Important note
The Moderate-Income Revolving Loan (MIRL) program is a voluntary affordable housing development program in which cities and counties (“Sponsoring Jurisdictions”) may choose to participate. It was created by Senate Bill (SB) 1537 (2024), sections 24-36, and amended by SB 48 (2025), which took effect on September 26, 2025. Oregon Housing and Community Services (OHCS) has developed a
toolkit to assist Sponsoring Jurisdictions in implementing the MIRL program. This guidance is one component of that toolkit.
This guidance is intended to provide a starting point for Sponsoring Jurisdictions as they process MIRL Project Applications in accordance with Section 26 of SB 1357. Sponsoring Jurisdictions are not required to use this guidance. This guidance reflects OHCS’s understanding of the requirements of the MIRL program, but it is not comprehensive, and it will need to be tailored to reflect any jurisdiction-specific practices or requirements.
This guidance is not intended to, and does not, provide legal advice. Sponsoring Jurisdictions are responsible for ensuring that any projects they approve for MIRL funding comply with SB 1537, SB 48, OAR chapter 813, division 410, and any other applicable local, state, and federal laws.
MIRL Underwriting Guidance
As a Sponsoring Jurisdiction is reviewing a MIRL project application, it should consider the following, at minimum, before provisionally approving any project:
- Project meets the statewide and local requirements of the MIRL Program
- Project application is complete; and
- Project’s feasibility/risk is tolerable to the Sponsoring Jurisdiction, especially in relation to the size of the program loan.
OHCS recommends the Sponsoring Jurisdiction establish processes to assess the above aspects of project applications. Sponsoring Jurisdictions ultimately are responsible for ensuring that the program loan is repaid to OHCS. Thus, OHCS recommends the Sponsoring Jurisdiction diligently assess the feasibility and risk of a project before provisionally approving it.
OHCS recommends that a Sponsoring Jurisdiction consider incorporating a comprehensive financial and risk analysis into its evaluation of project applications. A Sponsoring Jurisdiction may approach its financial and risk analysis in any manner consistent with statewide and local MIRL Program requirements. The MIRL Program does not have specific requirements around underwriting but as required in section 26(1)(a)(E), the proforma is required to demonstrate that the project would not be economically feasible but for the receipt of MIRL funding. If an underwriting process is used, the Sponsoring Jurisdiction may want to consider the following:
- Does the project have the appropriate permitting approvals in place to proceed with this development? If not yet in place, do they have proof of process?
- Does the project have an assembled capital stack that makes sense, and is there supporting documentation?
- Example: The other grants that will be received and those grant agreements attached
- Example: Proof of interest/intent from private lenders
- Has an environmental assessment been completed and is the property suitable for development? If there are any issues, what mitigating plans are in place?
- Are the costs reasonable?
- If early in the process, the Sponsoring Jurisdiction may consider asking for some form of estimate. This may include a narrative or preliminary pricing from a general contractor, and/or cost estimates based on a similar project.
- Has the development team sought an Oregon Bureau of Labor and Industries (BOLI) coverage determination inclusive of a potential MIRL grant?
- Does the developer have a history of successfully completing residential real estate development projects?
- Can the developer provide some level of architectural drawings or site plan?