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Maryland Department of Housing and Community Development

Notice 26-17: Definition of Complete Application for DDA/QCT Expiration

Community Development Administration Update |

To ensure administrative clarity and compliance with the HUD Statutorily Mandated Designations for Difficult Development Areas (DDA) and Qualified Census Tracts (QCT), the Maryland Department of Housing and Community Development (DHCD) standard for defining the date of submission of a “complete application”, for the purposes of locking in DDA or QCT status for the 730-day safe harbor, shall be defined and documented as follows:

  • A “complete application” means “no more than de minimis clarification of the application is required for the agency to make a decision about the allocation of tax credits or issuance of bonds requested in the application.”
  • For a competitive application for 9% LIHTC, the date of submission of a “complete application” will be the application deadline for the round.
  • For a non-competitive application for 4% LIHTC without an expiring DDA/QCT, the date of submission of a “complete application” will be the threshold review approval date. The threshold review approval is determined by DHCD staff. It is explicitly noted that this date may be later than the date of initial submission of the application.
  • For a non-competitive application for 4% LIHTC with an expiring DDA/QCT, the date of submission of a “complete application” will be the later of the threshold review approval date or the date the applicant submitted the abridged “Part 1: Application and Certifications Category”, whichever occurs before December 31st of the year in which the DDA/QCT is set to expire. The threshold review approval is determined by DHCD staff. It is explicitly noted that this date may be later than the date of initial submission of the application.

The abridged “Part 1: Application and Certifications Category” submission is:

  • Form 202 
  • Bond Execution Certification
  • Full-Time Equivalent Job Calculator - Rental Housing Works applications only
  • Accountant AUP Report or Developer Certification of Basis Eligibility 
  • TEFRA Form 
  • Certifications
  • Threshold Checklist 
  • Applicant Self-Scoring 
  • Organizational Charts – current (if applicable) and proposed 
  • Application Fee Payment and Copy of Application Fee Check 
  • Application Fee Cover Sheet 
  • Timeline acceptable to CDA for submitting the remainder of the documents in the Application Submission Package

This definition ensures that:

  • DHCD has a clear definition of a “complete application” to mitigate the risk of federal audits or challenges regarding the 30% basis boost eligibility.
  • Ambiguity is eliminated for the applicant and DHCD when the 730-day clock begins.
  • A transparent, digital paper trail is left in Procorem.
  • DHCD remains in strict compliance with IRC Section 42 requirements.

 

This policy will be effective for all applications received on or after 12/01/2025.

 

Applicants will receive formal confirmation of the “complete application” date and corresponding DDA/QCT expiration date through a post in the Procorem portal.

 

DHCD has a 10-day application completeness review period for initial submission and re-submission. Applications submitted after December 1st are not guaranteed to be deemed complete prior to December 31st.