Page 1 GAO-12-869R 

United States Government Accountability Office 

Washington, DC 20548

August 28, 2012

The Honorable Judy Biggert

Chairwoman

Subcommittee on Insurance, Housing and Community Opportunity

Committee on Financial Services

House of Representatives

The Honorable Shelley Moore Capito

Chairwoman

Subcommittee on Financial Institutions and Consumer Credit

Committee on Financial Services

House of Representatives

Subject: Community Reinvestment Act: Challenges in Quantifying Its Effect on Low-Income 

Housing Tax Credit Investment

The Low-Income Housing Tax Credit (LIHTC), which is estimated to cost $6.5 billion in forgone 

revenue in fiscal year 2012, is the largest federal program for financing affordable rental 

housing.1 This program is jointly administered by the Internal Revenue Service (IRS), within the 

Department of the Treasury, and state housing finance agencies (HFA). HFAs competitively 

award LIHTCs to owners of qualified rental housing projects that reserve all or a portion of their 

units for low-income tenants. Developers typically attempt to obtain funding for their projects by 

attracting third-party investors that are willing to contribute equity to the projects, and the project 

investors can then claim the LIHTCs. This process of providing LIHTCs in exchange for equity is 

generally referred to as “selling” the tax credits.2

Banks invest in LIHTC projects in part to meet regulatory tests under the Community 

Reinvestment Act (CRA), which encourages depository institutions to meet the credit needs of 

communities where they operate, consistent with safe and sound banking operations. Housing 

and banking industry experts cite concerns about the impact of CRA on bank investors’ demand 

 

1

The federal government provides assistance for financing rental housing through approximately 25 programs, tax 

expenditures, and other tools administered by four federal agencies; see GAO, Housing Assistance: Opportunities 

Exist to Increase Collaboration and Consider Consolidation, GAO-12-554 (Washington, D.C.: Aug. 16, 2012), and 

2012 Annual Report: Opportunities to Reduce Duplication, Overlap and Fragmentation, Achieve Savings, and 

Enhance Revenue, GAO-12-342SP, (Washington, D.C.: Feb. 28, 2012).

2

The owners of the LIHTC project are permitted to claim the LIHTCs on their income tax return. Technically, what is 

sold to the investor is not the credit but an ownership interest in the project (through a partnership or other entity). For 

purpose of this report, we refer to direct investors and syndicators generally as “investors.” 

 
Page 2 GAO-12-869R 

for LIHTCs in urban areas compared to rural areas. Based on your request, our objective was to 

determine, to the extent data allow, how CRA and other factors influence the market for LIHTCs, 

including investors’ equity contributions.

Scope and Methodology

For this report, we conducted a review of academic articles and industry reports on the 

determinants of LIHTC pricing and analyzed data from a survey of state HFAs responses on 

recent LIHTC investor equity contributions and factors that influence pricing. We identified 

factors that influence investor demand for LIHTCs and the supply of LIHTCs projects and 

developed a conceptual example of the benefits that investors receive in exchange for their 

equity contribution. We identified one common method for measuring investor equity 

contributions—price per tax credit; how that measure is used within the LIHTC community; and 

what that measure does and does not account for. As part of our review, we determined major 

data and methodological challenges in quantifying the effect of CRA on LIHTC pricing and 

identified any empirical analyses of the effect of CRA on LIHTC prices. Finally, we gathered 

documentation and interviewed officials from the IRS, Department of Housing and Urban 

Development, Board of Governors of the Federal Reserve System, Federal Deposit Insurance 

Corporation, Office of the Comptroller of the Currency, as well as state HFAs, private sector 

market participants and academic researchers knowledgeable about the LIHTC and CRA. 

Enclosure II contains more details on our scope and methodology, and enclosure III provides 

results from our survey of state HFAs.3

Background

Enacted in 1977, the purpose of CRA is to encourage insured depository institutions (banks) to 

help meet the credit needs of communities in which they operate, including low- and moderateincome neighborhoods, consistent with safe and sound banking operations.

Community Reinvestment Act

4 Federal financial 

regulators—the Board of Governors of the Federal Reserve System, the Federal Deposit 

Insurance Corporation, and the Office of the Comptroller of the Currency—are required to 

assess periodically each bank’s record of helping to meet the credit needs of its entire 

community. A bank is evaluated primarily on its performance in its local communities or 

assessment areas.5

While small banks are evaluated based on lending in their local communities, small-intermediate 

banks—with assets totaling at least $290 million and less than $1.16 billion—are subject to a 

two-part test and large banks—with assets totaling at least $1.16 billion—are subject to a threeIts performance in the broader statewide or regional area that includes its 

assessment area is considered when evaluating community development activities.

 3

Enclosure III presents survey questions about LIHTC pricing and the effect of CRA and other factors on the lowincome housing tax credit market. These questions were part of a larger survey; see, GAO, Recovery Act: Housing 

Programs Met Spending Milestones, but Asset Management Information Needs Evaluation, GAO-12-634 

(Washington, D.C.: June 18, 2012).

4

12 U.S.C. §§ 2901-2908.

5

Under CRA regulations, assessment areas are delineated by banks and (1) must consist of whole geographies (i.e., 

census tracts), (2) may not reflect illegal discriminations, (3) may not arbitrarily exclude low- or moderate-income 

geographies, and (4) may not extend substantially beyond a metropolitan statistical area or state boundary unless the 

assessment area is located in a multistate metropolitan statistical area. 
Page 3 GAO-12-869R 

part test that also evaluates investments. 6 The standards relate to both the quantity of a bank’s 

activities, as well as the quality of those activities. Under the large bank investment test and 

intermediate-small bank community development investment test, banks can choose to invest in 

various qualified community development investments, including LIHTC projects.7 Examiners 

evaluating a bank under the investment test consider not only how much money the bank has 

invested but also the quality in terms of how innovative or complex the investments are; how 

well the investments respond to credit and community development needs; and whether the 

investments differ from those provided by most private investors.

Enacted in 1986, the LIHTC provides an incentive for developers and investors to provide 

affordable rental housing for households whose income is at or below specified income levels.

Low-Income Housing Tax Credit

8

 6

The asset threshold amounts as of January 2012. Thresholds for small, intermediate-small, and large banks are 

updated annually.

