FAQ · 31 answers

What firms rarely explain.

Technical answers on development, land, federal tax credits, the Puerto Rico ecosystem, HUBZone, brokerage and how to work with CAHB.

Development and land

4 questions

What does a real estate feasibility study include?

A feasibility study answers whether a project can be built, sold or leased, and financed on the proposed site. It combines five fronts: market (demand, absorption, comparable prices or rents), regulatory (zoning, land use, required permits and endorsements), physical (acreage, topography, infrastructure and flood risk), financial (hard and soft costs, pro forma, sensitivity and returns) and capital (debt, equity and applicable incentives). The deliverable ends with an explicit recommendation: proceed, redesign or discard.

How is land evaluated for development in Puerto Rico?

First we confirm what the land is: ownership and liens in the Property Registry, acreage per survey, current zoning and land use, access, available infrastructure (water, power, sewer) and flood exposure. Then we determine what the land can be: the highest-value use that regulation allows and the market absorbs, with its density, permitting path and cost. That analysis sets the land's value to sell it, develop it or contribute it to a partnership.

What experience does CAHB have in assisted living and senior housing?

It is the line with the most mandates on record: programs and plans for 57- and 75-bed facilities, an 80-bed care home with NMTC structuring, project management of a 108-bed project under NMTC, a continuum-of-care master plan with a 125-bed base case and the acquisition valuation of an operating 44-bed home. Each mandate appears with its actual status in the portfolio.

Does CAHB work on projects in Florida?

Yes, on two fronts. Brokerage is offered under Florida real estate license SL3611103, through the brokerage AFS Living. Feasibility, financial structuring and capital advisory is available for projects in Florida. The firm's documented experience is concentrated in Puerto Rico; in Florida the record includes a residential listing in Jacksonville.

Federal tax credits

9 questions

What exactly is LIHTC?

The Low-Income Housing Tax Credit, codified in IRC §42, is the federal program that grants tax credits to private investors in exchange for capitalizing affordable housing. The credit is claimed over 10 years and monetized through syndication to corporate investors with tax liability to absorb. In Puerto Rico, the PRHFA allocates the credits under an annual Qualified Allocation Plan.

9% vs 4% LIHTC — when to use each?

9% credits cover roughly 70% of eligible cost on a present-value basis and are awarded competitively under the QAP. 4% credits cover ~30%, are non-competitive, but require part of the project to be financed with tax-exempt bonds (Private Activity Bonds). The choice depends on the gap to close, bond cap availability, the NOFA calendar and the syndication partner's return thesis. For large rehabilitations and projects with ample soft debt, 4% is often the faster route.

What is the “50% test” for 4% LIHTC?

For a project to receive 4% credits on its full eligible basis, tax-exempt bonds must finance at least 50% of aggregate basis (land plus building). It is the constraint that derails most 4% financial models. 2025 federal legislation reduced the threshold to 25% for bonds issued starting in 2026, which significantly expands the viable pipeline in Puerto Rico; confirm the current rule with bond counsel before modeling.

What is the 30% basis boost and does it apply in Puerto Rico?

Projects located in a HUD-designated Qualified Census Tract (QCT) or Difficult Development Area (DDA) can increase eligible basis up to 130%, which directly increases the credit generated. A large share of Puerto Rico's census tracts qualify as QCTs, and the PRHFA QAP can grant a discretionary boost to 9% projects that justify it. It is one of the most underused levers in local underwriting.

How does the LIHTC compliance period work?

The federal compliance period is 15 years. During that time the property must maintain its elected set-aside (20/50, 40/60 or average income test), HUD AMI-based income and rent limits, and annual tenant certification. It is followed by an extended use period of 15 more years under the Land Use Restriction Agreement (LURA), for a total of 30 years of restriction. Credit recapture remains active during the first 15.

What happens in Year 15?

When the compliance period ends, the investor typically exits the partnership. Common paths are: exercise of the general partner's or a nonprofit's right of first refusal, purchase of the limited partner's interest at fair market value, or resyndication with new 4% credits if the property needs rehabilitation. The exit strategy should be modeled at the original closing, not in year 14.

