency discretion, rather than a scored table of desirable/undesirable land uses the way some other states' QAPs run. New-construction sites must also have their public-street-facing boundary corners physically marked and kept marked clear through MHC's announcement of funded developments.

What the QAP does not do, confirmed by a direct text search of the full document, is address flood risk at all: there is no mention of FEMA, floodplain, floodway, base flood elevation, the National Flood Insurance Program, or wetlands anywhere in the 116-page QAP, and no Phase I environmental or hazardous-materials threshold either (see Phase 2 for what little the QAP does say about environmental review). That silence matters because Mississippi's own geography carries real, well-documented exposure on both ends of the state: the three Gulf Coast counties (Hancock, Harrison, and Jackson) were extensively remapped by FEMA after Hurricane Katrina, with Special Flood Hazard Areas and coastal high-hazard V/VE zones that a site screen needs to check directly against FEMA's current Flood Insurance Rate Maps rather than assume from a pre-Katrina map; and several South Delta counties (Warren, Yazoo, Issaquena, Sharkey, and Humphreys) sit inside the Mississippi River's Yazoo Backwater area, which most recently flooded for roughly five months in 2019 -- Mississippi State University Extension Service's own survey work on that event put the inundated area at roughly 548,000 acres. None of this is an MHC threshold or scoring question; it is due diligence a Mississippi screen has to run on its own initiative, using FEMA's and the Corps of Engineers' own data, because the QAP will not surface it.

The QAP does reward storm-resilient construction, just not as a site-selection filter: developments can earn up to 7 Development Characteristics points for building to the IBHS FORTIFIED Multifamily (Gold) standard -- described in the QAP as addressing "specific natural hazard risks... to resist wind, water, and hail damage from tropical cyclones or convective storms" -- as an alternative to the more common green-building certifications, and individual unit amenities include 3 points for Storm Doors and 3 points for a Storm Shelter built to FEMA safe-room guidance. Those are building-design incentives, not a reason to treat a hazard-exposed site as pre-screened.