OHC submits comments on the first draft of the Ohio LIHTC State Fiscal Year 2026 Guidelines, including key recommendations and forward-looking opportunities:

Key Recommendations

• Cost Containment and Exception Requests: OHC urges OHFA to allow reasonable exceptions for Total Development Cost under Bond Gap Financing, especially for projects with unique cost factors (e.g., historic preservation, prevailing wage requirements, or BABA compliance) to ensure adaptability amid changing economic conditions.
• Competitive Scoring – OLIHTC per Unit: The current emphasis on a low per-unit score may encourage point-chasing over long-term financial stability. OHC recommends revising the scoring scale to balance cost efficiency with overall project robustness.
• Financial Commitment Timing: While OHC appreciates the shift of conditional commitment requirements to the Final Application stage—critical for urban markets—it continues to express concerns about how resource commitments are demonstrated.
• Accessibility Group Notification: OHC suggests reconsidering this requirement to avoid duplicative administrative burdens since existing federal and local regulations already ensure compliance
• Geographic Distribution and Funding Pools:
  OHC questions the revised order of operations for set-asides and funding pools, urging OHFA to clarify the rationale behind this change and consider reverting to the previous approach if more effective.

Looking Ahead

• Rural Developments: OHC encourages initiating discussions to integrate rural projects into the 9% LIHTC program, including a discretionary boost for rural developments to leverage efficiencies in that structure.
• Set-Asides: OHC recommends evaluating the current set-aside framework to determine if a more tailored, program-specific approach could better meet the intended policy goals.

OHC's Letter to OHFA