The program is jointly administered by IRS and HFAs, state-chartered authorities established to 

help meet the affordable housing needs of the residents of their states. The LIHTC is an indirect 

financing source and resembles a grant program in that HFAs are responsible for allocating the 

credit on a competitive basis to owners of qualified low-income rental projects. Figure 1 depicts 

the multistep federal/state process.

7

Limited purpose banks, which provide services such as credit cards, and wholesale banks, which are not in the 

business of offering mortgages or loans to retail customers, are also assessed under a community development test.

8

26 U.S.C. § 42.
Page 4 GAO-12-869R 

Figure 1: Transferring Tax Credits from the Federal Government to the Private Sector

Note: For a fuller description and additional graphic on the LIHTC oversight and 

compliance system, see GAO, Opportunities to Improve Oversight of the Low-Income 

Housing Program, GAO/GGD/RCED-97-55 (Washington, D.C.: Mar. 27, 1997). 

1. The Department of the Treasury and IRS administer the LIHTC program and state HFAs 

receive tax credit allocations. LIHTCs are allocated by statutory formula to states annually 

according to population, with a minimum amount awarded to states with small populations.9

For 2012, the formula was $2.20 per capita or a minimum of $2,525,000.10 When the credits 

have been awarded, they are usually available to the owners/investors annually for a 10-

year credit period as long as the project meets LIHTC requirements.

 9

26 U.S.C. § 42(h)(3).

10The annual state credit volume ceiling applies to the 9 percent LIHTC and does not cover 4 percent tax credits 

issued for low-income housing projects financed with tax-exempt rental housing bonds. These bonds are subject to 

annual state-by-state caps on the volume of private activity bonds.
Page 5 GAO-12-869R 

2. Developers apply to HFAs for tax credits. A project’s developer submits a detailed proposal 

to an HFA. To qualify for consideration, a project must:

• be a residential rental property,

• meet occupancy thresholds by reserving either 20 percent or more of the available units for 

households earning 50 percent or less of the area’s median gross income adjusted for 

family size or 40 percent or more of the units for households earning 60 percent or less of 

the area’s median gross income adjusted for family size,

• restrict the rents (including the utility charges) for tenants in low-income units to 30 percent 

of an imputed income limitation based on the number of bedrooms in the unit,

• meet habitability standards, and

• operate under the program’s rent and income restrictions for at least 30 years for projects 

placed in service since 1990.11

3. HFAs award tax credits to selected housing projects. Tax credits are competitively awarded 

to housing projects in accordance with states’ qualified allocation plans. Qualified allocation 

plans outline a state’s affordable housing priorities and set out its procedure for ranking the 

projects on the basis of how well they meet state priorities and selection criteria that are 

appropriate to local conditions. For example, some states establish geographic preferences 

setting aside a specific portion of tax credits by region or for rural areas. By law, each state 

must set aside at least 10 percent of its credit allocation for projects developed by qualified 

nonprofits, but states may set aside a larger share. In addition, the qualified allocation plan 

must give preference to projects that serve the lowest income tenants, serve qualifying 

tenants for the longest period of time, and are located in a qualified census tract and 

contribute to a local community revitalization plan.12 HFAs are responsible for providing no 

more tax credits to projects than necessary for their financial viability for the 10-year credit 

period.13 LIHTC projects receiving other federal subsidies are to receive less in tax credits 

than projects not otherwise subsidized by the federal government.14

 11A LIHTC project is subject to a 15-year compliance period during which a taxpayer is subject to IRS oversight and 

an extended use period of at least 30 years during which the project is subject to HFA oversight. The 15-year 

compliance period and the extended use period begin at the same time.

12Under 26 U.S.C. § 42(d)(5)(B)(ii)(I), qualified census tracts are designated by the Secretary of Housing and Urban 

Development and include census tracts where either 50 percent or more of the households have income below 60 

percent of the area median gross income or the poverty rate is at least 25 percent. 

1326 U.S.C. 42(m)(2)(A).

14To guard against oversubsidization, almost all federal housing programs have statutory requirements requiring the 

administering agencies to confirm that, at the time of making a grant or subsidized loan, the total amount of subsidy 

being provided by public sources does not exceed eligible costs.
Page 6 GAO-12-869R 

4. Tax benefits provide a return on equity investments. Investment partnerships are a primary 

source of equity financing for LIHTC projects. Syndicators recruit investors who are willing to 

become partners (generally, limited partners with 99.99 percent ownership share) in LIHTC 

projects. The money investors pay for the partnership interest is paid into the LIHTC project 

as equity financing. Although investors are buying an interest in a rental housing 

partnership, this process is commonly referred to as buying tax credits. Once the LIHTC 

project is placed into service—ready for occupancy—investors can claim their share of the 

credits to offset taxes otherwise owed on their tax returns annually for a 10-year credit 

period. Investors also receive a share of other tax benefits, such as deductions for interest 

on debt and depreciation and amortization deductions, and the possibility of cash proceeds 

from the sale of the project.

After LIHTC projects are placed into service, HFAs monitor the projects for compliance with 

federal requirements for LIHTC eligibility, such as household income, rents, and project 

habitability. The private sector, both investors and lenders, has an interest in overseeing the 

LIHTC project, in part to ensure that they receive their full complement of LIHTCs over the 

designated credit period. In general, IRS only collects information necessary for tax 

administration and other purposes required by law. IRS collects data on LIHTCs awarded and 

other information necessary to check the amount claimed on tax returns. Noncompliance with 

federal LIHTC requirements within the 15-year compliance period may result in IRS’s denying 

claims for the credit in the current year or recapturing credits claimed in prior years. HFAs are 

also responsible for overseeing compliance over the entire LIHTC extended use period, which is 

at least 30 years. Noncompliance after the 15-year LIHTC compliance period is not reported to 

IRS, but may result in action under state or local law. Although not an administering agency, the 

Department of Housing and Urban Development collects data from HFAs and maintains a 

database of LIHTC project-level data, such as geographic location, total number of units and 

LIHTC units, allocation year of the LIHTC, and the year the property was placed into service. 

The Department of Housing and Urban Development commissioned a recent study examining 

what happened to projects placed in service between 1987 and 1994 after the end of the 15-

year compliance period.

