Key Takeaways:

• The forum is scheduled for September 9, 2026, from 2:00–3:00 p.m. ET — a free, one-hour event hosted jointly by BPC and NAAHL.
• Speakers will address the full range of housing policy reforms included in the 21st Century ROAD to Housing Act, not just headline provisions.
• A key focus is implementation: where the rules still need to be written and where agency-level decisions will determine real-world outcomes.
• The legislation's potential impact on housing supply will be examined across states and communities — directly relevant to QAP strategy and state HFA engagement.
• Participants include experts from across the affordable housing industry, positioning this as a cross-sector intelligence opportunity for practitioners active in LIHTC, lending, and policy.
• The implementation phase is where broad reform legislation typically diverges from its stated intent — early engagement in forums like this can inform how organizations position their pipelines and advocacy.

The 21st Century ROAD to Housing Act represents one of the more significant federal affordable housing reform efforts in recent years. With implementation underway, the September 9 forum is an early-stage opportunity to hear directly from practitioners and policymakers shaping the rules. Teams active in state HFA relationships, LIHTC structuring, or affordable housing lending should treat this as a must-attend or must-monitor event ahead of the next QAP and allocation cycle.

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Key Takeaways:

• Approximately 12 senior executives were eliminated in a single action, reported Friday by the Wall Street Journal.
• Cuts specifically targeted Fannie's multifamily loans unit and its LIHTC investment operations — two divisions central to affordable housing finance.
• Finance, regulatory, and communications leadership were also among the eliminated roles, suggesting a broad, coordinated reduction.
• Affected executives were identified by Mortgage Point after their internal employee profiles were quietly removed from Fannie Mae's directories.
• The shakeup introduces near-term uncertainty around Fannie's LIHTC equity investment appetite and multifamily deal underwriting continuity.
• The timing overlaps with ongoing conservatorship exit discussions and potential FHFA-driven cost and mandate restructuring.
• Developers, syndicators, and lenders with active Fannie Mae relationships should immediately confirm the status of their deal contacts and relationship managers.

Fannie Mae is one of the largest institutional LIHTC equity investors in the country and a cornerstone multifamily lender. Leadership disruption at this scale — particularly concentrated in affordable housing units — warrants close monitoring. Whether this is driven by conservatorship politics, FHFA directives, or internal restructuring, the downstream effect on deal flow and credit availability could be significant. Watch for further personnel disclosures and any formal statements from Fannie Mae or FHFA about the future direction of its multifamily and affordable housing operations.

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Key Takeaways:

• Seven federal agencies — HUD, CFPB, DOJ, FDIC, NCUA, OCC, and FHFA — jointly rescinded the February 2022 Interagency SPCP Statement on August 25, 2026.
• Creditors are explicitly directed not to rely on the 2022 statement, prior guidance, or related issuances going forward.
• The rescission is anchored in Executive Orders 14173 and 14151, which directed agencies to eliminate race-based preferences across federal programs and federally influenced credit markets.
• FHFA's participation signals direct implications for GSE seller-servicers — Fannie Mae and Freddie Mac counterparties should expect updated guidance on race-conscious credit products.
• DOJ Assistant AG Harmeet Dhillon explicitly identified enforcement of equal-treatment civil rights standards as a priority, elevating litigation risk for non-compliant programs.
• The underlying ECOA/Regulation B legal framework for SPCPs remains intact — programs built on economically relevant, non-protected criteria are not automatically disqualified.
• State HFAs and mission-driven lenders with demographic targeting in down-payment assistance or soft-second structures face the most immediate compliance exposure.

The legal authority for SPCPs has not been eliminated — but the federal policy environment that made race-conscious credit programs administratively safe is gone. For the affordable housing industry, the priority action is an immediate legal review of any SPCP or targeted lending product that uses protected characteristics as a qualifying criterion. Watch for FHFA seller-servicer guidance as the next concrete signal of how GSE-connected lenders will be expected to respond.

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Key Takeaways:

• OHFA posted draft PY 2026 4% LIHTC with Bond Gap Financing guidelines for public comment on or before August 25, 2026.
• The public comment deadline is Thursday, August 27, 2026 — a narrow window of approximately two days from publication.
• Written comments must be submitted to BGF@ohiohome.org; no other comment channel is specified.
• Both a clean version and a redline of the draft guidelines have been published, enabling direct comparison to prior-year program terms.
• BGF is a subordinate debt program designed to close financing gaps in 4% LIHTC deals paired with private activity bonds — changes to loan terms, subsidy caps, or underwriting criteria affect senior debt sizing and syndicator pricing.
• Ohio four percent pipeline deals expected to close in PY 2026 should be stress-tested against draft BGF terms before the comment deadline.
• State HFAs routinely incorporate specific, deal-grounded written feedback into final guidelines — the comment process carries real influence.

With the comment window closing in less than 48 hours from publication, Ohio market participants need to move quickly. Review the redline for material changes to eligible costs, maximum subsidy amounts, and underwriting standards. If draft provisions create structural problems for deals in your pipeline, submit written comments before Thursday. Final guidelines will govern program year 2026 transactions — there is no second opportunity to shape the terms once they are adopted.

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Key Takeaways:

• Total 2026 HTF funding is $255 million, a ~14% increase over the 2025 total of $223 million.
• HTF is formula-distributed to states based on the shortage of affordable units and renter household incomes — states with larger affordability gaps receive larger absolute allocations.
• HTF exclusively funds units serving households at or below 30% of AMI, making it structurally distinct from LIHTC, which typically targets 50–60% AMI.
• HTF layered with 4% or 9% LIHTC equity can close the feasibility gap on the deepest affordability units in high-cost markets.
• State HFAs administer HTF through allocation plans — developers should engage their state agency now to confirm application timelines and available amounts.
• Deals with 30% AMI set-asides that currently have an unresolved gap should be reassessed in light of updated state HTF availability.
• QAP amendments and HTF plan updates from state HFAs are expected in the coming weeks — watch for competitive and over-the-counter application cycles opening soon.

The 2026 HTF increase arrives at a moment when deep affordability is under intense pressure from rising construction costs and land prices. For developers structuring deals in high-cost markets, this is a timely opportunity to layer HTF into capital stacks before state application windows close. Teams that engage their HFAs early will be best positioned heading into year-end underwriting cycles.

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Key Takeaways:

• HUD's 2027 HOTMA annual inflationary adjustments and passbook rate are effective January 1, 2027 — compliance teams should update income examination procedures before year-end.
• PIH has rescinded the EHV/SV payment standard waiver that allowed ranges of 90–120% of FMR; PHAs must now operate within the standard 90–110% FMR range.
• Existing exception payment standards already approved outside the 90–110% FMR range are not impacted by the rescission notice.
• HUD has proposed removing disparate-impact liability from its Title VI regulations, aligning with recent DOJ revisions — comments are due October 9, 2026.
• HUD is requesting comments on HUD Form 9834 (MOR) and HUD Form 91067 (VAWA Lease Addendum) — comments due September 3, 2026.
• PIH's updated FYI guidance removes the per-fiscal-year cap on vouchers PHAs can request under the Melania Trump Foster Youth to Independence Initiative, subject to funding availability.
• HUD launched a new Secure Systems landing page in July 2026 as part of its EICAM modernization initiative — no user action required, but the current URL remains available only through August during transition.

The EHV payment standard rollback is the most operationally urgent item for housing authorities working in high-cost markets, where the 120% ceiling had been a critical placement tool for homeless and at-risk populations. Combined with the HOTMA adjustment cycle and the October 9 comment deadline on Title VI disparate-impact rules, this is a dense policy period — teams should prioritize review of all four items before Q4.

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Key Takeaways:

• S. 5366 introduced by Senators Gallego (D-AZ) and Rounds (R-SD) — a companion to H.R. 9012, introduced in May by Reps. Carey (R-OH) and Panetta (D-CA).
• The bill creates a 5-year carryback for the Housing Credit, versus the current carry-forward-only structure.
• Carryback authority allows investors to recover credit value against prior-year tax liability, converting a deferred benefit into immediate cash — directly impacting investor pricing.
• Bipartisan co-sponsorship in both chambers is intentional, designed to strengthen the bill's chances of attachment to a broader tax package.
• The bill was introduced as a standalone measure specifically to better position it for inclusion in a viable tax vehicle moving through Congress.
• Expanded investor capacity through carryback could widen the buyer pool for LIHTC credits, particularly when corporate tax appetite is variable.
• Bill is now pending before the Senate Committee on Finance — committee calendar activity is the next signal to watch.

With bipartisan support in both chambers and a strategic standalone posture, the Affordable Housing Credit Carryback Act is better positioned than most standalone tax measures. LIHTC developers, syndicators, and equity investors should track the Senate Finance Committee's legislative schedule and begin stress-testing deal structures against the possibility that carryback authority becomes law — because if a tax package moves, this provision has a credible path to inclusion.

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Key Takeaways:

• HUD's new baseline for HOME and HTF new construction is the 2009 IECC and ASHRAE 90.1-2007 — a significant rollback from the 2021 IECC and ASHRAE 90.1-2019 standards.
• A federal court sided with NAHB and 15 state attorneys general in March, ruling the 2021 IECC mandate violated the Cranston-Gonzalez National Affordable Housing Act.
• Unlike FHA programs, the stricter 2021 IECC standards actually took effect for HOME and HTF new construction in late 2024 — meaning projects completed or started under those standards face a different compliance calculus than pipeline deals.
• NAHB estimates the 2021 IECC and ASHRAE 90.1-2019 standards could add $9,600 to $21,400 to the cost of a new home.
• The buyer payback period for those added upfront costs could stretch up to 90 years, undermining the affordability case for mandatory adoption in subsidized programs.
• HUD has published updated FAQs formally clarifying the applicable standards for all HOME- and HTF-assisted new construction projects.
• Developers and participating jurisdictions should verify that project specifications and lender requirements align with the 2009 IECC baseline and seek field office guidance on any deals designed under the 2021 standards.

This rollback closes a real cost exposure for affordable housing pipelines — but the fact that the 2021 standards were in effect for HOME and HTF new construction during late 2024 means practitioners cannot treat this as a clean slate. Any project that was scoped, bid, or completed under the stricter standards needs a careful compliance review before funds are drawn or deals are closed. Watch for additional HUD guidance as participating jurisdictions update their own program requirements in response.

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Key Takeaways:

• KHC awarded more than $231 million in tax-exempt bonds across 15 selected applications in its 2026 round.
• Projects are supported by over $20 million in 4% LIHTC, the automatic credit unlocked by private activity bond financing.
• The funded pipeline will create or preserve 2,134 affordable rental units throughout Kentucky.
• At an average of roughly 142 units per deal, the round suggests substantial project scale — not small scattered-site transactions.
• Preservation deals in this cohort are particularly significant, as bond-plus-4% structures can lock in long-term affordability restrictions for units otherwise at risk of market-rate conversion.
• For lenders, 15 bond transactions represent meaningful construction loan volume, credit enhancement decisions, and forward rate-lock exposure in the current rate environment.
• Developers not already engaged on these 15 projects should note that closing timelines typically follow award announcements by several months — the race to close has started.

This round reinforces the role of the 4% LIHTC and private activity bond pairing as a primary production tool for state HFAs. Investors, syndicators, and lenders active in the Southeast should monitor KHC's QAP and future bond round announcements closely, as the agency's appetite for volume at this scale suggests a sustained strategic direction — not a one-cycle anomaly.

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Key Takeaways:

• HUD's notice formally removes the Selected Mobility-Related Services (SMRS) treatment arm from the CCD, narrowing the demonstration's evaluation scope.
• The CCD evaluation enrollment timeline has been revised, requiring PHAs to reassess staffing, outreach, and case management commitments accordingly.
• HUD has clarified the recapture and reallocation process for Mobility Demonstration Vouchers, defining what triggers a clawback and how funds are redistributed to other participants.
• The demonstration was formerly known as the Housing Choice Voucher mobility demonstration; the rebranding to Community Choice Demonstration reflects HUD's repositioning of the program's goals.
• CCD research outcomes are expected to influence future congressional and HUD policy on voucher mobility, including how mobility factors into competitive funding rounds.
• PHAs holding Mobility Demonstration Vouchers should review the updated notice immediately to avoid administrative disruption or unintended fund recapture.
• Removal of the SMRS arm reduces the evidence base the demonstration will generate, a concern for advocates and policymakers seeking rigorous data on mobility intervention effectiveness.

The Community Choice Demonstration remains one of HUD's most closely watched active laboratories for voucher policy. Its findings will inform how mobility is weighted in future funding competitions and how Congress frames the next generation of housing mobility legislation. For developers and syndicators operating in opportunity areas, the direction of that policy conversation has real implications for deal viability and subsidy layering strategies. Stakeholders should engage with HUD's updated notice now and monitor the revised evaluation design as it takes shape.

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Key Takeaways:

• H.R. 10075 would exempt qualified mortgage bonds from the PAB volume cap, directly reducing single-family demand on cap that multifamily deals also compete for.
• In 2023, $9,143.8 billion of total PABs issued went to single-family programs, versus $21,677.3 billion for multifamily — per the CDFA 2021–2023 Annual Volume Cap Report.
• 4% LIHTC deals are structurally dependent on Private Activity Bond financing; any expansion of effective cap availability translates to more viable multifamily pipelines.
• The bill is bipartisan — two Republican and two Democratic co-sponsors — improving its odds relative to single-party legislation.
• States with chronically oversubscribed volume cap would see the most direct benefit, as fewer competing claims on the pool means more allocable authority for multifamily deals.
• The policy mechanism is additive, not redistributive — it doesn't eliminate the single-family program, it removes it from the cap calculation.
• Developers and syndicators in high-demand cap states should monitor this bill's progress as the broader tax legislative calendar unfolds.

This bill won't move in isolation — its fate is tied to the broader tax and housing finance legislative environment in Congress. But the mechanism is straightforward and the bipartisan framing is an asset. For affordable housing deal-makers in volume-cap-constrained markets, this is one of the more consequential single-family bills to watch precisely because of what it would do for multifamily. Stay close to your state HFA on cap availability regardless of outcome — but a favorable ruling here would materially change the calculus for 4% pipeline planning.

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Key Takeaways:

• TDHCA awarded over $114 million in housing tax credits in this cycle — one of the largest single announcements in recent Texas history.
• Awards span 70 rental properties, supporting construction or rehabilitation of more than 4,400 affordable units across the state.
• The award mix includes both new construction and rehabilitation deals, reflecting TDHCA's ongoing preservation strategy alongside new supply.
• 4% LIHTC deals paired with tax-exempt private activity bonds remain a key tool for rehab transactions, particularly as construction costs keep ground-up deals under pressure.
• Texas's QAP prioritizes proximity to amenities, income targeting, and geographic distribution — factors that will shape competitive positioning in future cycles.
• Developers who did not receive awards should analyze the geographic distribution of winning deals to inform future application strategy.
• TDHCA's full award list — including property-level credit amounts and credit types — is expected to be published on TDHCA's website and is essential reading for anyone active in the Texas market.

