Frequently Asked Questions (FAQs)

Revised August 20th, 2026

For any questions, inquiries can be directed via email to HTC.FAQ@wheda.com. A team member will respond as promptly as possible, and the webpage will be updated to include all answered questions. The page is regularly reviewed and updated to ensure the information remains accurate and current. Any significant updates or important notices will be clearly highlighted for easy reference.

Scoring

The following questions address the scoring criteria for the Housing Tax Credit application, organized by scoring category as outlined in Appendix C. These topics encompass the factors considered in evaluating and scoring applications and are intended to assess each project’s potential impact, feasibility, and alignment with program and funding priorities.

Areas of Economic Opportunity

Q: If a grocery store is opening after the 9/30 date but before the 11/2 submission deadline and is publicly shown in the data could that be included in the final grocery store list?
A: No. If the store isn’t open, WHEDA would be unable to review the store to determine if it meets expectations, and there wouldn’t be certainty that it would in fact be open at application submission.

Tribal, Rehabilitation & Neighborhood Stabilization, or Counties without a Recent Award

Q: What is the timeframe for “Counties without recent awards” to be awarded points?
A: The list includes counties without an award in the last 5 years excluding tribal awards and deals where credits were returned or revoked.

Q: For the Scoring category ‘Tribal, Rehabilitation & Neighborhood Stabilization, or Counties Without a Recent Award’ would WHEDA confirm that projects that score points under the category ‘Area of Economic Opportunity’ cannot score points in undersection 3?
A: Projects can only score points in either category 1 or 3.

Serves Large Families or Seniors

Q: For the scoring category ‘Serves large Families or Seniors’, can WHEDA please confirm whether the federal project-based voucher units must also be three-bedroom or larger units in order to qualify for points under this category?
A: Correct – whether the units are low-income or PBV, the units must be 3-bedroom or larger to be in the numerator.

Serves Lowest Income Residents

Q: For scoring category ‘Serves Lowest Income Residents’, if a project elects points in this category, is the project required to do income averaging?
A: No. The project can choose 40% at 60% and get points by having ¼ of the units set aside at the AMI levels prescribed for High, Moderate or Low Income Counties.

Q: For Appendix C, scoring category 5, What is the policy rationale for requiring an ADRC letter for senior housing, and how does an ADRC’s ability to serve residents relate to the demonstrated need for senior housing in a community? Could this requirement create an unnecessary administrative barrier, particularly if ADRC capacity varies by location?
A: Section 42 requires a QAP contain selection criteria regarding serving families with children, and WHEDA wanted applications for senior projects to earn a corresponding number of points without taking the same approach (effectively mandating a unit mix). An ADRC letter also should help build a bridge to relevant resources/support. Please let us know if proves to be a barrier (as in ADRCs refuse to cooperate).

Location

Q. For scoring category ‘Site Characteristics’, could a project submit a site to WHEDA in advance of the Concept Phase deadline for review and consideration of points in this category?
A: WHEDA will not prescreen sites for points in advance of application submission.

Section 811 PBRA

Q: Can WHEDA please confirm if the 811 vouchers would be considered as ‘project based rental assistance’ for the scoring category B2?
A: Section 811 PRA are considered project-based rental assistance.

Q: Are 811 units only available in the counties listed on the 811 Flyer posted on WHEDA’s 811 page?
A: The counties listed on the 811 flyer are those where 811 units are currently available - not counties that the program is restricted to. WHEDA will accept applications in any county.

Q: For scoring category ‘811 vouchers’, would WHEDA please define “special unit designation?” Will WHEDEA allow 811 voucher units to be reserved using AHP/HOME/TIF/HTF/City and County Municipal funding?
A: Everything mentioned in the question (AHP/HOME/TIF/HTF/City and County Municipal funding) are financing sources and not directly related to unit designation. 811 units can't overlap with anything that would contradict the Program Guidelines, which applicants are required to review and adhere to. WHEDA’s 811 page can be found here. For example, an 811 unit cannot also be a Veteran designated unit, cannot have other project-based operating subsidy, and may not be able to be layered on existing use restrictions for people with disabilities.

