The Tennessee Housing Development Agency (THDA) released the draft 2021 Multifamily Tax Exempt Bond Authority (MTBA) Program Description for public comment. Comments should be submitted to TNAllocation@thda.org by noon CT on Friday, October 30. The two areas of significant change are around special requests and aggregate basis for multi-phase projects.
Given the many discussions the THDA board had on special requests, THDA changed the guidelines for submitting and processing those applications. The new guidance stipulates:
- MTBA available for special request applications is offered on a first-come, first-served basis, subject to the availability of MTBA as of the date a special request application is received by THDA. When a special request application is received by THDA, the amount of MTBA requested shall be set aside and will not be available for other MTBA requests under this MTBA Program Description until the special request application is evaluated and acted upon by the Tax Credit Committee of the THDA Board of Directors. MTBA for Special Request applications will be set aside from MTBA remaining available upon receipt of an application pending review and Tax Credit Committee Action.
- Special request applications are exempt from the Total Development Cost Limits as described in Section 3-G and Section 19-C of the QAP.
- Special request applications approved by the Tax Credit Committee of the THDA Board of Directors will not count against the maximum amount of MTBA per developer or related parties as defined in Section 5.
THDA also changed the formula for maximum MTBA for all developments to the lesser of a hard dollar cap or Previous phases of 60 percent of the development’s aggregate basis including land, with all previous phases of the same development included in the aggregate basis.