The Tennessee Housing Development Agency released a list of preliminary proposed changes to the Draft 2021 QAP, which include:

  1. Revert to a 1-year QAP format.
  2. Update Total Development Cost limits [see Section 3].
  3. Restructure New Construction Regional Pools [see Section 3]:
    1. Statewide pool for large urban/suburban counties;
    2. Statewide pool for other urban/suburban counties;
    3. Statewide pool for at-risk and distressed counties; and
    4. Statewide pool for the remainder of the state.
  4. Change requesting a site change from Minor SAE to Major SAE [see Section 6].
  5. Modify the Public Housing Authority Set-Aside so that first priority is assigned to proposed developments that (a) involve Rental Assistance Demonstration (“RAD”), (b) are covered by a Community Revitalization Plan (“CRP”), and (c) will be the second or subsequent RAD and CRP development under the CRP. Second priority is assigned to proposed developments that (a) involve RAD, (b) are covered by a CRP, and (c) will be the first RAD and CRP development under the CRP [see Section 10].
  6. Add a new construction scoring criterion based on the economic security, education, and mobility components of Opportunity360.
  7. Add a new construction scoring criterion favoring proposed developments with the lowest ratio of Housing Credit requested to the imputed number of persons to be served by the development (1.5 persons per 1 BR, 3.0 persons per 2 BR, 4.5 persons per 3+ BR).
  8. Add a rehabilitation scoring criterion favoring proposed developments with the highest average occupancy percentage over the prior 3 years.
  9. Add a rehabilitation scoring criterion favoring proposed developments with the highest ratio of post-rehabilitation LIHC units to the sum of the currently existing affordable units in the county and the LIHC and MTBA “pipeline” units. Within this criterion, favor proposed developments with soon-to-expire HAP contracts.
  10. Delete points associated with 60 Percent Income Averaging Test [see Section 14].
  11. Reduce points associated with Project Location for developments proposing rehabilitation of existing multifamily housing [see Section 14].
  12. Change competitive scoring criteria for Public Housing Authority Waiting Lists and Energy Efficiency to threshold and minimum new construction and rehabilitation requirements [see Section 14].
  13. Delete computer systems option from scoring criterion for Serving Resident Populations with Special Housing Needs and scoring criterion for Serving Resident Populations with Children [see Section 14].
  14. Clarify that if property control involves a ground lease, the fee owner must join the Land Use Restrictive Covenant to encumber the fee simple interest [see Section 13].
  15. Non-substantive changes including (without limitation) correction, clarification, rewording, reformatting, renumbering, and relocating text within the document.

Comments should be sent to TNAllocation@THDA.org with the subject line “2021 QAP COMMENT” by Sunday, April 26. THDA will host a 2021 Multifamily Programs Developer Forum on April 22 from 1:00 to 3:00 pm CT. Dial 650-479-3208 and code: 281-905-243 to join the call.