The Capital Stack
Most Streamlined Affordable (EDI / SB 35 / AB 2011) deals layer several sources rather than a single loan:
- Construction loan (bank, CDFI, or mission-focused lender)
- 4% or 9% LIHTC equity
- Tax-exempt bond financing (for 4% deals)
- State soft debt: HHAP, NPLH, AHSC, or MHP depending on project profile
- City / county soft debt (trust funds, linkage fees, HOME, CDBG)
- Sponsor equity and deferred developer fee
Why the approval pathway changes the financing conversation
A ministerial approval removes the single biggest source of construction-loan timing risk on affordable deals: entitlement uncertainty. Lenders who understand ED1, SB 35, and AB 2011 will often quote a shorter rate lock and a tighter construction contingency because the approval risk most banks price into affordable ground-up is largely gone. The gap that remains is capital stack complexity, not entitlement risk.
The stack underneath the entitlement
The entitlement pathway doesn't finance the deal by itself. Most ED1 and SB 35 projects still layer a construction loan against 4% or 9% LIHTC equity, tax-exempt bond proceeds on the larger 4% deals, and two or three rounds of state or city soft debt (HHAP, NPLH, AHSC, MHP, local trust funds) to close the gap between hard costs and permanent debt capacity. The ministerial approval buys time and certainty; it doesn't buy equity.
For the full program mechanics, see our deeper guide: Program Deep Dive →