Thank you for accepting comments on the second draft of the proposed administrative rules and second draft of the proposed QAP for the new Single-Family Tax Credit. We are grateful that Governor DeWine, the Legislature, and OHFA are working to create more attainable homeownership opportunities in Ohio.

We Deeply Appreciate the Following Revisions

• The Tax Credit can now be used as a development subsidy.

As you know from GOPC’s previous comments, we were concerned that the first draft of the SFTC rules and QAP would not work in most communities outside of Central Ohio due to the systemic appraisal gap many neighborhoods face.

We greatly appreciate the revisions to the rules and QAP that now allow for the STFC to be used as an affordability subsidy and development subsidy.

Thank you for listening to our concerns and making these revisions.

• There is now a lower minimum number of units in the urban and suburban geographies.

In our previous comments, we were concerned that a minimum of twenty units in urban and suburban settings would limit interest in the first iteration of this brand-new tax credit program.

We thank you for revising the minimum threshold to five units for all geographies.

Suggested Changes to the Second Draft of Rules and QAP

The second draft of the rules and QAP include provisions that were not part of the first drafts or contain elements that we still have concerns with. We have itemized those below.

• “Qualified Buyer” definition is too restrictive.

In Rule 175-12-01(S), the 80% AMI floor for qualified buyers is too restrictive. There are other safeguards, including financial counseling, built into the definition and in other program requirements. Local banks in parts of Ohio will loan to buyers who earn less than 80% AMI. We recommend dropping this requirement.

• Homebuyer Education requirement

In Rule 175-12-01(S), OHFA rightly requires prospective homebuyers to attend and receive homebuyer education. We recommend OHFA provide reimbursement for the homebuyer education cost for qualified buyers that purchase a SFTC home. OHFA currently pays counseling providers $75 per client that purchases a home. A similar reimbursement would help ensure the success of the SFTC.

• “Rehabilitation” definition does not need to require properties to be in Qualified Census Tracts.

In Rule 175-12-01 (U), requiring SFTC properties that will be rehabbed to be blighted is sufficient; most blighted homes that will use the SFTC are likely located in a QCT. Asking applicants to prove the property is in a QCT seems like an unnecessary application question. We recommend dropping it.

• “Vacant” definition is too vague.

in Rule 175-12-01(Z), the current definition of “vacant” includes a timeframe but does not specify when the clock starts for that “one year”. We suggest removing this definition and reference to vacant properties within the program rules and slightly expanding the definition of “blight”.

• Home warranty requirements are too onerous.

The home warranty requirements [(A) 2 on page 7 of the QAP] are out of step with industry standards, which is typically a 1-year. Onerous warranty requirements may reduce developer interest in the SFTC. We recommend revising the warranty requirement to 1-year.

• Phase I and Phase II Environmental Site Assessment are unnecessary.

Requiring a Phase I Assessment [(A) 14 on page 10 of the QAP] would be atypical for single family housing projects and increases costs unnecessarily. We recommend dropping this requirement.

• Local Government Support Letter is unnecessary if a municipality or limited home rule township is the project sponsor.

Regarding provision A (23) in the QAP (page 12): Project sponsors that have home rule authority (e.g. municipalities) or limited home rule authority (e.g. limited home rule townships) have clear self-government powers, which includes authority over development. Municipalities and limited home rule townships that are project sponsors, should not need support from the county or other local government.

If the project sponsor is another type of eligible local government—like a county, regional planning commission, CIC, land bank, port or economic development corporation—then yes, the project sponsor should secure a letter of support from the municipality or township in which the project will be located.

• Developer Fee is too low.

The $10,000 cap [II (C) on page 14 of QAP] will not sufficiently cover staff costs, even of non-profit project sponsors or development partners. We recommend changing this to 10% or 15% of the total project cost, which is in-line with other development funding programs.

Thank you for your continued consideration of these suggestions. We have the same goals as you—affordable homeownership and quality housing throughout the state.