A panel of two prominent tax equity investors and two prominent lenders talked at the CLEANPOWER 2026 convention in early June in Houston about the latest rumors and other changes this year in the market for financing renewable energy projects.
The panelists are Elizabeth Waters, managing director for project finance, Americas, with Japanese bank MUFG, Rubiao Song, head of tax equity for JPMorgan, Jon Peeples, head of tax equity and project finance lending for US Bank, and Greg Hutton, head of project finance Americas for Dutch bank Rabobank. The moderator is Keith Martin with Norton Rose Fulbright in Washington.
The panelists used three key terms. "FEOC" stands for "foreign entity of concern" and is a set of three restrictions that took effect on January 1 this year in an effort by the US Congress to move the US renewables sector away from Chinese equipment, Chinese equity, debt and participation in management, and use of Chinese intellectual property. "Legacy" tax credits are federal tax credits claimed on renewable energy projects that were under construction for tax purposes by the end of 2024. "Technology-neutral" tax credits are tax credits on projects that started construction more recently. The FEOC restrictions are an obstacle to claiming technology-neutral tax credits but not legacy tax credits.
MR. MARTIN: There have been news reports that lenders and tax equity investors are reluctant to finance projects on which technology-neutral credits will be claimed until the Treasury issues more FEOC guidance. Are you seeing a slowdown?
MS. WATERS: I don't think I personally have had any projects come to me yet for financing that will claim technology-neutral tax credits and have FEOC risk. I am doing financings currently of projects on which legacy tax credits will be claimed.
We are looking at FEOC. Developers have been questioning us since at least September last year about whether we have FEOC problems as a bank. We have had to represent that we do not. Banks do not typically make representations, but developers are concerned about FEOC.
MR. MARTIN: So you will finance projects on which technology-neutral tax credits will be claimed, but you have not had to do that yet?
MS. WATERS: Correct. We will do our due diligence to make sure the FEOC restrictions are not an issue. We have to be careful when making tax credit bridge loans – we’ll need to have certainty that tax equity will not have FEOC problems with the deal.
MR. MARTIN: The FEOC statute has been available to read since it first started taking shape in the House in May last year. People have had a lot of time to read and reread it. My own copy is badly dog-eared at this point. Are you feeling comfortable about FEOC?
MS. WATERS: I would ask my lawyers to review the sponsor due diligence relating to FEOC to get us comfortable.
MR. MARTIN: Rubiao Song, is JPMorgan stepping back from financing projects on which technology-neutral tax credits will be claimed?
MR. SONG: I would not say we are stepping back. Most deals at which we are looking at today still qualify for legacy tax credits, so FEOC is not an issue.
Would we finance projects with technology-neutral tax credits? We have closed a few, and we are looking at a few others in the deal pipeline. The ones we closed are with the kind of investment-grade sponsors who are very comfortable with their own FEOC status and also very comfortable with JPMorgan's FEOC status.
We are encouraging our sponsors with technology-neutral deals in the pipeline to do a lot of homework before they come to us. They can do a preliminary due diligence memo on the sponsor side. We encourage them to share that with us as it will help our counsel with our diligence.
MR. MARTIN: Are you comfortable with your own FEOC status as a bank?
MR. SONG: I am very comfortable.
MR. MARTIN: Have you made any legal representations to sponsors?
MR. SONG: No. There is not enough IRS guidance to say definitively that we will be FEOC compliant.
MR. MARTIN: Jon Peeples, are you still in the market for technology-neutral tax credit deals?
MR. PEEPLES: Yes, we are. That said, we are ultra selective about the deals that we do. We prefer legacy deals, but we have longstanding partnerships at the bank. US Bank is a relationship-based bank. Like Rubiao said, if we feel comfortable with the sponsor, we can underwrite that.
We do the diligence. We expect sponsors to share a significant amount of diligence with us and not just to pound the table and insist we rely solely on a representation.
MR. MARTIN: Do you have any doubt about whether US Bank is a prohibited foreign entity?
MR. PEEPLES: I am not going to opine on that, but we work closely with our counsel to ensure that we are not doing anything in a transaction that would be contrary to what the bank believes. We are a US-based publicly traded bank.
MR. MARTIN: Do you represent that you are not a FEOC entity?
