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Why affordable housing schedules can be especially interdependent
Many affordable developments rely on more than one source of capital. Low-Income Housing Tax Credit (LIHTC) equity, loans and other federal, state or local funds may all be needed to make a project feasible. Each source can bring its own award, underwriting, documentation and closing steps, so a project may have to wait for multiple pieces to align before it can move forward. The Government Accountability Office’s review of LIHTC oversight describes this layered financing structure, but does not quantify how much schedule time each funding source adds.
This does not mean every affordable project uses the same financing model. LIHTC developments, Housing Trust Fund projects and projects using HUD-insured multifamily loans have different program mechanics. A useful explanation of a delay identifies the actual funding path and pending decision rather than treating “affordable housing” as one uniform process.
Where delays can arise
| Potential bottleneck | How it can affect delivery | What the evidence establishes |
|---|---|---|
| Financing assembly and underwriting | Multiple awards, loans and equity commitments may need to be approved, documented and coordinated before closing or construction. | GAO describes layered LIHTC financing. HUD OIG documents a specific processing risk in HUD multifamily mortgage applications; neither source establishes a universal financing delay. |
| Land, site readiness and infrastructure | High land or development costs, utility or other infrastructure needs, and site hazards can make a planned site harder to prepare or financially feasible. | These were among barriers reported by communities applying in round one of HUD’s PRO Housing program; they are not a national ranking of causes among completed projects. |
| Land-use rules and permitting | Required reviews, permits and local processing can add steps or uncertainty to a project’s path. | HUD’s summary of round-one PRO Housing applications identified outdated land-use policies and permitting processes as reported barriers. It does not measure how often they delay projects nationwide. |
| Construction economics and project conditions | Cost and feasibility can differ with project type, scale, income mix, location and local market conditions, changing what a project needs to proceed. | GAO reports variation in LIHTC costs and differences between new construction and rehabilitation in a selected Housing Trust Fund sample. Cost variation alone does not prove the cause of a specific schedule delay. |
Financing and loan processing
Several capital sources must line up
LIHTC is a major federal source of assistance for affordable rental housing. State and local housing finance agencies administer allocation plans, developers attract investor equity, and projects may need additional financing to cover development costs. Where a project depends on several pieces, a pending award, underwriting decision or closing requirement can hold up the next stage. The funding mix and sequence matter: a delay in one project’s loan processing should not be assumed to explain another project’s schedule.
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A documented HUD processing example
A 2024 HUD Office of Inspector General audit found that delays in processing multifamily mortgage applications slowed affordable housing production and availability. During the pandemic-era backlog, more than 500 applications were waiting to be assigned to underwriters. HUD later cleared that nationwide queue. The figure refers to applications awaiting assignment, not to 500 delayed developments.
The audit also found that HUD continued to rely on multiple systems, email and manual processes, creating risks for tracking and future backlogs if application volumes changed. It describes HUD’s own application intake, completeness screening, prioritization, contract underwriters, workload sharing and one-step processing for certain cases. This is evidence about HUD’s workflow—not a measure of all lenders, all projects or a typical project timeline.
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Land, infrastructure and site conditions
A site can be expensive or difficult to develop, and a housing plan may depend on infrastructure that is not yet in place. Environmental hazards and climate-related extreme-weather risks can also affect site readiness. HUD’s summary of round-one PRO Housing applications reported high land and development costs, inadequate infrastructure, environmental and climate hazards, and underused vacant land or property among barriers identified by applicant communities. Those applications describe what participating communities reported; they do not show how often each condition delays completed projects across the country.
For a specific development, distinguish a land acquisition problem from work needed to make the site buildable. The relevant questions include whether the land is available at a feasible cost, what infrastructure is needed, and whether environmental or climate conditions require additional work or review.
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Land-use rules and permitting
Local land-use policies and permitting processes can add steps or uncertainty. HUD identified outdated policies and permitting processes among barriers reported by PRO Housing applicants. Its 2026 state and local best-practices guidance recommends approaches such as streamlining reviews, publishing required approvals and modernizing permitting technology. These are federal policy recommendations, not an independent evaluation proving that permitting is the dominant cause of delay or that every local requirement is unnecessary.
When a project is described as “stuck in permitting,” the useful details are which approval remains outstanding, which agency handles it and whether the issue is a required review, an incomplete submission or processing capacity. Without those specifics, the label does not identify the actual bottleneck.
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Construction costs differ by project
Construction economics can affect feasibility and the work needed to deliver a development, but cost figures need context. GAO reports that LIHTC costs vary with factors including new construction versus rehabilitation, project size, target income levels, location and local market conditions. In a separate 2023 analysis, GAO examined 70 completed Housing Trust Fund projects from 12 selected grantees. That selected sample was designed for diversity but was not representative of all projects nationally.
| Figure | Scope and meaning |
|---|---|
| About $232,000 per unit | GAO’s average development cost for the 70 completed Housing Trust Fund projects in its selected 12-grantee sample. It is not a national average or a measure of delay; costs varied by project type and location. GAO report |
| About 10 percent | Housing Trust Fund’s share of total funding for those same 70 selected projects; LIHTC investor equity was the largest funding source. This share should not be generalized to all affordable housing. GAO report |
GAO’s Housing Trust Fund sample found new construction more expensive per unit than rehabilitation. That comparison, like the figures above, describes selected projects and does not show that higher costs alone caused a delay. GAO has also noted gaps and inconsistency in federal LIHTC cost data, which limits comparisons of cost drivers across places.
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How to identify the cause in a particular project
Rather than assume one explanation, trace the project’s sequence and identify what must happen next. Separate a documented pending decision or site condition from a general claim about affordable housing.
- Financing path: Identify the funding sources, their sequence, and any award, underwriting or closing step still pending.
- Site readiness: Check land availability and cost, infrastructure needs, and environmental or climate conditions.
- Approval path: Name the land-use status, outstanding permits or reviews, responsible agencies and current processing step.
- Project characteristics: Note whether the work is new construction or rehabilitation, along with scale and income mix.
- Local context: Account for local market conditions, rules and agency capacity rather than assuming another jurisdiction’s experience applies.
- Evidence behind the explanation: Distinguish an audit finding, a barrier reported by grant applicants, policy guidance and a project-specific account.
HUD’s 2024 announcement described funding for communities intended to cut red tape and build more affordable homes with urgency. Acting Secretary Adrianne Todman said the funding was designed to “cut red tape” and build more homes, “especially affordable homes, with urgency because people need help now.” That statement explains the policy purpose; it is not evidence that red tape is the leading cause of delays.
What the evidence can—and cannot—say
The available official findings point to a chain of possible bottlenecks, not a single nationwide cause. GAO’s Housing Trust Fund analysis is a nongeneralizable sample of selected grantees and completed projects, not a national schedule study. HUD OIG examined HUD’s mortgage application process, while HUD’s PRO Housing barriers came from round-one community applications. These sources do not establish a typical delay duration or rank causes across all affordable developments.
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