Afleveringen
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HUD has published its FY 2026 Renewal Funding Inflation Factors (RFIFs) for the Housing Choice Voucher (HCV) program, setting a national per unit cost growth projection of 2.337% and proposing a significant methodology change for FY 2027 that would incorporate local regulatory housing policy as a driver of rent inflation. The notice is effective July 6, with comments due August 5, 2026 β a narrow window for PHAs, syndicators, lenders, and LIHTC stakeholders with PBV exposure to engage.
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 β 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 β 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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HUD has proposed a rule to rescind the Federal Flood Risk Management Standard (FFRMS) final rule and its associated regulations, originally published in April 2024. The proposed rule would restore HUD's Part 55 floodplain management regulations to their pre-April 2024 state β removing the elevated site elevation and freeboard requirements that affected HUD-assisted and HUD-insured projects in or near floodplains. For LIHTC developers relying on FHA-insured debt or other HUD program dollars, the proposal would reduce site selection friction and eliminate costly engineering requirements triggered by the 2024 rule. Comments are due September 8, 2026.
Key Takeaways:
HUD's proposed rule targets the FFRMS final rule published in April 2024 β 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 β not rescinded. Deals using FHA 221(d)(4) or 223(f) financing on sites near Special Flood Hazard Areas are directly affected β 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 β 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 β 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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Zijn er afleveringen die ontbreken?
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The Ohio Housing Finance Agency (OHFA) has opened a public comment period on the first draft of its 2026β2027 9% LIHTC Qualified Allocation Plan (QAP) Technical Amendment, alongside updated opportunity area data and maps from the Urban Institute. For developers, syndicators, and investors with active Ohio pipeline, this mid-cycle amendment has direct implications for site scoring, geographic eligibility, and additional credit allocation strategies heading into the next competitive round.
Key Takeaways:
OHFA has posted the first draft of its 2026β2027 9% LIHTC QAP Technical Amendment for public comment β 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 β 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 β 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 β 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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The 21st Century Road to Housing Act β the ROAD Act β became law on July 11, 2026, without a presidential signature, after Congress passed it on June 23. Described as the most significant federal housing reform in a generation, the nearly 400-page bill includes dozens of provisions touching manufactured housing, zoning, Community Development Block Grants, the Rental Assistance Demonstration program, and bank investment capacity. For LIHTC investors, developers, syndicators, and lenders, several provisions have direct and near-term implications for deal structure, financing capacity, and preservation pipelines.
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 β 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 β 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 β 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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The Trump administration's effort to eliminate HUD's Restore-Rebuild initiative is now a national story, following a Politico report that highlights the program's cancellation and its cascading effects on public housing authorities and affordable housing developers. The San Diego Housing Commission is walking back plans for 700 units; the Council of Large Public Housing Authorities says the move contradicts HUD's stated mission. For LIHTC investors, developers, and lenders with Restore-Rebuild exposure in their pipelines, the implications are immediate and concrete.
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 β 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 β waiting is not a strategy.
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HUD's newly released LIHTC Tenant Tables for 2023 reveal that 57.2% of LIHTC residents earn 30% or less of area median gross income β the highest share of extremely low-income tenants ever recorded in the dataset. With a national median tenant income of just $18,600 and nearly half of all residents receiving rental assistance, the data paints a clear picture of who the program is actually serving and raises urgent questions for investors, developers, and policymakers about income targeting, layered subsidy, and underwriting assumptions.
Key Takeaways:
57.2% of LIHTC residents are classified as extremely low-income (β€30% AMI) β 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 β 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 β in QAP comment periods, in advocacy, and in deal structuring.
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The Housing Assistance Council's latest research brief confirms what many rural housing advocates have feared: USDA's Section 515 Multifamily Housing portfolio is shrinking faster than scheduled maturities alone would explain. With 504 properties already gone ahead of their loan maturity dates and seven Midwestern states each losing more than 10% of their Section 515 stock since 2021, the affordable rural housing supply is eroding now β and USDA's own projections show the worst is still ahead, with exits peaking around 2040 and the program potentially depleted by 2056.
Key Takeaways:
504 Section 515 properties have exited the portfolio before their mortgage maturity date β signaling early opt-outs and deterioration, not just scheduled wind-down. Seven states β Nebraska, North Dakota, Michigan, South Dakota, Wisconsin, Indiana, and Iowa β 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 β 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 β 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 β 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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A coalition of local governments and nonprofits has filed a supplemental complaint challenging HUD's FY 2026 Continuum of Care Notice of Funding Opportunity, arguing it mirrors the version a federal court already found likely unlawful in December 2025. With applications still due August 26, developers and syndicators structuring supportive housing deals with CoC operating subsidies face real underwriting uncertainty as the litigation advances.
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 2024β25 version. Plaintiffs argue the FY 2026 NOFO "bears many similarities to the version the court already determined likely to be unlawful" β strong language signaling a high-confidence legal posture. FY 2026 CoC applications are still due August 26, despite the active litigation β 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 β 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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The Connecticut Housing Finance Authority (CHFA) has released its draft Qualified Allocation Plan (QAP) for 2027 and 2028, opening a brief public comment window that closes July 10, 2026. For LIHTC developers, syndicators, investors, and lenders active in Connecticut, this two-year plan will govern how CHFA scores and ranks tax credit applications through the end of 2028 β making early engagement critical for anyone with a Connecticut pipeline.
