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14.19 Other Matters

HUD Multifamily Accelerated Processing (MAP) Guide, HUD Handbook 4430.G (2020 ed., rev. Mar. 19, 2021) · 2026 edition · updated 2026-10-05 · United States

A. The market study, appraisal and underwriting for all Tax Credit projects must address the relationship between the Tax Credit ceiling rents, the attainable rents, any subsidy contract rents and terms, and true market rents. Any disparities among these rents and the related risks must also be addressed.

B. HERA’s Exception to the Tax Credit Program’s 10-Year Holding Period. HERA provides for an exception to the LIHTC’s ten-year holding period requirement for certain federally assisted buildings, specifically those that are 221(d) or 236-insured. Because the HERA language refers to the two specific programs noted above as well as to “…any other program administered by the Department of Housing and Urban Development…” the waiver should apply to all FHA-insured tax credit projects. HUD does not render tax advice, however, so owners should seek tax counsel with respect to this interpretation.

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Chapter 14 LIHTC and Other Tax Credit Programs 14.19 Other Matters

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