LIHTC permanent loans and forward commitments compared
A LIHTC permanent loan is sized to restricted-rent income at a coverage ratio and usually locked years ahead through a forward commitment, so the developer knows the takeout before construction starts. The main sources are Freddie Mac's Targeted Affordable Housing loans (including the Tax-Exempt Loan), Fannie Mae's Multifamily Affordable Housing executions (including M.TEB and unfunded forwards), FHA-insured 221(d)(4), 223(f) and 223(a)(7) loans, USDA Section 538 guarantees, and bank or CDFI loans, with FHLB AHP subsidy as a common add-on.
The permanent loan is the one piece of a tax credit stack that pays interest for decades, so its size sets how much soft money the deal needs. And because it is usually committed before construction, its terms ripple back into the construction loan, the equity pay-in and the bond structure.
How every lender sizes it
All of these programs land on the same arithmetic, with different limits:
- Underwritten NOI at the lower of restricted rents (after utility allowances) and market rents, less vacancy, operating expenses, replacement reserves and any lender-required items.
- Coverage: maximum annual debt service = NOI / minimum DSCR.
- Loan constant from the locked rate and amortization period turns that payment into a loan amount.
- Caps: loan-to-value, loan-to-cost, and for FHA and USDA, statutory per-unit limits.
- The lowest result wins.
The supportable debt calculator runs the first three steps. For FHA loans, add the mortgage insurance premium to the constant.
The comparison
Only terms read from the program’s own documents are in this table. Where a program’s sheet doesn’t publish a number, the cell says so.
| Program | What it finances | Verified terms | Source |
|---|---|---|---|
| Freddie Mac Tax-Exempt Loan (TEL), TAH | Stabilized 4% LIHTC acquisition or refinance, and forwards | Term up to 30 years; min DCR 1.15x; max LTV lower of 85% of adjusted value or 90% of market value; amortization up to 40 years; forward commitment term up to 48 months; subordinate financing allowed | TEL term sheet, 02/25 |
| Fannie Mae M.TEB | Fannie MBS used as collateral for tax-exempt bonds on 4% deals, new issues or refundings | Term 10 to 30 years; amortization 35 years; max LTV 90% (at least 90% of units affordable), 85% (fewer) or 80% (refundings); min DSCR 1.15x or 1.20x; yield maintenance or declining premium; non-recourse. All Fannie MAH terms | M.TEB term sheet |
| Fannie Mae unfunded forward commitments (4% and 9%) | Rate-locked permanent loan funded at conversion; third party provides construction loan | 36-month lock plus one (9%) or up to two (4%) 6-month extensions; 1% good faith deposit; conversion at 90% occupancy for 90 days; term 10 to 30 years; amortization up to 35 years; 9%: 90% LTV, 1.15x DSCR. All Fannie MAH terms | 9% term sheet, 4% term sheet |
| FHA 221(d)(4) | New construction or substantial rehab, single close construction-to-permanent, non-recourse | MIP 25 bps for applications submitted or amended on or after Oct 1, 2025; statutory per-unit limits re-based by Pub. L. 119-101 sec. 211 | 90 FR 45789; Pub. L. 119-101 |
| FHA 223(f) | Acquisition or refinance of a stabilized property, including LIHTC resyndications with moderate rehab | MIP 25 bps for applications submitted or amended on or after Oct 1, 2025 | 90 FR 45789 |
| FHA 223(a)(7) | Streamlined refinance of an existing FHA-insured loan | Term up to 12 years beyond the unexpired term of the existing loan; documented as an amendment to the existing insurance contract; MIP 25 bps for applications submitted or amended on or after Oct 1, 2025 | 12 U.S.C. 1715n(a)(7); 90 FR 45789 |
| USDA Section 538 guaranteed | Rural rental housing; permanent loans, or construction-and-permanent | Guarantee up to 90% (Option One permanent); term 25 to 40 years (3565.209); loan up to 97% (nonprofit or public borrower) or 90% (other borrowers) of the lesser of development cost or value (3565.204); tenant income at move-in up to 115% of AMI; per-unit limits tied to National Housing Act 207(c) | 7 CFR Part 3565 |
| Bank or CDFI permanent loan | Smaller deals, rural deals, mixed-income, deals needing flexibility | Set by each lender | Lender term sheet |
| FHLB Affordable Housing Program (AHP) | Grant or subsidized-rate advance layered onto any of the above through a member bank | Each FHLBank contributes the greater of 10% of prior-year net earnings or its share of $100 million; rental: at least 20% of units for households at or below 50% AMI; 15-year retention period | 12 CFR Part 1291 |
Two 2026 changes affect the table. FHA’s mortgage insurance premium is now 25 basis points for all multifamily programs, for applications submitted or amended on or after October 1, 2025 that were not yet initially endorsed, down from tiered rates that ran as high as market-rate levels (90 FR 45789). And the 21st Century ROAD to Housing Act re-based FHA’s statutory per-unit limits and indexed them to a Census multifamily construction price index (Pub. L. 119-101 sec. 211, enacted July 11, 2026); check HUD’s implementing notice for the current dollar figures. Section 538’s per-unit cap points to the same 207(c) limits.
