Frequently Asked Questions (FAQs)

Revised October 22nd, 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.

Threshold

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

Application Submission Process

Q: Can a project applying in the 2027 LIHTC round may submit both a 9% and a 4% competitive application, as was permitted under the previous QAP?
A: Applicants may submit both a 9% and a State application for the same project.

Q: The underwriting guidelines state that State Metro projects may request a 15% HFA boost. Could WHEDA clarify whether the HFA boost is guaranteed upon request or whether there are circumstances in which it may not be approved? When will WHEDA make this determination? Additionally, does the HFA boost apply to both the federal and state LIHTC, or only to the state LIHTC?
A: Applicants may request the HFA boost at the time of application. WHEDA will determine whether the boost is necessary during its application review. The boost may not be approved if WHEDA determines that the project does not need it to demonstrate financial feasibility.

Q: If a project intends on requesting the 15% HFA basis boost can be used during the calculations for project concept submission and full application?
A: The project concept phase will not include a calculation of tax credits. At full application, The applicant will make a request for a boost. WHEDA will determine the need for a boost when reviewing the application.

Q: Are applicants / developers able to change the number units they are proposing from Project Concept Submission to Full LIHTC Application?
A: Yes. Applicants are able to change the number of units proposed between project concept and full application. We are trying to get a sense of the projects at this stage, but some shifting is permitted.

Q: Are applicants / developers able to change the unit mixes they are proposing from Project Concept Submission to Full LIHTC Application?
A: Yes. Applicants are able to change the number of units proposed between project concept and full application. We are trying to get a sense of the projects at this stage, but some shifting is permitted.

Q: In previous years 70% of funds needed to be committed at project concept submission. Is 70% still acceptable or is it in line with the full application requiring 80% of funds to be committed?
A: There is not a committed funding level requirement at project concept. The 80% commitment requirement stands for full application.

Q: In the past, WHEDA has allowed a maximum of (2) applications from any developer to proceed from concept to full app (and a max of 2 awards). Will there be a limit on how many full applications a single applicant may submit?
A: There will not be a limit on the number of full applications a developer can submit at the Full Application stage. The applicant list published at Project Concept is intended to provide developers information in determining their projects for Full Application. Developers will be limited in the number of awards they can receive as outlined in the QAP.

Q: The Project Concept submission checklist states that a completed Appendix P must be uploaded for the development team section. However, when I examined this appendix, there really isn’t anything to fill out or upload, unless you are bringing on an emerging developer, which we are not. What is required?
A: Development Team Experience Forms are required for all submissions. Applications which include a Lead Experienced Developer and an Emerging Developer must also submit a complete Appendix P, along with all supporting documents. Appendix P must be consistent with the applicant information provided in Tab 5 of the Multifamily Application Workbook.

Site Control

Q: Can the sale / acquisition price for a site change after the concept application approval? E.g. different amount in concept app and final app?
A: No. The site control should be secured for at least 90 days after Full Application submission and the purchase price cannot change.

Q: Do non arm’s length sale / acquisitions require an appraisal to determine market value if they are land only and not generating acquisition credits?
A: An appraisal is required if (i) Seller financing is being provided or (ii) if you are seeking acquisition credits.

Q: Please clarify when site control must extend through.
A: Site control must extend 90 days beyond the Full Application submission deadline of 2/5/2027.

Zoning

Q: What would be allowed to satisfy threshold requirements for a full LIHTC application with regards to zoning. Would highlighting that the project’s intended use is conditionally permitted be acceptable, or would a project’s need to have the actual conditional use permit approved at time of final application submittal?
A: WHEDA has accepted zoning with the conditional use outstanding and will in 2027. In those instances, the municipality has stated the number of units in the project and stated, “Permissive zoning is in place for the development listed above with a conditional use permit.” Note that WHEDA reserves the right to modify this requirement in the future.

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: If a project in one of these counties is awarded in 2027, will that county fall off the list for 2028?
A: WHEDA will update the list of Counties without a Recent Award annually, so if a county receives an award in 2027, it would no longer be on the list.  If a county is excluded from the list because it received an award in 2022, but hasn’t received one since then, it would be added in 2028.

Q: Could WHEDA please clarify whether the “on call” transportation scoring criterion is applicable only to projects located in both a non-metro county and on federally designated Tribal Land, such that both conditions must be satisfied in order for a project to qualify for points? Specifically, would a project located in a non-metro county but not on federally designated Tribal Land, or a project located on federally designated Tribal Land but outside a non-metro county, be ineligible for points under this criterion?
A: The intent of that language is for projects either in nonmetro counties or on federally designated Tribal Land may qualify for points with evidence of an “on call” transportation program. 

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 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).

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.

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: For Appendix C, scoring category 7, How is “qualifying 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 HUD811 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.

