SUBJECTIVITY WITH STATE QAP’S
With the recent housing bill (HR-3221) allowing the state Housing Finance Agencies (HFA) the ability to offer the 30% eligible basis boost to certain buildings at their discretion it seems as if there is too much subjectivity involved. For example, North Carolina’s 2009 Draft QAP states, "Establish standards for determining the Agency-designated increase in eligible basis. The Housing and Economic Recovery act (HR 3221) allows the Agency to designate projects as receiving an increase in eligible basis of up to 30%. Under the draft QAP, proposed projects with high land costs, extensive site preparation, or off-site costs would be considered for the boost". How do they expect developers to underwrite their deal with the possibility of achieving the boost? How is one to obtain a commitment letter on that assumption? Thoughts?