What is NMTC and how does it differ from LIHTC?

The New Markets Tax Credit under IRC §45D is administered by the CDFI Fund (U.S. Treasury). It grants a 39% credit on the investment, spread over 7 years (5% × 3 years, 6% × 4 years). Credits are awarded to Community Development Entities (CDEs), not directly to projects; the sponsor competes for an allocation within a CDE's pipeline. Unlike LIHTC — restricted residential housing — NMTC finances commercial, mixed-use, health, education and any QALICB in a designated Low-Income Community.

What requirements must a QALICB meet?

A Qualified Active Low-Income Community Business must simultaneously satisfy: (1) ≥50% of gross income from activities within the LIC, (2) ≥40% of tangible property use within the LIC, (3) ≥40% of employee services performed within the LIC, (4) <5% of assets in nonqualified financial property and <5% in collectibles, and (5) no prohibited line of business (golf, massage, casinos, liquor stores, residential rental). The tests apply throughout the full 7 years.

How does an NMTC transaction end?

After the 7-year compliance period, the structure unwinds through a put/call: the investor exercises its put for a nominal amount or the CDE exercises its call, and the leverage lender's debt stays with the QALICB on pre-negotiated terms. In practice, much of the NMTC subsidy becomes permanent project equity at that point. The unwind is documented at closing, seven years before it is executed.

The Puerto Rico ecosystem

5 questions

What is the PRHFA and why does it matter?

The Puerto Rico Housing Finance Authority (Autoridad para el Financiamiento de la Vivienda) administers the local LIHTC program, issues the tax-exempt bonds for 4% LIHTC, runs soft debt programs (including delegated HOME and CDBG-DR funds) and publishes the annual QAP. Every LIHTC transaction in Puerto Rico goes through the PRHFA.

What is the QAP and how should it be read?

The Qualified Allocation Plan is the PRHFA's annual document that sets the scoring criteria and priorities for awarding 9% credits: population served, location, cost efficiency, sponsor experience, resident services and closing schedule. Reading it well means modeling the project against the point matrix before buying the land. A project designed for last year's QAP may not compete in the current one.

How does CDBG-DR integrate with LIHTC?

Community Development Block Grant — Disaster Recovery (HUD) reaches Puerto Rico after presidential disaster declarations (María, Fiona) and is administered by the Department of Housing. Within a LIHTC capital stack it works as a gap filler, typically non-amortizing soft debt or cash-flow-contingent debt. It requires cross-compliance (Davis-Bacon, NEPA, URA, Section 3, duplication of benefits) that most sponsors underestimate in time and cost.

What role do Act 60 and Opportunity Zones play?

Act 60-2019 (Puerto Rico Incentives Code) consolidates local tax incentives, including benefits for Opportunity Zone investment and decrees for certain development activities. Nearly all of Puerto Rico is designated a federal Opportunity Zone. These incentives can improve returns on non-LIHTC equity in a mixed-use project, but they do not replace the federal credit or stack automatically: they require separate legal structuring and a compatibility analysis.

Why is Puerto Rico strategic for affordable housing?

Three structural reasons: (1) a historic affordable housing deficit amplified by disasters and migration, (2) the same federal treatment as the mainland for LIHTC, NMTC, CDBG-DR and HUBZone, (3) local advantages — Act 60, a high share of QCTs, competitive land costs and an active CDBG-DR ecosystem. The combination allows institutional returns with quantifiable risk, provided the sponsor understands local execution.

HUBZone and federal contracting

5 questions

What does HUBZone certification mean?

HUBZone (Historically Underutilized Business Zone) is an SBA certification that requires: a small business at least 51% owned by U.S. citizens (or another eligible category), a principal office in a designated HUBZone, at least 35% of employees residing in HUBZones, and annual recertification. It grants access to reserved federal contracts (set-asides) and a 10% price evaluation preference in full and open competitions.

What is SAM.gov registration?