Q: For 811 vouchers, what is the timing of the WHEDA review process?
A: 811 voucher applications will be due with the tax credit application.

Q: How will vouchers be awarded by project if the 811-voucher applications received result in the vouchers being oversubscribed?
A: Projects should submit assuming no Section 811 vouchers. If the project is selected to receive vouchers, no change would be made to the tax credit award. 811 vouchers are unlikely to result in the project being over subsidized based on the operational realities of the program.

Q: How is “qualifying Section 811 PBRA application” defined, and what level of review or commitment is required to ensure that applicants have a meaningful intent and ability to participate in the HUD Section 811 program as represented in the application?
A: A “qualifying application” means one WHEDA determines meets all relevant programmatic standards. The HUD 811 points are no different than any other category: developers must abide by their representations. Inability or refusal to do so would result in various forms of negative consequences.

Universal Design

Q: Would you please provide a Redline version of the Universal Design document?
A: A redline of the Universal Design scoring options against the prior year’s can be found here.

Land Donation and Other Support

Q: Can WHEDA confirm if rehab historic projects and adaptive reuse historic projects are eligible to receive points under the ‘Land Donation and Other Support’ category?
A: Projects that utilize historic tax credits for an acq/rehab would not be eligible for these points. Projects with Historic Credits are eligible to earn points if they are adaptive reuse with or without a new construction component.

Below-Market Financing

Q: For the scoring category ‘Below-Market Financing’, will the number of “applicants” be the total number of LIHTC applications received, or the total number of applications that are electing points in this category?
A: WHEDA will rank applications selecting points in this category. Any that have no qualifying loans will get 0 points. WHEDA will divide the 20 points by the number of applications qualifying for points and will assign based on that. So, if 15 projects elect points but only 12 qualify for points, the highest would be 20, and each increment down would be (20/12 = 1.67).

Q: Replacing the credit efficiency category with the proposed Below-Market Financing is concerning, particularly given the limited availability of forward commitments from HOME, AHP, HTF, and other funding sources. How will “established local government housing programs” be defined and applied?
A: Every affordable housing program wants to be the “last in” (wait for others to award first). Each entity is making its own decision. However, all else is not equal:

Section 42 requires LIHTC agencies to consider other committed sources before allocating.
WHEDA’s financial contribution can be 10x those of any other.
Too many developers recently have shown sources which did not materialize, causing delays, returns, and other problems.

So, if a lender wants to help earn points, it has just as much ability to change its practices. WHEDA does see applications with these funds committed, which merits positive recognition. A developer may still apply to these entities after an award.

The phrase "established local government housing programs" is meant to give applicants an opportunity to find other sources. They can decide whether to do so. WHEDA may give guidance in response to a specific set of facts if you have questions on whether something would qualify.

Development Team

Q: In Appendix P, will there be two points for qualifying non-profit developers?
A: Two points will no longer be provided for nonprofit developer participation.

Site Characteristics

Q: What is the intent of this category, and what criteria will WHEDA use to ensure consistent scoring of wetlands, steep slopes, and similar site characteristics, particularly when appropriate site design or mitigation may address potential development concerns?
A: The need for this category is to help control costs and reduce problems. As for the specifics mentioned:

Wetlands reduce the amount of buildable land; complicate site design; increase infrastructure and stormwater costs; may create long-term risks related to flooding, drainage, and maintenance; often require protective buffers that further reduce usable acreage; can delay construction schedules due to environmental reviews and permitting.
Steep slopes can create the need for extensive cut/fill grading and retaining walls; complicate utility installation and site access; increase erosion and stormwater-management challenges; create long-term maintenance and safety concerns for residents.

For more information on the above, consult with an experienced engineer, general contractor, or other qualified professional.

The phrase “if the site design allows for it” is an example why the category must be assessed subjectively: WHEDA may determine negative points are unnecessary in such an instance. Describing every possible fact pattern in objective terms would be at best extremely difficult. Worse, it might create unintended consequences, such as making feasible sites ineligible. If you have a suggestion for such phrasing, please submit it for consideration in future years’ policies.