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Quarterly report relating to staff-issued Determination Notices for 2023 and 2024 Non-competitive 4% Housing Tax Credit applications
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BACKGROUND
The 4% Housing Tax Credit (HTC) applications are reviewed by program, underwriting, and compliance staff within an approximately 90-day period, and Determination Notices are issued once all reviews are complete and the underwriting report is posted to the Department’s website. Applications are submitted at the beginning of each month and are then slated for a Determination Notice to be issued approximately 90 days later, which generally coincides with the Board meeting calendar, in order to provide internal and external expectations regarding the Determination Notice issuance date.
The 4% HTC applications listed in Exhibit A include those where the Determination Notice was issued administratively by staff. From March through May 2024, staff has administratively issued eight Determination Notices. This represents 1,684 total units and $17,059,371 in annual 4% Housing Tax Credits.
2023 Application Log Summary
The 2023 Private Activity Bond (PAB) program had an annual ceiling amount of $3.6 billion, and as of January 17, 2024, eligible requests totaled approximately $7.5 billion, with much of the requests coming from multifamily issuers. The 2023 4% HTC Application Log is included as Exhibit B and highlights 4% activity for the 2023 program year. There are seven applications that have been approved, and have had Determination Notices issued, but have yet to close. Those approved applications represent total issuances of approximately $20 million in 4% Housing Tax Credits. The closing of those applications will mark the end of the 2023 program year.
Moreover, the log reflects the 44 applications that have closed on their respective bond allocations. Those projects that have closed represent 9,281 units, and over $99 million in 4% Housing Tax Credits. Altogether, when considering what has closed, and been approved, the total number of units is 10,892. Additionally, assuming all of the approved projects close, $119 million in 4% Housing Tax Credits will have been issued throughout the 2023 program year.
Finally, the log reflects those applications that were submitted to TDHCA, but subsequently withdrawn. This represented a total of 8,726 units. The reasoning behind these withdrawals were varied, but most commonly involved feasibility and timing concerns.
2024 Application Log Summary
The 2024 PAB program has an annual ceiling amount of approximately $3.8 billion, and as of May 20, 2024, eligible requests total approximately $5.7 billion, with much of the requests coming from multifamily issuers that participated in the 2024 PAB Lottery. The 2024 4% HTC Application Log is included as Exhibit C, and reflects those applications that have been submitted to TDHCA from December 2023 through May 2024 in conjunction with the issuance of bond reservations from the Bond Review Board.
Currently, there are 43 applications under review for a total of 9,245 units, and $105M in requested 4% Housing Tax Credits. Additionally, reflected on the log are ten applications that have been approved, and have had Determination Notices issued, but have yet to close. Those approved applications represent total issuances of more than $23M in 4% Housing Tax Credits. When considering what has been approved, and is currently under review, the total number of units is 11,493.
Also reflected on the log are four pre-applications that were submitted to TDHCA and added to the Department’s waiting list for a bond reservation during the 2024 program year.
Finally, the log reflects those applications that were submitted to TDHCA, but subsequently withdrawn. This represented a total of 1,435 units. The reasoning behind these withdrawals were varied, but most commonly involved feasibility and timing concerns.