Texas consistently operates one of the most competitive LIHTC allocation programs in the country. With this cycle closing at over $114 million across 70 deals, the state's pipeline remains robust — but so does the competition. Investors, syndicators, and lenders should monitor TDHCA's website for the full award list and begin positioning now for the next application cycle. For those tracking affordable housing capital deployment at scale, Texas remains one of the most consequential state markets to watch.

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Key Takeaways:

• Current OZ designations remain in effect through December 31, 2028; new designations take effect January 1, 2027.
• The IRS's transitional guidance signals that forthcoming proposed regulations will closely mirror its provisions — a key underwriting reference for deals spanning both designation periods.
• Through 2024, 77% of both rural and non-rural OZs received investment, but the average rural OZ received only $7.3 million vs. $23.3 million for non-rural OZs — a 3-to-1 gap.
• Rural-urban investment disparities vary significantly by state, meaning national averages obscure major regional differences.
• Rural tracts eligible for new designations show higher homeownership rates, higher housing vacancy rates, and lower home values than eligible non-rural tracts.
• Rural eligible tracts have older populations with lower educational attainment and weaker labor market attachment — factors affecting both demand underwriting and exit assumptions.
• Layered subsidy structures — combining OZ equity with LIHTC, USDA financing, or state rural set-asides — will likely be necessary for rural OZ deals to achieve financial feasibility.

With the new designation round approaching and IRS regulations on the horizon, investors and developers should evaluate rural OZ pipeline opportunities now. The Treasury data provides a data-driven baseline for market demand assumptions, and the IRS transitional guidance offers regulatory clarity that reduces near-term structuring risk. Teams building rural OZ strategies should also monitor state-level variation closely — aggregate national figures mask the states where rural OZ capital is already flowing competitively.

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Key Takeaways:

• D.C. filed suit to block relocation of both HUD and Ginnie Mae headquarters to Alexandria, Virginia, citing the Residence Act of 1790 and agency-specific governing statutes.
• More than 80% of HUD headquarters staff and most Ginnie Mae employees have already been moved — the relocation is not proposed, it is substantially complete.
• The lawsuit alleges required environmental and historic preservation reviews were skipped, undermining the procedural basis for the move.
• The District disputes the agencies' cost estimates for renovating HUD's Robert C. Weaver Federal Building, a landmark that has housed the agency since 1968.
• D.C. claims the relocation will reduce local tax revenue by nearly $2 million annually, establishing concrete economic harm for standing purposes.
• No ruling has been issued; the court has not yet tested any of the allegations.
• Ginnie Mae's role in backing mortgage-backed securities for FHA-financed affordable deals makes its operational stability a direct concern for LIHTC and bond-financed transactions.

This case is one to watch. A court order requiring both agencies to return to Washington would trigger significant operational disruption — and set a ceiling on unilateral executive action over agency placement. Conversely, if the relocation is allowed to stand, it establishes that headquarters can be moved without explicit congressional approval, a precedent with reach far beyond affordable housing. Developers, syndicators, and lenders with active HUD or Ginnie Mae pipelines should monitor the docket and assess contingency scenarios now.

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Key Takeaways:

• 121 House members signed the letter urging HUD to withdraw the proposed rule — the largest congressional action on this issue to date.
• A separate June letter from 28 U.S. Senators, led by Warren (D-MA) and Merkley (D-OR), was sent prior to the close of the comment period.
• Over 23,000 public comments were submitted during the rulemaking period — creating a substantial administrative record for any future legal challenge.
• If finalized, the rule would require HUD-funded shelters to determine access based on HUD's definition of sex, removing the gender identity accommodation requirement currently in place.
• The rule is tied to the Executive Order "Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government," signaling administration commitment to finalization.
• LIHTC properties in states with strong LGBTQ+ protections face potential direct conflict between federal program requirements and state law if the rule is finalized.
• HUD is not legally required to withdraw the rule in response to congressional pressure — operators and lenders should not wait for political resolution before consulting counsel.

Congressional opposition is significant, but it does not stop rulemaking. If HUD finalizes this rule, operators of HUD-funded and HUD-insured properties — including LIHTC developments — will need immediate legal guidance on how to navigate conflicts between the new federal requirements and applicable state and local fair housing law. Investors and lenders should be stress-testing this as a compliance and reputational risk factor in existing and prospective deals. The time to engage counsel is before the final rule publishes, not after.

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Key Takeaways:

• The proposed small bank threshold rises from $412 million to under $1 billion (lending test only); small banks are not subject to the investment test.
• A new "intermediate bank" tier ($1B–$10B) replaces intermediate small banks, subject to lending and community development tests only — not the investment test.
• The large bank threshold rises from $1.649 billion to $10 billion, removing approximately 416 banks (61%) from the investment test requirement.
• The CRA incentivized ~80% of Housing Credit equity investment in 2024, totaling just over $23 billion, according to a new NAAHL report.
• From 2015–2022, the Housing Credit comprised 79% of OCC-regulated bank public welfare investments — $95 billion total.
• Regulators are also soliciting comment on alternative thresholds: an intermediate bank floor of $3.252 billion, an intermediate ceiling of $30 billion, and a small bank ceiling of $10 billion.
• The Federal Reserve is not party to this proposal, creating the possibility of divergent CRA frameworks across different bank regulators.
• The comment period opens 60 days after Federal Register publication; NH&RA is coordinating an industry response.

This proposal arrives at a moment of significant housing affordability stress and represents one of the most consequential potential changes to the CRA investment framework in decades. LIHTC syndicators, equity investors, and affordable housing lenders with bank partners in the $1.649 billion to $10 billion asset range should assess their exposure and engage the comment process. The Federal Reserve's absence from the rulemaking also raises the prospect of regulatory fragmentation that could complicate multi-bank capital stacks going forward.

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Key Takeaways:

• Jeffrey Ledbetter's confirmation vote was skipped entirely on July 23 — the committee will vote at a later, unspecified date.
• Ledbetter is the administration's second HUD IG nominee; Jeremy Ellis's nomination was withdrawn September 30, 2025.
• Ledbetter has 30+ years with the Army's Criminal Investigation Division, including service in the Defense Department's Office of Inspector General.
• Ranking Member Elizabeth Warren cited troubling responses to pre-hearing Questions for the Record, potentially signaling a contested confirmation path.
• Irving Dennis, nominated as HUD CFO, spent 37 years at Ernst & Young and served as Secretary Ben Carson's principal financial management advisor during the first Trump administration.
• Dennis authored Transforming a Federal Agency: Management Lessons from HUD's Financial Reconstruction — a signal of the financial management priorities he may bring to the role.
• A sustained HUD IG vacancy affects oversight posture across LIHTC, Section 8, and CDBG programs — audit priorities and enforcement consistency remain uncertain until the post is filled.

The committee's decision to table Ledbetter's vote — rather than vote it down outright — keeps the nomination alive but in a holding pattern. If the QFR responses Ranking Member Warren flagged become public before the next scheduled vote, they could shape both the confirmation outcome and the broader political environment around HUD oversight heading into fall budget negotiations. Stakeholders across the affordable housing spectrum should monitor whether the next vote date is set before or after the September appropriations deadline.

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Key Takeaways:

• JP Morgan will deploy more than $750 billion through 2035 via the American Dream Initiative, covering debt, equity, and grants to create and preserve housing supply.
• The initiative targets preservation of 1 million affordable units, directly relevant to LIHTC preservation pipelines and recapitalization deals.
• JP Morgan explicitly supports the 21st Century ROAD to Housing Act, which became federal law on July 11, 2026, aimed at boosting supply and curbing large investor home purchases.
• The rollout begins in five markets — Alabama, San Francisco, Philadelphia, Atlanta, and Los Angeles — with New York and Chicago to follow, signaling geographic deployment priorities for the near term.
• In San Francisco's Dogpatch neighborhood, JP Morgan used a recycled bond structure to deliver 105 affordable middle-income apartments at reduced per-unit cost, then committed $200 million for an adjacent multifamily community in the same redevelopment.
• Karen Purcell, who joined as head of community development banking in December 2025 after 16 years at Bank of America, is leading the community development deployment and is actively mobilizing multiple internal JP Morgan business lines.
• The firm is hiring additional professionals to support loan origination and client outreach, and is equipping bankers with policy, program, and subsidy toolkits — expanding its capacity as a financing counterparty.

For LIHTC developers, syndicators, and state housing finance agencies operating in JP Morgan's initial target markets, early engagement is strategically important. The firm is explicitly seeking public-private partnerships and intends to shape housing policy at the local, state, and federal levels. The recycled bond solution deployed in San Francisco points toward a willingness to absorb structuring complexity that could unlock stalled feasibility-challenged pipelines. Firms that position themselves as partners in these markets now will have the greatest influence over how this capital is ultimately allocated.

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Key Takeaways:

• Goldman Sachs's Urban Investment Group provided a $116 million construction loan — the anchor piece of a $269 million total financing package.
• Federal LIHTC equity is projected to raise $88 million; New York State LIHTC equity adds another $13.6 million to the capital stack.
• The remaining funds derive from interest earnings on tax-exempt bond proceeds and interim project income, indicating a 4% PAB-driven deal structure.
• The project delivers 393 affordable apartments: 200 renovated units in six existing buildings and 193 new units across two new four- and five-story buildings.
• Renovations to the six western buildings begin in September 2026, with completion targeted for early 2028; new construction is projected ready for occupancy by late 2028.
• Four of the oldest buildings will be demolished after residents are relocated on-site — protecting HAP contract continuity for the Section 8 component.
• New York Homes and Community Renewal is the state agency partner; the demolished building footprints are designated for a future additional housing phase.

Parkside Commons is a case study in institutional-scale affordable housing finance: a Section 8 preservation deal layered with dual-track LIHTC equity, tax-exempt bonds, and a nine-figure Goldman construction loan in an upstate New York market. For syndicators, lenders, and developers tracking where institutional capital is flowing in 2026, this transaction — and the phased pipeline it sets up — deserves close attention. The future development phase on the demolished building footprints represents an already-entitled land position inside an active affordable community, a rare asset in today's environment.

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Key Takeaways:

• Maryland DHCD awarded more than $1 billion in total financing commitments in FY 2026.
• The round funds the creation or preservation of 3,025 affordable rental units statewide.
• Awards span LIHTC (4% and 9%), state rental housing funds, the Multifamily Bond Program, and energy efficiency programs — a full capital stack approach.
• Implied public subsidy commitment averages approximately $330,000 per unit, reflecting current construction cost realities.
• The Multifamily Bond Program component reinforces Maryland's commitment to bond-financed 4% deals as a volume driver.
• Energy efficiency program layering signals a dual focus on development feasibility and long-term resident operating cost reduction.
• Deal closings from this award round are expected to flow over the next 12–24 months, creating active transaction opportunities for syndicators and lenders.

Maryland's FY 2026 round is one of the larger state HFA commitments on record for the state, and it sets a pricing and absorption benchmark for investors already holding Maryland LIHTC paper or evaluating new placements. Developers with active relationships in the state should move quickly to understand specific award recipients and capital stack structures. The subsidy is committed — execution is the next hurdle.

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Key Takeaways:

• The new NSPIRE compliance deadline for HCV and PBV programs is February 1, 2027 — extended from the previously anticipated timeline.
• The PIH notice formalizes a September email announcement, giving PHAs a defensible administrative record and regulatory clarity.
• Moving to Work PHAs are included in this notice — no separate compliance timeline or carve-out applies.
• NSPIRE standards differ materially from HQS in how life-threatening deficiencies, violation categories, and scoring are handled — affecting operational assumptions in existing and pipeline deals.
• PBV-layered LIHTC transactions are particularly exposed: rent structures and underwriting assumptions built around HQS inspection outcomes may require reassessment under NSPIRE.
• Owners and operators should use the remaining window to conduct gap analyses between current HQS performance and NSPIRE requirements and build remediation into asset management plans.
• The extended deadline is a planning opportunity — deals closing now with PBV components should model NSPIRE compliance costs before February 2027.

With a firm deadline now on record, the window for passive monitoring is closed. LIHTC investors and developers with PBV exposure should be running NSPIRE gap assessments now, not in late 2026. The transition from HQS to NSPIRE represents one of the most significant shifts in voucher-program physical inspection standards in decades — and the February 2027 deadline will not move again.

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Key Takeaways:

• KHRC published the 2027 draft QAP with a full redline against the current plan — review it to identify any changes to scoring, set-asides, basis boost eligibility, or developer fee caps.
• Virtual public hearing is set for Wednesday, August 19, 2026 at 10:30 a.m. — registration is required in advance.
• The public comment period is open now; written comments submitted alongside hearing testimony carry the most influence.
• Scoring and threshold changes in the QAP directly determine which deals are competitive in Kansas for the full 2027 LIHTC cycle.
• Developers with active Kansas pipeline should map proposed changes against site selection criteria, income targeting requirements, and amenity scoring before pre-development spending deepens.
• State HFAs track stakeholder participation — repeat applicants and lenders with existing relationships have particular standing to shape final QAP language.
• Once the QAP is finalized, comment-period leverage disappears; organizations with positions on any provision should act now.

Kansas is one of several states finalizing QAPs for the 2027 allocation cycle this summer. Tracking redlined changes across state HFAs is increasingly important as developers balance multi-state pipelines against shifting scoring environments. If your team operates in Kansas or is evaluating entry, the KHRC draft QAP and public hearing represent direct access to the decision-makers setting next year's rules. Engage early and on the record.

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Key Takeaways:

• Fund 31 closed at $160 million, making it a significant multi-investor vehicle in the current market.
• 10 institutional limited partners participated, signaling broad LP interest despite a challenging development environment.
• Equity will flow to nine affordable housing properties — implying an average of roughly $17–$18 million per asset.
• The fund is structured to create or preserve more than 1,400 affordable homes.
• The multi-investor fund format diversifies risk across a portfolio of deals, a structure increasingly favored by institutional LPs seeking LIHTC exposure without single-deal underwriting.
• Freshly closed funds carry deployment timelines — developers with near-term, shovel-ready deals are well-positioned to engage Merchants Capital now.
• The close reinforces that institutional LIHTC equity demand remains intact heading into the second half of 2026.

The Merchants Capital Fund 31 close comes at a moment when the affordable housing industry is closely watching LP sentiment. Higher construction costs and prolonged interest rate pressure have complicated deal underwriting, yet this closing demonstrates that well-capitalized syndicators are still assembling large, diversified equity pools. Developers, co-syndicators, and lenders should treat this as a signal to engage active equity platforms early — capital with a deployment mandate moves fastest to sponsors who are ready to close.