Summary of Findings

While CRA should increase investor demand for LIHTCs, quantifying the extent of any effect of 

CRA on LIHTC equity contributions is difficult given data and methodological challenges. In part 

because of the qualitative nature of the CRA investment test, regulatory ratings cannot be 

systematically linked to banks’ LIHTC investments. Although a bank’s overall rating and the 

associated narrative of its CRA examination are publicly available, the performance evaluation 

report does not individually list qualified investments and how they were considered for that 

examination. Furthermore, quantifying potential bank demand for LIHTCs in specific geographic 

areas is complicated because not every bank assessment area is considered to the same 

degree in a CRA examination. Although one way to assess demand for LIHTCs is by examining 

how much equity investors are willing to contribute, the common LIHTC price measure—the 

ratio of investors’ equity contribution to the total amount of LIHTCs in nominal dollars—is subject 

to misinterpretation. Specifically, an investor’s equity contribution reflects the value of not just 

the LIHTCs, but also any other tax and regulatory benefits—such as higher CRA ratings—plus 

project risks. Such other tax benefits include deductions for depreciation and interest expenses. 

Furthermore, complete and reliable data on LIHTC investor equity contributions are not readily 

available, creating a challenge to analyzing the determinants of pricing. Although no empirical 

analyses of the effect of CRA on LIHTCs are available, CRA is widely cited by academic 

researchers, federal officials, and LIHTC market participants, and HFAs surveyed as one factor 

that increases bank demand for LIHTC investments particularly in urban areas. LIHTC market 
Page 7 GAO-12-869R 

participants interviewed and HFAs surveyed indicated other factors that influence investors’ 

decisions to invest in LIHTCs, such as the strength of housing markets in urban areas and 

developer experience with LIHTC projects.

Enclosure I provides more details about the challenges in linking bank regulatory ratings to 

LIHTC investments, as well as, information about how the LIHTC is calculated and how an 

investor evaluates a LIHTC investment in deciding how much equity to contribute. Enclosure I 

also summarizes our findings about evidence available about the effect of CRA and other 

factors on LIHTC investor demand and equity contributions.

Agency Comments and Our Evaluation

We provided a draft of this report to the Department of the Treasury, IRS, Department of 

Housing and Urban Development, Board of Governors of the Federal Reserve System, Federal 

Deposit Insurance Corporation, and Office of the Comptroller of the Currency for review and 

comment. The Department of Housing and Urban Development stated that it had no comments, 

and the other agencies provided technical comments, which we incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of this report earlier, we 

plan no further distribution until 30 days after the date of this report. At that time, we will send 

copies of this report to other congressional committees, the Secretary of the Treasury, the 

Commissioner of Internal Revenue, the Secretary of the Department of Housing and Urban 

Development, the Board of Governors of the Federal Reserve System, the Federal Deposit 

Insurance Corporation, the Office of the Comptroller of the Currency, and other interested 

parties. Copies are also available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions or wish to discuss the material in this report further, 

please contact me at (202) 512-9110 or whitej@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page of this report. GAO 

staff members who made major contributions to this report include MaryLynn Sergent, Assistant 

Director; Kevin Daly; Lois Hanshaw; Edward Nannenhorn; Melanie Papasian; Erinn L. Sauer; 

and Elwood D. White.

James R. White

Director

Tax Issues

Strategic Issues

Enclosures–3 
Page 8 GAO-12-869R 

Enclosure I

The Community Reinvestment Act and LowIncome Housing Tax Credit Investment

Bank Regulatory Ratings Cannot Be Linked Specifically to

Housing Tax Credit Investments

How CRA Works

The CRA framework sets out regulatory tests and performance standards for 

banks based on the dollar value of an institution’s assets for the previous 2 

years, as shown in the figure on the following page. While small banks are 

evaluated based on lending in their local communities, small-intermediate 

banks—with assets totaling at least $290 million and less than $1.16 billion—

are subject to a two-part test and large banks—with assets totaling at least 

$1.16 billion—are subject to a three-part test that also evaluates community 

development investments. The standards relate to both the quantity of a 

bank’s activities, as well as the quality of those activities. 

CRA-Qualified Investments May Include Low-Income Housing 

Tax Credit Projects

The large bank investment test and intermediate-small bank community 

development test consider a bank’s record of helping to meet the credit needs 

of its assessment area through qualified investments that benefit its 

assessment area or a broader statewide or regional area that includes its 

assessment area. A qualified investment is a lawful investment, deposit, 

membership share, or grant that has community development as its primary 

purpose. Under CRA, community development includes affordable housing for 

low- and moderate-income individuals; community services targeted to the 

low- and moderate income; activities that promote economic development by 

financing small businesses and farms; activities to revitalize or stabilize lowand moderate-income neighborhoods; and loans, investments, and services 

that among other things benefit low-, moderate-, and middle-income 

individuals and geographies in the bank’s assessment area. Banks can invest 

in various qualified community development investments, including LowIncome Housing Tax Credit (LIHTC) projects, as well as other tax-preferred 

investments such as New Markets Tax Credits and state and local tax-exempt 

bonds. 

As shown in the figure below, examiners evaluating a large bank under the 

investment test consider not only how much money the bank has invested, 

but also the quality in terms of how innovative or complex the investments 

are, how well the investments respond to credit and community development 

needs, and whether the investments differ from those provided by most 

private investors. 

Regulators consider a bank’s investments within the context of the bank, its 

community, and its competitors. A qualified investment of a lower dollar 

amount may receive more weight under the investment test than one with a 

higher dollar amount that has fewer qualitative aspects. For example, an 

LIHTC investment that is particularly responsive to the needs of low- and 

moderate-income neighborhoods in the bank’s community may receive 

greater consideration than those not as responsive. Examiners assign a 

bank’s rating based on its demonstrated response to the performance criteria. 

Although a bank’s overall rating and the associated narrative of its CRA 

examination are publicly available, the performance evaluation report does 

not individually identify qualified investments and how they were considered 

for that examination. Thus, it is difficult to determine in a systematic way the 

extent to which certain qualified investments, such as LIHTC investments, 

were considered as part of a bank’s CRA performance evaluations.

