The Spring Street Brief

Episode 28: 25% PAB Threshold Takes Effect — States Implement New Rules


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The reduced private activity bond financing threshold—from 50% to 25% of aggregate basis—took effect January 1, 2026, unlocking significant additional 4% LIHTC production capacity.

What Changed:

  • Previous threshold: 50% of aggregate basis in bond financing required
  • New threshold: Only 25% bond financing needed for 4% LIHTC eligibility
  • Result: Less bond volume cap consumed per project
  • Impact: States can finance more deals with same allocation

State Implementation Approaches:

  • California: Encouraging return of unused 2025 PAB allocations for redeployment
  • Colorado: Phasing in threshold, starting at 45% upper limit for 2026 rounds
  • Other states: Updating QAPs and application materials

Developer Implications:

  • Acquisition-rehab deals can proceed with smaller bond issuances
  • Improved project economics through reduced debt service
  • New opportunities in bond-constrained states
  • Work closely with bond counsel on state-specific requirements

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The Spring Street BriefBy Spring Street Management Group