Q: Appendix S explains that the Section 811 units must serve households at or below 30% AMI and that rents for the Section 811 units are capped at the lessor of 60% AMI or Fair Market Rents. Can you please confirm that we should be underwriting the Section 811 units at lessor of 60% AMI or Fair Market Rents at application?
A: Threshold Requirements on page 2 of Appendix S states that the 811 vouchers may only be paired with 30% AMI set-aside units. As such, the units you intend to apply for vouchers for should be included as 30% units in the LIHTC application with 30% rents. As noted in the FAQs, if the project is selected to receive the 811 vouchers, WHEDA does not anticipate making changes to the tax credit award. 811 vouchers are not likely to result in a project being over-subsidized based on the operational realities of the program.

Q: Appendix S states that, "Due to limited funding and capacity, WHEDA will limit the number of awards per application cycle. Not all applications that meet threshold requirements may receive an award." If a project is underwriting 11 Section 811 units and receives an award for only 6 units, the remaining 5 units would no longer be supported by Section 811 rental assistance. If those units were originally underwritten at 60% AMI rents or Fair Market Rents and must instead be underwritten at 30% AMI rents, the project could experience a significant financing gap or fall below WHEDA’s 80% committed sources threshold. How will WHEDA evaluate a project's financial feasibility in situations where the project does not receive all the requested Section 811 units and, as a result, the original underwriting assumptions are no longer achievable?
A: As noted above, the LIHTC application should be submitted assuming 30% rents on units that are being proposed for 811 vouchers.

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.

Veterans Housing

Q: The submittal checklist references completing all of Tab 4 “Project Description”. Under the targeting of units there is an input cell for Veterans Units. Is an MOU with a County Veterans Service Office required to be submitted as part of the concept application phase if we are selecting points in this category?
A: At this stage, an MOU isn’t required. Please refer to Appendix C for requirements at full application.

Energy Efficiency and Sustainability

Q: Will NGBS Net Zero still qualify as a 20-point Advanced Scoring Cert this year?
A: Yes – NGBS Net Zero or other “Stretch” Net Zero categories from 2026 would count for 20 points. Please select a 20 point scoring category in the MFA and note in the Comments the Net Zero certification you intend to pursue from the 2025-2026 QAP.

Q: Given that Energy Star specifications for non-downlight fixtures, including vanity, linear, and decorative fixtures, are no longer available, could WHEDA clarify how applicants should demonstrate compliance with the high-efficiency lighting requirement? Is there an alternative Energy Star listing, certification, or standard that should be used for these types of fixtures?
A: WHEDA is looking for high-efficiency or Energy Star-rated lighting. LED lighting has become the industry standard for high-efficiency lighting and is typically what we see on projects to meet this requirement. LED fixtures generally meet the applicable Energy Star efficiency qualifications, even when the individual fixture does not carry a specific Energy Star label or listing.

Q: Could WHEDA please confirm that a project pursuing NGBS Net Zero certification is not required to also meet WGBH 200 points or any other lower-tier WGBH threshold in order to satisfy the applicable requirement?
A: Projects that meet NGBS Net Zero will not be required to achieve WGBH 200 points or any other lower threshold.

Universal Design

Q: Could WHEDA please clarify its definition of “common space” for purposes of this requirement? Specifically, does common space include areas such as offices, restrooms, storage rooms, vestibules, halls, and corridors?
A: Yes. WHEDA considers the listed areas to be common space. Generally, any interior space within the building that is designed for resident use is considered common space. This includes vestibules, halls, and corridors.

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: Do TID extension funds count as TIF for scoring purposes?
A: This depends on how the extension funds are contributed to the project. Typically, extension funds are contributed below market financing or a grant, which would be provided points under category 14. If the funds function as a TIF, then they may be eligible for points under this category. TID extension funding in a project would not be eligible for points under both 12 and 14.

Q: If the project includes tax incremental financing, does this need to be committed at the time of concept or full application to receive points? Same question for the fee waiver.
A: Yes – the TIF or fee waiver would need to be fully committed at the time of full application to receive points.

Q: Will partial land donations qualify for partial points based on the proportion of the discounted land value relative to the appraised value? We have seen this approach used for AHP and would like to confirm whether WHEDA will apply a similar methodology.
A: No. Appendix C requires a donation, and there is no provision to account for a partial donation. One reason for adopting this policy is that WHEDA prefers to avoid disputes regarding appraised values.

Q: Would land qualify for Land Donation points if it is donated to a nonprofit organization and subsequently sold by the nonprofit to the tax credit project ownership entity at fair market value in exchange for a seller note rather than cash?
A: No. The land must be donated and cannot be sold in exchange for a seller note. To qualify for points, the land may instead be donated directly to the project ownership entity.

Q: Can the land be donated by a related party?
A: Yes.

Q: Can the land be transferred at a nominal amount and count as donation?
A: Yes. Land sold to the project for $10 or less may be considered donated.

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: May a ground lease include a balloon payment at the end of the lease term that exceeds $100 per month?
A: No. Appendix C states that “total payments for a ground lease may not exceed $100 annually.” The inclusion of the word “total” is intended to prevent arrangements such as the one described.

