The agency & primary document
- Allocating agency
- New York State Homes and Community Renewal (HCR / DHCR / HTFC)
- QAP / guidelines
- https://hcr.ny.gov/qualified-allocation-plan-qap
- Governing document
- HCR Capital Programs Manual §5.07 — Underwriting Standards (Market Support of Project), August 2025 edition
- Methodology
- Agency-specific standalone methodology
Required market study sections
New York uses its own standalone market study methodology rather than the NCHMA Model Content Standards. Agency-specific methodology — HCR publishes its own Market Study Content Guidelines in Capital Programs Manual §5.07 (sections A–I). NCHMA is not the controlling standard. Market study must be prepared by a disinterested professional market analyst pre-qualified by HCR.
Key New York rules
- Staleness window
- 12 months prior to the application deadline (same staleness window as Phase I ESA per §2040.3(e)(9) of the QAP); HCR may request an update if market conditions have materially changed
- Capture-rate threshold
- Capture rates must be 20% or less for each targeted income limit by unit type AND for the total project; unmet demand must be more than 5 times the number of units proposed
- Rent-burden standard
- 35% of gross income for rent plus utilities (eligible households pay no more than 35%); 1.5 persons per bedroom assumed for maximum eligible household income
- Persons per bedroom
- 1.5 persons per bedroom (1 person for units without a separate bedroom) — prescribed for income eligibility calculation
New York-specific overlays
- Pre-qualified analyst list — comprehensive market studies must be prepared by a pre-qualified HCR analyst; studies from non-approved analysts will not be accepted
- Two-tier study requirement: LIHTC/SLIHC projects outside NYC require a full Comprehensive Market Study; NYC projects of any size require only a Market Analysis (prepared by applicant using NYC Rent Guidelines Board data)
- Senior projects: no more than 25% of income-eligible senior homeowners may be included in the demand pool
- Non-senior projects: 100% of income-eligible renter households included; homeowners may NOT be included as prospective tenants
- Capture rates calculated as 'net' capture rates accounting for existing affordable housing supply in arriving at unmet demand
- PMA boundary: applicants strongly encouraged to use entire census tracts or block groups; NYC projects should indicate Community Board
- Secondary Market Area (SMA) should NOT be used in capture rate calculations — demand must come from within the PMA
- In-migration: field not addressed in guidelines — apply professional judgment with documentation
- Household income breakdown must be in $5,000–$10,000 increments by household size and tenure (Census + current year + 5-year projection)
Required companion documents
- For NYC projects: market analysis utilizing data from the most current NYC Rent Guidelines Board Report (prepared by applicant, not an independent analyst)
- Separate map of PMA showing all existing regulated affordable housing built in the last 10 years (required in Section F of study)
Things analysts miss in New York
- Two-tier study type: LIHTC projects outside NYC require a Comprehensive Market Study (independent pre-qualified analyst); NYC projects require only a Market Analysis (prepared by the applicant using Rent Guidelines Board data) — the distinction is critical and affects who prepares the study
- HCR operates under three entity names (DHCR, HTFC, HCR) — all refer to the same agency for LIHTC purposes per QAP §2040.2(h) and (m)
- Market study requirements live in the Capital Programs Manual (CPM) §5.07, NOT in the QAP body — the QAP §2040.3(e)(9) references the study requirement but defers detailed content to the CPM
- Pre-qualified analyst list maintained on hcr.ny.gov — verify before engagement; list changes periodically
- Preservation projects must also submit an IPNA (Integrated Physical Needs Assessment); market study requirements apply in addition
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Start a free New York report →Frequently asked questions
Who reviews LIHTC market studies in New York?
New York State Homes and Community Renewal (HCR / DHCR / HTFC) sets the market study requirements and reviews submissions for New York Low-Income Housing Tax Credit applications.
How current must a New York LIHTC market study be?
12 months prior to the application deadline (same staleness window as Phase I ESA per §2040.3(e)(9) of the QAP); HCR may request an update if market conditions have materially changed
Does New York follow NCHMA standards?
Agency-specific methodology — HCR publishes its own Market Study Content Guidelines in Capital Programs Manual §5.07 (sections A–I). NCHMA is not the controlling standard. Market study must be prepared by a disinterested professional market analyst pre-qualified by HCR.
Is there a capture-rate threshold in New York?
Capture rates must be 20% or less for each targeted income limit by unit type AND for the total project; unmet demand must be more than 5 times the number of units proposed
Other states
This summary is for general reference and reflects New York State Homes and Community Renewal (HCR / DHCR / HTFC)'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.