The Texas Department of Housing and Community Affairs’ (TDHCA) final 2020 QAP requires that the provisions for Feasibility Reports be applicable to rehabilitation developments.
At the January 16 board meeting, TDHCA Executive Director Bobby Wilkinson shared with the Board and the public that staff will be bringing an action item for Board consideration at its meeting scheduled for February 20, 2020, that will propose a waiver of the concerning provision. The item in February will propose that 10 TAC Sec. 11.204(15), relating to Feasibility Reports, be waived, and therefore not required, for each submitted 2020 Rehabilitation Application.
As background, feasibility report requirements had not been applicable to rehabilitation development applications under the previous QAP. Because the new applicability of this requirement to rehabilitation developments was not specifically described during the QAP public comment period, many applicants may not have been aware of this requirement. Several potential applicants have let TDHCA know that if they had been aware of this change, they would have voiced significant concern because the items required are not typically required at the early stages of a Rehabilitation Development, and because they will add significant cost.
