2026 4% LIHTC Q&A

Question: Are new construction and rehab sites eligible to apply as one application?

Answer: Rehab and new construction can be part of one LIHTC application; however, if it’s a scattered site, Average Income Test cannot be selected, and the occupancy type must be the same for all buildings on all sites in the application and the construction requirements for New Construction and Rehab as set forth in the QAP would apply.

Question: Are Developers able to submit more than one 4% Tax Credit Application or does IFA make the determination about submission eligibility prior to the Submission Due Date?

Answer: Per Section 1.3 of the QAP, Developers may always submit more than one application in the 4% round but would be limited to one award if IFA is oversubscribed on Bond Cap requests. Developers must have a corresponding Bond Inducement Resolution for each planned Tax Credit Application.

A Developer planning to submit more than one Tax Credit Application in the 4% round would either be able to choose prior to submitting the Tax Credit Application to only submit one Tax Credit Application or to submit multiple Tax Credit Applications, recognizing that only the highest scoring Project, if any, would be awarded.

If necessary, tiebreakers as set forth in Section 6.3 of the QAP will be applied to the round prior to applying the Developer Cap.

Question: Is there a deadline to start construction that developers need to keep in mind if awarded a 4% Project in 2026?

Answer: Per QAP Sections 1.2 and 2.1, all 2026 4% Projects must close on their bond issuance in calendar year 2027 and the final day that IFA will accept Volume Cap Applications is November 1, 2027. If a Project has not closed using their bond issuance by December 24, 2027, their bond allocation is no longer valid.

Note that per QAP Section 2.1, IFA also requires that all buildings in 4% Projects be placed in service no later than 24 months after their Bond Issuance Date, which is variable for each project.

Question: Does proper zoning need to be in place for the Project's Bond Inducement Resolution application or by August 5th for the Tax Credit Application?   
Answer: QAP section 3.4.A states that the current zoning at the time of Application submission will permit the proposed project. This is referring to the 4% LIHTC application that is due August 5, 2026.

Question: Can a Scattered Site Project have more than 3 total sites if it is located in multiple cities?
Answer: Per 3.4.B of the 2026-27 4% QAP, Scattered Site Projects are limited to three sites in adjacent counties.

Question: What are IFA's requirements if a 4% Project is including a Community Service Facility?

Answer: The Market Study must include the proposed Community Service Facility, and the Tax Credit Application must demonstrate the purpose and the use of the Community Service Facility, as well as a completed Exhibit 18T.

Question: Does IFA regard sites protected by a levee as a detrimental condition?
Answer: A site that is protected by a Levee (Zone X) does not fall under the Detrimental Site Characteristic category. Only sites that are located within a flood hazard area, 100-year flood zone or a 500-year flood zone would fall into this category. It is still important to note this flood zone feature in the application so it is recorded as a site characteristic, but it would not be counted as detrimental to the project.

Question: If a Project has market rate units, could the market rate units be condoed out in order to keep the applicable fraction for the LIHTC project at 100%?
Answer: While IFA allows the traditional condo split for commercial/retail separate from the residential units, market rate units in a LIHTC project cannot be separated from the affordable units.

Question: In Sections 5.1.A.3 and 5.1.C.4, can you clarify what cross cutting is referring to?

Answer: If you have a federal funding source that would require federal cross cutting measures like an environmental review, Davis Bacon, or similar, the project would not be eligible for points under those sections in the QAP. Applicants are responsible for understanding the requirements of their federal funding sources.

Question: Can you clarify the number of points available for Disaster Recovery?

Answer: Communities are eligible for disaster recovery points as listed in the Appendix.

There are no communities eligible for 5 points under Disaster Recovery in 2026.

Question: Is IFA's intent in adding the dates to 5.4.A that 4% projects are placed-in-service 24 months from the Tax Credit Reservation?
Answer: IFA's expectation is that 4% projects are placed-in-service no later than 24 months after the initial bond issuance (See QAP Section 2.1). Language was added to clarify when IFA considers a project open (from Reservation through 8609) and to clarify that if the event that a project receives multiple bond issuances, IFA will use the initial bond issuance date to calculate these points. Initial bond issuance typically coincides with construction loan closing.

Question: What are the requirements for NGBS certification for Projects for the initial application submission?
Answer: The only thing IFA needs at the time of the initial application review for the energy requirements is to confirm that the energy consultant is NGBS certified. We do not expect for the project to be registered until after the project is awarded, at the time the initial construction package is being reviewed.

Question: In a new construction project containing townhome units where all townhome units are two-story units, would IFA require a wheelchair lift for a unit to be considered fully accessible when the ground floor has a fully accessible kitchen, bedroom, bathroom, and laundry?
Answer: It is IFA’s policy that all sections of a Fully Accessible unit should be on an accessible route and usable by persons with mobility disabilities. A wheelchair lift would be a sufficient solution to provide access to a unit’s second-floor space but IFA’s preference for new construction projects is to design Fully Accessible units without stairs.

Question: In a new construction project containing townhome units where all townhome units are two-story units, would IFA require a wheelchair lift for a unit to be considered fully accessible when the ground floor has a fully accessible kitchen, bedroom, bathroom, and laundry?
Answer: Per Section 9.4 of the QAP, projects using Historic Tax Credits may request exceptions to the QAP when recommended by SHPO. If such a recommendation has been made, IFA requires documentation of that recommendation before the Tax Credit Application can be submitted as the application system may need an override to allow design exceptions to proceed.