The Federal Historic Tax Credit (HTC) Program provides low-cost capital to real estate developers who agree to preserve historic building elements. The credit can be used for a wide variety of real estate projects. The Historic Tax Credit certification process is complex. But research, preparation, and the solid understanding of the process can help you satisfy its requirements. Along the way, we are happy to share industry information about financing structures and third parties who can help improve your application. Typically, we encourage our customers to consider hiring an industry consultant for help throughout the HTC application process.
Once your project is eligible, you can begin the 3-part application process. In part 1, you present information about the significance and appearance of the building. The property must be listed in the National Register of Historic Places or be certified as contributing to a registered historic district's significance. We recommend contacting JPMorgan Chase once Part 1 has been approved to set up discussions about financing structure early on. For Part 2, you need to describe the building's condition and the planned renovations, which must meet the National Park Services' (NPS) Substantial Rehabilitation Test. For Part 3 after the project is done, you submit proof that the work was completed as originally proposed according to NPS standards for historic preservation. The building must be used as an income producing purpose for at least five years after rehabilitation.
You'll submit each part of the application form to your State Historic Preservation Office (SHPO, or Shi-poh) which may request more information and conduct site visits. As outlined on the U.S. Technical Preservation Services website, SHOP then sends its recommendation to the National Park Service for final approval.
Upon completion of the project milestones, you become eligible to receive low-cost capital from JPMorgan Chase. JPMorgan Chase is here to help you with HTC capital. Contact one of our bankers today.
Through the federal Historic Preservation Tax Incentives program, commonly known as the Historic Tax Credit (HTC) program, real estate developers can transform buildings. The program can help convert office buildings and shuttered factories into apartments, or turn former hospitals into schools and community centers.
A growing number of affordable housing projects also use the HTC program. “We’re doing a lot of public housing with buildings built as recently as the ‘60s and ‘70s,” said Cindy Hamilton, President of Heritage Consulting Group.
Congress enacted the tax credit program as an incentive to preserve historic building elements. The HTC program can also be an economic development tool, as developers often create jobs and revenue to revitalize distressed communities.
The HTC program is an indirect federal subsidy that finances the rehabilitation of historic buildings. The federal government provides the financial incentive to real estate developers in the form of a 20% tax credit for qualified expenditures.
However, many developers aren’t in a position to use the tax credits. Instead, banks or other third parties invest in the credits to raise equity funding for the HTC project, reducing the amount of debt financing developers need for the property’s rehab.
Significant time and effort go into obtaining HTC approval for these projects. That work begins with determining a property’s eligibility.
To be eligible for the HTC program, a building must be:
Once the project is determined eligible, the developer can begin the U.S. Technical Preservation Services’ three-part application process with their local state historic preservation office (SHPO). These offices may request more information and conduct site visits before sending recommendations to the National Park Service (NPS), which provides the final approval.
If the project building is listed individually on the National Register, it’s automatically certified historic and Part 1 isn’t required.
If the building is not on the National Register, the developer must establish its historic significance through a separate application process. A building’s significance may relate to its history, architecture or association with an important person or event.
“A successful National Register nomination finds the hook to the story—why it is significant and worthy of preservation,” said Elizabeth Rosin, Principal and CEO of Rosin Preservation.
In Part 1, the developer details the building’s significance, appearance and history. “History is more than names and dates,” Rosin said. “It’s about the people who envisioned, built and occupied a building.” She looks to city directories, census records and historic maps to learn more about how the structure fits into the community.
In Part 2, the developer describes the building’s condition and planned rehabilitation work. Historic consultants can help determine what building elements are historic and should be preserved.
Elements to preserve could be decorative, such as exterior stonework and plaster details in the lobby, or even the walls themselves. For example, midcentury modern buildings are often characterized by their all-glass exteriors and lack of applied ornaments. “These elements communicate just as much about the building and when it was constructed as a mosaic tile floor or elaborate wood trim,” Rosin said.
After the project is done, the developer submits proof the work was completed as originally proposed. NPS approval of Part 3 officially recognizes the property as a certified rehabilitation to receive the tax credit.
Upon completion of project milestones, the developer can claim the HTC credits. In return, the developer receives low cost-capital from the bank.
Dozens of states have historic tax credit programs that can provide incentives for rehabbing income-producing properties. State application processes and allocations, however, vary from state to state.
JPMorgan Chase’s bankers specialize in Historic Tax Credit transactions and can share information on financing structures and third parties that can help improve your application.
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