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Key Takeaways:

• Federal funding expires September 30, 2026 — a CR is the base case, not a full-year spending bill.
• The House passed 3 of its 12 FY2027 funding bills; the Senate has released no CR text and no FY2027 bill language.
• The House CR includes zero anomalies requested by the Trump Administration — a significant omission for HUD program continuity.
• Senate Majority Leader Thune (R-SD) plans to bring a stopgap to the floor before August 7; the Senate version is expected to include some anomalies.
• Senate Appropriations Ranking Member Patty Murray (D-WA) called the House CR flawed and said it is unlikely to pass the Senate as written.
• HUD programs — including tenant-based rental assistance, project-based Section 8 renewals, and HOME — are funded through annual appropriations and are directly exposed to CR terms.
• Absence of HUD-specific anomalies could create operational disruptions to voucher renewals and rental assistance payment timing.

A bicameral negotiation between the House's clean CR and the Senate's anomaly-inclusive version will play out over the coming weeks. For affordable housing stakeholders, the Senate CR text — when released — is the document to watch. Whether HUD programs receive anomaly protection will determine the operational risk heading into the fourth quarter. Monitor Senate Appropriations closely for any program-specific language affecting Section 8, HOME, or housing finance agency allocations.

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Key Takeaways:

• OGC rescinded 13 guidance documents in a single notice issued July 17, with a September 25, 2025 effective withdrawal date.
• Rescinded documents cover four major compliance areas: Fair Housing, VAWA, the Mrs. Murphy exemption, and tenant admittance and eviction in federally assisted housing.
• OGC's stated grounds include: guidance not prescribed by statute, guidance inconsistent with statute or regulation, and guidance imposing compliance burdens beyond the regulatory baseline — that third category has the broadest implications for owners.
• HUD's Office of Fair Housing and Equal Opportunity (FHEO) had already withdrawn a separate set of guidance documents in April, with an earlier effective date of September 17, 2025 — this OGC action is a continuation of the same rollback strategy.
• Underlying statutes and regulations remain in force; what's disappearing is the interpretive layer that shaped day-to-day compliance expectations.
• VAWA implementation guidance and tenant screening standards are among the highest-risk areas where the removal of agency direction creates immediate operational ambiguity.
• State HFAs and larger PHAs are likely to issue their own interim guidance to fill the void — watch for that activity in the coming months.

This rollback removes compliance scaffolding that owners and management agents have built procedures around for years. Until replacement guidance — from HUD, state HFAs, or PHAs — arrives, operators of federally assisted housing should treat their VAWA policies, tenant screening criteria, and eviction procedures as requiring immediate legal review. The gap between statutory text and prior agency interpretation is now exposed, and the direction of risk exposure has shifted.

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Key Takeaways:

• USDA proposes allowing Section 515 Direct Multifamily Housing subsequent loans to be used for acquisition — a use currently not permitted under existing regulations.
• The change is specifically targeted at preservation transactions involving properties originally financed by USDA's Section 515 program.
• Section 515 properties are among the most at-risk affordable units in the U.S. — typically small, rural, aging, and serving extremely low-income residents with few market alternatives.
• Adding acquisition as an eligible use could reduce equity or gap financing requirements in rural preservation deals, improving deal feasibility.
• 4% LIHTC transactions involving Section 515 property transfers will need to model the new debt layer against USDA loan assumption and subordination requirements.
• The comment deadline is August 31, 2026 — a tight window given the technical complexity of the proposal.
• Final regulatory language will determine real-world usability; industry comment on structuring mechanics and rural market realities is essential before the window closes.

Rural multifamily preservation has long been constrained by small deal sizes, scattered geographies, and limited capital tools. If finalized in a workable form, this rule change could meaningfully expand USDA's role as a preservation lender — but the devil is in the drafting. Developers, state HFAs, syndicators, and lenders active in rural markets should review the proposed rule and submit comments before August 31.

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Key Takeaways:

• A House continuing resolution — rather than full appropriations — risks carrying forward flat or reduced funding baselines for HOME, Housing Choice Vouchers, and HUD administrative operations.
• HUD's withdrawal of FHA guidance documents creates underwriting uncertainty for lenders closing FHA-insured multifamily deals paired with 4% LIHTC and private activity bonds.
• Without current written guidance, lenders and counsel will need direct HUD program staff engagement to confirm policy positions, adding timeline and closing risk to active pipelines.
• DHS finalized a rule rescinding the 2022 public charge clarification that explicitly excluded housing assistance from inadmissibility determinations.
• The rollback reintroduces documented chilling effects among eligible immigrant households, directly threatening voucher utilization rates and occupancy stability at affordable properties.
• Compliance teams should brief on-site staff on the public charge change now — income certification integrity and occupancy projections used in underwriting can be affected by resident behavior changes.
• All three developments converge on the same pipeline simultaneously: financing-layer friction (FHA guidance), program-layer funding uncertainty (CR), and resident-layer chilling effects (public charge).

The combination of a continuing resolution, withdrawn FHA guidance, and a reversed public charge rule represents compounding regulatory headwinds arriving at the same time. Developers and syndicators should stress-test deal timelines against HUD processing delays, lenders should escalate FHA guidance questions to program staff rather than relying on withdrawn documents, and property managers should prepare residents and compliance teams before confusion reaches the lease level. Forward-looking teams will map their exposure across all three vectors now.

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Key Takeaways:

• OHCS is updating the QAP for the 2027 and 2028 LIHTC award cycles — changes will affect scoring, set-asides, and underwriting parameters for both 9% and 4% allocations.
• An engagement session is set for Monday, July 27, 2026, 11 a.m.–noon Pacific, held via Microsoft Teams webinar — registration required.
• The April 2026 QAP survey focused on three areas: current QAP performance, financial challenges developers face, and specific policy questions — signaling OHCS is open to feasibility-driven changes.
• A formal public hearing and open comment period is anticipated for fall 2026, providing a second structured opportunity for industry input.
• QAP draft documents and comment opportunities will be distributed through OHCS Technical Advisories — teams not on that list risk missing critical windows.
• Direct questions to OHCS can be submitted to the QAP team via email ahead of or following the July 27 session.

Oregon's QAP revision comes as developers across the state are navigating persistent cost and feasibility pressures. OHCS's explicit focus on financial challenges in its survey suggests the agency may be considering meaningful adjustments to how it underwrites or scores projects under current market conditions. Stakeholders with Oregon LIHTC exposure — whether active in competitive 9% deals or bond-financed 4% transactions — should participate in the July 27 session and position their organizations to comment during the fall public process before the QAP is finalized.

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Key Takeaways:

• Fund II closed at $137 million; combined with Fund I, Greystone has raised $240 million total in less than 12 months.
• Eight institutional LIHTC investors participated in Fund II; three are repeat investors from Fund I, indicating strong platform execution.
• Portfolio is 60% new construction / 40% rehabilitation, with 80% of properties carrying project-based rental subsidies.
• Average affordability level across the portfolio is 56% of Area Median Income.
• Individual equity investments range from $3 million to $29 million, averaging $11 million per deal; total development costs including debt approach $500 million.
• Portfolio spans nine states: North Carolina, Louisiana, Illinois, Pennsylvania, Connecticut, Arkansas, Tennessee, New Jersey, and Ohio.
• Projected economic impact includes ~2,700 jobs, ~$300 million in business revenue, and at least $111 million in local tax revenue.

The Greystone story is worth tracking for what it signals about institutional demand. CRA-motivated investors are increasingly drawn to LIHTC funds as a vehicle for stable, long-term, impact-linked returns — and the repeat investor participation in Fund II suggests that demand is translating into real performance confidence. Developers active in the nine portfolio states should take note of Greystone's deal parameters as a benchmark for where institutional fund capital is pricing and sizing today.

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Key Takeaways:

• HUD projects national per unit cost growth at 2.337% between FY 2025 and FY 2026.
• The RFIF notice is effective July 6, 2026; public comments are due August 5, 2026.
• HUD is updating its PUC prediction methodology — not just setting an inflation number.
• For FY 2027, HUD proposes adding a factor for local land use, permitting, and regulatory housing policies that may be influencing local rent inflation above national trends.
• The proposed localized regulatory factor could increase HAP contract revenue predictability in supply-constrained markets with restrictive zoning environments.
• Syndicators and lenders underwriting deals with project-based voucher components should monitor how the FY 2027 methodology change interacts with local market conditions in their portfolios.
• PHAs relying on RFIF projections for renewal budget planning should review the methodology changes before the August 5 comment deadline.

The FY 2027 methodology proposal is the more consequential development here. HUD explicitly linking local regulatory housing policy to funding inflation factors is a notable shift — one that could affect underwriting assumptions in high-cost, supply-constrained markets and reshape how PHAs and project-based voucher deals are modeled. Stakeholders with active PBV pipelines or PHA advisory relationships should engage the comment process before the August 5 deadline.

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Key Takeaways:

• HUD's proposed rule targets the FFRMS final rule published in April 2024 — a full rescission of its elevated flood hazard standards.
• HUD's Part 55 floodplain management regulations would generally revert to their pre-April 2024 state.
• Flexibilities related to floodways, categorical exclusions, exemptions from Part 55 applicability, and the decision-making process would be preserved — not rescinded.
• Deals using FHA 221(d)(4) or 223(f) financing on sites near Special Flood Hazard Areas are directly affected — reduced elevation and freeboard requirements lower development cost and complexity.
• Developers and syndicators with deals in the pipeline structured around FFRMS requirements should revisit site engineering assumptions with environmental counsel.
• The public comment period closes September 8, 2026 — state HFAs, syndicators, and developers have a direct opportunity to shape the final rule.
• The proposed rule represents a broader rollback of Biden-era climate risk standards embedded in HUD program requirements.

This proposal is a significant policy reversal with real deal-level implications. For teams active in HUD-insured lending or layering HUD grants into LIHTC transactions, now is the time to assess how the FFRMS has affected your underwriting and site selection — and whether the retained flexibilities adequately address floodplain risk management going forward. Engaging in the comment process before September 8 is the clearest way to influence the final outcome.

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Key Takeaways:

• OHFA has posted the first draft of its 2026–2027 9% LIHTC QAP Technical Amendment for public comment — a mid-cycle revision with potential scoring implications across the state.
• Updated Urban Institute data and maps have been published alongside the draft, directly affecting how OHFA defines opportunity areas and eligible geographies for competitive scoring.
• The comment period also covers OHFA's additional credits policy, which governs how allocations beyond standard awards are handled — a key lever for deals with above-average credit need.
• The comment deadline is 5 p.m. on the date published on OHFA's website; written submissions must be received by that time.
• Developers should cross-reference active Ohio sites against revised Urban Institute maps immediately — a change in opportunity area designation can materially alter a deal's competitive scoring position.
• Ohio operates one of the most active 9% LIHTC programs in the Midwest, making QAP amendments consequential for a large share of regional affordable housing pipeline.
• Substantive public comment during this window is the last point of real leverage to influence final QAP language before the amendment is locked for the cycle.

Mid-cycle QAP technical amendments don't happen in a vacuum — when an agency like OHFA updates its underlying opportunity mapping through a partner like the Urban Institute, the ripple effects on deal competitiveness can be significant. Teams with Ohio pipeline should treat this comment period as an active workstream, not a passive notification. Review the maps, assess your sites, and engage with the additional credits policy language if it touches your capital stack. The window is open now.

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Key Takeaways:

• Section 203 raises the Public Welfare Investment Cap from 15% to 20% of overall bank capital, expanding balance-sheet room for CRA-driven affordable housing equity investment.
• Section 204 reforms CDBG to permit new housing construction for the first time, allowing cities to allocate up to 20% of their CDBG funds toward new development.
• Section 212 expands the Rental Assistance Demonstration (RAD) program, giving PHAs broader authority to take on debt for unit preservation and rehabilitation.
• Section 301 eliminates HUD's permanent steel chassis requirement for manufactured homes; Section 303 updates FHA lending rules to allow home improvement loans for manufactured homes used as ADUs — opening a new federally backed financing lane.
• Section 208 authorizes a $200 million innovation fund for communities that increase housing supply, subject to congressional appropriation.
• HUD is directed under Section 107 to develop zoning and land use best practices for localities — guidance that could influence future state QAP incentive structures.
• The bill does not appropriate new demand-side dollars, does not address HUD staffing cuts, and leaves the mixed-status rule and housing-first policy questions unresolved.

The ROAD Act's passage required genuine cross-aisle cooperation — Senate Banking Chair Tim Scott and Ranking Member Elizabeth Warren, House Financial Services Chair French Hill and Ranking Member Maxine Waters all had to find common ground. That political signal matters as much as the technical provisions: housing affordability is now a durable bipartisan priority, which sets the table for future, potentially larger reforms. For practitioners, the immediate focus should be on HUD implementation guidance for the CDBG construction flexibility and the Public Welfare Investment Cap increase, and on how state HFAs begin to incorporate the new manufactured housing financing pathways into upcoming QAP cycles.

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Key Takeaways:

• The Trump administration is moving to shut down HUD's Restore-Rebuild initiative, drawing national coverage from Politico.
• The San Diego Housing Commission is walking back plans to build 700 new affordable units that were structured around Restore-Rebuild funding.
• CLPHA CEO La Shelle Dozier called the move a direct contradiction of HUD's stated goal to expand affordable housing supply.
• Restore-Rebuild was one of the few remaining federal tools capable of delivering deep affordability layering in markets where 9% credits alone cannot close the financing gap.
• NH&RA led a letter-signing effort to HUD as recently as June 24 urging reconsideration — a sign that organized industry advocacy is underway but has not reversed course.
• Deals with Restore-Rebuild assumptions in their financing stacks face repricing, restructuring, or collapse without a replacement mechanism.
• State HFAs may face pressure to respond through QAP incentives or state-funded bridge programs as the federal gap widens.

With the fiscal year-end approaching and congressional appropriators still engaged on housing funding, there is a narrow window for legislative intervention. Developers and PHAs with active Restore-Rebuild pipelines should begin stress-testing their financing structures now and engaging state HFAs about potential gap-filling strategies. The program's elimination is not yet finalized in statute, but the administrative intent is clear — waiting is not a strategy.

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Key Takeaways:

• 57.2% of LIHTC residents are classified as extremely low-income (≤30% AMI) — the highest share ever recorded in this dataset.
• Only 6.2% of residents earn more than 60% AMI, meaning the program is heavily concentrated well below its statutory eligibility ceiling.
• 48.3% of LIHTC residents received monthly rental assistance in 2023 — the highest share since HUD began tracking this figure in 2015.
• The national median LIHTC tenant income was $18,600; nearly 20% of households reported annual income of $10,000 or less.
• The growing share of assisted tenants signals deepening interdependence between the LIHTC program and the Housing Choice Voucher system.
• This data strengthens the policy case for extremely low-income set-asides and deeper income targeting in state QAPs.
• Developers and underwriters should reassess rent collection risk assumptions given the declining income profile of the LIHTC tenant population.