Q: What level of documentation is required for TIF or a fee waiver to qualify for points? Is a commitment letter from the municipality sufficient?
A: WHEDA will require the same documentation outlined in Appendix D to serve as a committed financing source. Per Appendix D, to document a TIF commitment:

Evidence of firm commitment from the Municipality, Developer Agreement, or Common Council approval.
Evidence of Annualized TIF Increment sizing methodology not limited to: Baseline Property Value, Forecasted Stabilized Property Value, Municipal Taxing Rate.

Developer-financed TIF loan amount should be calculated based on the following items:

Term and amortization not to exceed the Municipal TIF Developer Agreement term and amortization.
Interest rate equal to WHEDA’s Permanent Financing rate for the WHEDA senior debt associated with HTC projects on the date of application.
Loan sizing not to exceed 90% of net present value of the annual tax reimbursement, discounted by the current WHEDA posted financing rate that matches the WHEDA senior debt for the duration of the property tax reimbursement
Not stated in Appendix D, but a firm commitment from another lender for TIF financing would theoretically qualify, as well, if it could be secured.

For fee waivers, WHEDA would require a firm commitment from the municipality that documents the fees that should have been due based on their standard fee schedules.

Q: Do WHEDA competitive loan financing products count towards below-market financing points? If so, do these need to be committed at the time of application to receive points?
A: To receive points for committed below-market financing, the loan products do need to be committed. The terms of the competitive loan products align with the required terms in category 14. However, the competitive loan products are required by statute to be “last in” financing, so applications submitted in the competitive financing funding rounds for RMS/IAL/VTV that rely on LIHTCs must have already received a tax credit award. Applications that assume tax credits that haven’t been awarded have been and will continue to be disqualified in the competitive loan financing funding rounds.

Q: Appendix C states that WHEDA may disregard sources affiliated with a sponsor loan. Would a seller note based on the appraised value of the property qualify as a source for purposes of receiving Below-Market Financing points?
A: A seller note, regardless of its terms, is not one of the financing sources identified in Appendix C, Section 14(a).

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: Can you clarify how noncompliance with the Strategic Business Program would result in a loss of development team points? Our understanding is that the Strategic Business Program is optional, and the recourse for not meeting the goals is the fee waiver would not be received.
A: The above is correct. Failure to participate in the Strategic Business Program would not result in negative developer points. WHEDA will update that in a future iteration of Appendix P.

Q: Is there a minimum ownership percentage required for a developer to qualify as an Experienced Developer (ED)? Based on the current language, it appears that no minimum ownership percentage is specified. Therefore, would a developer with as little as 5% ownership qualify as an ED, provided they are otherwise a participating member of the development team?
A: Correct. There is no minimum ownership percentage required for an Experienced Developer. However, an Emerging or Experienced Developer may receive negative points or otherwise be subject to consequences if the project encounters issues, regardless of their ownership percentage.

Q: Can you clarify how the unit count and number of projects are applied under the Experienced Developer qualification criteria?
A: To qualify as an Experienced Developer, a developer must meet one of the following criteria:

Complete one tax credit project in Wisconsin for which 8609s have been issued and stabilized occupancy has been achieved between January 1, 2017, and January 1, 2025; or
Complete six separate HTC projects anywhere in the country that collectively contain at least 200 units, with 8609s issued and stabilized occupancy achieved between January 1, 2017, and January 1, 2025.

If a developer has completed four projects in Wisconsin, regardless of unit count, they may qualify as an Emerging Developer and partner with an Experienced Developer to receive points or proceed independently. The intent is to continue incentivizing Experienced Developers to partner with Emerging Developers on more than one project, allowing additional opportunities for capacity building.

If a developer has completed four projects but all four are located outside Wisconsin, they would remain classified as an Emerging Developer because they would not meet the six-project Experienced Developer test.

Q: Appendix P states that a Developer must qualify as an “Experienced Developer” to apply independently. Could WHEDA please clarify how this requirement applies to Tribal applicants under Section A.iii, including whether Tribal applicants are exempt from the standard Experienced Developer requirement and therefore may apply independently without a co-Developer, regardless of when or whether their most recent development was completed? Additionally, if a Tribe or a Developer that otherwise qualifies as an Emerging Developer elects to apply independently without a co-Developer, would they be ineligible to receive Emerging Developer points?
A: The intent of Section A.iii was to clarify that projects owned by Tribes may be considered to have an Experienced Developer and are not required to have a co-developer, regardless of when the Tribe’s most recent development was completed or whether the Tribe has previously completed a development.

If a Tribe, or a Developer that otherwise qualifies as an Emerging Developer, elects to apply independently as an Experienced Developer without a co-Developer, the applicant would not receive points available under the Emerging Developer scoring category.

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: In Appendix C, section 16, site characteristics- 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.

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.