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NMTC Working Group

About the Group

The members of the NMTC Working Group are participants in the NMTC industry who work together to help resolve technical regulatory and administrative NMTC Program issues and provide recommendations to make the NMTC Program even more efficient in delivering benefits to qualified active low-income community businesses.

Novogradac & Company LLP has taken the lead to coordinate the efforts of the group. Novogradac & Company LLP also provides expertise and administrative support to the group.

Each month, members of the group participate on a conference call hosted by Novogradac & Company LLP, led by Michael Novogradac, its managing partner and Brad Elphick, partner in the Metro Atlanta office. Members are encouraged to participate in discussions and provide input regarding pending action items as agreed to by the members of the group. Novogradac & Company LLP also hosts a NMTC Working Group meeting at a scheduled time at each of its national NMTC conferences. Comments and suggestions are agreed to and submitted in writing directly to the IRS, CDFI Fund and other agencies based upon the group discussions. Michael Novogradac and Brad Elphick report back to the group information they have received from follow-ups with the IRS, the CDFI Fund and other agencies regarding the submissions.

Priority Issues

The NMTC Working Group's recommendations address priority issues including but not limited to the following:

  • Current and proposed regulations
  • The latest NMTC Program Allocation Agreement
  • The latest NMTC Program Allocation Application
  • Development of industry recommended practices
  • The latest version of CIIS
  • Updates to the NMTC Mapping Tools created by the NMTC Working Group

Addressing these issues as a group, provides the CDFI Fund and IRS with very concise suggestions and comments on global issues from a broad spectrum of the NMTC industry. These are only a sample of the priority issues of the current members of the NMTC Working Group. As new issues arrive or new guidance is provided, the group's direction and priority often change in order to address the most important topics in a timely manner.


Membership in the NMTC Working Group offers a number of important benefits:

  • The Working Group provides a platform where members can collaborate on similar issues in an effort to solve them together.
  • Members effectively share the costs of resolving similar issues more efficiently as a group rather than having to pay for them individually.
  • The NMTC Working Group is one of the most widely recognized groups in the NMTC industry. Our comment letters are often cited by the CDFI Fund and IRS when discussing industry response.
  • Members are able to participate directly but have their ideas and suggestions included anonymously in letters submitted to governmental agencies.
  • Members gain direct access to the CDFI Fund and the IRS – Brad Elphick and Mike Novogradac have built a relationship with these and other agencies within the Treasury Department and have regular calls and meetings to discuss program issues and ways to address them.
  • Members have the opportunity to keep abreast of emerging issues and provide input for recommended practices in the industry.
  • Members gain access to tools created specifically to make it easier to map a project's location to determine its qualification, application tools, and investment threshold tools.
  • Members gain access to provide input for solutions to issues affecting the industry as a whole.
  • Members gain access to Mike Novogradac's congressional update on issues as they happen.
  • Members are invited to Working Group only networking events and monthly meetings/conference calls at each of the three annual Novogradac NMTC conferences.


For information regarding the group and how to become a member, complete this form or contact Brad Elphick at (678) 339-3675 or [email protected]. Once becoming a member, you will have access to the Members Only portion of the website which houses all prior comment letters, recommended practices, and other resources including annual NMTC Allocation Application tools, allowing you to review and comment on current action letters, review a recap of prior calls and meetings, and interact with other members.

The fee for each member is $5,000 for 12 months.

Membership fees cover the time incurred by Novogradac & Company LLP professionals to research, collaborate and prepare written and verbal communications to the respective agencies. Each month, Novogradac & Company LLP updates the group on the status of each issue and the necessary actions to address them.

Public Input

The NMTC Working Group does consider input from non-members when drafting of comment letters, recommended practices and other content. To submit input on a new markets tax credit topic, contact Brad Elphic at (678) 339-3675 or [email protected].

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