"Is this parcel's REDC region even the right competition — and is DHCR, HFA, or HPD the agency this site's deal actually runs through?"
One statewide round, ranked within REDC regions — and a different split for cost
HCR's Multifamily Finance 9% LIHTC RFP is a single annual competitive round, not Florida's simultaneous geographic RFAs. In the most recently verified round (RFP released July 17, 2025), the application deadline was September 11, 2025 at 11:59 PM ET, following a single statewide credit ceiling. But comparison isn't statewide: per the RFP, "Proposals that meet all Threshold and Eligibility requirements will be scored and ranked within the Regional Economic Development Council (REDC) geographic region in which the project is located." New York has 10 REDC regions — Western New York, Finger Lakes, Southern Tier, Central New York, Mohawk Valley, North Country, Capital Region, Mid-Hudson, Long Island, and New York City, which is its own region. A site's REDC region is the pool it actually competes in for scoring and ranking, even though every applicant files against the same single deadline and the same statewide credit ceiling.
| REDC ranking region (10 regions) | Cost region (2 regions) | |
|---|---|---|
| Used for | Scoring and ranking comparison pool for all applications | Cost Effectiveness scoring and High-Cost Project identification only |
| Geography | Western NY, Finger Lakes, Southern Tier, Central NY, Mohawk Valley, North Country, Capital Region, Mid-Hudson, Long Island, New York City | Region 1: NYC plus Rockland, Westchester, Nassau, and Suffolk Counties. Region 2: the remaining 53 counties |
For Cost Effectiveness, HCR compares each project's Total Residential Development Cost per square foot, per bedroom, and per unit against the median for other complete applications in the same round and the same cost region, then averages the three ratios. Projects scoring at or below 100% of the regional median earn full points (105% if pursuing Stretch Sustainability Goals) — meaning a site's realistic construction cost relative to its regional peers is a screening question, not just an underwriting one.
Three agencies, and a New York City site can run through any of them
DHCR runs the competitive 9% process described above under 9 NYCRR Part 2040. HFA processes 4% credits tied to tax-exempt private-activity-bond volume cap entirely separately: per 9 NYCRR § 2040.4(a), such projects "will be processed by the New York State Housing Finance Agency under its procedures," and per § 2040.4(b), "complete applications must be submitted at 60 days prior to the proposed construction start date... and will be accepted and processed throughout the calendar year." There's no REDC pool, no annual deadline, and no competitive scoring on that track — site screening for a 4%/bond deal is a feasibility and bond-capacity question, not a ranking question.
For a New York City site, HCR sub-allocates credits to HPD, which runs its own RFPs and its own LIHTC Qualified Allocation Plan, distinct from DHCR's statewide document. HPD's own subsidy programs include ELLA (Extremely Low & Low-Income Affordability — minimum 80% of units at ≤80% AMI, at least 15% set aside for formerly homeless households) and Mix & Match (40–60% of units at ≤80% AMI blended with moderate/middle-income units up to 120% AMI), typically paired with tax-exempt bonds issued by HDC rather than HFA. A City-located site should be screened against both doors: whether it's competitive in DHCR's statewide 9% round (ranked within the New York City REDC region) and/or whether it fits one of HPD's own subsidy RFPs, which carry their own threshold criteria, AMI mix, and site-control mechanics covered in Phase 2.
What the scoring criteria reward before underwriting even starts
DHCR's 9% QAP (effective June 11, 2025) scores across 17 categories; several relevant to site selection: Community impact/revitalization (up to 10 points) is earned by advancing one of HCR's State Housing Goals — among them, demonstrating site control of land from a Land Bank in a high-abandonment neighborhood, a $0/$1 municipal land donation, a completed rezoning or variance "necessary to complete the project," committed municipal capital financing, a draft PILOT commitment above the Real Property Tax Law §581-A baseline, priority-project status in the municipality's Annual Action Plan, an Urban Renewal Plan site, or Designated Developer status. Projects in Well-Resourced Areas (up to 5 points) requires a Tier 1 census tract on HCR's Neighborhood Resource Index map, an average unit size of at least 2 bedrooms, at least 10% of units at ≤30% AMI, and excludes any project restricted to occupants 55 or 62 and older. Investment in Underserved Areas (5 points) requires a market-study-backed Primary Market Area map showing little or no subsidized housing built in the past 10 years. Transit-oriented development / "Workforce Opportunity" scoring is explicitly limited to projects located outside New York City, within a safe half-mile walk of frequent, fixed-route transit.
Project readiness (up to 10 points) is scored, per 9 NYCRR § 2040.3(f)(8), "to the extent the application demonstrates the likelihood of a construction closing in the shortest possible timeframe based upon an assessment of the status of financing commitments and whether the project is supported by the implementation of significant measures including but not limited to infrastructure improvements, real property tax relief and rezoning." A site still working through entitlements scores worse on this criterion than an identically located, already-entitled site — which makes the Phase 3 entitlement-pathway election a scoring decision at screening time, not only a schedule risk.
Where this goes wrong
- Assuming NY's 9% process runs on a rolling or staggered calendar like Florida's overlapping RFAs — DHCR runs one statewide round a year with a single hard deadline (September 11, 2025 in the most recently verified round); missing it means waiting for next year's RFP.
- Screening a site as though it competes statewide — it's actually scored and ranked only within its REDC region, so an unusually strong Long Island application doesn't affect, and isn't affected by, a North Country application's ranking.
- Conflating the 10-region REDC ranking pool with the 2-region cost-effectiveness pool (NYC+Rockland/Westchester/Nassau/Suffolk vs. the remaining 53 counties) — they're different geographic splits serving different scoring purposes within the same RFP.
- Treating DHCR's statewide 9% RFP as the only door for a New York City site — missing that HPD runs its own subsidy RFPs (ELLA, Mix & Match) with their own term sheets, typically paired with HDC as bond issuer rather than HFA.
- Screening a 4%/tax-exempt-bond deal against the 9% RFP's competitive scoring criteria — HFA's 4% process under § 2040.4(a)-(b) is non-competitive, has no REDC pool, and runs on a rolling 60-days-before-construction-start submission clock instead.
- Missing the Well-Resourced Areas exclusion for age-restricted senior housing — a Tier 1 NRI census tract doesn't earn the 5 points if the project is restricted to occupants 55 or 62 and older, regardless of unit mix.
- Assuming transit-oriented/Workforce Opportunity scoring applies statewide — the RFP defines it as projects located outside New York City only.
- Scoring against a pre-June 2025 summary of the QAP — several categories (Community impact/revitalization, Sponsor characteristics, Sustainability, Additional HCR accessible units, Individuals with children, Special housing needs, Well-Resourced Areas, Transit-oriented development, MWBE/SDVOB) are marked in HCR's own RFP as revised in the QAP effective June 11, 2025.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies