Policy updates
32 events · last refreshed 2026-05-20
July 2026
2026-07-01
UpcomingSTATEPendingGeorgia HB 376 would double HTC annual cap from $30M to $60M effective July 2026
House Bill 376 has passed both chambers of the Georgia General Assembly and would double the statewide annual HTC cap from $30M to $60M, effective July 1, 2026 through 2029. The companion to SB 496 (signed by Gov. Kemp 2024-04-18, which extended the sunset to 2029 and expanded historic homes definitions starting 2026), HB 376 is the volume-side complement to the duration extension.
Impact
If enacted, Atlanta and statewide Georgia historic adaptive reuse capacity doubles overnight. Could shift Monarch's Tier B Georgia state up into competitive sourcing territory.
Monarch action
Watch HB 376 signing in summer 2026. Pre-position pipeline for Q3 / Q4 2026 if the bill becomes law.
December 2028
2028-12-31
UpcomingSTATESunsetIllinois statewide HTC scheduled to sunset Dec 31, 2028
Under current statute, Illinois HTC sunsets at end of 2028. Whether it is extended (as in 2023) will determine the post-2028 pipeline. Watch IL legislature in 2027-2028 session.
Impact
Creates urgency for projects to begin construction by mid-2028 to qualify under current rules.
Monarch action
Prioritize IL deals that can break ground by Q2 2028.
January 2026
2026-01-09
FIRMFirm actionMonarch + Crayhill launch $300M JVT Funding for tax credit transfer partnerships
Monarch and Crayhill Capital Management announced Monarch JVT Funding, a $300M facility for tax credit transfer partnerships under the IRA's IRC § 6418 transferability mechanism.
Impact
Monarch is doubling down on the transferable tax credit market (the digital marketplace adjacent to Crux, Reunion, Basis Climate). New growth vector for the firm.
Monarch action
Pipeline that produces both equity-syndicated AND transferable credits is the most attractive shape going forward.
July 2025
2025-07-04
FEDERALCap upOBBBA permanently boosts 9% LIHTC allocation 12% and cuts 4% bond test from 50% to 25%
The One Big Beautiful Bill Act (signed by President Trump July 4, 2025) permanently raises each state's annual 9% LIHTC allocation authority by 12% and permanently reduces the private activity bond test for 4% LIHTC projects from 50% to 25% of aggregate basis. Projects must begin construction by July 4, 2026 or be placed in service by December 31, 2027 to qualify under the new rules. AHCIA estimates support for an additional 1.94 million affordable rental homes over 10 years.
Impact
The biggest LIHTC structural change since the credit was made permanent in 1993. The 4% bond test cut removes the binding constraint in states that routinely hit their PAB cap, unlocking project volume that has been stuck. The 12% permanent boost to 9% allocations is meaningful in every state given chronic oversubscription.
Monarch action
Increase 4% LIHTC pipeline volume aggressively in 2026 and 2027 while the bond-test relief is fresh. Coordinate with Brent Barringer and Steve LeClere on a PAB-constrained-state push (CA, NY, IL, MA, NJ).
2025-07-04
FEDERALExtensionOBBBA makes NMTC permanent at $5B annual allocation
OBBBA permanently extends the New Markets Tax Credit, which had been scheduled to expire at the end of 2025. Annual allocation authority is set at $5 billion, adjusted for inflation. IRC Section 45D now reads 'calendar years after 2025' with no sunset.
Impact
Removes the existential overhang on NMTC that had been compressing CDE allocation timing for years. NMTC-paired historic deals (Rail & Commerce Building style) now have multi-year planning runway.
Monarch action
Resume NMTC + HTC stacked pipeline conversations with CDE partners. Long-running CDE relationships become more valuable now that the program is permanent.
2025-07-04
FEDERALExtensionOBBBA makes Opportunity Zones permanent with modifications
OBBBA converts the 2017 Tax Cuts and Jobs Act's Opportunity Zone program from a temporary incentive into a permanent feature of the tax code, with modifications to the deferral and exclusion mechanics. New OZ designations and deferral elections are now available on an ongoing basis rather than against a hard sunset.