Key Takeaways:
CHFA's draft QAP covers two full allocation cycles β 2027 and 2028 β 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 β 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 β 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 β whether to basis limits, scoring weights, or set-aside priorities β 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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HUD has announced that all Preservation Rent Increase (PRI) funding available under the RAD for PRAC program has been exhausted for calendar year 2026. Any new RAD for Section 202/Project Rental Assistance Contract conversion plan submissions that include PRI funding and were submitted after May 29, 2026, will be waitlisted on a first-come, first-served basis. For sponsors, syndicators, lenders, and investors active in elderly affordable housing preservation, this announcement has immediate deal-structuring consequences.
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 β 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 β 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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The Federal Housing Finance Agency has proposed a sweeping overhaul of the Duty to Serve regulations governing Fannie Mae and Freddie Mac. The proposed rule replaces the existing prescriptive Activities framework with a flexible, principles-based approach β and expands LIHTC credit eligibility across all three Duty to Serve underserved markets. For LIHTC investors, affordable housing developers, and structured finance practitioners, the comment deadline of July 24 and a target effective date of January 1, 2028, make this a near-term priority.
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 β rural housing, manufactured housing, and affordable housing preservation β 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 β 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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HUD has issued a Request for Information (RFI) targeting a shift from project-specific waivers to general applicability (product-category) waivers under the Build America, Buy America Act (BABA). For LIHTC developers and their construction teams, this is the most actionable near-term opportunity for relief from one of the most disruptive compliance requirements introduced into federally assisted housing. Comments are due July 20, 2026.
Key Takeaways:
HUD's RFI targets product-category BABA waivers β 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 β 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 β 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 β 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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President Trump canceled a planned signing of the 21st Century Road to Housing Act, leaving enrolled housing legislation in a holding pattern with no rescheduled signing date confirmed. NAHB Chairman Bill Owens expressed confidence the bill will eventually become law, but the delay introduces meaningful uncertainty for LIHTC investors, developers, syndicators, and state HFAs watching for any federal policy changes tied to the legislation.
Key Takeaways:
The 21st Century Road to Housing Act has cleared Congress β 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 β 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 β 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 β 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 β but the distinction only matters if you're positioned accordingly.
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Senator Ron Wyden (D-OR) and Rep. Val Hoyle (D-OR) have reintroduced the Decent, Affordable, Safe Housing for All (DASH) Act for the third consecutive Congress. The bill expands LIHTC, introduces a new Middle-Income Housing Tax Credit (MIHTC), restructures the first-time homebuyer tax credit to be advanceable at closing, and adds a new home-sale loss deduction of up to $100,000 for low- and middle-income sellers. For LIHTC investors, developers, and syndicators, the MIHTC provision and the LIE-tek strengthening language are the provisions with the most direct market implications.
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) β 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 β new to this version of the bill β 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 β 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 β 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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The Missouri Housing Development Commission (MHDC) has opened a public comment period to gather input on topics under consideration for its 2028 Qualified Allocation Plan (QAP). With this window opening nearly two years ahead of the plan's effective year, developers, syndicators, lenders, and investors active in Missouri have an early and meaningful opportunity to influence how LIHTC and MHDC resources will be allocated β before internal drafts are even in circulation.
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 β 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 β submitted before internal drafts are circulated β 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 β not after a draft is released. Monitor MHDC communications for draft publication timelines and plan your comment strategy accordingly.
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A bipartisan House bill β H.R. 9311, the Build Housing Affordably Act β has been introduced by Rep. Mike Flood (R-NE), Chairman of the House Housing and Insurance Subcommittee, and Rep. Maggie Goodlander (D-NH). The legislation targets Build America Buy America Act (BABA) requirements that have created cost and timeline friction for affordable housing developers relying on federal funding streams, including LIHTC deals with federal program exposure.
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) β 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 β 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 β 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 β 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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May housing starts fell 15.4% to a seasonally adjusted annual rate of 1.18 million units, but the headline understates the real shock: multifamily construction cratered 40.2% in a single month to an annualized pace of just 295,000 units β down 14.2% year-over-year. For LIHTC developers, syndicators, and lenders, the data lands at a critical moment, signaling that the construction pipeline is under serious stress from elevated interest rates, rising costs, and persistent labor shortages.
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 β 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 β 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 β 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 β 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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Bond markets have shifted from pricing in Fed rate cuts to assigning greater-than-even odds to a rate hike β a reversal with direct consequences for LIHTC developers, syndicators, and lenders. With core inflation at a three-year high of 3.3%, headline CPI at 3.8%, and the two-year Treasury up more than 70 basis points since March, the rate environment for affordable housing finance has materially tightened. This episode breaks down the macro forces behind the shift and what they mean for deals in the pipeline today.
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% β a three-year high and well above the Fed's 2% target β 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% β the lowest since June 2022 β 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 β 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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Cinnaire has closed Fund for Housing Limited Partnership 45 (Fund 45), a $307 million LIHTC equity fund targeting the creation and preservation of 2,259 affordable housing units across 27 properties in 10 states. The fund will directly benefit an estimated 5,196 residents and represents one of the larger single-fund LIHTC equity closes in Cinnaire's history β a notable signal of sustained institutional appetite for affordable housing tax credit investment.
Key Takeaways:
Fund 45 closed at $307 million in LIHTC equity β 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 β and close it β 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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Senators Jeanne Shaheen (D-NH) and Dave McCormick (R-PA) have sent a bipartisan letter to HUD Secretary Turner calling for administrative reforms to the Build America, Buy America (BABA) waiver process. The current system β designed to accommodate products not domestically available in sufficient supply β has instead created significant delays and, in some cases, hard stops for affordable housing construction and preservation projects. For LIHTC developers, syndicators, and lenders working on federally assisted deals, this letter signals real momentum toward procedural relief that HUD can deliver without waiting for Congress.
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 β 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 β 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 β 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 β 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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