The 2023 Tenant Tables arrive at a moment when state housing finance agencies are refining their qualified allocation plans and Congress is debating the future of both the LIHTC program and the voucher system. The convergence of these policy tracks matters: if nearly half of LIHTC tenants depend on rental assistance to afford a tax credit unit, program design decisions made in Washington and in state capitals are more tightly coupled than ever. Stakeholders across the capital stack should be using this data now — in QAP comment periods, in advocacy, and in deal structuring.

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Key Takeaways:

• 504 Section 515 properties have exited the portfolio before their mortgage maturity date — signaling early opt-outs and deterioration, not just scheduled wind-down.
• Seven states — Nebraska, North Dakota, Michigan, South Dakota, Wisconsin, Indiana, and Iowa — each lost more than 10% of their Section 515 housing stock between 2021 and 2026.
• Michigan recorded the largest unit loss: 2,072 affordable rural housing units departed the program in just five years.
• Losses are concentrated in the Midwest and Upper Great Plains, where early Section 515 loans are now reaching maturity — making this a regional crisis first, but a national one soon.
• USDA projects annual exits will accelerate sharply, peaking around 2040, with complete program depletion possible by 2056.
• Section 515 markets largely fall outside the LIHTC financing stack, meaning lost units are rarely replaced by conventional affordable housing mechanisms.
• Preservation opportunities exist now in the seven hardest-hit states — before the exit curve steepens further.

For LIHTC investors, syndicators, and rural lenders, this brief is a signal to watch for preservation vehicles targeting Section 515 — including potential loan restructuring programs, new USDA appropriations, and rural housing tax credit proposals that have been circulating in Congress. The states losing the most units today are also the states most likely to assemble preservation pipelines first. That's where the near-term deal flow will be.

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Key Takeaways:

• Plaintiffs filed a supplemental complaint in the existing CoC lawsuit, extending the legal challenge from the FY 2025 NOFO to the newly released FY 2026 NOFO.
• A preliminary injunction issued in December 2025 already blocked HUD's altered FY 2025 CoC NOFO, reverting to the prior FY 2024–25 version.
• Plaintiffs argue the FY 2026 NOFO "bears many similarities to the version the court already determined likely to be unlawful" — strong language signaling a high-confidence legal posture.
• FY 2026 CoC applications are still due August 26, despite the active litigation — applicants must decide whether to proceed under a potentially enjoined NOFO.
• CoC operating subsidies are frequently paired with LIHTC equity in permanent supportive housing deals; litigation-driven disruption creates bankability risk for deals in predevelopment.
• Any emergency motion for a temporary restraining order before August 26 could force HUD to extend the deadline or revert to prior NOFO terms.
• Developers and syndicators with CoC-dependent deals should build contingency language into timelines and monitor court dockets closely.

This case is a live test of HUD's authority to reshape the CoC program's criteria and emphasis through the NOFO process alone. If the court extends injunctive relief to the FY 2026 cycle, it would mark the second consecutive year HUD's CoC funding notice has been blocked — a significant constraint on the agency's ability to redirect the program without statutory or regulatory change. Stakeholders across the supportive housing spectrum should treat August 26 as a fluid target and maintain close contact with their legal counsel and CoC intermediaries as the case develops.

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Key Takeaways:

• CHFA's draft QAP covers two full allocation cycles — 2027 and 2028 — giving it an unusually long governance horizon for Connecticut LIHTC deals.
• A virtual public hearing is scheduled for July 7, 2026 at 10:00 AM ET via Zoom; all stakeholders are invited to participate.
• Written comments are accepted through close of business July 10, 2026 — just three days after the hearing.
• Submissions can be sent by email or by mail to Terry Nash Giovannucci, CHFA, 999 West Street, Rocky Hill, CT 06067.
• QAP provisions that merit close review include scoring criteria, set-aside allocations, geographic targeting, income targeting requirements, and developer fee caps — all of which directly affect deal feasibility.
• Syndicators and investors should use the draft to anticipate deal flow composition (project type, location, tenant population) from Connecticut over the next two years.
• Any party with active or planned Connecticut LIHTC applications should prioritize submitting formal comments before the July 10 deadline.

With a two-year QAP, CHFA is setting the rules of the road for Connecticut affordable housing finance through the end of 2028. Changes embedded in this draft — whether to basis limits, scoring weights, or set-aside priorities — will compound across two full funding rounds. Stakeholders who engage now, during the comment period, have the best opportunity to shape outcomes before the plan is finalized.

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Key Takeaways:

• All PRI funding available under RAD for PRAC has been fully exhausted for calendar year 2026.
• New RAD for PRAC conversion plan submissions with PRI submitted after May 29, 2026, will be waitlisted and evaluated first-come, first-served.
• HUD's immediate priority is to assess funding availability and obligations tied to submissions already in the pipeline as of June 25, 2026.
• Deals submitted before May 29 are likely queue-protected; post-cutoff submissions face an indeterminate hold.
• PRI is often the critical bridge between existing PRAC contract rents and the rents required to support debt service in a conversion — making its absence a potential deal-stopper for many transactions.
• No timeline has been published for when HUD will resolve the backlog or when new PRI capacity may become available.
• Sponsors with post-cutoff submissions should confirm their waitlist position and engage their HUD field office directly to understand deal status relative to the June 25 assessment date.

The exhaustion of PRI capacity this far into the calendar year signals that demand for RAD for PRAC conversions is outpacing available resources — a reflection of both the scale of need in the aging Section 202 housing stock and a rapidly building pipeline. Stakeholders should monitor HUD's funding assessment closely and evaluate whether alternative deal structures are viable while awaiting PRI availability. Proactive communication with HUD field offices and early queue positioning will be essential for deals dependent on this funding source.

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Key Takeaways:

• FHFA proposes to eliminate the current Activities framework entirely, including Statutory and Regulatory Activity lists, Additional Activities, extra credit provisions, and minimum activity requirements from three-year plans.
• Enterprises would instead be permitted to pursue any action consistent with Duty to Serve, unless FHFA has specifically deemed it ineligible by regulation or case-by-case review.
• LIHTC investments would earn Duty to Serve credit across all three underserved markets — rural housing, manufactured housing, and affordable housing preservation — up from rural only under the current framework.
• The restriction on subordinate multifamily liens (previously limited to energy and water improvement financing) would be removed, opening the door to broader layered financing structures for multifamily affordable deals.
• The income calculation methodology would be revised to more accurately reflect families in areas of concentrated low-income populations, and affordability determinations for manufactured housing communities would be updated.
• Comments on the proposed rule are due July 24, 2026; regulatory changes are targeted to take effect January 1, 2028.
• A correction affecting refinancing mortgages that are not arms-length or borrower-driven transactions was posted June 26, 2026.

The shift from a prescriptive activity checklist to a principles-based framework with a published ineligible-actions list will fundamentally reshape how Fannie Mae and Freddie Mac structure their Duty to Serve plans — and, by extension, how they engage with LIHTC deals, manufactured housing finance, and preservation transactions. The July 24 comment deadline gives the industry a narrow window to influence what ends up on the ineligible list. Practitioners with active pipeline in any of the three underserved markets should engage now.

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Key Takeaways:

• HUD's RFI targets product-category BABA waivers — meaning relief, once granted, would apply broadly across all projects using those products, not just on a deal-by-deal basis.
• The 30-day comment period closes July 20, 2026 — a tight window requiring immediate action from developers and their procurement teams.
• Covered product categories include HVAC systems (VRF, heat pumps, PTACs), plumbing fixtures, door hardware, elevators, fire alarm/suppression systems, solar panels, wood trusses, and a broad range of electrical components.
• Heat pump subcategories specifically called out include cold climate air-source, ducted split, ductless mini-split, geothermal/ground source, and water source — all common in energy-efficient affordable housing.
• Electrical components targeted include LED lighting fixtures, panelboards, distribution panels, GFCI receptacles, surge protection devices, and security cameras.
• NH&RA has announced it will submit a comment and has offered to assist others in drafting submissions.
• Project-specific BABA waivers are slow and resource-intensive; general applicability waivers would remove deal friction across the entire affordable housing pipeline for affected product types.

The Build America, Buy America Act has added significant procurement complexity to federally assisted housing deals since its implementation. This RFI is HUD's clearest signal yet that it recognizes the operational burden and is looking for an evidence-based path to systemic relief. The public record built from this comment period will directly influence the scope and speed of any waivers granted — making the quality and specificity of developer and contractor submissions critically important. If your pipeline includes deals subject to BABA, this filing deserves attention at the leadership level today.

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Key Takeaways:

• The 21st Century Road to Housing Act has cleared Congress — the only remaining step is a presidential signature.
• President Trump canceled the signing with no rescheduled date announced as of today.
• NAHB Chairman Bill Owens characterized the situation as a timing issue, not a policy breakdown — language that typically signals active negotiation.
• Developers and syndicators with deal structures or financing assumptions tied to any new federal housing authority in this bill should carry a contingency flag on effective dates.
• If the delay moves toward a veto or pocket veto, state HFA QAP planning that anticipated federal policy changes would need to be reassessed.
• Housing supply and affordability remain explicit political pressure points — Congressional passage of a bill of this scope is not routine and is unlikely to be abandoned quietly.
• Watch for a White House statement clarifying the basis for the delay; that statement will determine whether this is a weeks-long pause or a more significant obstacle.

The legislative work is done — this is now an executive timing question. For LIHTC market participants, the practical implication is straightforward: do not underwrite to any policy change in this bill until a signing is confirmed. State HFAs drafting or finalizing QAPs should build flexibility for federal provisions that remain contingent on enactment. The market signal here is a holding pattern, not a collapse — but the distinction only matters if you're positioned accordingly.

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Key Takeaways:

• The DASH Act has now been introduced in three consecutive Congresses (2023, 2024, and 2026); it has failed to advance out of committee both prior times.
• The bill proposes a new Middle-Income Housing Tax Credit (MIHTC) — a separate credit structure targeting the gap between LIHTC-eligible households and market-rate renters, which would require new equity market infrastructure to deploy.
• LIHTC is explicitly named as a strengthening target, alongside investment in deeply affordable housing for extremely-low-income households.
• The first-time homebuyer tax credit is restructured to be advanceable at closing, eliminating the liquidity gap that previously delayed access until tax filing season.
• A new home-sale loss deduction — new to this version of the bill — allows low- and middle-income sellers to deduct up to $100,000 when they sell for less than their original purchase price.
• Housing Choice Vouchers are central to the bill's homelessness strategy, with a five-year mandate to house all people experiencing homelessness, prioritizing children and families.
• The bill's fate depends on markup activity in the Senate Finance and House Ways and Means committees — neither of which has advanced prior versions.

The DASH Act's repeated reintroduction reflects durable Democratic consensus on housing supply, voucher expansion, and tax credit tools — but legislative momentum remains the open question. For the LIHTC community, MIHTC is the provision worth building institutional familiarity with now. If it ever advances, syndicators and equity investors will need frameworks ready. Track Senate Finance and House Ways and Means for any sign of markup activity.

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Key Takeaways:

• MHDC governs allocation of both 9% and 4% LIHTC through its annual QAP and associated Notice of Funding Availability (NOFA).
• The comment period targets the 2028 QAP — opening approximately two years ahead of the plan's effective year, which is earlier than many peer state HFAs.
• Written comments can be submitted directly to MHDC and are formally incorporated into the QAP development process.
• Key policy levers subject to change include scoring criteria, basis limits, income targeting requirements, set-aside categories, and developer fee structures.
• Early input — submitted before internal drafts are circulated — typically carries more influence than comments on a published draft.
• Missouri is one of the more active Midwest HFAs; QAP changes have direct implications for project feasibility and investor returns across the state's deal pipeline.
• Stakeholders with views on rural vs. urban prioritization, income averaging, deeper affordability scoring, or basis boost policy should act now.

Missouri's decision to solicit feedback this early signals that MHDC intends a deliberate, stakeholder-informed process for the 2028 cycle. For organizations with Missouri projects in development or under evaluation, this is the moment to engage — not after a draft is released. Monitor MHDC communications for draft publication timelines and plan your comment strategy accordingly.

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Key Takeaways:

• H.R. 9311, the Build Housing Affordably Act, was introduced as bipartisan legislation in the U.S. House of Representatives.
• Lead sponsors are Rep. Mike Flood (R-NE), Housing and Insurance Subcommittee Chairman, and Rep. Maggie Goodlander (D-NH) — a pairing designed to attract votes from both sides of the aisle.
• The bill directly addresses BABA domestic content procurement requirements that have added cost drag and schedule risk to affordable housing deals with federal funding exposure.
• The stated goal is to "strike a better balance" between promoting domestic production and sustaining the affordable housing development pipeline — framed as a housing production argument, not a deregulatory one.
• BABA compliance friction has hit deals involving HUD programs and certain bond-financed structures particularly hard, where domestic supplier availability and pricing have not kept pace with project needs.
• Flood's subcommittee chairmanship gives the bill a credible path to markup — making this more than a messaging exercise.
• Developers with projects in predevelopment that rely on federal funding should model both current BABA compliance costs and potential relief scenarios as the bill advances.

BABA has been a quiet deal-killer and cost inflator across the affordable housing pipeline since its requirements expanded under the infrastructure law. This bill represents the first serious, bipartisan legislative vehicle aimed at resolving that tension. Developers, syndicators, and lenders should monitor committee activity closely and engage their federal advocacy channels now — the window for industry input on bill language is typically widest before markup. A Senate companion bill, if introduced, would signal genuine momentum toward enactment.

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Key Takeaways:

• Overall May housing starts fell 15.4% to a 1.18 million seasonally adjusted annual rate (HUD/Census Bureau).
• Multifamily starts dropped 40.2% in May to a 295,000 annualized pace — the sector is down 14.2% vs. May 2025.
• Single-family starts declined 1.9% to an 882,000 annualized rate, down 6.7% year-over-year; homes under construction at 587,000, off 5.9% from a year ago.
• Multifamily permits fell 2.8% to a 527,000 annualized pace in May, though they remain up 2.5% vs. May 2025 — a modest forward-pipeline signal worth watching.
• The Northeast is the only region running positive on both starts (+17.5% YTD) and permits (+10% YTD); the South is down 6.7% on permits YTD.
• NAHB's June builder sentiment survey weakened further, with elevated mortgage rates and affordability challenges cited as primary headwinds.
• New LIHTC transactions underwriting today face elevated feasibility risk — the starts-to-permits gap indicates financing and cost execution, not demand, is where deals are stalling.

The divergence between permits (relatively stable) and starts (sharply lower) is the key signal for affordable housing finance professionals. It suggests developers intend to build but cannot make the numbers work at current cost and rate levels — a dynamic that directly pressures LIHTC equity pricing, increases gap financing needs, and may drive further requests for basis boosts or state subsidy layering. Teams actively underwriting new transactions in the South and West should stress-test construction budgets more aggressively and revisit financing structures before locking commitments.