Background

Enacted in 1977, the purpose of 

the Community Reinvestment Act 

(CRA) is to encourage insured 

depository institutions (banks) to 

help meet the credit needs of 

communities in which they 

operate—including low- and 

moderate-income neighborhoods—

consistent with safe and sound 

banking operations. CRA is 

implemented by federal financial 

regulators, including the Board of 

Governors of the Federal Reserve 

System, the Federal Deposit 

Insurance Corporation, and the 

Office of the Comptroller of the 

Currency. 

CRA regulators are required to 

examine periodically each bank’s 

record in helping meet the credit 

needs of its entire community. That 

record is taken into account in 

considering a bank’s application for 

deposit facilities, including mergers 

and acquisitions. Banks are 

evaluated primarily on their 

performance in their local 

communities, which the regulations 

define as the banks’ assessment 

area. Assessment areas are 

delineated by banks and (1) must 

consist of whole geographies (i.e., 

census tracts), (2) may not reflect 

illegal discrimination, (3) may not 

arbitrarily exclude low- or 

moderate-income areas, and (4) 

may not extend substantially 

beyond a metropolitan statistical 

area or state boundary unless the 

assessment area is located in a 

multistate metropolitan statistical 

area. A bank’s performance 

outside its assessment area or 

broader statewide or regional area 

that includes its assessment area 

is considered only when evaluating 

community development activities. 
Page 9 GAO-12-869R 

CRA Tests and Performance Standards

Notes: Asset thresholds as of January 2012; thresholds for small, intermediate-small, and large banks are updated annually. A bank may choose to 

develop its own strategic plan, subject to public comment and prior regulatory approval, or may be evaluated using the standards. Limited purpose 

banks, which provide services such as credit cards, and wholesale banks, which are not in the business of offering mortgages or loans to retail 

customers, are assessed under a community development test that differs from the intermediate-small bank test shown. 

 

Role of Geography in CRA Examinations

Under the interagency CRA examination procedures, all 

of a bank’s assessment areas are reviewed as part of 

the CRA evaluation process. For a large bank with 

multiple assessment areas, each area will receive either 

a full- or limited-scope review. The determination of the 

review scope is based on a variety of factors, including 

the number of branches, volume of deposits, and/or 

reportable loans. During the CRA exam, the relative 

importance of the selected assessment areas to the 

bank’s operations and activities is also determined to 

derive an overall rating. 

The criteria used in that determination are similar to 

those used to determine which assessment areas 

receive a full-scope review. Quantifying bank demand 

for certain qualified investments, such as LIHTCs, in 

specific geographic areas is complicated because not 

every bank assessment area is considered to the same 

degree in a CRA examination.
Page 10 GAO-12-869R 

Enclosure I

Calculation of LIHTC Project Costs and Eligible Credit

A portion of the total project development costs for a qualified rental housing 

project are eligible for the LIHTC. Eligible costs include depreciable rental real 

estate, common areas, facilities reasonably required for the operation of the 

project, and community service facilities. Costs associated with the land, most 

land improvements, partnership start-up costs, and certain financing costs are 

not eligible. Further, only the applicable fraction of qualifying costs associated 

with providing low-income housing is included in the basis for claiming the 

credit. This fraction is the lesser of the fraction of affordable units to total units

or the fraction of square feet in the affordable units to the total square feet for 

all the residential rental units in the building. The annual credit amount is 

equal to the qualified basis multiplied by the applicable percentage. The 

applicable percentage is determined either on the month the LIHTC project is 

placed into service—that is ready for occupancy—or at the taxpayer’s 

irrevocable election at the time the credit is allocated. Once the LIHTC project 

is placed in service, project owners and investors can claim the LIHTCs to 

offset taxes otherwise owed on their tax returns over a 10-year credit period. 

The following table shows how project costs and total credit are calculated for 

an illustrative LIHTC project with all units set aside for low-income renters.

Example of LIHTC Project Costs and Total Credit

Source: GAO analysis. 

Notes: 

a

Projects located in a qualified census tract or difficult to develop area can have their eligible basis 

increased by up to 130 percent, referred to as a “basis boost.” HERA allows a housing finance agency 

to designate certain buildings which need the “basis boost” to be financially feasible as located in a 

difficult to develop area, and hence, eligible for the enhanced credit. Allowing a property to use the 

basis boost and claim a higher credit does not change the state's total credit allocation. 

b

This example shows a project with 100 percent of the units eligible for the credit. 

In exchange for the LIHTCs, the rental project owner must agree to set aside 

a minimum number of units for qualified low-income households and charge 

no more than the maximum allowable rents. An extended use agreement with 

these affordability restrictions for the LIHTC project for at least 30 years, or 

longer if agreed to by the state and project owner, must be in place to begin 

claiming the credits.

Background

The Department of the Treasury 

(Treasury) estimates that the LowIncome Housing Tax Credit 

(LIHTC) will cost $6.5 billion in 

forgone revenue in fiscal year 

2012. Taxpayers claiming the 

LIHTC may be individual investors, 

although in recent years the 

majority of investors are 

corporations—either investing 

directly or through partnerships—

such as banks, real estate, 

insurance, utility, or manufacturing 

firms. 

The 9 percent LIHTC was designed 

to provide a 70 percent subsidy for 

new rental construction not 

receiving other federal subsidies or 

for certain rehabilitation expenses. 

To achieve the 70 percent subsidy, 

a credit rate is calculated such that 

the present value of the stream of 

LIHTCs over the 10-year credit 

period is equal to 70 percent of the 

qualified basis of the LIHTC 

project. Tax credit percentage rates 

are prescribed monthly by 

Treasury. From 1986 to 2008, the 

rate fluctuated from between 7.89 

percent to 9.27 percent to maintain 

the subsidy of 70 percent. The 

Housing and Economic Recovery 

Act of 2008 (HERA) established a 

temporary minimum rate of 9 

percent for projects placed in 

service after the date of enactment 

and before December 31, 2013. 

Under HERA, the credit rate may 

fluctuate, but will not be less than 9 

percent. As a result, the present 

value of the credits cannot fall 

below 70 percent and can exceed 

70 percent if interest rates are low. 

While this report focuses on the 9 

percent LIHTC, a 4 percent LIHTC 

providing a 30 percent subsidy is 

also available.

