LIHTC Market Study Requirements in District of Columbia

The agency & primary document

Allocating agency

DC Department of Housing and Community Development (DHCD) — QAP / 9% allocation; DCHFA handles 4% / bond underwriting

QAP / guidelines

https://dhcd.dc.gov/page/low-income-housing-tax-credit-lihtc-program

Governing document

FY2026 Consolidated RFP, Threshold Eligibility Requirements (§VI) — the operational market-study rule; the DHCD QAP is the governing federal plan

Methodology

NCHMA Model Content Standards

Required market study sections

District of Columbia market studies follow the NCHMA Model Content Standards. The required sections are:

• Executive Summary — Concise summary of each section including data, analysis, and conclusions. 11 minimum content items including feasibility opinion, strengths/weaknesses, absorption estimate.
• Introduction and Scope of Work — Purpose, intended use, intended users, scope of work, effective date, physical inspection date.
• Project Description — Unit mix, utilities, target market, unit and community amenities, construction date. If rehab: scope of work, existing rents and vacancies.
• Location — Site description, site photos/maps, community services map, neighborhood evaluation (visibility, accessibility, crime).
• Market Area Definition — PMA description and rationale, PMA map. Extended/secondary market area if applicable.
• Employment and Economy — Employment trends, employment by sector, unemployment rates, major employers and proximity, planned expansions/reductions.
• Demographic Characteristics — Population and household estimates/projections, building permits, household characteristics (income, tenure, size). Senior/special needs: target-market data.
• Competitive Environment — Comparable profiles and photos, map of comps, vacancy and rents analysis, subject comparison, affordable housing alternatives, pipeline projects.
• Affordability Analysis, Demand Analysis, Capture Rates, and Penetration Rates — Demand estimate, affordability analysis, capture rate, penetration rate.
• Local Perspective of Rental Housing Market and Housing Alternatives — NEW in MCS 3.1 (September 2025). Local market context and housing alternatives beyond standard comparable analysis.
• Analysis / Conclusions — Absorption rate and lease-up timeline, market feasibility statement, strengths and weaknesses, key conclusions reconciling any conflicting indicators, recommendations if any.
• Other Requirements — Analyst qualifications, data sources, physical inspection date, limiting conditions, signed certification.

Key District of Columbia rules

District of Columbia-specific overlays

• Analyst must be NCHMA-accredited with affordable-housing experience in the District of Columbia
• Subject-property characteristics in the study must be identical to the proposed Project
• Study must consider/address the post-pandemic increase in economic vacancy in DC
• Mixed-income / mixed-use projects must demonstrate demand for ALL components
• PSH: DHCD has sufficient evidence of need; the study need not formally address it
• Must comply with IRC §42(m)(1)(A)(iii)

Required companion documents

• Appraisal (≤120 days old at closing)
• Form 202 (sources & uses, development budget, pro forma operating budget)
• Phase I Environmental Site Assessment (≤2 years at application; ≤1 year for selected projects)
• DCHFA underwriting standards (all 4% LIHTC / tax-exempt bond projects)

Things analysts miss in District of Columbia

• Two-agency split: DHCD = QAP / 9% allocation + market-study threshold rule; DCHFA = 4% / bond underwriting
• The market-study rule is in the FY2026 Consolidated RFP (Threshold Eligibility, p.28), not a separate appendix

Frequently asked questions

Who reviews LIHTC market studies in District of Columbia?

DC Department of Housing and Community Development (DHCD) — QAP / 9% allocation; DCHFA handles 4% / bond underwriting sets the market study requirements and reviews submissions for District of Columbia Low-Income Housing Tax Credit applications.

How current must a District of Columbia LIHTC market study be?

Completed no more than 6 months prior to the RFP application deadline

Does District of Columbia follow NCHMA standards?

District of Columbia market studies follow the NCHMA Model Content Standards section structure — NCHMA-deferring. The RFP requires the study to 'adhere to the current NCHMA Model Content Standards'; no DC-specific numeric thresholds..

Other states

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This summary is for general reference and reflects DC Department of Housing and Community Development (DHCD) — QAP / 9% allocation; DCHFA handles 4% / bond underwriting's published guidance as understood by StudyScribe; it is not legal or compliance advice. Always confirm requirements against the current QAP / market study guidelines before submission.