Forward commitments, step by step
- Application and early rate lock, usually at or before construction closing. The lender underwrites the completed, stabilized property.
- Deposit or fee. Lenders take a good-faith deposit and often a standby or commitment fee. Read the sheet for which part is refundable.
- Construction by a separate lender (or by the same lender on a construction-to-permanent forward).
- Conversion tests: completion, a period of sustained occupancy and DSCR at actual rents, final cost certification, and often evidence that Forms 8609 are issued or applied for.
- Outside date and extensions. Freddie Mac’s TEL forward runs up to 48 months; extensions usually cost a fee. If the property isn’t ready, the loan may fund at a reduced “rebalanced” amount sized to actual NOI.
The developer’s risk is the gap between the locked loan amount and the amount at conversion. If utility allowances, insurance or taxes come in higher than underwritten, NOI falls and so does the loan. The shortfall typically lands on the deferred developer fee.
Choosing between them
| If the deal… | Look first at |
|---|---|
| Is a 4% bond deal and you want one lender from construction through permanent | Freddie TEL forward, FHA 221(d)(4), or a bank drawdown bond that converts |
| Uses short-term cash-collateralized bonds to pass the bond test | A taxable GSE or FHA permanent loan, with the bonds redeemed at conversion |
| Is a stabilized resyndication | Freddie TEL, FHA 223(f), Fannie MAH |
| Already has an FHA-insured loan | 223(a)(7) to lower the rate without a new underwrite |
| Is rural and small | USDA 538, a CDFI, or a community bank |
| Needs a few hundred thousand dollars more subsidy | FHLB AHP through a member bank |
FHA timing and LIHTC
FHA-insured construction loans process under HUD’s MAP Guide, which runs longer than a GSE forward. That matters for a 9% deal racing a placed-in-service deadline and for 4% deals whose bond cap award expires. The HUD MAP Guide (Handbook 4430.G) is at hud.gov; read the current edition for LTV and coverage limits by loan type before modeling.
Section 8 and other contract rents
Where a property has project-based rental assistance, lenders underwrite to the contract rents, which can exceed LIHTC rent limits because Section 8 payments are excluded from LIHTC gross rent (IRC 42(g)(2)(B)(i)). Lenders also look at the contract’s remaining term. See LIHTC with RAD and Section 8.
Ready to price two or three executions on the same rent roll? The Janover Capital desk can run them side by side.
Questions people ask
What is a forward commitment on a LIHTC deal?
A permanent lender's commitment, made before construction, to fund a loan at a locked rate once the property is built and stabilized. The developer pays a fee or deposit for the lock. Construction lenders and investors rely on it as the takeout. If the property misses the conversion tests by the outside date, the commitment can expire or the loan can fund at a smaller amount.
Which is cheaper, an FHA loan or a GSE loan?
It depends on the deal. FHA-insured loans carry a mortgage insurance premium, a uniform 25 basis points for FHA multifamily applications submitted or amended on or after October 1, 2025 (90 FR 45789); loans already endorsed keep their MIP, and a longer processing path, but offer long fully amortizing non-recourse terms. GSE loans close faster and can be structured as tax-exempt executions. Price both on the same rent roll.
Can a LIHTC permanent loan be non-recourse?
Yes. GSE, FHA and USDA 538 permanent loans are generally non-recourse after conversion, with standard carve-outs for fraud, environmental issues and similar acts. Recourse during construction is a separate question.
Do Fannie Mae and Freddie Mac loans on LIHTC deals count against FHFA's caps?
FHFA set 2026 caps at $88 billion per Enterprise and requires at least 50% of each Enterprise's multifamily business to be mission-driven affordable. Workforce housing loans are excluded from the caps; other mission-driven loans count toward them. How a specific LIHTC loan is classified is set out in FHFA's 2026 cap definitions.