The Community Reinvestment Act and LowIncome Housing Tax Credit Investment

Investors Benefit from Claiming Low-Income Housing Tax 

Credits to Reduce Their Tax Liability 

Project cost and LIHTC calculation

Total project development cost $11,500,000

Less ineligible costs ($1,500,000)

Eligible basis $10,000,000 a

Multiplied by applicable fraction 100% b

Qualified basis $10,000,000

Multiplied by applicable percentage (or credit rate) 9%

Annual credit amount $900,000

Total amount taken over 10 year credit period $9,000,000
Page 11 GAO-12-869R 

Enclosure I

The Community Reinvestment Act and LowIncome Housing Tax Credit Investment

Equity Contribution Is the Investor’s Valuation of a LowIncome Housing Tax Credit Investment

Investor Equity Contribution Reflects Additional Benefits and 

Risks Associated with LIHTC Investment

In evaluating the attractiveness of an LIHTC investment relative to alternative 

investments and determining how much equity to contribute, an investor 

would consider the stream of tax benefits and operating income as well as the 

risks associated with achieving those flows. Because of rent restrictions, 

LIHTC investors would generally not expect to receive rental profits. For our 

illustrative project, the following table shows certain tax benefits—$9 million in

LIHTCs over the 10-year tax credit period and $1.9 million in reduced taxes 

from depreciation deducted over the 15-year compliance period. An investor 

would receive a share of tax benefits proportionate to its partnership share, 

typically 99.99 percent. 

Example of LIHTC Project Tax Benefits

Source: GAO analysis. 

a

Other tax benefits reflect $363,636 annually in depreciation on a $10 million LIHTC project basis for a 

corporate taxpayer with a 35 percent tax rate. This simplified example does not include interest 

expense or other deductions associated with an LIHTC project. 

b

Profits are shared according to the partnership agreement. Typically, investors do not expect an 

LIHTC project to produce income, and the principal flows are the tax benefits. 

c

Nominal totals for the project not adjusted for time value of money. Investors typically have a 99.99 

percent partnership share in an LIHTC project and would receive a proportionate share of the tax 

benefits and possibly cash proceeds from the sale of their ownership interest. 

Background

In deciding to invest in a LowIncome Housing Tax Credit 

(LIHTC) project, investors consider 

the total benefits and risks

associated with the investment. In 

addition to the dollar for dollar 

reduction in tax liability provided by 

the LIHTC, additional benefits may 

include: 

• Tax deductions for interest on 

debt and depreciation, which 

can be claimed from the time an 

LIHTC project is placed in 

service until the investor 

disposes of its interest. For tax 

purposes, rental real estate 

structures are depreciated using 

the straight line method over a 

27.5 year recovery period. 

• Regulatory benefits for banks

investing in communities they 

serve, such as through higher 

Community Reinvestment Act 

(CRA) ratings. 

Investment risks include:

• Potential lack of tax liability and 

therefore being unable to make 

full use of the LIHTCs. 

• Unanticipated inflation (LIHTC 

amounts are not adjusted for 

inflation after the projects are 

completed). 

• Variation in the actual value of 

the LIHTCs from year to year 

depending on the number of 

habitable, rent-restricted units 

occupied by qualifying lowincome households. 

• Operational losses from the 

LIHTC project (typically limited 

to the amount of investment in 

the property). 

• Potential LIHTC recapture if the 

project is not compliant with 

federal requirements.

LIHTC Project Cycle Year Tax credits Other tax 

benefits

Project 

cash flow a Total annual tax benefits b

Construction period 1 $0 - - -

10-year 

tax credit 

period

15-year 

compliance 

period

2 900,000 $127,273 $0 $1,027,273

3 900,000 127,273 0 $1,027,273

4 900,000 127,273 0 $1,027,273

5 900,000 127,273 0 $1,027,273

6 900,000 127,273 0 $1,027,273

7 900,000 127,273 0 $1,027,273

8 900,000 127,273 0 $1,027,273

9 900,000 127,273 0 $1,027,273

10 900,000 127,273 0 $1,027,273

11 900,000 127,273 0 $1,027,273

12 0 127,273 0 $127,273

13 0 127,273 0 $127,273

14 0 127,273 0 $127,273

15 0 127,273 0 $127,273

16 0 127,273 0 $127,273

Totals through the 15-year 

compliance period

$9,000,000 c $1,909,091 $0 $10,909,091
Page 12 GAO-12-869R 

In calculating the upfront equity contribution, the 

investor would discount the returns from the investment 

to take into account that equity is contributed early in the 

life cycle of the project while the tax benefits will be 

received over time. In general, investors choose an 

equity contribution that will give them a high enough rate 

of return to justify investing in an LIHTC project rather 

than an alternative asset. The discount rate is the rate of 

return that could be earned on alternative investments in 

the financial markets with similar risks. In our illustrative 

example, the investor contributes equity of $6,750,000 

upfront during the construction period. The investor’s 

expected return would depend on its ability to claim any 

tax benefits, such as those illustrated in the table above. 

If the LIHTC investment was riskier, for example, 

because the investor is less certain to have sufficient tax 

liability to fully use the tax benefits, the discount rate 

would be higher and the investor would be willing only to 

make a smaller equity contribution. 

In addition to the tax benefits accruing to any LIHTC 

investor, a bank may receive positive consideration 

towards its regulatory rating for LIHTC projects that 

qualify under the CRA investment test. In determining 

the amount of equity to contribute, a bank investor

would likely account for this additional regulatory benefit 

for LIHTC investments in its assessment area or the 

broader statewide or regional areas that includes its 

assessment area. According to one researcher, large 

banks focus their qualified investments in larger urban 

areas, which represent a larger share of their deposits 

or total branches and are more likely to be selected for 

full-scope review in a CRA examination. Qualified 

investments in other assessment areas, while inside a 

bank’s overall footprint, receive less consideration, and, 

as a result, banks may not receive the same regulatory 

benefit from investing in those areas.

In addition to the amount of benefits expected and 

timing of the equity payment, an investor’s equity 

contribution would take into account project 

characteristics and risks that may affect the flow of tax 

benefits and potential operating gains and losses. 