Impact
OZ-paired historic deals get a permanent equity-side incentive layer. Deals that combine HTC + OZ (urban infill, gateway-city downtowns) become more attractive.
Monarch action
Re-evaluate the OZ + HTC stacked product offering. Coordinate with Marco Cordova on West Coast OZ deal pipeline.
2025-07-04
FEDERALCap upOBBBA restores 100% bonus depreciation for FF&E and landscaping
OBBBA brings back full first-year expensing for furniture, fixtures, equipment, and qualifying landscaping. Combined with permanent 100% bonus, mixed-use and hospitality conversion projects (which carry substantial FF&E budgets) capture larger first-year deductions.
Impact
Hotel and mixed-use historic conversions (Fairmont, Kimpton Cottonwood, Kinley, Hotel Retlaw profiles) get materially better after-tax economics. Investor demand for hospitality HTC deals rises.
Monarch action
Re-underwrite hotel-conversion pipeline at the new bonus depreciation assumption. Reach out to Foutch Brothers, Kailas Companies, Barker Financial / Legendary Hotels.
2025-07-04
FEDERALStabilityOBBBA final bill omits HTC-GO provisions despite advocacy push
Despite a sustained advocacy campaign from Preservation Action, the National Trust, and the Historic Tax Credit Coalition, the final OBBBA reconciliation bill (signed July 4, 2025) does not include any of the HTC-GO Act provisions. Federal HTC remains at the post-TCJA 5-year spread with the basis adjustment intact. Advocates redirect to standalone HTC-GO legislation (H.R. 2941 / S. 1459) for the 119th Congress.
Impact
Status quo for federal HTC. Equity pricing assumptions hold. The structural improvements (1-year claim, no basis adjustment, 30% small-project rate) would have raised pricing 15-25% if included; with them excluded, no near-term re-pricing event is on the horizon.
Monarch action
Hold current HTC equity pricing methodology. Continue HTC-GO advocacy through industry channels but model FY26-27 against current law.
2025-07
FEDERALCurtailmentOBBBA accelerates 45V sunset from end-2033 to end-2027
The One Big Beautiful Bill Act (signed July 2025) moves the 45V clean hydrogen tax credit's construction-start deadline from December 31, 2033 to December 31, 2027, a five-year acceleration.
Impact
Renewable energy tax credit pipeline (Monarch's energy pillar) faces a 2027 cliff. Wave of project cancellations already observed (Exxon Baytown, multiple Gulf Coast blue ammonia).
Monarch action
Renewable pillar should race to qualify projects before 2027 begin-construction cutoff. Re-weight portfolio toward HTC + LIHTC pillars which are unaffected.
2025-07
FEDERALStabilityOBBBA leaves federal HTC intact
Despite renewable energy curtailments, the One Big Beautiful Bill Act preserved the 20% federal HTC at its current rate and structure (5-year spread post-TCJA).
Impact
Federal HTC remains the foundation of the historic-adaptive-reuse stack. Combined with state HTC growth (IL, NE, IN state programs), the HTC market should grow in 2026-2028 even as renewable contracts.
Monarch action
Lean into HTC + LIHTC pillars. Use the renewable cliff as a recruiting / positioning tool: 'the renewable money is rotating into HTC and LIHTC.'
2025-07
STATECap upOhio HTC annual cap raised from $60M to $75M for FY26-27
The Ohio FY26-27 biennial budget bill (signed July 2025) increased the Ohio Historic Preservation Tax Credit's annual statewide allocation from $60M to $75M for fiscal years 2026 and 2027. The Catalytic Project provision (previously up to $25M per project) was discontinued for new applications, though legacy catalytic projects continue to completion.
Impact
Ohio HTC capacity rises 25%. Mid-market historic adaptive reuse pipeline in Cleveland, Cincinnati, Columbus, and Akron has more room. Catalytic-style mega-projects no longer accessible for new applications.
Monarch action
Increase deal volume on the Ohio HTC in FY26 and FY27 competitive rounds. Re-underwrite mid-market historic conversions where the prior $60M ceiling had compressed timing.