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Key Takeaways:

• The two-year Treasury has risen more than 70 basis points since March, reflecting a bond market repricing from easing to potential tightening.
• Core PCE inflation is running at 3.3% — a three-year high and well above the Fed's 2% target — eliminating near-term justification for rate cuts.
• Headline CPI reached 3.8% year-over-year, also a three-year high, driven in part by energy and commodity prices tied to the Iran conflict and lingering tariff impacts.
• Q1 and Q4 2025 GDP averaged just 1% annualized growth, while the personal saving rate fell to 2.6% — the lowest since June 2022 — signaling household financial stress relevant to rental demand underwriting.
• Single-family built-for-rent starts fell 26% on a four-quarter basis to 62,000 homes, reflecting broad developer caution that should be mirrored in affordable pipeline assumptions.
• Mortgage rates are expected to remain above 6% through 2026, keeping pressure on 4% LIHTC bond pricing and debt service coverage in new construction deals.
• Residential construction added only 900 jobs in May, led by remodeling — a signal of constrained new-build capacity that affects affordable housing timelines and labor cost assumptions.

The rate environment has changed faster than many pipeline deals were underwritten to handle. With no credible near-term catalyst for Fed easing and geopolitical uncertainty keeping inflation elevated, LIE-tek developers and their capital partners should be revisiting interest rate stress tests before commitment, not after. A resolution of the Iran conflict remains the most plausible inflation relief valve, but the timeline is unpredictable. Deals that are thin at today's rates deserve a hard look now.

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Key Takeaways:

• Fund 45 closed at $307 million in LIHTC equity — a significant raise in the current rate environment.
• The fund will finance 2,259 affordable housing units across 27 properties in 10 states.
• An estimated 5,196 residents will benefit directly from Fund 45 investments.
• The fund explicitly blends new construction with preservation, giving Cinnaire pipeline flexibility across deal types.
• Geographic diversification across 10 states signals a risk-management structure designed for institutional corporate investors.
• The close indicates continued investor demand for LIHTC equity despite tax policy uncertainty and compressed deal economics.
• Developers in Cinnaire's Midwest, Mid-Atlantic, and Southern footprint should engage now on fund allocation and deal timing.

Fund 45's close arrives at a moment when preservation pipelines are competing aggressively for equity capital alongside new construction. Cinnaire's ability to blend both deal types into a single $307 million vehicle — and close it — suggests the fund structure resonated with investors seeking diversification. Developers and syndicators should treat this as both a market signal and a near-term equity access opportunity, particularly as deployment timelines will shape deal economics for participating properties through the remainder of the year.

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Key Takeaways:

• Bipartisan Senate pressure targets HUD's BABA waiver backlog, which has caused significant project delays and blocked some affordable housing deals entirely.
• The letter calls on HUD Secretary Turner to improve communication around waiver request status — a basic transparency gap developers have flagged for months.
• Senators are pushing for faster action on completed waiver submissions, meaning requests already in queue should not be stalled by administrative inaction.
• HUD is asked to assess the actual availability of BABA-compliant housing products — addressing the root supply chain disconnect driving most waiver requests.
• All three requested reforms are administrative in nature, meaning HUD can act without new legislation — a faster potential path to relief than a statutory fix.
• Projects using HOME funds, CDBG dollars, or other federal financing that triggers BABA applicability are most directly affected.
• New Hampshire developers with active BABA concerns should contact Ilana Morof directly for advocacy and technical support.

The bipartisan framing here is significant. When both sides of the aisle are putting the same ask in writing to a cabinet secretary, it increases the likelihood of an administrative response. Developers and sponsors with deals stalled on BABA waivers should document the specific timeline and cost impacts — that data is exactly what congressional offices and HUD need to justify accelerated action. Watch for HUD guidance or a public response from Secretary Turner's office in the coming weeks.

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Key Takeaways:

• Pulte retains all three roles simultaneously: FHFA Director, Fannie Mae chairman, and Freddie Mac chairman, in addition to his new acting intelligence post.
• Senate Majority Leader John Thune (R-SD) warned Pulte would face a "lengthy road" to Senate confirmation if nominated permanently — Trump has indicated no permanent nomination is planned, bypassing a confirmation vote.
• Bipartisan criticism came from Sen. Chuck Schumer (D-NY) and Sen. John Cornyn (R-TX), the latter saying he sees "no evidence of any qualifications for that job."
• Section 702 of FISA — authorizing warrantless surveillance of foreign targets — expires June 12; Pulte's appointment threatens to complicate bipartisan reauthorization efforts ahead of that deadline.
• FHFA leadership distraction carries downstream risk for multifamily deal structures that depend on GSE execution certainty, including bond credit enhancement and LIHTC equity transactions.
• Acting status insulates the appointment from a Senate vote, meaning no near-term forcing function for leadership change at FHFA.

For affordable housing deal teams, the practical question is whether FHFA's multifamily and affordable housing agenda maintains momentum under a director now carrying a second, high-profile national security portfolio. Developers and lenders with active GSE-dependent transactions should monitor for any signs of policy slowdown or delegated authority at the agency level. If GSE engagement softens on bond or LIHTC deals in the months ahead, Pulte's divided attention will be the first variable to examine.

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Key Takeaways:

• 745,652 people were counted as homeless in January 2025, a 3.3% decrease from 2024 — the first annual decline since 2016.
• Families experiencing homelessness fell 11.3%; unaccompanied youth dropped 7.9%; unsheltered homelessness declined 2.9%; homeless veterans fell 1.2%.
• Illinois posted the steepest state-level drop at -43.6%, followed by Hawaii at -41.3% and Florida at -11.1%; California fell 2.8% and New York fell 7.9%.
• Since 2013, overall homelessness is up 27%, unsheltered homelessness is up 36%, and chronic homelessness is up 81%.
• An estimated 17,500 people per week entered homeless systems for the first time over the course of 2024, underscoring the sustained demand pressure on housing resources.
• Ann Oliva of the National Alliance to End Homelessness warned that "homelessness remains a crisis" despite the positive headline, calling for sustained investment in housing-focused programs.
• Part 2 of the report — which includes subpopulation and program-level data used in CoC funding allocations — is still pending and will be critical for supportive housing and rental-assistance-layered LIHTC deals.

The report is already being deployed on both sides of the federal budget debate — by advocates as proof that housing-first interventions work, and by fiscal hawks as justification for funding reductions. For LIHTC developers and syndicators with supportive housing components or projects layered with rental assistance, the upcoming Part 2 data will be the more actionable release. State-level outliers like Illinois and Hawaii signal where concentrated public investment is moving the needle — and where deal flow may follow.

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Key Takeaways:

• CHFA updated compliance policies across 3 multifamily program areas simultaneously — a scope that signals either federal regulatory realignment (likely HOTMA) or monitoring-driven corrections.
• The revised manual governs all CHFA-financed developments with Housing Tax Credits, CHFA multifamily loan financing, or a combination of both.
• CHFA has explicitly designated this as the authoritative version — prior editions are no longer controlling for procedures, rules, or regulations.
• LIHTC developments out of conformance on income calculation, asset verification, or recertification procedures face findings that can escalate to credit recapture.
• HOTMA implementation remains an active recalibration point for state HFAs; any alignment in this update has immediate implications for site-level compliance programs.
• Syndicators and investors with Colorado assets should confirm asset management and compliance monitoring partners have reviewed the new manual and benchmarked it against current practices.
• Developers with active CHFA-financed deals in lease-up or construction should complete their review before the first compliance monitoring event under the new framework.

State HFA compliance manual updates rarely make headlines, but they set the standard by which properties are measured during monitoring — and findings under an updated framework can carry serious consequences for LIHTC equity. Colorado operators and investors should treat this as effective immediately, pull the full change list from CHFA, and close any gaps between current site practices and the new guidance before the next monitoring cycle.

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Key Takeaways:

• CHFA allocated $11.5 million in 9% LIHTCs across six developments in a single board-approved round.
• The 319-unit portfolio includes 282 affordable apartments — approximately 88% affordability across the slate.
• Five municipalities received awards: Cromwell, Farmington, Hartford, Naugatuck, and New Britain — signaling a geographic distribution preference in the current QAP cycle.
• The round covers both new development and preservation, creating distinct underwriting profiles for lenders and syndicators on construction financing and exit assumptions.
• Annual credit per affordable unit runs roughly $36,000 — a benchmark for syndicators pricing Connecticut 9% deals against current construction cost environments.
• Suburban and small-city markets (Naugatuck, Cromwell) clearing the same credit threshold as Hartford suggests CHFA is actively rewarding non-urban supply solutions.
• Developers with projects in the Connecticut pipeline should analyze this round for active QAP preference signals before the next application cycle.

Connecticut's affordable housing shortfall remains measured in the tens of thousands of units, so 282 affordable apartments won't close the gap on its own. But this allocation confirms that CHFA's 9% pipeline is active and competitive heading into the second half of 2026. Investors and lenders tracking Northeast market health should watch for corresponding state bond or Housing Trust Fund activity to fill financing gaps — particularly on new construction deals in the smaller markets represented in this round.

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Key Takeaways:

• Two bills passed in 2026: the Maryland Transit and Housing Opportunity Act and the Maryland Housing Certainty Act — each targeting a distinct barrier to affordable housing production.
• The Transit and Housing Opportunity Act focuses on production near transit corridors, a signal that transit-oriented sites may receive favorable treatment in future QAP scoring cycles.
• The Housing Certainty Act is designed to reduce entitlement and approval unpredictability — a direct risk-reduction mechanism for 9% LIHTC deals with tight credit reservation timelines.
• Maryland DHCD's FY2027 budget is explicitly framed as supporting robust affordable housing investment and safeguarding existing program capacity alongside the new legislative framework.
• Specific appropriation figures tied to the new acts have not yet been publicly detailed — watch for Maryland DHCD guidance releases for dollar amounts and program-level allocations.
• Developers should map existing pipeline against Maryland transit corridors now, ahead of any QAP revisions that may incorporate the new legislative priorities.
• State HFA watchers should monitor Maryland's next QAP cycle closely — new production legislation paired with a budget commitment frequently precedes changes to set-asides and scoring criteria.

Maryland's legislative move is part of a broader state-level trend of pairing transit-oriented development policy with affordability mandates. For deal teams active in the state, the window between legislative passage and QAP operationalization is the highest-leverage period for site selection and partnership positioning. Early alignment with stated policy priorities has historically translated into competitive advantages in 9% allocation rounds and stronger bond-financing narratives in 4% transactions. Stay close to Maryland DHCD communications over the coming months.

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Key Takeaways:

• The proposed rule affects up to $1 trillion in federal financial assistance across grants, cooperative agreements, and other assistance mechanisms.
• Comments are due July 13, 2026; OMB is targeting a final rule effective October 1, 2026.
• E-Verify screening and English-only materials requirements would add new compliance layers to HUD and other federal grant programs.
• Fraud allegations would be referred directly to inspectors general and prosecutors, bypassing standard internal agency review processes.
• Proposed limits on disparate-impact enforcement could alter fair housing compliance strategies for affordable housing operators.
• Greater authority for political appointees over grant approvals and monitoring reduces agency-level flexibility and insulation from political intervention.
• OMB would gain expanded discretion to withhold funding — introducing timing and certainty risk for transactions dependent on reliable federal funding flows.

This rule is not abstract policy. If finalized as proposed, it restructures the compliance environment and funding certainty for any affordable housing deal touching federal grants. Stakeholders with operational exposure to HUD programs should submit detailed, program-specific comments before the July 13 deadline. The October 1 effective date leaves little runway for implementation planning once a final rule is issued.

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Key Takeaways:

• Total HUD funding proposed at $71.4 billion, a $5.9 billion reduction from FY 2026 enacted levels.
• HOME funded at $500 million, down from $1.25 billion — a significant cut, but an improvement over FY 2026's starting position, when both the President's budget and the House bill proposed zeroing it out entirely.
• Tenant-based Section 8 at $38.083 billion, slightly below the $38.4 billion enacted in FY 2026 — a narrow but real gap for housing authorities already under pressure.
• Project-based Section 8 receives a $432 million increase over FY 2026 enacted levels, coming in at $18.975 billion — a positive signal for preservation and new construction pipelines.
• Choice Neighborhoods zeroed out again; Congress restored it at $25 million in FY 2026, but that outcome is not guaranteed to repeat.
• HOME, CDBG, public housing, and several other programs exempted from Build America, Buy America compliance for FY 2027 and prior years — a significant relief provision for deals where BABA has been slowing draws and closings.
• Continuum of Care funded at $3.778 billion, down $231 million from enacted levels, but the House rejected the administration's proposal to eliminate CoC and fold homeless assistance into ESG.

Today's full committee markup is the next inflection point. The House bill is the floor of negotiations, not the ceiling — the Senate is expected to take a less aggressive posture on cuts, particularly for HOME and tenant-based vouchers. Developers and syndicators with HOME-dependent deal structures should model a wide range of outcomes. The BABA exemption provision, if it survives to enactment, would remove a material compliance barrier on HOME-funded closings. Watch for Senate appropriators' response and any floor amendments that could shift the HOME or voucher numbers before a final conference agreement takes shape.

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Key Takeaways:

• HUD's FY2026 CoC NOFO releases $4.04 billion — described by HUD as a record funding level for the program.
• $1.3 billion is specifically reserved for new projects, with explicit priority given to Transitional Housing and Supportive Services over permanent supportive housing.
• Automatic renewal of CoC grants is eliminated; CoC recipients must now competitively scrutinize and prioritize projects based on performance outcomes.
• HUD is conditioning funding on prohibiting facilitation of illicit drug use, directly targeting harm-reduction models that have operated within CoC-funded programs.
• HUD is actively encouraging new applicants, signaling that incumbent grantees no longer hold a structural funding advantage.
• Deals carrying CoC-dependent operating revenue — particularly those built on housing-first frameworks — face genuine renewal risk under the new NOFO structure.
• State QAP scoring of supportive housing and lender underwriting of CoC grant revenue may need to be reassessed as the federal program's priorities realign.

This NOFO represents the most significant structural overhaul of the CoC program in its history. For the affordable housing finance community, the shift isn't just ideological — it changes the risk profile of supportive housing deals that depend on CoC operating subsidies. Developers, syndicators, and lenders should review existing and pipeline deals for CoC revenue exposure, and state HFAs should expect pressure to realign supportive housing priorities in upcoming QAP cycles. The $1.3 billion in new project funding is a real opportunity, but only for organizations positioned to compete under the new performance and programmatic framework.

