OHC submits comments on the first draft of the 4% LIHTC with BGF Program Year 2025 Guidelines, addressing several key points:

• Prior HDAP Awards and BGF Eligibility: OHC recommends modifying the exclusion of projects with prior HDAP awards by allowing adjustments—either by deducting the prior award from the eligible amount or by permitting repayment—to avoid disqualifying preservation projects.
• Cost Containment and Exception Requests: OHC urges OHFA to permit reasonable Total Development Cost exception requests for developments with unique cost factors, ensuring flexibility amid high interest rates and economic uncertainties.
• Historic Approval Timing: OHC calls for revising the requirement for SHPO Part II approval at the proposal stage, suggesting alignment with the 9% QAP process to reduce undue burden on developers.
• Geographic Distribution and Funding Pools: OHC questions the new order of operations for allocating set-asides and funding pools, seeking clarification on the rationale to prevent unintended consequences.
• BABA Compliance: OHC advises against imposing a blanket Build America, Buy America requirement, recommending that compliance be handled on a case-by-case basis.
• Minimum Rehabilitation Threshold: OHC suggests establishing a minimum rehabilitation threshold of $50,000 per unit to ensure meaningful investments in preservation projects.
• Tie Breaker Clarification: OHC requests clear guidance on the application of Tie Breaker #4 to eliminate ambiguity in future funding rounds.

OHFA's Letter to OHFA