Paying for a Non-Federal Share in Pictures

1. A non-federal asset is created when a non-federal participant pays for a share of a federally involved project with upfront cash from non-federal sources, right?

2. If the non-federal participant finances the same share by issuing a federally subsidized tax-exempt bond to be repaid from non-federal sources, that’s OK too, right? The cost share is still a non-federal asset, yes?

3. But if the non-federal participant finances 49% of the same share with a federally subsidized WIFIA or CWIFP loan to be repaid from non-federal sources, that’s — not OK? The cost share is now not a non-federal asset, but a federal asset, because — why, exactly?

4. Because the current WIFIA Criteria say so?

“Ineligibility first — application of FCRA principles afterwards!”