The System for Award Management (SAM.gov) is the single federal registry for entities that receive federal contracts or financial assistance. It assigns the UEI (Unique Entity Identifier) and CAGE Code and must be renewed annually. CAHB LLC is actively registered: UEI CU7AR2KBTLG7 · CAGE 15HK0.

Set-aside, sole source and price preference — what is the difference?

A set-aside is a solicitation restricted to HUBZone firms when the agency expects at least two certified offers. A sole source allows a direct award to a single HUBZone firm under dollar thresholds defined by the FAR. The price preference applies in open competitions: the HUBZone offer is considered the winner if it does not exceed a large competitor's by more than 10%. Each mechanism requires a different capture strategy.

What types of federal contracts can CAHB perform?

Through HUBZone and SAM.gov, CAHB is eligible for real estate advisory, financial analysis, capital structuring, housing finance research, federal compliance support and land and site analysis contracts for agencies such as HUD, SBA, Treasury (CDFI Fund) and quasi-governmental entities in Puerto Rico. It can also participate as a HUBZone subcontractor within prime contractors' subcontracting plans.

Why Bayamón?

Bayamón is Puerto Rico's second most populous municipality and contains designated HUBZones, which enables the firm's certification. It is minutes from San Juan, where the PRHFA, the Department of Housing and federal offices operate, at the center of the metro corridor where affordable housing demand is concentrated. Location and federal eligibility coincide in one place.

Brokerage · Bocheciamp Real Estate

2 questions

What services does Bocheciamp Real Estate offer?

Sale of residential, commercial and land properties; buyer representation; leasing; and inherited (succession) properties, where title is put in order before marketing. It operates in Puerto Rico (license C-24140) and Florida (license SL3611103, through the brokerage AFS Living), with bilingual documentation and the same analytical diligence CAHB LLC applies.

How is an inherited (succession) property sold?

With title resolved before going to market: declaration of heirs, powers of attorney or signatures from all heirs, registered acreage and debts (CRIM property tax, mortgage, condominium) identified. The price is aligned with what the buyer's bank will appraise, not with an optimistic appraisal. That keeps the sale from falling through after the offer.

Working with CAHB

6 questions

Is CAHB a developer, an advisor or a broker?

It depends on the division, and the role is disclosed in each mandate. Development & Advisory works as a fee-based advisor, as project manager or, on its own projects, as developer or co-principal. Capital & Institutional Finance advises on a fee or success-fee basis on structuring and capital introduction. Bocheciamp Real Estate is the licensed brokerage practice (PR C-24140 · FL SL3611103 through AFS Living) and earns a commission. When a transaction involves more than one role, the conflict is disclosed in writing before signing.

Who is CAHB's typical client?

Four profiles: (1) landowners and developers who need feasibility, permits and a development path; (2) family offices, investors and financial institutions evaluating or deploying capital in Puerto Rico; (3) federal agencies, municipalities and quasi-governmental entities that need bilingual technical support with a local presence; and (4) buyers and sellers of residential, commercial and land properties, served by Bocheciamp Real Estate.

How long does a typical engagement take?

Full underwriting: 4–8 weeks. A complete capital stack design: 8–16 weeks. End-to-end LIHTC structuring (allocation, syndication and closing): 12–18 months, subject to the QAP and NOFA calendar. CAHB does not speed up processes at the expense of institutional rigor.

What do I need for a first consultation?

A complete package is not required. The location or description of the site, the proposed use and approximate scale (units, beds or square feet), a preliminary budget if available and the capital sources identified are enough. With that, the first meeting determines which analysis is needed — feasibility, permitting, capital structure or brokerage — and the next step.

How is confidentiality handled?

All information received before or during an engagement is treated as confidential by default, and CAHB signs an NDA when the client requires it. The firm does not publish client names, project figures or transaction terms without written authorization. Cases cited on this site are presented with the corresponding consent or anonymized.

In what language is the advisory work performed?

Natively bilingual — Spanish and English — with no technical loss in either. Federal regulatory documentation in English; coordination with local sponsors, contractors and Puerto Rico agencies in Spanish. The firm considers bilingualism a structural competitive advantage, not an add-on.

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