Episode 103: Missouri MHDC Opens Public Comment on 2028 QAP

The Missouri Housing Development Commission (MHDC) has opened a public comment period to gather input on topics under consideration for its 2028 Qualified Allocation Plan (QAP). With this window opening nearly two years ahead of the plan's effective year, developers, syndicators, lenders, and investors active in Missouri have an early and meaningful opportunity to influence how LIHTC and MHDC resources will be allocated — before internal drafts are even in circulation. Key Takeaways: MHDC governs allocation of both 9% and 4% LIHTC through its annual QAP and associated Notice of Funding Availability (NOFA). The comment period targets the 2028 QAP — opening approximately two years ahead of the plan's effective year, which is earlier than many peer state HFAs. Written comments can be submitted directly to MHDC and are formally incorporated into the QAP development process. Key policy levers subject to change include scoring criteria, basis limits, income targeting requirements, set-aside categories, and developer fee structures. Early input — submitted before internal drafts are circulated — typically carries more influence than comments on a published draft. Missouri is one of the more active Midwest HFAs; QAP changes have direct implications for project feasibility and investor returns across the state's deal pipeline. Stakeholders with views on rural vs. urban prioritization, income averaging, deeper affordability scoring, or basis boost policy should act now. Missouri's decision to solicit feedback this early signals that MHDC intends a deliberate, stakeholder-informed process for the 2028 cycle. For organizations with Missouri projects in development or under evaluation, this is the moment to engage — not after a draft is released. Monitor MHDC communications for draft publication timelines and plan your comment strategy accordingly. Subscribe to The Spring Street Brief for daily updates on affordable housing in America.