Rethinking year 15 : what determines the terminal valuation of LIHTC financed transactions?

Abstract

The Low Income Housing Tax Credit (LIHTC) program is one of the most successful government subsidy programs for the creation of affordable housing in the history of the United States. Over its 27 year existence, more than two million affordable apartments have been developed or rehabilitated using private equity financing through the sale of federal tax credits. Over the past 12 years the industry has digested the first wave of transactions getting to the end of the 15 year Initial Compliance Period. This is the point at which the Investor Limited Partner (ILP) is able to exit the transaction without tax credit recapture risk with the IRS. There is often a recapitalization event that accompanies the exit, but many times there is not. Since the secondary market for both LP and GP interests both during and after the compliance period is relatively illiquid, it is difficult to discern the fair market value of such an asset. This is further complicated by the unique and multi-layered financing structures common in these transactions and the additional 15-year Extended Use Period requiring the property to remain as affordable housing, in many cases beyond its useful life. This study will use limited partner transaction disposition data provided by a national tax credit syndicator to create a hedonic pricing model to determine the factors that drive valuation at disposition. Using the sample of 223 observations, the characteristics of which closely resemble the population of dispositions industry wide, the resultant hedonic model suggests that a partnership's original total development cost, net operating income (NOI) at disposition, cash or reserve balances on hand at disposition, the strength of the rental market and whether affordability requirements are expiring are the driving forces behind valuation of ILP interests at Year 15. As expected, some common factors that drive valuation in conventionally financed multi-family real estate transactions, including transaction size and regional location, have little predictive impact on valuation as determined by the model. The results of the analysis are contained within, along with the policy implications and some suggested programmatic reforms that could help to enhance the value of LIHTC properties at Year 15 and thus increase the likelihood of long-term financial health and ultimate preservation as Affordable Housing.