Hawaii's 2027 LIHTC round: what's published, what isn't, and the FY 2027 trap
HHFDC has released nothing about a 2027 Consolidated Application round, and its board was told in July that QAP revisions now underway land in 2028. The "FY 2027 Consolidated Application" currently open is a different program. Here is the actual state of play, and what to do with the gap.
If you are sizing up a Hawaii deal for next year’s Consolidated Application round, the useful thing to know today is what has not happened. As of October 8, 2026, HHFDC has published no 2027 Qualified Allocation Plan in draft or final, no 2027 ConApp page, no round schedule, and no public hearing notice. The Housing Developers index has moved the 2026 round under an “FY 2026 Archive” heading, and the QAP landing page still carries a process timeline last updated August 14, 2025.
That silence is worth reading carefully, because one piece of it is on the record and points somewhere specific.
The FY 2027 application that is open is not the round you want
Search for “HHFDC 2027 Consolidated Application” and you will land on a live page marked AVAILABLE NOW, describing the “FY 2027 Consolidated Application release,” with a rolling round that opened July 1, 2026 and closes at 12:00 p.m. HST on December 31, 2026.
That is the Mixed Income Rental Program. It is not the competitive LIHTC round, and the two have almost nothing in common.
| Annual ConApp round | MIRP | |
|---|---|---|
| Programs | 9% and 4% LIHTC, HMMF bonds, RHRF | RHRF Mixed-Income Subaccount only |
| Product | Credits, bonds, loans and grants | Construction and permanent loans only |
| Timing | Competitive, opens mid-December | Rolling, July 1 to December 31, 2026 |
| Scoring | QAP 118 points (9%), HAR 15-312 50 points (HMMF), HAR 15-311 250 points (RHRF) | A separate 10-point sheet |
| Affordability | LIHTC rules, 45-year minimum under the 2026 QAP | 20%+ of units at or below 140% AMI, 30 years minimum |
| Max request | Program-dependent | $25 million unless HHFDC approves otherwise |
MIRP came out of Act 159 (SLH 2025), with Act 250 (SLH 2025) appropriating $50 million for FY2026 and $50 million for FY2027. Its scoring is its own animal: depth of affordability 2 points, length of affordability 1, state or county land 1, efficient use of state resources 2, sponsor equity 1, loan structure 1, readiness 1, transit-oriented density 1. A self-score at 7.5 to 10 goes to the board immediately; 5.5 to 7 sits on a three-month hold; 5 or below waits until the round closes. There is a $2,000 RHRF application fee, and HHFDC targets a completeness review within 30 calendar days.
It is also making awards right now — the October 8, 2026 board agenda carried MIRP items for Cardinal O Waikiki and Lipoa Apartments in Kihei. If a project pencils at 140% AMI and wants loans rather than credits, this is an open door for another eleven weeks. It just is not the round most developers mean when they say “the ConApp.”
What the board actually said about the QAP
On August 13, 2026 the board approved forming a Permitted Interaction Group to update the Qualified Allocation Plan and review the award process and criteria — Chair Grant Chun, Vice Chair Susan Kunz, Director Scott Glenn and Director Seth Colby. The minutes record its purpose as updating the QAP for the 2028 funding round.
The reason is procedural and was spelled out a month earlier. At the July 9, 2026 meeting, Vice Chair Kunz was told directly that starting a PIG then “would target the 2028 funding round, not 2027,” because amending the QAP requires at least two 30-day public notice periods. The 2026 cycle bears that out: an ideas memo on January 24, 2025, working group meetings on February 21 and 28, a hearing notice in late June, a hybrid public hearing on July 30, written testimony, board approval, and a final QAP dated November 14, 2025 — roughly eleven months from memo to a round opening on December 19.
Nothing equivalent happened in 2026. There was no ideas memo, no working group, no hearing notice. No board agenda from January through October 2026 contains an item on a 2027 QAP or a 2027 funding round.
So what governs a 2027 round?
HHFDC has not said, and this is the open question a developer should actually be asking.
The 2026 QAP states on its face that it governs reservations and awards for calendar year 2026. If a 2027 round runs, it needs something: a light-touch 2027 QAP, a board action extending the 2026 document, or a combined plan. There is precedent for the last of these — HHFDC once issued a single 2022–2023 Qualified Allocation Plan. None of those paths has been announced.
