On October 9, QAP Co-Chairs Karsten Lowe and Emily Abeln submitted TAAHP’s formal comments to the Texas Department of Housing and Community Affairs (TDHCA) on the official draft of the 2027 Qualified Allocation Plan (QAP). The TDHCA Governing Board will vote on the final rule in November, and the plan then goes to the Governor by December 1.
TDHCA staff substantially rewrote the 2027 QAP with input from the Texas Regulatory Efficiency Office (TREO) in the Governor’s office and an outside consultant. Staff cut the plan by about 28%, removing roughly 25,000 words, before the Board approved it for public comment at its September 3 meeting. Staff described most of the edits as shortening language while keeping the policy intent. TAAHP’s comments focus on the changes that alter requirements for applicants. A status report tracking 20 items TAAHP raised on the staff draft is attached. Click any item to go to the published rule text.
Major Policy Items from the 2026 QAP to the 2027 Draft QAP
- Achievable Affordable Rent: Under the proposed rule, underwritten rents for restricted units are capped at an Achievable Affordable Rent set by the Market Analyst. After Emily Abeln and Karsten Lowe raised the industry’s concerns, the Board directed staff to restore the 10% allowance in the public comment draft. Watch
- Capture Rates for Bond Deals: The proposed rule removes the 15% capture rate allowance for bond deals in high-occupancy large metropolitan areas, which has been in place since 2018, and applies the standard 10%. After Karsten Lowe raised the industry’s concerns, staff agreed to seek comment on a 12.5% rate. Watch
- Heat Pumps: The proposed rule requires electric heat pumps as threshold, with natural gas heating and a 1.5-point option added by the Board in September. TAAHP asked TDHCA to adopt the 1.5-point amenity in place of the threshold.
- Operating Feasibility for Bond Deals: Bond deals without a Direct Loan or with a non-TDHCA issuer would no longer receive the streamlined underwriting review, and TDHCA’s expense estimates would control unless the Applicant’s are within 5%. TAAHP asked TDHCA to keep the 2026 review, because lenders, investors and issuers underwrite these expenses with their capital at risk.
- Neighborhood Risk Factors: Reconstruction developments with federal assistance or a TDHCA Land Use Restriction Agreement (LURA) would lose the exemption they held in 2026 and prior QAPs. TAAHP asked TDHCA to restore it for HUD Choice Neighborhoods and Rental Assistance Demonstration (RAD) conversions, and staff has indicated it will address this in the November draft.
- 9% Tiebreakers: Urgent care clinics are added as a sixth amenity, and a grocery store and its pharmacy count separately. Seafood is removed from the grocery store requirements, and stores requiring a paid membership qualify.
TAAHP’s 2026 QAP Advocacy Timeline
- May 20, 2026: First TDHCA QAP Roundtable. TDHCA hosts the first public 2027 QAP Roundtable to gather stakeholder input. See Agenda
- June 3, 2026: TDHCA Rules Committee Meeting. The Rules Committee meets to discuss early concepts for the 2027 QAP. Read Update
- July 14, 2026: TDHCA Releases Staff Draft. TDHCA posts the preliminary staff draft of the 2027 QAP. Read Draft
- August 2026: TAAHP Comments on Staff Draft. TAAHP submits formal comments on the staff draft. Read Comments
- September 3, 2026: TDHCA Board Approves Official Draft. The Board approves the rewritten 2027 QAP for public comment. Watch
- October 9, 2026: TAAHP Submits Final Comments. TAAHP submits formal comments on the official draft. Read Letter
- November 2026: TDHCA Board Vote. The Board considers the final 2027 QAP.
- December 1, 2026: Governor’s Final Action. The Governor approves, rejects or modifies the QAP.