MR. PEEPLES: Every deal is different. We work with internal and external counsel to understand what everybody needs to be comfortable with us as a tax equity investor or a lender and adjust accordingly.
MR. MARTIN: Greg Hutton, is Rabobank still financing deals with technology-neutral tax credits?
MR. HUTTON: Like the others, we are still working through the legacy tax credit deals. We are not averse to financing projects on which technology-neutral tax credits will be claimed, but we will rely on the diligence by the borrower and of our own counsel and other advisers to confirm FEOC compliance.
To anticipate your next question, we have made qualified FEOC representations in recent deals. We are an interesting animal. We are a cooperative bank headquartered in the Netherlands and do not technically have any shareholders or private owners. That said, there are some debt-related definitions that are not fully nailed down yet in the statute and existing IRS guidance. For example, should a depositor that has limited member rights in a cooperative in the Netherlands, but that is a FEOC entity, trigger concerns at our level?
MR. MARTIN: Beth Waters, how else would you describe the market this year?
MS. WATERS: It is still insanely busy. Everyone is just trying to keep up with the pace. If someone takes a vacation, it is a major challenge. We keep having bigger years over prior years at our bank. We don't just finance power projects. We also finance infrastructure projects, including data centers, and natural resources. It is crazy busy. There is no lack of business.
MR. MARTIN: The US is expected to install 86,000 megawatts of new electric generating capacity this year, with 93% of it coming from solar, wind and storage. The irony of the Trump administration trying to squash renewables is renewables have become turbo charged, which should not be a surprise. It you accelerate the end dates for tax credits, then people work a lot faster.
Do you have a date in mind after which you can relax? There is a tax deadline to start construction of remaining wind and solar projects by July 4 this year.
MS. WATERS: No. It is nonstop.
MR. MARTIN: Rubiao Song, how would you characterize the market this year?
MR. SONG: I agree with Beth. We are very busy as well. But we do let our juniors take vacations. We have a few sitting in the back row in the audience.
MR. MARTIN: So this is their vacation? [Laughter]
MR. SONG: Our pipeline of 2026 and 2027 deals continues to grow. We are doing more dollar volume, but on the same number of deals. The deal sizes are getting bigger. Our average deal size probably doubled in the last few years.
MR. MARTIN: What is the minimum deal size someone must bring you to be of interest?
MR. SONG: Two to three hundred million.
MR. MARTIN: That is the tax equity investment?
MR. SONG: That's right.
MR. MARTIN: It is already June 2. Is it too late to talk to you about a tax equity financing that has to close this year?
MR. SONG: It is probably not too late, but we are already largely committed for the year. There may be special exceptions.
MS. WATERS: Beth Waters, is it too late to talk to you about a loan this year?
MS. WATERS: Never too late. To pick up on a point Rubiao made, we have weekly marketing meetings where we all talk about our deals. They have been getting bigger. A lot of the deals are now mega deals in the billions of dollars. The data center deals are enormous.
MR. MARTIN: Jon Peeples, let's stipulate that everyone is extremely busy. Is there anything else you see in the market this year?
MR. PEEPLES: The deal sizes have definitely gotten a lot larger over the past few years. The tax equity check sizes are much larger. We still focus on relationships. If there is a deal that is smaller than the average, we can still do it if it makes sense for the bank.
We are paying a lot of attention to exposures to specific sponsors, given how large deals have gotten.
The different tax credit adders that people are financing -- domestic content, energy community, low-income bonus credits -- are contributing to the larger deal sizes.
MR. MARTIN: You have to be an expert in carbon capture, renewable natural gas and other clean fuels, manufacturing, solar, wind, storage and various bonus credits.
MR. PEEPLES: Correct. We might be a bit different from other tax equity investors. We will do straight sales of tax credits. We are also still doing traditional tax equity partnerships. The direct sale could be of section 45X tax credits for manufacturing solar, wind or storage equipment.
MR. MARTIN: Greg Hutton, how would you characterize the market this year?
MR. HUTTON: We are also extremely busy and seeing larger deals. All of that.
In addition, the tax credit cliff of July 4 has been driving a lot of equipment purchases this year. We have seen an uptick in demand for equipment supply loans. We have a value-chain finance option out of another team that has been getting considerable traction with developers.
The diligence has also been a lot heavier on FEOC, tariffs, supply chains and permitting, and the deals take longer to close on account of the extra diligence.
