In response to questions by developers, the Delaware State Housing Authority (DSHA) provided some clarifications to its 2012 Qualified Allocation Plan (QAP) for Delaware’s annual allocation of low income housing tax credits (LIHTC).
Pool Limit – A tax credit application should not request more than ten percent (10%) over the amount of LIHTC’s allocated to a specific pool. DSHA provided an example using the 2012 New Creation Pool which is $600,000. An applicant to this pool should not request more than $660,000. When responding to the impact on an application for requesting more, DSHA stated that a project may be deemed ineligible for financial feasibility if a higher request is made. I assume this means that DSHA will run the numbers with no more than 10% above the pool amount and the application would be short financing required to get the job done. This is a new rule/policy for 2012 that is cited in the QAP and was mentioned in the public meeting for the QAP.
Limit of Total Number of LIHTC’s that may be requested in applications by one developer – This limit continues to be 50% of DSHA’s credit ceiling. In the past there has been confusion over whether the 50% applies to the allocation or the credits available for that year after forward commitments from prior years. DSHA provided the exact number so there should be no confusion, which is $1,262,500.
Senior Housing and the New Creation Pool – The definition of New Creation excludes elderly projects unless 50% of all units are subsidized, including market rate units. To qualify, the project must currently be non-subsidized. The New Creation Pool is designed to create new affordable units.