Agencies Should Not Require Local Letters of Support Says New NCSHA Report of Recommended Practices for LIHTC Administration
Agencies Should Also Avoid Prioritizing Requirements for Local Financial Contributions
On December 28th, the National Council of State Housing Agencies (NCSHA) released its updated and revised “Recommended Practices in Housing Credit Administration” (RPs). The report includes 46 new and updated best practice guidelines for housing agencies. While these recommendations are not binding, they are highly-regarded as they are developed by NCSHA staff, members and LIHTC industry experts. Housing agencies tend to align their QAPs with these recommendations whenever possible.
One of this year’s new RPs is of particular interest to TAAHP – recommendation #4 entitled Reducing Local Barriers to Development. Citing fair housing concerns, 2016 IRS guidance and last year’s GAO report, NCSHA finds that housing agencies should not require local approval as a threshold or scoring item. This recommendation also includes language directing housing agencies to avoid prioritizing local financial contributions in their QAPs.
Texas has long struggled with the challenges that local support, both at the state and city/county levels, poses to developing quality, affordable housing. NIMBY groups are empowered by the many local support mechanisms permitted in the Texas QAP, mechanisms that have red-lined large swaths of the state from citing a successful development. Letters of support from statewide officials, a 16-point item that is unique to Texas, often decide the winners and losers in each QAP round.
Read more analysis of the new RPs on the Novogradac blog.