The Ohio Housing Council submitted formal comments to the Ohio Housing Finance Agency on the draft Program Year 2026 4% LIHTC with Bond Gap Financing (BGF) Guidelines. The comments addressed three areas of the draft guidelines with potential cost and risk implications for applicants. 

Key recommendations include:

• Allowing applicants to submit a lower-percentage design set with the February application, with a complete construction document set due within 90 days of an Invitation to Proceed, rather than requiring a full design package before OHFA has indicated interest in a project.
• Replacing the NHTF funding pool's committed-closing-date scoring criterion with milestone-based readiness measures, such as a CHAP letter, a HUD financing plan, and environmental review progress, since tax-credit-financed developments are rarely fully "shovel ready" for reasons largely outside an applicant's control.
• Limiting Lien and Litigation Report requirements to an applicant's parent or sponsor entity at application, rather than newly formed development entities that may never come into existence absent an award.

OHC's Letter to OHFA