What the historical pattern supports is narrower than people assume. Two data points, both confirmed:
| Round | Opens | Final deadline |
|---|---|---|
| 2025 | December 13, 2024 | February 14, 2025 |
| 2026 | December 19, 2025, 2:00 p.m. | February 20, 2026, 2:00 p.m. |
Awards in both years landed June through August. The 2026 round added a Letter of Intent deadline of January 16, 2026 and mandatory Procorem training on January 21 — but those two intervals are confirmed for 2026 only. The 2024 round’s dates are not published in a form I could verify, so the “mid-December open, late-February close” pattern rests on two years, not a tradition.
Plan against mid-December. Do not plan against a date.
The thing that already changed, and nobody called it by name
While the QAP sat still, one requirement moved — and it is in force now.
The 2026 Reference Guide sets an HMMF bond threshold requiring an applicant to demonstrate that no more than thirty percent of the aggregate basis of the building and land is financed, directly or indirectly, with tax-exempt obligations. Applications exceeding 30% “will not be considered for the HMMF Bond Program.”
That is a response to OBBBA’s cut of the 4% bond financing test from 50% to 25% of aggregate basis. Seven states adopted and two drafted initial allocations in the 27.5%–30% range, matching the Affordable Housing Tax Credit Coalition’s recommendation, so Hawaii’s number sits squarely in the national band.
Two things about it are worth flagging. First, HHFDC never says so. The words OBBBA, One Big Beautiful Bill Act, H.R. 1, §42(h)(4) and “25% test” appear nowhere in the Reference Guide, the 2026 QAP, the 2026 board agendas and minutes, or the Finance Branch reports. The policy is there; the framing is inference. Hawaii also does not appear in the national survey of state responses, because the 30% cap arrived quietly inside a December 2025 reference document rather than as an announced rule.
Second, and more consequentially, HHFDC’s 30% is a hard ceiling that disqualifies, while most peer states treat 27.5–30% as an initial allocation with discretion to go higher where debt supports it. That is a materially more restrictive posture, and the reason is in the balance sheet.
The numbers that should set your expectations
This is where the 2026 round earns its reputation. From HHFDC’s own exhibits, as of September 30, 2026:
| Resource | Position |
|---|---|
| Private activity bond cap | Oversubscribed by $174,934,496 — $436.1M available against $611.0M of HMMF commitments pending issuance |
| RHRF, net | $(24,965,829) — the base program at $(57.7M), offset by MIRP’s +$32.8M |
| DURF, net available | $14,879,840 |
| HMMF uncommitted bond authority | $235,111,793 of a $3 billion program authority |
The PAB figure is the one to sit with. In the January 31, 2026 snapshot the cap was oversubscribed by $78.4 million. By September 30 that had grown to $174.9 million. It more than doubled over a single year, and that is before the 25% test’s effect on demand fully works through. A hard 30% ceiling on bond sizing is what a state does when it is rationing, not optimizing.
On the competitive side, the 2026 round took in 35 Consolidated Applications covering 4,092 affordable units across four counties. Read that number carefully: the ledger lists one project three ways and four projects twice as paired 4% and 9% submissions, so 35 is applications, not distinct projects — the real count is closer to 29 or 30.
The 9% competition is the cleanest arithmetic in Hawaii affordable housing:
| Applications | 8 (6 new construction, 2 rehabilitation) |
| Federal credits requested | $12,956,202 |
| Available, including 2025 rollover | $7,383,369 |
| Funded | 4 projects, 142 units |
| Credits awarded | $7,112,539 federal, matched by state |
| Remaining volume cap | $270,830 |
The four: Pua Lane Family Affordable (Oahu, 63 units, ranked first), Puuhona Phase III (Maui, 22), 614 Wailepo (Oahu, 37), and Kemole Lane Apartments (Oahu, 20). All four carried the nonprofit set-aside. The motion carried unanimously.
Half the 9% applicants were funded, and 142 units were awarded against roughly 4,092 affordable units that applied across all programs.
One more pattern, visible in the award minutes and useful when you build your sources and uses: HHFDC negotiates RHRF asks down at the award stage. Pua Lane went from $6.6M requested to $6,075,492 awarded; 614 Wailepo from $6.8M to $5,144,364 — both at 0.5% interest with cash flow payments raised to 85%. Hoomalu at Waikoloa went $45M to $44.5M; Hanapepe Phase 2 from $7M to $5.9M. Roughly a quarter off the smaller asks. Underwriting your RHRF request as though you will receive it in full is optimistic.
What to do with the gap
The absence of a 2027 QAP is not a reason to wait. It is close to the opposite: whatever governs the next round will look much more like the 2026 QAP than like whatever emerges for 2028.