LIHTC market participants interviewed and state 

housing finance agencies surveyed identified a number 

of conditions that could influence investor equity 

contributions. For example, delays in the developer 

completing the project on time or renting the units to 

income qualified tenants would, in turn, delay the flow of 

tax benefits. Potential LIHTC investors would consider 

both a developer’s experience both with a specific 

LIHTC project type, such as senior housing or family 

housing, as well as reputation in the local market and be 

willing to contribute more equity for a project with an 

experienced developer and less to a project with an 

unproven developer. Similarly, investors would be 

willing to contribute more equity for an LIHTC project 

with a reasonable cash flow to cover expenses and 

mortgage debt service and well-capitalized reserves to 

cover any unforeseen costs. Our example assumed that 

investors expect no cash flow from operations. An 

investor would also take into account investment fees, 

costs to monitor compliance with LIHTC rules, and the 

financial viability of the LIHTC project. Syndicators and 

bank regulators reported that investor demand for 

LIHTCs is weaker in rural areas in part because rural 

LIHTC projects tend to be smaller in scale. As a result,

fixed transaction costs are spread over fewer units, and 

a few vacancies can have a relatively greater impact on 

the viability of a small project. Also, rural areas tend to 

have smaller margins between allowable LIHTC rents 

and market rents, so the risk that tenants could move to 

alternative housing and create LIHTC vacancies would 

be greater than in urban areas. 
Page 13 GAO-12-869R 

Enclosure I

The Community Reinvestment Act and LowIncome Housing Tax Credit Investment

CRA is One of Many Factors that Influence Investor 

Demand and LIHTC Equity Contributions

Industry Price Ratio May be Misleading If Interpreted as 

Measuring What Investors Pay for LIHTCs Only

The common LIHTC price measure is a ratio of the equity contribution to the 

sum of nominal LIHTCs only, whereas equity contributed reflects an investor’s 

valuation of an LIHTC project’s total returns and risks discounted to account 

for the time value of money. For our illustrative project receiving $9,000,000 in 

LIHTCs, an investor equity contribution of $6,750,000 would be expressed as 

a price ratio of $0.75; the price ratio would be lower if measured as equity 

contributed per dollar of total nominal tax benefits. However, the equity 

contributed reflects both the LIHTCs and additional benefits discounted for the

timing of those benefits and taking into account the rate of return available on 

other investments with similar risks. The common LIHTC price ratio can be 

misleading if it is interpreted as the price that investors pay for the LIHTCs 

only. An equity contribution buys a partnership interest in an LIHTC project 

including all tax benefits flowing over time and subject to the risks inherent in 

investing in these types of rental housing.

Despite its limitations, the price ratio used by market participants is the 

measure commonly used to gauge LIHTC pricing, thus facilitating broad 

comparisons across equity invested in LIHTC projects and gauging 

investment trends. The following figure summarizes the range of average 

price ratios reported by the 50 states and the District of Columbia for 2005 

through 2010. As reported by HFAs, average LIHTC price ratios peaked in 

2006, then declined from 2007 to 2009, and generally increased in 2010. 

Average price ratio of equity to LIHTCs, 2005 to 2010

Background

Low-Income Housing Tax Credit 

(LIHTC) market participants—

project developers, syndicators and 

state housing financial agencies 

(HFA)—commonly calculate the 

LIHTC “price” by dividing the 

investor equity contribution by the 

total LIHTCs to be claimed over the 

10-year tax credit period. The sum 

of LIHTCs received over time is 

nominal and is not discounted to 

reflect the time value of money. 

The ratio of equity to the sum of 

nominal LIHTCs is expressed as 

cents per LIHTC dollar. Complete 

and reliable data on investor equity 

contributions or price ratios are not 

readily available. HFAs obtain data 

on equity investments to ensure 

that projects receive no more 

LIHTCs than necessary for their 

financial viability, but there is no 

centralized national database. 

In February 2009, the American 

Recovery and Reinvestment Act 

(Recovery Act) created two grant 

programs to provide stopgap 

funding for LIHTC projects. As part 

of our Recovery Act work, 

managers of all HFAs were asked 

to participate in a survey in 2009 

and 2011 to collect HFA responses 

on LIHTC prices and market 

condition. We did not verify HFAreported price averages, and states 

may have used varying methods to 

calculate average prices. All HFAs 

responded to both surveys. The 

2011 survey included questions on 

how the Community Reinvestment 

Act (CRA) and other factors affect 

LIHTC pricing. See enclosure III for 

survey questions and responses.

We also interviewed market 

participants about factors that 

influence investor demand for 

LIHTC projects.
Page 14 GAO-12-869R 

Notes: The price typically refers to the ratio of investor equity per dollar of LIHTC and does not take into account other tax and investment benefits 

received. The median is the value—in this case, the average price—which falls in the middle of a set of values arranged from smallest to largest; there 

are an equal number of values above and below the median value. 

Many Factors, Including CRA, Likely Contribute To Investor Demand and LIHTC Equity 

Contributions

HFA officials, regulatory officials, academics, and other 

experts we talked to all cited a number of factors 

affecting investor demand for and equity contributions to 

LIHTC projects in recent years. The onset of financial 

struggles for large banks and the exit of two large 

LIHTC investors—Fannie Mae and Freddie Mac—

contributed greatly to decreased investor demand. 

Changes in the mix of the limited supply of LIHTC 

projects can also lower the average price ratio if state 

HFAs award LIHTCs to rental housing projects viewed 

by investors as riskier. However, it is unclear how much 

of the broad decline in the average price ratio shown in 

the previous figure reflects investors’ valuation of 

increased risks associated with available LIHTC 

projects.

While we identified multiple articles and papers 

describing LIHTC price ratio trends, we found few 

studies that empirically modeled various determinants of 

LIHTC equity contributions and found none that 

quantified the effect of CRA on LIHTC investment. One 

researcher who used state-level data said that the lack 

of readily available data on investor equity contributions 

was a challenge in conducting LIHTC analysis.

Across the range of market participants interviewed and 

HFAs surveyed, CRA was widely cited as one factor 

that increases bank demand for LIHTC investments. 

