Forgiven Loan Test
The NMTC Program subsidy provided to the Borrower in the form of a Forgiven Loan.
The Forgiven Loan net proceeds must generally be between approximately $1,200,000 and $2,500,000, which require that the Borrower has between approximately $6,000,000 and $12,500,000, respectively, of (a) Prior Qualifying Expenditures; (b) Borrower equity; (c) third-party debt; or (d) grants or other subsidies.
Why is there an approximately $1,200,000 NMTC industry minimum threshold?
Answer:
Transaction costs and the amount of time to close a NMTC financing starts to begin to offset the NMTC Program subsidy of the Forgiven Loan at this particular amount of NMTC financing.
NMTC transaction costs include:
- the Allocatee’s “Sub-Allocation Fee” (which is generally approximately 4.0% of the “Sub-Allocation” to its CDE, which is facilitating the particular NMTC financing);
- legal and accounting fees of the NMTC transaction participants; and
- other typical fees and costs associated with any other comparable type of financing.
Why is there an approximately $2,500,000 limitation?
Answer:
This approximately limitation is based on (a) the difficulties in securing multiple Allocatees (which can be difficult to coordinate for a single closing), and (b) the community impacts typically do not support a higher amount. However, Borrower can apply for and obtain additional NMTC Financing after few years of the prior NMTC Financing provide that such financial can provide additional community impacts.