June 2025
2025-06
STATEExpansionIllinois adds Alton to River Edge Redevelopment Zone (12th city)
Public Act 104-0006 (June 2025) added Alton, Illinois to the list of certified RERZ cities eligible for the 25% River Edge Historic Tax Credit. Brings total to 12 cities (Aurora, East St. Louis, Elgin, Joliet, Kankakee, Moline, Peoria, Quincy, Rock Island, Rockford, Sterling, Alton).
Impact
Opens a new geography for stacking RE-HTC with federal HTC and statewide IL-HTC. Alton's downtown historic stock is now eligible.
Monarch action
Survey Alton's downtown historic stock for adaptive reuse candidates; first-mover advantage in a newly-eligible geography.
April 2025
2025-04
FEDERALPendingHTC-GO Act 2025 reintroduced: 1-year claim, 30% small-project rate, basis adjustment fix
Reps. LaHood (R-IL) and Suozzi (D-NY) introduced H.R. 2941, and Sens. Cassidy (R-LA) and Warner (D-VA) introduced S. 1459, the Historic Tax Credit Growth and Opportunity Act of 2025. Key provisions: restore the federal HTC to a one-year claim (reversing the post-TCJA 5-year spread), create a 30% transferable credit for small and rural projects under $3.75M, eliminate the basis adjustment under Section 50(c), and lower the substantial rehabilitation test threshold from 100% to 50% of expenses. The basis adjustment elimination would apply to property placed in service after December 31, 2023.
Impact
Passage would materially raise HTC equity pricing (estimates run 15-25% higher) and unlock smaller deals that currently struggle to pencil. The basis adjustment fix alone is a structural win that has been on the industry wish list since 2017.
Monarch action
Track bill status quarterly. Pre-position equity pricing models against both current law and post-HTC-GO scenarios so Monarch can quote into either environment. Engage Preservation Action advocacy efforts.
January 2025
2025-01-01
STATECap downLouisiana resets state HTC: rate up to 25% (35% rural), aggregate cap cut from $125M to $85M
Effective for Part 2 applications received by the Louisiana Department of Culture, Recreation and Tourism on or after January 1, 2025, the aggregate annual reservation cap was reduced from $125M to $85M. Separately, the credit rate stepped up: 25% on eligible costs incurred from January 1, 2023 through January 1, 2029 (35% for historic structures in rural areas during the same window). The program sunsets January 1, 2029.
Impact
LA state HTC is simultaneously more valuable per dollar (25% vs 20%) and more scarce (capped lower). Existing Monarch LA deals (Bank of New Orleans / Fairmont) re-value upward, but new LA pipeline placement becomes more competitive given the reduced reservation pool.
Monarch action
Lock in LA pipeline allocations early in each program year. Rural deals (35%) become disproportionately attractive: a New Orleans deal returns 25% but a rural Louisiana mill or commercial rehab returns 35% on the same QRE, with the same federal 20% on top.
2025-01-01
STATECap upMaine HTC doubles annual project cap to $10M; small-project rate raised to 30%, affordable bonus to 35% / 45%
Governor Janet Mills signed LD 435 to expand the Maine HTC, effective January 1, 2025. The per-project annual cap doubles from $5M to $10M in the first two years of the four-year credit (years three and four remain at $5M). Small-project rate raised from 25% to 30%; small-project QRE eligibility cap raised from $250K to $1M. Affordable-housing bonus raised to 35% for significant projects and 45% for small projects. A new homeowner credit (25% standard, 30% if rehab creates housing) is added for incomes under $120K.
Impact
First Maine HTC cap increase since the program was created in 2008. Mill conversions in Lewiston, Biddeford, Saco, and Bangor become meaningfully more economical, particularly when paired with affordable set-asides.
Monarch action
Open a Maine sourcing track. Chinburg Properties and similar New England mill-conversion developers are natural counterparties; reach out via Brent Barringer's New England network.
2025
2025
STATEExtensionKansas amends KAHTC via HB 2289 (2025)
House Bill 2289 (2025) amended the Kansas Affordable Housing Tax Credit Act first enacted as HB 2237 (2022). The 1:1 federal LIHTC match structure remains; HB 2289 adjusts program parameters and continues KHRC administration. Specific changes warrant a direct read of the bill text before quoting to clients.