HFA survey responses supported this general view with 

40 of 56 HFAs responding that CRA increased pricing to 

some extent. LIHTC market participants stated that CRA 

increases banks’ demand for LIHTC investment 

opportunities in urban areas. In August 2010, a group of 

LIHTC market participants attributed pricing differences 

at that time of 20 to 30 percent between large urban 

markets and the rest of the country to CRA-motivated 

investor demand. Of the 40 HFA respondents that 

provided written comments on CRA as a factor, 14 

HFAs commented that CRA was more influential in 

urban or suburban areas, and 21 cited specific cities or 

regions within their states—in almost every case a 

metropolitan area. Three states—Maine, Nebraska, and 

Vermont—indicated that CRA motivates banks to invest 

in LIHTC projects in rural as well as urban areas. 

There was widespread agreement about the direction 

and the effect of other factors that affect the level of 

LIHTC equity investments in urban versus rural areas. 

According to some LIHTC market participants, investors 

tend to invest in a limited number of geographic areas 

that they understand and those tend to be areas with 

stronger housing markets. The majority (40) of HFA 

survey respondents indicated that the LIHTC market is 

stronger in urban areas than rural areas within their 

state. Some market participants interviewed said that, 

for example, New York City, Boston, and San Francisco 

generally have strong housing markets and also have 

strong LIHTC markets. One reason cited for the 

correlation is that increased demand for housing results

in higher housing prices, thus increasing the need for 

more affordable housing, including LIHTC projects. Most 

HFA survey respondents indicated that a strong housing 

market (49) and low rental vacancy rates (47) would 

increase the price of LIHTCs. 
Page 15 GAO-12-869R 

Enclosure II: Objective, Scope, and Methodology

Our objective was to determine, to the extent data allow, how the Community Reinvestment Act 

(CRA) and other factors influence the market for Low-Income Housing Tax Credits (LIHTC), 

including investors’ equity contributions.

We gathered documentation and interviewed officials from the Internal Revenue Service (IRS), 

Department of Housing and Urban Development, Board of Governors of the Federal Reserve 

Board System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the 

Currency.

We conducted a review of academic articles and industry reports on the determinants of pricing 

for the LIHTC, including studies that empirically modeled various determinants of LIHTC equity 

contributions.15

We selected a group of LIHTC market participants to interview on the extent and nature of the 

interaction between the CRA and LIHTC prices. LIHTC market participants were selected from a 

variety of organizations, including government agencies, universities and academic research 

centers, and industry groups. Methods used to select LIHTC market participants for interviews 

included our review of literature, referrals from our internal housing-industry experts, or referrals 

from external experts consulted for this or related engagements. We interviewed officials from 

six state housing finance agencies (HFA) that administer the LIHTC in their states. HFAs were 

selected in coordination with audit work conducted for our June 2012 report on American 

Recovery and Reinvestment Act (Recovery Act) housing programs.

We identified factors that influence investor demand for LIHTCs and the supply 

of LIHTC projects. We also developed a conceptual example of the benefits that investors 

receive in exchange for their equity contribution. We identified one common method for 

measuring investor equity contributions—price per tax credit; how that measure is used within 

the LIHTC community; and what that measure does and does not account for. As part of our 

review we determined major data and methodological challenges in quantifying the effect of 

CRA on LIHTC pricing and identified any empirical analyses of the effect of CRA on LIHTC 

prices. We interviewed Reznick Group about its ongoing study examining the relationship 

between CRA assessment areas and LIHTC pricing, but the final study was not available at the 

time we did our work.

16

To assess state LIHTC markets, we asked mangers of state HFAs in all 50 states, the District of 

Columbia, and the insular areas to complete a web survey as part of our Recovery Act work.

We added questions regarding LITHC pricing to our 2011 survey of HFAs’ use of two LIHTC 

HFAs selected include 

California, Colorado, Illinois, Massachusetts, Mississippi, and Pennsylvania. The selection of 

states provided geographic diversity and included states with varying amounts of urban and 

rural areas.

 15Michael D, Eriksen, “The market price of Low-Income Housing Tax Credits,” Journal of Urban Economics 66 (2009): 

141-149; and Leslie A. Robinson, “Do Firms Incur Costs to Avoid Reducing Pre-Tax Earnings? Evidence from the 

Accounting for Low-Income Housing Tax Credits,” The Accounting Review vol. 85, no. 2 (2010): 637-669.

16GAO, Recovery Act: Housing Programs Met Spending Milestones, but Asset Management Information Needs 

Evaluation, GAO-12-634 (Washington, D.C.: June,18, 2012).
Page 16 GAO-12-869R 

temporary financing programs.17 Our questions asked how CRA and other factors affected 

LIHTC pricing. Data collection took place from December 2011 through February 2012. We 

received usable responses from all 56 agencies. In addition, when reporting on approximate 

average tax credit price for 2007, 2008, and 2009, we used information gathered from HFAs in 

response to our 2009 questionnaire.18

See enclosure III for the wording of our 2011 survey questions and a summary of the results. 

While all state agencies returned questionnaires, and thus our results are not subject to 

sampling or overall questionnaire nonresponse error, the practical difficulties of conducting any 

survey may introduce other errors in our findings. We took steps to minimize errors of 

measurement, question-specific nonresponse, and data processing. We obtained comments on 

a draft of our self-administered questionnaire from the National Council of State Housing 

Agencies, the Department of the Treasury that administers the Recovery Act Section 1602 grant 

program, and pretested draft questionnaires with two housing finance agencies. During the 

survey, we made follow-up contacts with nonrespondents to encourage participation, and to 

clarify answers respondents made, as necessary. In addition, our analysts resolved respondent 

difficulties in answering one question during the survey. Finally, analysis programs and other 

data analyses were independently verified.

The “price” as reported by HFAs typically reflects the 

ratio of equity contributed per dollar of LIHTC. We did not verify HFA-reported price averages, 

and states may have used varying methods to calculate average prices. While this common 

industry measure does not account for additional tax benefits received by an LIHTC investor, 

the equity to LIHTC ratio is commonly used in describing overall trends in LIHTC pricing.

We conducted our work from July 2011 to August 2012 in accordance with all sections of GAO’s 

Quality Assurance Framework that are relevant to our objectives. The framework requires that 

we plan and perform the engagement to obtain sufficient and appropriate evidence to meet our 

stated objectives and to discuss any limitations in our work. We believe that the information and 

data obtained, and the analysis conducted, provide a reasonable basis for any findings and 

conclusions in this product.

