The Ohio Housing Council submits comments to the Ohio Housing Finance Agency on the first draft of the State Fiscal Year 2027 Ohio Low-Income Housing Tax Credit (OLIHTC) Guidelines.

OHC emphasizes that the OLIHTC program has been instrumental in addressing Ohio's housing shortage, enabling the creation of affordable homes—particularly in underserved communities—that would not be financially feasible with 4% LIHTC alone. As the program enters its fourth year, its smooth implementation reflects strong program design by OHFA and capable execution by Ohio's development community, positioning it well for extension and expansion.

Key Recommendations

• Ohio-Based Developer Tiebreaker – Add preference for Ohio-based development teams as first tiebreaker to demonstrate in-state capability, deliver economic multiplier effects, and strengthen evidence that OLIHTC creates both homes and Ohio jobs
• Metropolitan Scoring Threshold – Raise maximum scoring threshold from $8,750 to $10,000 per unit to reflect current development economics while maintaining efficiency standards
• Strategic Initiative Clarity – Clarify that Strategic Initiative is discretionary, providing professional flexibility rather than requiring annual fulfillment
• Application Fee Requirements – Clarify that timely payment is non-curable but proof of payment may be submitted during cure period
• HDL Monitoring – Encourage monitoring whether the $2.5 million HDL cap constrains feasible projects as the program matures

Provisions OHC Supports

OHC expressed strong support for OHFA's approach of scoring projects before addressing set-asides and clarity that single projects can fulfill multiple set-asides.

OHC's Letter to OHFA