On July 14, TDHCA staff released the draft of the 2027 Qualified Allocation Plan (QAP), which establishes the rules that will govern tax credit awards. It is essential for stakeholders to evaluate the proposed changes before they are finalized.
This year’s draft contains numerous revisions. A substantial portion of the edits reflect the Texas Regulatory Efficiency Office (TREO) initiative, which sought to improve brevity, clarity, and administrative efficiency. TDHCA staff indicate that TREO’s edits were intended to preserve the underlying meaning and policy intent of the rules; the TREO markup therefore accounts for the majority of textual changes in the draft QAP.
Among the substantive revisions, several are responsive to widespread input from developers and advocates. Notable examples include the removal of “fresh seafood” as a requirement in the grocery-store definition and the introduction of additional points for floors served by two or more elevators. Nevertheless, certain proposals continue to raise concerns for TAAHP and its members. These include the proposed “Achievable Affordable Rent” standard, which would impose additional underwriting requirements and could delay development timelines, and the potential for double-counting pharmacies located in grocery stores. For TAAHP’s complete comment package, click here.
The next step is for TDHCA staff to review submitted comments and provide reasoned responses. Following that review, staff will issue an updated QAP draft for formal consideration. The TDHCA Board is expected to vote on the recommended 2027 QAP in November; subsequent to the Board’s action, the QAP will be forwarded to the Governor for signature to meet the statutory December 1 approval deadline.