Impact
Kansas remains a state-LIHTC-stacking jurisdiction. Monarch closed first KS state LIHTC deals (Canyon Creek, Hope Estates); HB 2289 likely refines but does not disrupt that pipeline.
Monarch action
Continue partnership with MRE Capital and Riverstone Platform Partners on KS state LIHTC layered deals. Pull HB 2289 text and update assumptions for Q3 2026 underwriting.
2025
STATEPendingWisconsin bill would expand state LIHTC program total from $42M to $100M with rural set-aside
A bipartisan bill in the 2025-26 Wisconsin Legislature would increase the WHEDA state LIHTC program total from $42M to $100M annually (raising the $7M annual new-credit allocation accordingly), with the condition that at least 35% of allocated credits each year go to rural areas of the state. Heading into 2025, WHEDA had received applications for $20M in housing tax credits but could only grant the existing $7M in new state housing credits annually.
Impact
If enacted, Wisconsin state LIHTC nearly 2.4x's. KCG Companies and similar WI mill / industrial heritage developers gain a much deeper state-LIHTC layer to pair with WI HTC.
Monarch action
Engage KCG and Wisconsin developer network on rural set-aside opportunities. Tannery / dairy-plant / brewery conversion stock in greater Wisconsin (outside Milwaukee / Madison) becomes disproportionately attractive.
December 2024
2024-12
MARKETMarketCrux reports $30B in transferable tax credit transfers in 2024; projects $55-60B for 2025
Crux Climate published its 2024 year-end market intelligence report estimating $30B of tax credit transfers completed in calendar 2024, with the first half of 2025 alone exceeding $20B (nearly 2x H1 2024). Crux projects $55-60B total monetization in 2025. Reunion Infrastructure's parallel forecast pegs the 2024 market at $45B+ including $21-24B of transfers.
Impact
Transferable credit market is doubling year over year. Marketplaces (Crux, Reunion, Basis Climate) are now standard infrastructure. Monarch's JVT Funding facility operates against a much deeper liquidity pool than 12 months ago.
Monarch action
Quote Monarch transfer transactions against current Crux / Reunion market prints, not stale models. Position the JVT product as a price-taker-and-aggregator in a market that no longer needs convincing.
August 2024
2024-08-06
STATECap upMassachusetts doubles HTC cap to $110M via Affordable Homes Act
Governor Healey signed H.B. 4977, the Affordable Homes Act, on August 6, 2024. The legislation doubles the state historic rehabilitation tax credit annual cap from $55M to $110M, with the new ceiling running through 2030. The program continues at the 20% rate on certified rehabilitation expenditures for income-producing properties.
Impact
Massachusetts state HTC capacity doubled. Pipeline placement window meaningfully larger. Worcester, Lowell, Springfield, and Fall River mill-town stock newly more competitive.
Monarch action
Increase MA deal flow through Brent Barringer's team. Reach out to Worcester / Lowell / Springfield BD contacts to surface adaptive-reuse mill conversions now that the cap supports doubled syndication volume.
July 2024
2024-07-11
STATECap upPennsylvania HTC annual cap quadrupled $5M to $20M; per-project cap $500K to $2.5M
Governor Josh Shapiro signed the FY2024-25 PA state budget on July 11, 2024, quadrupling the Pennsylvania Historic Preservation Tax Credit annual cap from $5M to $20M and raising the per-project cap from $500K to $2.5M. The coalition's original ask was $50M; this is a partial win but a step-change for a program that has been chronically undersized relative to Pennsylvania's historic stock.
Impact
Pennsylvania moves from a thin state-HTC backstop to a meaningful layer for Philadelphia, Pittsburgh, Lancaster, Erie, and Scranton historic adaptive reuse. The per-project cap going from $500K to $2.5M is the bigger practical change for typical Monarch-scale projects.
Monarch action
Add Pennsylvania to the active Tier B sourcing list. Philadelphia industrial-heritage conversion stock (especially in the Navy Yard / Kensington corridor) is now competitive against MA / NY equivalents.
