Public Comment — Housing Tax Credit Program Qualified Allocation Plan

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Teresa Morales, Rule Comments
Texas Department of Housing and Community Affairs

Date:October 20, 2014

From:Belinda Carlton, Public Policy Specialist

RE:Public Comment — TRD–201404298
Chapter 11. Housing Tax Credit Program Qualified Allocation Plan
10 TAC §§11.1–11.3, 11.5–11.10

The proposed 2015 Qualified Allocation Plan, among other things, attempts to incentivize low income housing developers who participate in the housing tax credit program to set-aside new or existing multi-family developments for a new project rental assistance (PRA) option for extremely low income individuals with disabilities and youth aging out of the state foster care system. The new HUD Section 811 PRA will create the opportunity for extremely low income persons with disabilities to live as independently as possible through the coordination of voluntary services and providing a choice of subsidized, integrated rental housing options.

The TDHCA staff have held two meetings with developers, state agency long term services and protective services staff and disability advocates to consider how to incentivize tax credit developers to participate in the 811 program. Low income housing developers held misconceptions that they were responsible for provision of long term services and supports, myths about the people that will benefit, and concerns with the burdensome requirements for a provider of project rental assistance. The proposed new scoring criteria in the draft 2015 Housing Tax Credit Program Qualified Allocation Plan, Section 11.9(7) (A) & (B) are directed at incentivizing developers to participate in the Section 811 program.

TCDD supports:   §11.9. Competitive HTC Selection Criteria. (7) (A) & (B) Tenant Populations with Special Housing Needs.