On November 4th, several organizations wrote to the OCC, FDIC, and FRB urging guidance for HTC (Historic Tax Credit) Investments. In the letter, a diverse group of 168 organizations asked that proposed changes be included in the Community Reinvestment Act (CRA) Questions and Answers document language that expands and clarifies the circumstances in which a federal Historic Tax Credit (HTC) investment qualifies for CRA credit. The organizations who signed onto the letter support the position taken in the joint letter submitted by the National Trust for Historic Preservation, the Historic Tax Credit Coalition, the National Main Street Center, Inc. and the National Trust Community
Investment Corporation which asked that HTC transaction eligibility would be automatic for projects in low- and moderate-income (LMI) areas that are designated economic development districts and have support from the local redevelopment agency.
“The HTC program has rehabilitated nearly 40,000 historic structures, leveraged almost $110 billion in private investment, created 2.4 million jobs and generated $36.5 billion in state, local, and federal tax receipts. National Park Service data indicate that 84 percent of all HTC transactions between 2001 and 2013 have been located in LMI census tracts. These repurposed buildings are also often located in downtown development districts in urban and Main Street communities across the country. The underserved credit areas where historic properties are found are the communities CRA was intended to assist” the letter states.
Further the letter stated, “In addition to their location in LMI neighborhoods, HTC projects are also catalytic, with a documented ability to attract additional private investment that can help stabilize or revitalize LMI areas. We have seen this first hand in the areas where we live and work. We have also seen how historic rehab supports the creation and growth of small businesses. Most HTC transactions are small, generating less than $1 million in credits. They are most often sponsored by small businesses and, particularly in a Main Street context, provide space for independently-owned local businesses.”