May 2024
2024-05-20
STATECap upSC Abandoned Buildings Credit raised to $700K per building, extended through 2035
Governor McMaster signed S.1021 on May 20, 2024 (with a ceremonial bill signing on August 21, 2024). The legislation raises the income tax credit cap from $500K to $700K per building site and extends the credit's sunset from December 31, 2025 to December 31, 2035, removing the looming cliff.
Impact
Adds ~$200K per qualifying building to SC abandoned-mill pro forma. Lowenstein-style deals worth ~40% more in niche credit. Removes the 2025 cliff that had been compressing SC deal timing.
Monarch action
Re-underwrite the SC abandoned-building pipeline at the new cap. Greater room to pursue larger rehabs and stack with SC HTC plus federal HTC. Drayton-Mills/Lowenstein-class textile and downtown commercial buildings get a fresh look.
2024-05
STATEExtensionConnecticut makes historic homes HTC refundable against individual income tax
H.B. 5190 (enacted May 2024) expands the list of taxes against which the Connecticut Historic Homes Rehabilitation Tax Credit can be applied, making it refundable against individual income tax and allowing carry-forward for four additional years against other taxes. The credit pays 30% of up to $30,000 of historic rehabilitation expenditures on NR-listed or State Register homes.
Impact
Modest direct impact on Monarch's commercial pipeline. Relevant as a signal that Connecticut is leaning into preservation policy; the commercial CT HTC (which Monarch would use) is also under reform discussion.
Monarch action
Watch CT commercial HTC reform proposals in 2025-2026 session.
April 2024
2024-04-25
FEDERALGuidanceTreasury and IRS finalize regulations on transfer of clean energy tax credits
The Treasury Department and IRS released final regulations under Section 6418 on April 25, 2024 (effective July 1, 2024), governing the transfer of eligible clean energy tax credits between unrelated taxpayers. The final rules implement an arm's-length pricing standard, confirm that transfer elections are irrevocable, and limit transfers to one hop. Eligible credits include the ITC, PTC, 45Q, 45V, 45X, 30C, and the clean electricity successor credits.
Impact
Removes the regulatory uncertainty that had been slowing the transferable credit market through 2024. Crux, Reunion, Basis Climate and other platforms can now structure transfers against settled rules.
Monarch action
Monarch JVT Funding pipeline (the $300M Crayhill facility) operates against final rules. Quote transfer pricing with the arm's-length anchor.
2024-04-18
STATEExtensionGeorgia extends HTC sunset to 2029 and expands historic homes definition (SB 496)
Governor Brian Kemp signed Senate Bill 496 on April 18, 2024, extending the sunset of both Georgia state HTC programs (commercial and historic homes) through 2029, and expanding the definition of historic homes effective 2026. The commercial program's prior sunset was 2027.
Impact
Adds two years of program runway for Atlanta-centric historic deals. Reduces the timing pressure on Hotel Clermont-style projects in Monarch's Atlanta book.
Monarch action
Re-pace Georgia underwriting against the 2029 sunset rather than the prior 2027 cliff.
January 2024
2024-01-01
STATECap downNebraska HTC rate up to 25%/30% but annual cap slashed from $15M to $2M
LB 727 (signed by Governor Pillen, operative September 2, 2023; new allocation rules apply to calendar years beginning January 1, 2024) raised the Nebraska HTC rate from 20% to 25% in metropolitan and primary class counties (Douglas, Lancaster) and 30% in all other counties. The same bill cut the annual statewide allocation cap from $15M to $2M and established a $2M per-project cap. The maximum credit per project was simultaneously raised to $2M.
Impact
Nebraska is no longer a high-throughput state HTC despite the higher 25% and 30% rates. Monarch's Clarity Development pipeline now constrained to roughly one to two state-HTC-funded deals per year given the $2M statewide ceiling. Rate increase mostly benefits projects that fit under the per-project cap.
Monarch action
Re-weight Omaha pipeline toward NE AHTC (state LIHTC) layering or substitute into IA, IL, or MO when state-HTC capacity in Nebraska is exhausted for the year. Communicate the constraint to Clarity Development so deal timing aligns with annual allocation rounds.
June 2023
2023-06-07
STATECreationIllinois statewide HTC launched, replacing RERZ-only version
Public Act 103-0009 (June 7, 2023) created a statewide 25% Illinois HTC with $25M annual cap and $3M per-project cap, extending through December 31, 2028. Prior to this, only the 11 RERZ cities had state HTC.