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Key Takeaways:

• The House passed the 21st Century ROAD to Housing Act 396-13, reflecting overwhelming bipartisan support rarely seen on housing legislation.
• The White House issued a Statement of Administration Policy indicating presidential advisers would recommend the President sign the bill as passed — a strong pre-signature signal.
• Senate Banking Committee Chairman Scott and Ranking Member Warren issued a joint statement committing to continue work toward a bill that can pass the Senate, stopping short of endorsing the House text outright.
• The institutional investor single-family home-buying provision remains a point of disagreement between House Financial Services Ranking Member Maxine Waters (D-CA) and Senator Warren — a fault line that could force amendments or a conference process.
• The Senate previously passed its own strong bipartisan housing bill, meaning reconciliation between chambers is a live possibility, introducing timeline risk for practitioners.
• LIHTC stakeholders should monitor the Senate Banking Committee for markup activity and any targeted amendments to the institutional investor provision.
• The bill's momentum is real — a 396-13 vote and White House backing are rare alignments — but Senate procedure and intra-progressive disagreements could slow final passage.

This is one of the most significant bipartisan housing pushes in years, and the political window appears genuinely open. For affordable housing investors, developers, and syndicators, the near-term question is whether the Senate moves on the House text or insists on its own version — and how the institutional investor provision gets resolved without fracturing the coalition. Track Senate Banking Committee activity closely over the coming weeks.

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Key Takeaways:

• H.R. 9012 would permit 5-year carrybacks of unused LIHTC against prior-year tax liability — a mechanism currently unavailable for the Housing Credit.
• The current code allows only 20-year carryforwards, which defers value and reduces capital efficiency for investors who hit absorption ceilings in a given year.
• A carryback mechanism can generate immediate tax refunds rather than stranded credits, improving investor liquidity and willingness to commit capital.
• Improved investor absorption capacity is a direct input to credit pricing — better pricing at the deal level helps developers close financing gaps in a high-cost construction environment.
• The bill was introduced with bipartisan support: Rep. Carey sits on the House Ways and Means Committee, giving the bill a sponsor with direct committee standing.
• H.R. 9012 has been referred to Ways and Means — the same committee that would handle any broader tax legislation where this provision could be incorporated.
• The bill may move as a standalone measure or be folded into a larger tax package; either path requires early engagement from industry stakeholders.

The Affordable Housing Credit Carryback Act is early-stage legislation, but it targets a real friction point that the LIHTC investor community has long identified. With a Republican co-sponsor on Ways and Means and a bipartisan House introduction, the bill has a credible path to at least a committee hearing. Developers, syndicators, and lenders should monitor the Ways and Means calendar closely and engage their congressional contacts now — particularly as broader tax legislation remains active in the current session.

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Key Takeaways:

• The interim rule removes the final HUD clearance-officer approval for multifamily projects with 200+ units or a mortgage above $5 million receiving federal assistance.
• Effective date is June 22; public comments are due by July 21 — a real opportunity to shape whether the rule is finalized as written.
• HUD argues the requirement — added by a single sentence in 1996 to a 1971 rule — is not statutorily required and duplicates earlier review steps.
• The change is framed under Trump's Unleashing American Energy executive order, part of a broader agency-wide deregulatory push.
• Secretary Turner has also rolled back eviction-related rules and energy-efficiency standards, establishing a consistent pattern of regulatory rollback on the production side.
• Two March executive orders further direct agencies to eliminate development barriers and ease community bank mortgage underwriting restrictions.
• Developers with deals currently in the HUD environmental review pipeline should confirm with counsel how the June 22 effective date applies to in-process transactions.

The administration is building a deregulatory posture on housing production that, for LIHTC professionals, has tangible deal-level implications. The comment period is open and data-driven submissions from developers and lenders who have experienced timeline disruptions from the current clearance-officer step could directly influence the final rule. Watch for further regulatory rollbacks as HUD continues reshaping its operating framework under Secretary Turner.

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Key Takeaways:

• OHFA awarded more than $39.1 million in annual 9% LIHTC credits for the 2026 round — roughly $391 million in gross ten-year credit authority before pricing.
• 25 developments received conditional commitments, averaging just under $1.6 million in annual credits per project.
• Awards are conditional commitments from the OHFA Board — carryover agreements have not yet been executed, placing projects in the document and due diligence phase.
• Equity investors who pre-screened 2026 Ohio deals should expect formal term sheet activity to accelerate in the near term; the window to enter specific transactions is narrowing.
• OHFA's QAP priorities — community revitalization areas, deepest income targeting, and rental assistance pairings — shaped competitiveness in this round and will continue to do so in future cycles.
• Developers who did not receive 2026 awards should analyze this cycle's scoring outcomes now to strengthen positioning before the 2027 round opens.
• Ohio's oversubscribed round reflects national trend: 9% credit demand consistently exceeds state allocation authority across virtually every HFA.

Ohio remains one of the more active Midwestern states for affordable housing tax credit investment, and the 2026 round reinforces that pipeline depth. Syndicators and lenders not already engaged with these 25 projects should move quickly. For developers and policy stakeholders, the award list is the most current read on how OHFA is operationalizing its QAP priorities when supply is constrained — study it before the next allocation cycle begins.

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Key Takeaways:

• The House Financial Services Committee released an updated version of the 21st Century ROAD to Housing Act ahead of today's floor vote.
• The bill is advancing without the SAVE America Act, despite explicit pressure from President Trump via social media — a significant procedural decision by House leadership.
• Decoupling the SAVE America Act removes a potential complicating rider from the affordable housing finance provisions in the ROAD Act.
• A clean House passage would strengthen the bill's posture heading into the Senate, where it will face pressure within a broader reconciliation framework.
• Prior versions of the ROAD Act have included provisions relevant to LIHTC deal structures, bond financing, and HUD program administration — making floor amendments today a key watch item.
• Any modification to the tax title or housing finance provisions during floor consideration could affect deal pricing and credit assumptions for transactions in the pipeline.
• If the bill passes the House, attention shifts immediately to Senate Finance and the question of what survives a conference process.

The next 48 hours are a genuine inflection point for affordable housing legislation in this Congress. A successful House vote without the SAVE America Act sets up a cleaner Senate fight — but the Senate's reconciliation environment remains unpredictable. Developers and investors with active deal timelines should stay close to their government relations contacts and monitor floor amendments in real time. What passes the House today shapes the negotiating baseline for everything that follows.

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Key Takeaways:

• PIH's FY 2026 HCV allocation notice is now published and effective — deal teams should update pro formas accordingly.
• Policy changes are concentrated in two areas: Housing Assistance Payments (HAP) and Administrative Fees.
• HAP funding levels set the ceiling on rent subsidies in PBV transactions closing or renewing in FY 2026 — high-cost metro deals are most exposed to compression risk.
• Administrative fee rates directly affect PHA capacity to run PBV solicitations, process inspections, and advance LIHTC layered closings.
• Historically, underfunded administrative fees have caused PHAs to slow-walk new PBV commitments, creating mid-year closing risk for developers and lenders.
• The publication of formal allocation guidance signals administrative continuity at the program level despite ongoing congressional budget uncertainty.
• PHAs should assess administrative capacity against the new fee parameters before committing to new PBV solicitations in the second half of 2026.

This notice lands at a critical moment for voucher-dependent affordable housing pipelines. Developers, syndicators, and lenders with active PBV deals should reconcile FY 2026 HAP and administrative fee parameters against existing underwriting assumptions immediately. PHAs weighing new solicitations should model administrative fee sufficiency before making commitments they may not be able to operationalize.

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Key Takeaways:

• HUD Secretary Scott Turner testified before both the House and Senate Appropriations Committees in response to the Trump administration's FY27 budget request.
• Bipartisan committee support for HUD programs creates political cover for preserving Housing Choice Voucher and project-based rental assistance funding — both critical to LIHTC deal structures and compliance.
• The amended 21st Century ROAD to Housing Act text was released May 14; a House floor vote is expected the week of May 18.
• House Republicans held a closed-door meeting on May 12 to discuss a potential third reconciliation package — a vehicle that could carry tax title changes affecting LIHTC, depreciation, or bond financing.
• A separate $72 billion reconciliation bill focused on ICE and CBP funding is already in progress, signaling active use of the reconciliation process this Congress.
• NLIHC joined a national sign-on letter urging full inclusion of the Rural Housing Service Reform Act in the final housing supply package — a provision relevant to deals in rural markets and USDA-financed properties.
• HUD's proposed Equal Access Rule NPRM, which would scale back equal access protections in HUD programs, is drawing legal analysis from the National Housing Law Project, with a webinar scheduled for May 20.

Deals currently in predevelopment or financing are underwriting into a policy environment that could shift on multiple fronts at once. The ROAD Act's amended text deserves a close read for provisions touching private activity bond volume cap, zoning preemption, or federal land and financing tools. The third reconciliation conversation is early — but it is already happening behind closed doors, and the LIHTC community should be engaged before the vehicle takes shape.

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Key Takeaways:

• The FY2027 budget proposes full elimination of the Community Development Block Grant (CDBG) program, a common gap-financing source in affordable housing deal stacks.
• Work requirements of at least 20 hours per week and 5-year time limits are proposed for able-bodied adults in HUD rental assistance programs, including Section 8.
• $160 million is allocated for FHA administrative contracts to support homeownership access and program operations.
• $30 million is secured for the Melania Trump Foster Youth to Independence initiative, targeting the roughly 20,000 youth who age out of foster care annually, nearly 1 in 4 of whom experience homelessness.
• $30 million each is proposed for the Program Integrity Initiative and Project HUGS, HUD's sub-recipient reporting and improper payment detection program.
• HUD's FY25 Agency Financial Report identified over $5 billion in potential payment errors, including payments to nearly 30,000 deceased tenants — a figure driving the administration's oversight push.
• From January 2025 to March 2026, HUD reports supporting homeownership for over 1.2 million households, more than 70% first-time buyers — a metric Turner used to frame disciplined policy outcomes.

The FY2027 budget is a proposal, not law — CDBG elimination has been proposed and rejected in prior cycles. But the directional signal matters for deal structuring now. Developers and lenders with CDBG in their financing stacks should assess alternative gap sources. LIHTC asset managers and compliance officers at properties with project-based or tenant-based vouchers should begin evaluating what work requirement tracking and potential increased turnover would mean for their operating pro formas. The appropriations process will determine what survives, but the administration's priorities are on the table.

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Key Takeaways:

• President Trump posted on Truth Social Monday urging Congress to pass the Senate version of the 21st Century ROAD to Housing Act — a direct White House endorsement.
• Senator Tim Scott (R-SC), Chairman of the Senate Banking, Housing, and Urban Affairs Committee, publicly thanked the president on X, signaling committee-level alignment and readiness to move.
• The bill targets regulatory and land use barriers to housing production, with provisions that could reduce soft costs and improve deal feasibility for LIHTC transactions.
• White House backing shortens the effective window for industry stakeholder engagement — Senate committee markup could come quickly while presidential attention remains focused.
• LIHTC developers and syndicators should assess how the Senate version interacts with existing tax credit structures and Private Activity Bond volume cap rules.
• State HFAs and lenders should monitor provisions affecting federal fund flows to state-level affordable housing programs.
• The House will need to reconcile its own version — bicameral differences could affect final provisions relevant to the tax credit industry.

Presidential attention on housing legislation is rare and time-limited. With Senator Scott positioned to move quickly in committee, industry participants — developers, syndicators, investors, and HFAs — should be engaging their Senate offices now to ensure that LIHTC protections and enhancements are part of the final bill. This is an opening, not a guarantee, and the window for meaningful input may close faster than a typical legislative cycle.

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Key Takeaways:

• Waiting list applications are open now through June 2 — the deadline is firm and tenant selection is by random lottery.
• Affordable rents range from $559/month (studio) to $1,766/month (3BR); market-rate units in the same building run $1,950–$5,700/month, a gap of up to $4,000+/month.
• The 90 affordable units span very-low, low, and moderate income tiers, suggesting layered financing likely involving 4% LIHTC and state or county sources.
• The Sylvan is a mixed-income site: 90 affordable rental units within a larger development that also includes 112 market-rate townhomes.
• Geographic preference applies to applicants living or working in Bergen, Hudson, Passaic, or Sussex counties; veterans receive an additional preference tier.
• Amenities include a fitness center, pool, resident lounge, game room, and coworking space — a competitive amenity package that supports long-term occupancy stability.
• Location above the Palisades, minutes from the GWB, places this deal in a high-demand, transit-proximate submarket where affordability discounts are most durable.

Mixed-income developments in high-cost, transit-accessible Northeast submarkets continue to represent some of the most defensible LIHTC investments in the region. The Sylvan's structure — deep affordability discount, layered income tiers, and a competitive amenity package within a market-rate community — is a model worth watching as New Jersey's pipeline evolves. Developers and syndicators with community outreach obligations tied to this or adjacent Bergen County deals should act before the June 2 window closes.

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• Multiple states expanding revolving loan fund programs for affordable and mixed-income housing
• Funds offer below-market loans layered with LIHTC to improve project feasibility
• Revolving structure allows repayments to support future developments
• Wyoming Community Development Authority among states enhancing fund capacity
• Oversubscription in recent rounds indicates strong developer demand
• Repayment requirement encourages financial discipline while recycling capital
• Funds fill widening gap between debt capacity, equity, and total development costs

The expansion of state revolving funds complements federal LIHTC increases under OBBBA. More credit authority creates more deals requiring gap financing.

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Keywords: revolving loan fund, gap financing, mixed-income housing, LIHTC, affordable housing, state housing finance agency, Wyoming, Community Development Authority, below-market loans, construction costs, OBBBA, One Big Beautiful Bill Act, workforce housing, economic integration, residual receipts, refinancing, capital recycling, Spring Street Management Group]]>

• Oklahoma Watch analysis reveals paradox: vacant rental units exist yet affordable options remain scarce
• Disconnect illustrates limitations of supply-side solutions alone for affordability
• OHFA has made significant LIHTC investments over 50-year history
• Mismatch persists for extremely low-income renters below 30% AMI
• Market-rate vacancy doesn't translate to affordability for lowest-income households
• OHFA QAP includes incentives for lower income tiers but economics remain challenging
• 30% AMI targeting requires substantial additional subsidy beyond LIHTC equity

As LIHTC allocations expand under OBBBA, ensuring production reaches households with greatest need requires intentional QAP targeting and complementary resources like project-based vouchers.

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Keywords: Oklahoma, OHFA, Oklahoma Housing Finance Agency, LIHTC, affordable housing, housing paradox, vacancy rate, extremely low-income, 30% AMI, income targeting, QAP, Qualified Allocation Plan, project-based vouchers, Section 8, Housing Choice Voucher, supply-side, housing shortage, deep affordability, gap financing, Spring Street Management Group]]>

• North Carolina House Committee considers legislation on LIHTC property tax treatment
• Some jurisdictions assess LIHTC properties at values reflecting income-restricted rents
• Critics argue reduced assessments shift tax burden to other property owners
• Advocates counter that assessments appropriately reflect deed-restricted market value
• Higher property taxes would increase operating costs and potentially threaten financial viability
• NC Housing Finance Agency testified on potential pipeline impacts from changes
• Committee examining PILOT agreements and standardized assessment methodologies from other states

Developers with North Carolina projects should monitor this legislation closely. Changes could affect pending applications and existing properties approaching compliance period end.