 17The Recovery Act established two temporary funding programs that provided capital investments to LIHTC projects: 

(1) the Tax Credit Assistance Program (TCAP) administered by the Department of Housing and Urban Development 

and (2) the Grants to States for Low-Income Housing Projects in Lieu of Low-Income Housing Credits Program under 

Section 1602 of the Recovery Act (Section 1602 Program) administered by the Department of the Treasury. TCAP 

provided gap financing to be used by state HFAs in the form of grants or loans for capital investment in LIHTC 

projects that were awarded tax credits in fiscal year 2007, 2008, or 2009; project owners were to spend all TCAP 

funds by February 2012. Designed to be used in lieu of tax credits, the Section 1602 Program allowed state HFAs to 

exchange a portion of their 2009 ceiling (up to 100 percent of unused 2008 LIHTC and 40 percent of their 2009 

allocation) for grant funds from Treasury at the rate of 85 cents for every tax credit dollar, and then award proceeds to 

finance the construction or acquisition and rehabilitation of qualified low-income buildings.

18GAO, Recovery Act: Results of GAO’s Survey of State Housing Finance Agencies’ Use of The Low-Income 

Housing Tax Credit Assistance Program (TCAP) and Section 1602 Program, GAO-10-1023SP (Washington, D.C.: 

Sept. 20, 2010).
Page 17 GAO-12-869R 

Enclosure III: Results from Survey of State Housing Finance Agencies for 

Selected Questions about the Low-Income Housing Tax Credit Market

Questions about the Low-Income Housing Tax Credit (LIHTC) market were part of a larger 

Survey of State Housing Finance Agencies on Recovery Act Funding. Only results from these 

questions (1 through 10) are shown in this enclosure. For the results for questions 11 through 

46, please see appendix II in GAO-12-634.

19

Background on Your State’s LIHTC Market

1. Compared to 2009, considering both urban and rural areas, is your state’s market for low 

income housing tax credits: Click one button.

Much 

stronger

Somewhat 

stronger

About 

the 

Same 

Somewhat 

weaker 

Much 

weaker 

Don’t 

know 

Number of 

respondents

33 18 3 0 1 1 56

2. Compared to 2009, how would you characterize the current housing tax credit market in 

urban versus rural areas (however you may define them) in your state? Is it:

Much 

stronger

in urban 

areas

Somewhat 

stronger

in urban 

areas

About the 

same 

in urban and

rural areas

Somewhat 

stronger

in rural 

areas

Much 

stronger

in rural 

areas

Don’t have 

both

urban and 

rural

areas Don’t know 

Number of 

respondents

12 28 14 0 0 1 1 56

Tax Credit Pricing

3. In our previous survey we asked for the approximate average tax credit price set at closing 

with investors in your state for 2007, 2008 and 2009. What were the approximate prices for the 

following years? Enter cents using numeric digits and decimal points, if needed, in the boxes 

below

2005 – cents paid per dollar tax credit

Mean Median Minimum Maximum

Number

of respondents

89.2 90 75 100 48

2006 – cents paid per dollar tax credit

Mean Median Minimum Maximum

Number

of respondents

92.4 93 80 103 48

 19See GAO, Recovery Act: Housing Programs Met Spending Milestones, but Asset Management Information Needs 

Evaluation, GAO-12-634 (Washington, D.C.: June 18, 2012).
Page 18 GAO-12-869R 

2007 – your previous report was: _____ cents paid per dollar tax credit

2008 – your previous report was: _____ cents paid per dollar tax credit

2009 – your previous report was: _____ cents paid per dollar tax credit

2010 – cents paid per dollar tax credit

Mean Median Minimum Maximum

Number

of respondents

74.4 73 47 96 53

4. If you have any additional comments or would like to explain any of your answers on tax 

credit pricing, please provide them below. Box will scroll to accommodate text as necessary.

(Open-ended answers not displayed.) 

Impact of CRA on Tax Credit Pricing

5. In your opinion, does the Community Reinvestment Act (CRA) tend to increase, decrease, or 

have no effect on the pricing of low-income housing tax credits in your state?

Greatly 

increase 

Moderately 

increase

Slightly 

increase 

No 

effect 

Slightly 

decrease 

Moderately 

decrease

Greatly 

decrease 

Don’t 

know 

Number of 

respondents

14 20 6 5 2 0 1 7 55

6. Are there specific geographic location(s) within your state where CRA is more influential than 

others?

Yes No Number of respondents

38 16 54

7. IF YES: In what geographic locations is CRA more influential?

(Open-ended answers not displayed.) 

8. In your opinion, do each of the following project or market characteristics generally tend to 

increase, decrease, or have no effect on the pricing of low-income housing tax credits in your 

state? Click one button in each row. 

Project Features

A relatively large number of housing units in the project

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

8 32 9 1 0 6 56
Page 19 GAO-12-869R 

Multi-family structures, such as apartment buildings

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

4 10 31 0 0 10 55

Single-family structures, such as detached homes

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

0 5 23 10 2 16 56

Inclusion of other federal sources of funding

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

3 24 17 3 0 8 55

Project Feasibility

Experienced developer team

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

29 25 0 0 0 2 56

Well-capitalized reserves

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

15 34 1 0 0 6 56

Expectation of reasonable cash flow

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

11 33 6 0 0 6 56

Market Characteristics

Low rental vacancy rates

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

13 34 4 0 0 4 55
Page 20 GAO-12-869R 

A strong housing market

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

19 30 3 0 0 3 55

Presence of large banks within the state

Greatly 

increase 

Slightly 

increase No effect 

Slightly 

decrease

Greatly 

decrease Don’t know 

Number of 

respondents

13 20 10 0 0 13 56

9. Are there any other factors that generally tend to increase or decrease pricing of low-income 

housing tax credits in your state? If so, describe them in the box below.

(Open-ended answers not displayed.)

10. If you have any additional comments or would like to explain any of your answers on the 

impact of CRA on tax credit pricing, please provide them below.

(Open-ended answers not displayed.) 

Questions 11 through 46 intentionally not reported.20

(450960)

 20See GAO-12-634, appendix II.
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