Workforce housing,
faster.

It is income-restricted rental or for-sale housing built without the federal Low-Income Housing Tax Credit. Instead of selling tax credits to investors, the project is financed with conventional bank debt, equity from banks seeking credit under the Community Reinvestment Act (CRA), local incentives, grants and soft funds, and sponsor capital.

It typically serves the “missing middle”: households at or below 80% of area median income (AMI), such as teachers, nurses, transit operators, and line cooks, who earn too much for deep-subsidy housing and too little for new market-rate rents.

No. LIHTC is an extraordinary achievement. It has produced more than three million homes and remains essential for the deepest affordability, typically households between 30% and 60% of AMI. The shortage of homes for extremely low-income renters, estimated by the National Low Income Housing Coalition at roughly 7.2 million units, requires LIHTC, vouchers, public housing investment, or direct subsidy.

The argument is additive: alongside LIHTC, the country needs a strong parallel path for the 80% AMI band that moves at much higher velocity. Reading it as a case for shifting resources away from the tax credit misreads it.

With a simpler stack. A regional bank provides senior debt and, often, concessionary CRA equity. Local incentives, municipal and state grants, Federal Home Loan Bank funds, and sponsor equity fill the remainder. Philanthropic capital, including donor-advised fund dollars placed as concessionary debt, can close the last gap.

The Landing in Spokane is an example: a 24-unit intergenerational community assembled from six sources, $6.99 million in total, with Washington Trust Bank as senior lender and CRA investor. See the full capital stack.

Because they already carry Community Reinvestment Act obligations, and many want high-quality, mission-aligned assets that earn regulatory credit efficiently. When a project keeps the majority of its units at or below 80% AMI, it can qualify for substantial bank participation on straightforward, market-oriented terms, without the full tax-credit machinery. Scaling this approach expands production without increasing federal tax expenditures.

Because there is no competitive allocation round, no syndicator, and far fewer layers of subordinate debt to negotiate. Site control, entitlement, the bank term sheet, and construction closing can be sequenced and partly overlapped.

Spokane Rise Apartments, a 48-unit workforce and refugee housing development, moved from site control to groundbreaking in about seven months and ten days, then from groundbreaking toward occupancy in about twelve. A comparable 9% LIHTC project routinely needs 24 to 36 months from application through allocation, syndication, and construction closing. See the project.

Through filtering. When new homes are built, households move into them and vacate older units, which become available further down the income ladder. Vacancy-chain research by Evan Mast and others suggests that 100 new market-rate units can open the equivalent of 45 to 70 units for lower-income households.

Filtering works best when new supply arrives quickly. A faster pipeline of 80% AMI housing therefore reaches households at 50% AMI and below sooner than a multi-year pipeline can. It accelerates relief for those households; it does not replace deep subsidy for them.

LIHTC developer fees are typically capped around 15% of total development cost. On the non-LIHTC path, all-in developer fees can fall to roughly 5% to 6.5%. Fewer financing layers also mean fewer conflicting deadlines, lower transaction costs, and less predevelopment risk, the stretch where many tax-credit deals die before they reach an allocation round.

Extend to qualifying projects the same concessions they already grant to tax-credit deals. Five are immediately tractable:

1. 1.Fast-track permitting with concurrent departmental review and a single point of contact, compressing twelve-plus months of entitlement to three to five.
2. 2.Fee relief: full or partial waivers of impact and permit fees, and construction sales-tax rebates, on the affordable portion.
3. 3.Density and parking: bonuses of 25% to 50%, reduced parking ratios, and height and setback relief.
4. 4.Property tax: PILOT agreements or multi-year abatements calibrated to the 80% AMI band, which raise supportable senior debt.
5. 5.Land and infrastructure: donations or nominal long-term ground leases of surplus public land, plus cost-sharing for sewer, water, roads, and drainage.

Clear thresholds tied to Community Reinvestment Act performance: at least 51% of rental units at or below 80% AMI, or at least 20% of for-sale apartments and townhomes at or below 80% AMI. Spokane Rise, for example, restricts 51% of its units at or below 80% AMI.

As capital that comes back. In Spokane, Courage Housing is structuring a pilot under Washington HB 1590 in which the city covers a developer's construction-loan interest in exchange for a few units restricted at 60% AMI in good neighborhoods. Every dollar is repaid at permanent financing, so the same capital recycles into the next project. The pilot projects roughly 300 restricted unit-years per $1 million over 30 years, against roughly 180 for a one-time grant. See the pilot or run the calculator.

We design and assemble non-LIHTC capital stacks, structure CRA equity and bank partnerships, design housing funds and repayable public instruments, and lead pre-development from feasibility through capital close. We have not used LIHTC in any project we have led; both of our closed projects were financed with CRA equity. Our capital practice · Pre-development advisory · Housing policy.