The Ohio Housing Council submits formal comments on the Ohio Housing Finance Agency’s first draft of the 2026–2027 9% LIHTC Qualified Allocation Plan (QAP), highlighting the need to balance program integrity and resident benefit with development feasibility in an increasingly challenging financial environment.

Key recommendations include:

• Rethink the use of threshold requirements for cost-driving amenities
• Revisit the recent compliance fee increase
• Streamline the Experience & Capacity Review process, and 
• Remove the proposed Neighborhood Opportunity Index threshold that would exclude half of all census tracts in each region. 

OHC also emphasizes the importance of scoring transparency, flexibility in the redistribution of unused credits, and clear rules governing county-level allocations and set-asides.

OHC's Letter to OHFA