Impact
Massive value-creation event. Chicago Loop adaptive reuse deals (LaSalle Street Reimagined) immediately became eligible for state HTC stacking with federal HTC.
Monarch action
Chicago is now an A-tier state for Monarch's HTC pillar. LaSalle Reimagined cluster is the active pipeline.
2023-06-07
STATEExtensionIllinois HTC extended through 2028 with $25M annual cap
Same PA 103-0009 extended the sunset from earlier dates to December 31, 2028 and raised annual programmatic cap to $25M.
Impact
5-year visibility window for Illinois HTC stacking.
2023
2023
STATECreationIndiana enacts state LIHTC; Monarch closes first deal
Indiana created a state-level LIHTC program (administered by IHCDA). Monarch's Kilgore Place (Muncie) with TWG Development was among the first closings.
Impact
Indiana becomes more attractive for affordable deals stacking federal + state LIHTC.
Monarch action
Pipeline more deals through TWG and similar IN-active developers.
2022
2022
STATECreationKansas enacts state LIHTC via HB 2237
House Bill 2237 created a Kansas state LIHTC program. Monarch closed first deals (Canyon Creek in Lenexa with MRE Capital; Hope Estates in Newton).
Impact
Kansas becomes a viable state for affordable deals. It moves from C tier to B tier in Monarch's geographic priority.
Monarch action
Pipeline through MRE Capital and Riverstone Platform Partners.
April 2021
2021-04
STATERate upNew York adds 30% small-project HTC rate for buildings with QRE <= $2.5M
As part of the 2021-22 New York State budget (signed April 2021), the state enhanced its Historic Rehabilitation Tax Credit for small projects equal to 150% of the project's federal rehabilitation tax credit. Effective for buildings placed in service on or after January 1, 2022. Small-project eligibility: total qualified rehabilitation expenditures of $2.5M or less. Initial sunset window was Jan 1, 2025; current statute extends the program through Dec 31, 2029.
Impact
Creates a differentiated sourcing band: smaller upstate / mill-town deals now stack at federal 20% + NY state 30% = ~50% of QRE, versus 40% on large deals. Materially changes per-deal economics for sub-$15M TDC adaptive reuse.
Monarch action
Explore smaller-scale NY deals through Rivington Company and similar developers active in upstate adaptive reuse. Sub-$2.5M QRE projects deserve a second look given the enhanced state credit.
2021
2021
STATECreationCalifornia enacts 20% state HTC
California, one of the largest historic-building-stock states, finally enacted a 20% state HTC effective 2021, with a $50M annual cap.
Impact
Unlocks the California historic adaptive reuse market for federal+state HTC stacking. Combined with California's already-robust state LIHTC, CA becomes A-tier.
Monarch action
Build CA developer relationships (Hunt Capital Partners and CRP Affordable already active).
2017
2017
STATECreationNebraska enacts AHTC, matching federal LIHTC 1:1
The Nebraska Affordable Housing Tax Credit Act, passed by the Legislature in 2017, created a state LIHTC program administered jointly by NIFA and the Nebraska Department of Revenue. AHTC matches federal LIHTC 1:1 for qualified developments placed in service after the credit is allocated.
Monarch action
Continue partnership with Clarity Development to capture state LIHTC stack on Omaha historic adaptive reuse.
Watchlist topics
Federal HTC enhancement / restoration
Industry advocacy for restoring HTC to its pre-TCJA single-year claim (removing the 5-year spread). Historic Tax Credit Growth and Opportunity Act (HTC-GO) has been introduced in multiple Congresses. Passage would materially increase HTC equity pricing.
State HTC sunset extensions
IL (2028), MO (rolling), OH (annual round), MA (rolling). All subject to legislative cycles. Watch state revenue committees in 2027.
NMTC reauthorization
New Markets Tax Credit historically reauthorized every few years. Status of next reauthorization affects deals that pair NMTC with HTC.
Source: LegiScan / OpenStates / IRS notices / SHPO / HFA bulletins · Last refreshed 2026-05-20