Build the schedule backward from the staleness windows. The 2026 thresholds are where the calendar actually binds, and three of them expire:
- Market study by a disinterested HHFDC-approved party, dated within 6 months
- Phase I Environmental Site Assessment within 1 year of the deadline, plus the ConApp Environmental Questionnaire
- Preliminary engineering report or capital needs assessment completed within 1 year of the application date — new in 2026
Commission those too early and you pay twice. Against a mid-December open and a late-February deadline, a market study ordered before roughly September is a wasted invoice.
Treat readiness as the scoring event it is. Criterion 4 carries 24 of 118 points — the single largest block, more than development cost reasonableness at 12 — split across schedule, discretionary approvals and ministerial approvals. HHFDC weights it that way because carryover requires at least 10% of eligible costs paid within one year of award. Readiness is deliberately not a threshold; staff removed an earlier readiness threshold as too subjective. It is where a deal is won.
Know that cost scoring is relative. Criterion 3 is scored against the other applications in that round, not a fixed benchmark. With typical 9% volume at five to eight projects, your cost position depends on who else files.
Watch the thresholds that newly disqualify. The 2026 QAP added contractor profit including payment and performance bond costs within the 14% cap on hard costs; a prohibited-fees threshold aimed at developer personal-guarantee fees; management units counted in the 9% maximum developer fee calculation; and a provision letting HHFDC find an applicant or management agent ineligible for poor performance on an existing project, such as missed quarterly reports. Any one of them is a pass/fail rejection.
Do not route Hawaii Builds through the ConApp. Act 216 (SLH 2026), from SB 2544, establishes no application round at all. The statute says the board “shall designate specific projects,” with at least one pilot project per county, and related contracts are exempt from chapter 103D procurement. It is already running — the October 8, 2026 agenda carried approval of the Kapolei Workforce Housing Project as a Hawaii Builds pilot. The route in is board designation. Note also that the statute caps use at “not more than $20,000,000 each fiscal year” from DURF; the widely reported $100 million is five years of that maximum, not an appropriation, and HHFDC’s own exhibits put net available DURF at $14.9 million as of September 30, 2026.
Where this will show up first
Based on the 2026 cycle, the first public signal of a 2027 round would be a board agenda item authorizing the application cycle — the FY2027 MIRP round was authorized that way on June 18, 2026, item III.D. Agendas post at dbedt.hawaii.gov/hhfdc/meetings. A QAP amendment, if one comes, requires those two 30-day notice periods, so it cannot arrive quietly.
Two further notes for anyone reconciling numbers. The official Project Awards archive still has no 2026 entry; its most recent is the 2025 round. The 2026 awards exist only in board agendas, minutes and Finance Branch reports. And the 2026 round is still making awards — the September 10 meeting approved Hula Mae resolutions and reservations for Hoonanea Phase I at Hoopili Gateway, Hoola at Palamanui and Kaiaulu O Kapiolani, and October 8 took up an amended structure for Hoomalu at Waikoloa plus a reservation for Olohana. Any 4%/HMMF/RHRF total you see for 2026 is provisional.
Three questions are worth a call to the Finance Branch at (808) 587-0620: whether a 2027 LIHTC round will run and under which QAP; the application fee schedule, which is published nowhere I could find; and whether the 30% HMMF cap is HHFDC’s OBBBA response and whether it will be revisited.
Figures here come from HHFDC’s published agendas, minutes, exhibits and program documents as of October 8, 2026, and the round is ongoing. Where HHFDC’s own documents disagree — the 2026 volume cap appears as both $7,428,891 and $7,383,369, and the QAP criteria total as both 117 and 118 — this article uses the figure HHFDC staff cite publicly and the later exhibit. Verify against the source documents before relying on any of it, and treat nothing here as legal or tax advice.
Primary sources
- HHFDC — Consolidated Application for Financing 2026 (still the current round page)
- HHFDC — Consolidated Application for the Mixed Income Rental Program (the FY 2027 round that is open)
- HHFDC Board — minutes of July 9, 2026 (QAP timing, 9% awards, criteria discussion)
- HHFDC Board — minutes of August 13, 2026 (PIG formed to update the QAP for the 2028 round)
- HHFDC — 2026 Qualified Allocation Plan (final, November 14, 2025)
- HHFDC — 2026 Reference Guide (HMMF and RHRF thresholds and criteria)
- HHFDC — 2026 funding round applicant list (35 applications, 4,092 affordable units)
- HHFDC — Program Resources exhibit, as of September 30, 2026 (PAB, RHRF, DURF balances)
- HHFDC Finance Branch status report, September 10, 2026
- SB 2544 CD1 — Hawaii Builds, enacted as Act 216, SLH 2026