Mark Shelburne's Avatar

Mark Shelburne

@housingmark

housing policy consultant, attorney (barely), dance dad, YIMBY, former LIHTC allocator, UNC-CH x3 alum & adjunct professor, sweet tea & hushpuppy connoisseur

409
Followers
107
Following
144
Posts
03.07.2023
Joined
Posts Following

Latest posts by Mark Shelburne @housingmark

I’m very much in support of consolidating funding sources and actually have done it professionally.

That said, four is not really a challenge:
-federal LIHTC equity
-bank loan
-deferred fee
-local $, state LIHTC, etc.

Market rate deals are not that different.

17.01.2026 19:35 πŸ‘ 1 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

How about that! I probably shouldn’t say that most of them would be at least a bit outside what’s relevant for PRRAC… All of my recordings of course are spot on.
πŸ˜‰

17.01.2026 19:29 πŸ‘ 1 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

Admittedly I’m too ADD to read the whole article, especially on my phone.

Hopefully the author acknowledges the trade-off between rent levels and production. As in CA could make units more affordable, at the cost of creating fewer of them.

Unfortunately there are no right answers, only choices.

10.01.2026 13:38 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

Many people have that view, which is why I responded: they are either
β€’ not comparing it to anything, or
β€’ doing so in an entirely unbalanced manner.

Enough people being wrong doesn’t make them right.

29.12.2025 21:49 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

No, I’m not aware of any such study, which is why I don’t make accusations about inefficiency.

29.12.2025 19:39 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

My firm is one of those costs, so yes, I would include it.

29.12.2025 18:48 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

Yes, MoCo and the Center for Public Enterprise are great. I’ve actively supported them in several ways.

29.12.2025 18:41 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

So you weren’t already including those costs in your partial claim? Speaking of, as compared to what?

Or we can just skip to the fact that pretty much all such comparisons ignore the administrative costs of appropriations, inaccurately making them look better.

29.12.2025 18:40 πŸ‘ 0 πŸ” 0 πŸ’¬ 2 πŸ“Œ 0

Inefficient as compared to what? Before answering, consider the relative number of federal, state, and local employees tasked with administering it versus other programs.

29.12.2025 17:53 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0
More than Half of LIHTC Households Earn 30% AMI or Below Per New HUD LIHTC Tenant Data The August 2023 release of low-income housing tax credit (LIHTC) tenant data from the U.S. Department of Housing and Urban Development (HUD) further proves that the incentive continues to assist the m...

No comment on the candidate, but you’re wrong about the LIHTC:
www.novoco.com/notes-from-n...

29.12.2025 17:50 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0
New LIHTC Research Refutes Common Misconceptions of the Program Blog article addressing criticisms of the LIHTC program, citing new research data in,

I won’t defend the Code’s basis boost approach, but there’s more to the data:
www.novoco.com/notes-from-n...

07.12.2025 20:11 πŸ‘ 1 πŸ” 1 πŸ’¬ 1 πŸ“Œ 0

Accelerated depreciation would increase an investor’s return, allowing higher pricing.

The two conflict only in history, that one came into existence because Regan killed the other.

15.10.2025 15:54 πŸ‘ 2 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

Good. Those who critique the LIHTC often wrongly presume a need to eliminate it to achieve their desired approach. Glad that doesn’t describe you.

15.10.2025 15:23 πŸ‘ 2 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0
More than Half of LIHTC Households Earn 30% AMI or Below Per New HUD LIHTC Tenant Data The August 2023 release of low-income housing tax credit (LIHTC) tenant data from the U.S. Department of Housing and Urban Development (HUD) further proves that the incentive continues to assist the m...

What these β€œgood ol’ days” comparisons never mention:
β€’ the two tax treatments are not inherently mutually exclusive (we could have both);
β€’ affordability results of accelerated depreciation.

On the latter:
www.novoco.com/notes-from-n...

15.10.2025 14:38 πŸ‘ 1 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

In my experience most agencies are agnostic about mixed use. The real difficulties and challenges come from the debt and equity providers who aren’t comfortable underwriting the two different kinds of income streams.

26.09.2025 16:12 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

My understanding is every LIHTC project in CA involves a nonprofit developer so as to receive a property tax exemption. I’m sure many are joint ventures with for profits.

20.09.2025 11:25 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

The second one supports my point (look forward to using it).

06.09.2025 12:49 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

That was an interesting report, but I don’t recall it supporting the statement above.

06.09.2025 12:47 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

I’ve yet to see anyone actually substantiate this claim.

06.09.2025 11:39 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

The most important point is they are not alternatives, we need both. I’d argue the efficiency aspect, plus add that vouchers don’t add to production.

31.08.2025 19:18 πŸ‘ 1 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

Only if there’s some unique expectation to do so under a local program.

31.08.2025 19:12 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

An example so unique as to be newsworthy is not doing much to support β€œrarely ends well.” Exclusionary zoning needs to end so supply can meet demand.

31.08.2025 19:06 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

No one is kicked out of LIHTC housing for being over income. In fact, unlike with vouchers, your rent doesn’t even go up as your pay/salary increases.

31.08.2025 19:03 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

They’d be even more oversubscribed without the incentives to secure gap funding.

Creating a social housing developer/program would be a great addition to our current system. Many jurisdiction, especially in California, would benefit from adopting the Center for Public Enterprise model.

23.08.2025 23:30 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

I genuinely don’t understand the frustration with certain professionals’ positive reaction (was a whole ShelterForce article). The new provisions will create more than a million affordable units over the next decade. That’s good, right?

(Yes, of course the rest of the bill is terrible.)

25.07.2025 18:17 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0
Localities’ Interaction with the LIHTC: Benefits and Context (post 1 of 4) Welcome to the first in a series of blogs explaining how local governments interact with the federal low-income housing tax credit (LIHTC).

If it helps you’re welcome to use content from my blog post series:
www.novoco.com/notes-from-n...

20.07.2025 21:24 πŸ‘ 1 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0
QAP Drafting Considerations (post 9 of 10) When drafting qualified allocation plans (QAPs) two general concepts should guide the way: 1) Keep everything as brief as possible. 2) Remember that QAPs are effectively an extension of Internal Reven...

The field guide (not something I worked on) was meant to help. My understanding is it being well received. However, repeating rules does go against my advice to agencies:
www.novoco.com/notes-from-n...

13.07.2025 19:39 πŸ‘ 1 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

Huh, that was indeed after my time. I remember there being a problem with some kind of A/C unit back in the early 2000s.

13.07.2025 19:36 πŸ‘ 0 πŸ” 0 πŸ’¬ 0 πŸ“Œ 0

I don’t remember the story behind the A/C unit rules, other than we wrote them at least a dozen years ago. Maybe something has changed since then. Odds are they were, like most of the standards, in response to a developer trying to do something questionable.

Yes, those sizes are fairly small here.

13.07.2025 18:52 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0

I don’t have much, or maybe any debate with what you’re saying.

However, in the specific instance of the items mentioned above, the way to make a change for next year is to submit a QAP comment. Can be as simple as it is here, just copy/paste.

Understood that’s not a theoretical ideal.

13.07.2025 13:44 πŸ‘ 0 πŸ” 0 πŸ’¬ 1 πŸ“Œ 0