HOME/HTF Affordability Period Differs from OZ Investment Period
HOME- and HTF-assisted projects have long-term affordability provisions that need to be effectively communicated to investors. The term of the affordability period associated with projects that receive HOME funds is 20 years for new rental construction, and can be 5, 10, or 15 years for rental rehabilitation projects. The affordability period is always 30 years for HTF projects. When HOME- or HTF-funded housing fails to house income-eligible tenants at affordable rents for the full affordability period, grantees are subject to repayment of funds.
OZ investors seeking to maximize their financial return typically invest in projects for a period of 7 to 10 years. If an investor requires the maximum financial return, they may seek a viable exit strategy that includes the financial restructuring of the project at a period consistent with the objectives of the investor. Any restructuring that puts the property at risk of failing to meet the HOME or HTF affordability requirements—or failing outright-—could leave the grantee in a position of repaying HOME funds. Investors need to understand that the HOME and HTF long-term affordability requirements are not negotiable.
Grantees may be able to identify projects where the affordability period matches the investment period or may be able to structure projects to limit the affordability period. The affordability period for HOME rehabilitation projects is based on the per-unit HOME investment. Projects that require only modest rehabilitation, or projects that are able to secure additional funding to reduce the HOME per unit investment below $40,000 per unit, will carry a shorter affordability period (10 years or shorter) that coincides with the OZ investment period.
Note that some OZ investors and QOFs may shy away from investing in HOME- and/or HTF-assisted projects that require low-income housing compliance periods that extend for periods greater than the period of investment that is required for an OZ investment.