The Ohio Housing Council provides feedback on the second draft of OHFA's Multifamily Rental Underwriting Guidelines, acknowledging the agency's high responsiveness to priority concerns raised in initial comments while identifying unintended consequences of well-intended policy provisions.

Key concerns include:

• Fixed $60,000 per unit minimum hard construction costs fail to account for geographic variations, asset-type differences, and economies of scale that affect rehabilitation feasibility across Ohio's diverse markets
• Limiting construction loan interest in eligible basis unnecessarily restricts technical tax credit determinations already subject to rigorous oversight by project accountants, syndicators, and tax counsel
• Clarifying that cash-to-seller restrictions should explicitly apply only to transactions involving limited OHFA resources (9% OLIHTC, HDAP) to prevent confusion in 4% transactions

OHC recommends removing the dollar threshold from underwriting guidelines and addressing rehabilitation scope through OHFA's Design and Architectural Standards revision process, which provides the appropriate framework for establishing nuanced, market-appropriate physical requirements while preserving OHFA's authority to address disproportionate developer fees.

OHC's Letter to OHFA