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Keywords: North Carolina, NCHFA, North Carolina Housing Finance Agency, LIHTC, property tax, tax assessment, deed restriction, income-restricted rents, PILOT, payment in lieu of taxes, operating costs, net operating income, debt capacity, equity pricing, affordable housing production, compliance period, tax loophole, Spring Street Management Group]]>

• FHFA doubles annual LIHTC equity investment cap for Fannie Mae and Freddie Mac to $2 billion each
• Total GSE LIHTC investment capacity now $4 billion annually, up from $2 billion
• At least 50% of investments must support underserved markets
• 20% of underserved allocation specifically directed to rural areas
• GSE investments provide countercyclical market stability during reduced bank appetite periods
• Expanded caps coincide with larger LIHTC pipeline from OBBBA allocation increase
• GSE participation valuable for deals in smaller markets less attractive to traditional bank investors

Developers should note GSE investments come with specific underwriting requirements and reporting obligations. Work with experienced syndicators for smooth execution.

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Keywords: FHFA, Federal Housing Finance Agency, Fannie Mae, Freddie Mac, GSE, LIHTC equity, investment cap, underserved markets, rural housing, tax credit investor, syndicator, countercyclical, market stability, OBBBA, affordable housing goals, bank investors, underwriting requirements, Spring Street Management Group]]>

• Hawaii HHFDC announces 2026 funding round combining LIHTC, Hula Mae bonds, and Rental Housing Revolving Fund
• Hawaii faces among highest housing costs nationally with Honolulu median rents exceeding $2,500
• Geographic isolation and limited land create unique development constraints requiring deep subsidy
• Hula Mae program provides tax-exempt bond financing paired with 4% LIHTC
• 25% bond threshold enables more projects to qualify with smaller bond allocations
• Rental Housing Revolving Fund offers below-market gap financing loans
• QAP priorities include neighbor island projects and Native Hawaiian community developments

Construction costs in Hawaii typically exceed mainland averages by 30% or more. Developers should build appropriate contingencies into applications.

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Keywords: Hawaii, HHFDC, Hawaii Housing Finance and Development Corporation, LIHTC, 4% LIHTC, Hula Mae, tax-exempt bonds, Rental Housing Revolving Fund, Honolulu, neighbor islands, Native Hawaiian, bond volume cap, 25% threshold, construction costs, gap financing, QAP, sustainable building, affordable housing, Spring Street Management Group]]>

• Arizona Department of Housing releases 2026 NOFA for 9% LIHTC and National Housing Trust Fund
• NOFA implements 2026-2027 Qualified Allocation Plan for competitive funding round
• 2026 allocation reflects enhanced federal per capita amount following OBBBA increase
• Priority for projects serving extremely low-income households at or below 30% AMI
• NHTF provides gap financing with 30-year affordability requirements for deeper targeting
• Geographic set-asides ensure distribution across rural areas, tribal lands, and smaller metros
• QAP scoring emphasizes readiness with points for 12-month construction start capability

Arizona faces estimated shortage of over 140,000 affordable rental units, particularly in the Phoenix metropolitan area.

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Keywords: Arizona, Arizona Department of Housing, ADOH, LIHTC, 9% LIHTC, National Housing Trust Fund, NHTF, NOFA, Notice of Funding Availability, QAP, Qualified Allocation Plan, extremely low-income, 30% AMI, Phoenix, Tucson, tribal lands, rural housing, gap financing, site control, affordable housing shortage, Spring Street Management Group]]>

• Minnesota Housing submits detailed correspondence to state legislators on OBBBA impact
• 12% per capita increase translates to approximately $8 million additional annual credit authority
• Expansion enables estimated 400-500 additional affordable units per year in Minnesota
• 25% bond threshold expands eligibility for acquisition-rehabilitation projects
• Reduced bond proceeds create new gap financing challenges requiring creative solutions
• Private activity bond volume cap coordination remains essential across four issuing agencies
• Permanent allocation increase provides long-term planning certainty for development pipelines

Minnesota Housing is updating underwriting standards and encourages developers to schedule pre-application meetings to discuss project-specific impacts.

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Keywords: Minnesota Housing, Minnesota HFA, OBBBA, One Big Beautiful Bill Act, LIHTC, 9% LIHTC, 4% LIHTC, per capita allocation, private activity bonds, PAB, bond volume cap, acquisition-rehabilitation, gap financing, QAP, Qualified Allocation Plan, underwriting standards, affordable housing production, state housing finance agency, Spring Street Management Group]]>

• CREA closes largest-ever LIHTC fund at $403 million for affordable housing developments nationwide
• Fund reflects expanded pipeline from 12% OBBBA allocation increase and 25% bond threshold
• Investor base includes regional and national banks seeking CRA credit, insurance companies, and ESG-focused corporations
• Fund oversubscription indicates capital availability not currently constraining production
• Pricing in mid-80s to low-90s cents per dollar of credit, consistent with 2026 market trends
• Fund prioritizes high-opportunity areas and extremely low-income household projects
• Geographic diversity across Midwest, Southeast, and Western regions

For developers, the successful closing signals equity availability for well-structured deals throughout 2026. Key constraints remain gap financing and construction cost management.

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Keywords: CREA, Community Reinvestment Act, LIHTC fund, tax credit equity, syndicator, affordable housing investment, CRA credit, ESG, OBBBA, One Big Beautiful Bill Act, 25% bond threshold, 4% LIHTC, 9% LIHTC, investor appetite, credit pricing, high-opportunity areas, extremely low-income, gap financing, construction costs, Spring Street Management Group]]>

• HUD announces FY 2026 income limits release delayed to May 1, 2026
• Delay stems from Census Bureau's late release of 2024 American Community Survey data
• Income limits determine tenant eligibility at 30%, 50%, 60%, and 80% AMI thresholds
• Properties with April recertifications should continue using 2025 income limits until new figures published
• Lease-up properties targeting spring occupancy face particular challenges
• HUD Secretary Scott Turner emphasizes importance of accurate underlying data
• State HFAs expected to issue guidance on QAP applications and compliance monitoring

Property managers should document interim procedures and be prepared to adjust if new limits affect tenant eligibility.

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Keywords: HUD, income limits, FY 2026, area median income, AMI, Census Bureau, American Community Survey, LIHTC compliance, tenant eligibility, recertification, property management, Section 8, Housing Choice Voucher, lease-up, state housing finance agency, QAP, Scott Turner, affordable housing, income verification, Spring Street Management Group]]>

• Treasury corrects 2026 state ceiling calculations for 9% low-income housing tax credits
• Revised figures reflect permanent 12% allocation increase under One Big Beautiful Bill Act
• 2026 state ceiling: greater of $3.416 multiplied by state population or $3,953,600 minimum floor
• Correction addresses calculation error that understated allocations in several states
• Large states like California, Texas, and New York gain tens of millions in additional credit authority
• Small state minimum ensures adequate allocations for Wyoming, Vermont, and Alaska
• Industry groups flagged discrepancy; Treasury's swift correction ensures full OBBBA intent realized

State housing finance agencies should update their 2026 allocation projections accordingly. Developers with pending applications should confirm with state agencies whether corrected figures apply to current funding cycles.

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Keywords: Treasury Department, LIHTC, Low-Income Housing Tax Credit, 9% LIHTC, state allocation ceiling, per capita multiplier, One Big Beautiful Bill Act, OBBBA, IRS, state housing finance agency, HFA, QAP, Qualified Allocation Plan, tax credit allocation, affordable housing, small state minimum, California, Texas, New York, Wyoming, Vermont, Alaska, Spring Street Management Group]]>

Housing advocates should share findings with congressional representatives.

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Keywords: Enterprise Community Partners, AHCIA, Affordable Housing Credit Improvement Act, LIHTC, 9% LIHTC, 4% LIHTC, economic impact analysis, job creation, housing production, tax credit expansion, congressional advocacy, QAP, basis boost, minimum 4% rate, housing shortage, affordable rental housing, federal tax expenditure, property tax revenue, Spring Street Management Group

Expanded 4% pipeline should help address Colorado's production gap.

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Keywords: Colorado, CHFA, Colorado Housing and Finance Authority, 4% LIHTC, private activity bonds, PAB, 25% bond threshold, One Big Beautiful Bill Act, OBBBA, bond volume cap, tax-exempt bonds, inducement, Front Range, gap financing, application process, QAP, affordable housing development, multifamily construction, Spring Street Management Group

Complete applications aligned with QAP priorities consistently outperform.

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Keywords: Terner Center, UC Berkeley, HFA, state housing finance agency, QAP, Qualified Allocation Plan, LIHTC, 9% LIHTC, 4% LIHTC, application process, underwriting, best practices, administrative capacity, staffing, developer, regional cooperation, electronic submissions, pre-application conference, affordable housing development, Spring Street Management Group

Environmental review streamlining could meaningfully reduce LIHTC predevelopment timelines.

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Keywords: Housing for the 21st Century Act, Congress, bipartisan legislation, NEPA, environmental review, CDBG, Community Development Block Grant, manufactured housing, FHA, Fannie Mae, Freddie Mac, GSE, ROAD to Housing Act, Senate, LIHTC, zoning reform, NMHC, NAHB, Up for Growth, housing supply, affordable housing policy, Spring Street Management Group

Developers should engage with legislative advocacy and monitor state budget process.

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Keywords: Michigan, MSHDA, Michigan State Housing Development Authority, state tax credit, LIHTC, 9% LIHTC, 4% LIHTC, Governor Whitmer, affordable housing, NLIHC, National Low Income Housing Coalition, gap financing, construction costs, Ohio, Indiana, Illinois, housing shortage, budget, legislative advocacy, rental housing, Spring Street Management Group

Successful applicants typically begin community outreach months before LIHTC applications.

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Keywords: Illinois, IHDA, Illinois Housing Development Authority, R3, Restore Reinvest Renew, cannabis tax revenue, LIHTC, 9% LIHTC, 4% LIHTC, racial equity, climate resilience, economic mobility, QAP, community engagement, local hiring, Chicago, state tax credit, predevelopment, soft financing, affordable housing, Spring Street Management Group

Developers should monitor MassHousing's funding cycles for upcoming application opportunities.

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Keywords: Massachusetts, Governor Healey, MassHousing, Affordable Housing Trust Fund, state LIHTC, Housing Stabilization Fund, 40B comprehensive permit, Gateway Cities, supportive housing, extremely low-income, ELI, QAP, housing bond bill, public housing modernization, first-time homebuyer, behavioral health housing, homeless services, affordable housing development, Spring Street Management Group

Property managers should use the extension productively to ensure full compliance readiness by the new deadline.

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Keywords: HOTMA, Housing Opportunity Through Modernization Act, HUD, multifamily housing, income calculation, asset income, compliance, recertification, LIHTC, Section 8, Housing Choice Voucher, property management, NAHMA, software compliance, tenant qualification, fixed-income households, student eligibility, income verification, affordable housing, Spring Street Management Group

Realistic cost projections and contingency reserves are essential to successful deal execution in this environment.

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Keywords: TD Bank, developer survey, affordable housing, construction costs, insurance costs, development timeline, LIHTC equity, modular construction, prefabricated housing, HOME program, CDBG, gap financing, California, Massachusetts, Colorado, rental demand, cost containment, syndicator, investor, tax credit pricing, Spring Street Management Group

Developers should engage early with GSE lenders to lock rates and secure capacity for projects in the pipeline.

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Keywords: FHFA, Fannie Mae, Freddie Mac, GSE, multifamily lending, loan purchase cap, DUS, Optigo, affordable housing, LIHTC, 4% LIHTC, 9% LIHTC, permanent financing, workforce housing, rural rental housing, mission-driven lending, housing goals, tax-exempt bonds, private activity bonds, capital stack, Spring Street Management Group

Housing affordability is becoming a priority issue across the political spectrum as rent burdens increase nationwide.

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Keywords: Senator Jacky Rosen, Nevada affordable housing, Housing for the 21st Century Act, ROAD to Housing Act, bipartisan housing legislation, Las Vegas housing, Reno housing, Nevada Housing Division, manufactured housing, rent burden, housing affordability, 25% bond threshold, 4% LIHTC, housing supply, housing policy 2026, Nevada housing market, affordable rental housing, housing legislation, bipartisan coalition, housing crisis

Market conditions support moving forward with pipeline projects. Syndicators emphasize realistic operating projections and demonstrated development capacity.

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Keywords: LIHTC equity market, LIHTC syndicator, tax credit investor, 9% LIHTC, 4% LIHTC, LIHTC pricing, credit pricing, tax credit equity, affordable housing investment, LIHTC fund, One Big Beautiful Bill Act, 25% bond threshold, construction costs, NCSHA, Novogradac, LIHTC market outlook, investor demand, tax credit syndication, affordable housing equity, LIHTC deal flow

Property owners with project-based vouchers or high voucher concentrations should monitor policy developments and engage with advocacy efforts.

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Keywords: CLASP, work requirements, Housing Choice Voucher, Section 8, rental assistance, HUD policy, housing instability, time limits, voucher program, affordable housing policy, housing authority, Project-Based Voucher, LIHTC property management, tenant retention, housing assistance, supportive housing, employment requirements, safety net programs, housing policy research, HCV regulations

Developers new to the Kansas market should attend workshops to understand agency priorities and submission requirements.

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Keywords: Kansas Housing Resources Corporation, KHRC, Kansas LIHTC, 9% LIHTC, 4% LIHTC, QAP, Qualified Allocation Plan, Kansas affordable housing, rural housing development, veterans housing, senior housing, cost containment, market study requirements, 25% bond threshold, private activity bonds, One Big Beautiful Bill Act, Wichita housing, Kansas City housing, state housing finance agency, LIHTC application

The project demonstrates the complex financing structures required for urban affordable housing development in high-cost markets.

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Keywords: Oakland affordable housing, LIHTC equity, Bay Area housing, California LIHTC, 4% LIHTC, tax-exempt bonds, private activity bonds, CalHFA, California Housing Finance Agency, Alameda County housing, LIHTC transaction, affordable housing financing, LIHTC investor, tax credit equity, multifamily development, urban affordable housing, high-cost market, California tax credit, affordable housing construction, LIHTC closing

First-time LIHTC developers should consider partnering with experienced firms to strengthen applications in this competitive market.

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Keywords: Indiana Housing and Community Development Authority, IHCDA, LIHTC application, Rental Housing Tax Credit, 9% LIHTC, 4% LIHTC, Indiana affordable housing, QAP, Qualified Allocation Plan, Development Fund, workforce housing, 60% AMI, 80% AMI, Qualified Census Tract, QCT, high-opportunity area, private activity bonds, 25% bond threshold, tax-exempt bonds, gap financing, Indiana housing developer

Developers should explore pre-development financing options as part of their capital stack planning for upcoming LIHTC applications.

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Keywords: Rose Community Capital, pre-development loan, LIHTC financing, affordable housing development, predevelopment costs, CDFI lending, community development financial institution, Enterprise Community Loan Fund, LISC, 9% LIHTC, capital stack, affordable housing financing, development financing, bridge loan, construction financing, market study, environmental assessment, LIHTC application, emerging developer, affordable housing developer

Developers should begin site identification and local government engagement now to position competitive applications.

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Keywords: North Carolina Housing Finance Agency, NCHFA, LIHTC awards, 9% LIHTC, Low-Income Housing Tax Credit, affordable housing development, North Carolina affordable housing, Charlotte housing, Raleigh housing, One Big Beautiful Bill Act, state housing finance agency, QAP, Qualified Allocation Plan, senior housing, family housing, rural housing, 30% AMI, high-opportunity areas, tax credit allocation, multifamily development, affordable rental housing

Developers should track this legislation closely as expanded credits would reshape pro formas and accelerate pipeline activity.

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Keywords: Affordable Housing Credit Improvement Act, AHCIA, LIHTC expansion, 9% LIHTC, 4% LIHTC, Low-Income Housing Tax Credit, tax credit legislation, affordable housing legislation, Senator Maria Cantwell, Senator Todd Young, bipartisan housing bill, credit allocation ceiling, rural housing, LIHTC preservation, affordable housing development, tax credit investor, LIHTC syndicator, housing policy 2026, LIHTC reform, affordable housing production

Property owners and housing authorities should review tenant demographics to assess exposure to this proposed rule change.

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Keywords: HUD proposed rule, mixed-status families, federal housing assistance, immigration status, Housing Choice Voucher, Section 8, LIHTC, Low-Income Housing Tax Credit, Project-Based Vouchers, affordable housing policy, HUD regulations, multifamily housing, rental assistance, public housing, housing authority compliance, tenant eligibility, fair housing, housing policy 2026, HUD rulemaking, affordable housing compliance, property management

Texas Market Overview:

• One of largest LIHTC allocations in the nation
• 2026 QAP reflects 12% permanent credit increase under OBBBA
• Remains one of most competitive LIHTC markets

Application Requirements:

• Specific scoring criteria for location, tenant populations, experience
• Local support resolutions required
• Market studies and environmental assessments must be complete
• Regional allocation formula ensures geographic diversity

Alternative Paths:

• Texas implementing 25% bond threshold for 4% deals
• Bond-financed projects don't compete for limited 9% ceiling
• Consider 4% if 9% scoring is borderline

TAAHP Priorities:

• Expanding tax-exempt bonds and credits
• 89th Texas legislative session advocacy

Subscribe to The Spring Street Brief for daily updates on LIHTC applications, Texas TDHCA, QAP deadlines, 4% and 9% credits, and state HFA activity.

State Credit Importance:

• Fills financing gaps as development costs rise
• Makes marginal projects feasible
• Attracts investors layering state and federal credits
• Most states now have state housing credit programs

Illinois Program:

• Supported thousands of affordable units since inception
• Renewal would extend and potentially expand capacity
• Details on allocation amounts being finalized

Developer Action Items:

• Illinois 9% LIHTC deadline: February 25, 2026
• Track HB 4413 progress for financial projections
• Consider state credit in investor conversations

National Trend:

• Michigan advocates proposing $42M annual state credit
• More states complementing federal credits

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Key Findings:

• Voucher success rates vary significantly across housing authorities
• Tight rental markets challenge voucher holders finding units
• Payment standards competitive but landlord participation limited

LIHTC Integration:

• Many LIHTC developments accept voucher holders
• Provides pipeline of income-qualified tenants
• Reliable rent payments backed by housing authorities
• Reduces lease-up risk for LIHTC owners

Landlord Barriers:

• Inspection requirements cited as obstacle
• Payment processing delays
• Housing for the 21st Century Act may address inspection concerns

Subscribe to The Spring Street Brief for daily updates on Housing Choice Vouchers, Section 8, LIHTC compliance, and voucher utilization research.

Threshold Change:

• Minimum bond financing dropped from 50% to 25% of aggregate basis
• Less tax-exempt debt required per project
• Frees up bond volume cap for additional deals

State Implementation:

• California CDLAC: Emergency rulemaking initiated
• Housing New Mexico: Updated 4% LIHTC plan
• Colorado: Phased approach with 45% upper limit for 2026

Developer Impact:

• Acquisition-rehab deals: $5M bond requirement now $2.5M on $10M project
• Lower debt service and transaction costs
• Improved project economics
• Work with bond counsel on state-specific requirements

Subscribe to The Spring Street Brief for daily coverage of private activity bonds, 4% LIHTC, bond volume cap, and state HFA policy updates.

Key Allocations:

• Public housing operating funds: $5.02 billion
• Public housing capital funds: $3.2 billion
• Continuum of Care (homeless services): $4.01 billion
• Housing Choice Vouchers: Full renewal funding plus incremental vouchers
• Project-Based Rental Assistance: Contract renewals and inflation adjustments

Stakeholder Impact:

• 2.4 million voucher households protected from terminations
• Housing authorities can plan with funding security
• Property owners assured continued HAP payments
• Developers confident in lease-up assistance availability

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Key Provisions:

• Streamlines environmental review processes for residential projects
• Expands HUD and USDA program coordination for rural housing
• Modernizes manufactured housing regulations and financing
• Expands down payment assistance eligibility
• FHA modernization for first-time buyers

Legislative Context:

• Complements Housing for the 21st Century Act (House)
• Most significant housing reform effort in years
• Industry groups endorse pragmatic supply-focused approach
• National League of Cities praises local control provisions

Timeline:

• Full Senate vote expected late February/early March
• Conference committee to reconcile House and Senate versions

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Disparate Impact Standard:

• Upheld by Supreme Court in 2015 (Texas v. Inclusive Communities)
• Allows challenges to practices with discriminatory effects
• No proof of discriminatory intent required

Coalition Opposition:

• 24 state attorneys general call proposed rule unlawful
• NAACP Legal Defense Fund urges maintaining framework
• Housing Assistance Council highlights rural community impacts
• Marin County expresses local compliance concerns

Implications for Owners:

• Outcome shapes compliance requirements for years
• State fair housing laws may still enforce disparate impact
• Potential patchwork of requirements across jurisdictions

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Allocation Details:

• Nine developments across Colorado communities
• Mix of urban Front Range and smaller community projects
• New construction family housing, senior developments, and preservation deals

Policy Context:

• Reflects 12% permanent increase in 9% credits under OBBBA
• 25% bond threshold expands 4% LIHTC options
• Colorado phasing in with 45% upper limit for 2026

Developer Action Items:

• Second 9% application deadline approaching
• Review updated QAP and application materials
• Explore state housing trust fund layering strategies

Subscribe to The Spring Street Brief for daily coverage of LIHTC allocations, state HFA activity, 4% and 9% credits, and QAP updates.

Program Background:

• Launched during pandemic via American Rescue Plan Act
• Approximately 70,000 vouchers funded for vulnerable populations
• Intended for absorption into regular Housing Choice Voucher program

Impact by Region:

• San Diego: Hundreds face potential homelessness
• Tacoma, WA: Significant utilization concerns
• Multiple states scrambling for contingency plans

Action Items:

• Property owners: Communicate with local housing authorities on timelines
• Housing authorities: Identify EHV households and assess mainstream voucher eligibility
• Prioritize most vulnerable for available assistance slots

Subscribe to The Spring Street Brief for daily updates on Housing Choice Vouchers, Section 8, HUD policy, and rental assistance programs.

Key Provisions:

• Directs HUD to publish best practices for local zoning reforms
• Includes pre-approved housing designs and model codes for rural, suburban, and urban contexts
• Increases FHA multifamily loan limits for larger projects
• Streamlines Housing Choice Voucher inspection requirements
• Expands HOME Investment Partnerships flexibility for workforce housing
• Modernizes veterans' housing programs and manufactured home policies

Industry Support:

• Over 70 industry groups endorsed the legislation
• Addresses estimated 4-7 million unit housing shortage
• Senate expected to take up the bill in March

Subscribe to The Spring Street Brief for daily affordable housing news covering LIHTC, HUD policy, Section 8, and housing reform legislation.

30-Day Notice Rescission:

• Current rule: 30 days' notice required before eviction for nonpayment
• New rule: Owners follow state and local eviction timelines
• Impact: Some states require as little as 3 days' notice
• Affects: LIHTC, Project-Based Section 8, and public housing

Work Requirements Proposal:

• Able-bodied adults without dependents must meet work/training requirements
• Similar to SNAP and Medicaid work requirements
• Elderly and disabled tenants exempted

Action Items for Property Owners:

• Review lease enforcement policies and eviction procedures
• Update lease language and tenant notices as needed
• Train staff on new requirements
• Coordinate with legal counsel on federal and state compliance

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What Changed:

• Previous threshold: 50% of aggregate basis in bond financing required
• New threshold: Only 25% bond financing needed for 4% LIHTC eligibility
• Result: Less bond volume cap consumed per project
• Impact: States can finance more deals with same allocation

State Implementation Approaches:

• California: Encouraging return of unused 2025 PAB allocations for redeployment
• Colorado: Phasing in threshold, starting at 45% upper limit for 2026 rounds
• Other states: Updating QAPs and application materials

Developer Implications:

• Acquisition-rehab deals can proceed with smaller bond issuances
• Improved project economics through reduced debt service
• New opportunities in bond-constrained states
• Work closely with bond counsel on state-specific requirements

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Connecticut HFA 2026 Activity:

• Nine developments financed across multiple communities
• Combination of LIHTC, tax-exempt bonds, and state trust funds
• 2026 9% LIHTC application deadline: March 4th
• Webinars scheduled on QAP changes and application requirements

Nationwide State HFA Activity:

• Ohio Housing: Accepting pre-applications for 2026 4% LIHTC credits
• Vermont HFA: Published 2026 application schedule for federal and state credits
• New Hampshire Housing: Processing nine applications for $6.99M in 9% credits

Key Takeaway: State HFAs are aggressively deploying expanded resources under OBBBA. Early engagement with your state HFA is essential as competition remains intense.

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• Allows fair housing claims based on discriminatory effects without proving intent
• Challenges policies like tenant screening criteria and occupancy standards
• Protects against facially neutral policies that harm protected classes

Implications of Elimination:

• Plaintiffs would need to prove intentional discrimination—a higher legal bar
• Current compliance programs built around disparate impact could become less critical
• State and local fair housing laws may still enforce disparate impact standards
• Creates potential patchwork of requirements across jurisdictions

Action Items:

• Review the proposed rule before the February comment deadline
• Consider submitting comments to shape housing policy
• Assess current compliance programs and potential changes

Subscribe to The Spring Street Brief for daily affordable housing news covering fair housing, HUD policy, LIHTC, and compliance updates.

• Additional LIHTC enhancements beyond the 12% increase in OBBBA
• New tax credits for first-time homebuyers facing affordability challenges
• Tax credits for renters struggling with housing costs
• Incentives to convert vacant office buildings to residential housing
• Targets households at 80-120% of area median income

Why This Matters:

• Office vacancy rates at historic highs create adaptive reuse opportunities
• Commercial conversions can be faster and cheaper than ground-up construction
• Bipartisan interest signals continued support for affordable housing expansion

For LIHTC developers, this bill could open new deal structures and acquisition opportunities in the commercial conversion space.

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• New deadline: January 1, 2027 (extended from January 2026)
• Affects income and asset calculation rules for HUD-assisted households
• Impacts asset limits, income exclusions, hardship exemptions
• Multifamily owners have 12 months to update systems and train staff

Other HUD Updates for 2026:

• 2026 Annual Inflationary Adjustments and Passbook Rate published (effective January 1, 2026)
• FY2026 Annual Adjustment Factors (AAFs) released for Section 8 PBRA contract rents
• Updated Qualified Census Tract (QCT) and Difficult Development Area (DDA) designations for LIHTC
• $129.9 million in Family Self-Sufficiency (FSS) grants awarded to 713 PHAs and owners

Property managers should use this extension to refine HOTMA implementation and ensure staff are fully trained before the new deadline.

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• Passed House 263-147 with 57 Democrats joining Republicans
• Restores HUD authority over manufactured housing energy standards
• Repeals pending DOE energy efficiency rule for manufactured homes
• Estimated $10,000 cost reduction per manufactured housing unit
• Bill now heads to Senate where bipartisan support expected

Related Legislation - Housing in the 21st Century Act:

• Modernizes building codes nationwide
• Increases allowable height for single-stairway buildings from 5 to 6 stories
• Enables more density in mid-rise urban infill projects

For affordable housing developers, manufactured housing components become more viable in LIHTC and subsidized developments, particularly for rural and workforce housing projects.

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• Fannie Mae: Cap increased from $1 billion to $2 billion annually
• Freddie Mac: Cap increased from $1 billion to $2 billion annually
• Total GSE LIHTC investment capacity: $4 billion per year

Targeting Underserved Markets:

• 50% of allocations dedicated to underserved markets
• 20% of underserved allocation (10% of total) targeted to rural communities
• Addresses persistent equity gap in secondary and tertiary markets

For rural developers and sponsors working outside major metros, this represents a game-changing capital source. The expanded GSE presence should also help stabilize LIHTC pricing and improve terms for developers across all markets.

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• House bill: Cuts assistance to 181,900 households
• Senate bill: Cuts assistance to 107,800 households
• Current program serves 2.4 million households—only 1 in 4 who qualify
• Continuing resolution funds program only through January 30, 2026

Proposed Policy Changes:

• Two-year time limits on rental assistance for able-bodied adults
• Stricter income verification requirements
• Potential restrictions for families with undocumented members
• Possible shift to state-managed block grants
• Elderly and disabled exempted from time limits

Property owners with significant voucher exposure and housing authorities should plan for potential volatility in the Section 8 program.

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• Permanent 12% increase in 9% LIHTC allocations beginning 2026
• Bond financing threshold lowered from 50% to 25% for 4% LIHTC rehabilitation projects
• Estimated 80,000 additional affordable units from 9% credit expansion through 2035
• Over 1 million additional affordable rental homes projected from bond threshold change

State-by-State Impact:

• California: 200,000 new units projected through 2035
• Georgia: 98,000 new units
• Texas: 97,000 new units

For LIHTC developers, syndicators, and tax credit investors, the math on 4% acquisition-rehab deals just got significantly better. Properties placed in service after December 31, 2025 qualify under the new rules.

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