MR. MARTIN: Jon Peeples, what is your minimum ticket size?
MR. PEEPLES: We don't necessarily have a minimum ticket size, but we do have a human resource constraint.
It all comes down to our relationship analysis. Is it a new technology? Does it make sense to do something small just to get our feet wet? Or does it make sense for the relationship? Is there an opportunity to co-market another project finance product as well?
MR. MARTIN: Are your younger analysts vacationing here like the JPMorgan analysts?
MR. PEEPLES: I will say our younger analysts find way cooler vacations than I ever took, that's for sure. But they're not here now.
MR. MARTIN: Greg, minimum ticket size?
MR. HUTTON: We are probably a little lower. Anything below a final hold of $75 million is hard to justify. We have done underwritings of as much as $1 billion, and our average underwriting is in the $200 to $300 million range.
MR. MARTIN: President Trump is bent on erecting a new tariff wall by the time his 10% across-the-board tariffs expire on July 24. The 10% tariffs were struck down by a lower court on May 7, but he is still able to collect them while the decision is being appealed.
How is the threat of additional tariffs factoring into deals? Just before midnight last night, the US Trade Representative announced a potential 25% tariff on Brazilian products.
MS. WATERS: It is just one more thing contributing to the additional diligence we have to do on deals.
The lenders will not take tariff risk. We are focused on who will pay the tariffs. The sponsors negotiate a split with the equipment suppliers. Many of the suppliers are not big companies with deep pockets to pay unexpected tariffs. The developer has to cover some. Some tariffs might be passed to the EPC contractor. The split among the parties varies from one deal to the next.
We also look at how much has been set aside in a contingency account to cover cost increases. It needs to be big enough to cover unexpected tariffs.
MR. MARTIN: How do you address the countervailing and antidumping duties that the administration imposed this spring on Indian and Indonesian solar panel imports? Some of them are as high as 234% and are retroactive to November 28 last year. How do you deal with that as a contingency?
MS. WATERS: We have to take a view on what is the maximum possible hit and build it into the contingency.
MR. MARTIN: Does anyone have a different answer on tariffs than what Beth just said?
MR. SONG: Not a very different answer, but the flip side is we know that IEEPA tariffs that were struck down by the Supreme Court in February will be refunded.
MR. MARTIN: One hopes. Customs and Border Patrol said it has refunded $20.6 billion through May 22 out of $166 billion in total. No process has been set up yet to refund 37% of the tariffs that were collected. The administration asked a US appeals court today to spare it from having to refund tariffs on imports that were already liquidated by the time the Supreme Court ruled on February 20. Imports are usually liquidated 314 days after entry.
MR. MARTIN: How is the Iran war affecting financings, if at all?
MR. HUTTON: We do not see direct effects currently, but there are indirect effects for US projects. A lot of the equipment is coming via Pacific routes or Atlantic routes. Closure of the Strait of Hormuz will not stop the flow of equipment, but there are logistical challenges from so many vessels being tied up, raising shipping costs. Increasing fuel costs will also contribute to the higher cost of shipping components into this jurisdiction.
MS. WATERS: An effect of the Iran war is interest rates have become more volatile day to day. We are seeing more developers entering into deal contingent hedges and swaptions to manage the risk.
MR. MARTIN: What is the difference between a deal contingent hedge and an interest rate hedge?
MS. WATERS: A deal contingent hedge is an option to walk from a loan if the interest rates move against you. It is an option not to draw on the loan. It does not have to be exercised. I don't know if Greg wants to try to describe them.
MR. HUTTON: They are a form of hedging before the construction period starts to lock in the interest rate. [Editor's note: For more information on such hedges, see here.]
MR. MARTIN: Let me ask the tax equity investors a few questions.
In the last few months, the big law firms have been overwhelmed with requests to bless construction-start strategies that nobody would have blessed in the past. They are being asked to bless physical work at factories not just on main power transformers, but also on medium-voltage transformers, tracker parts, inverters, inverter skids, racking for rooftop solar installations, wind turbine drive trains, $95 magnets and similar items. Have you drawn any lines on what you will tolerate as the start of construction?
MR. PEEPLES: I can start. It is interesting to hear you say "currently" because we have seen some very interesting strategies over the years. When a lot of us were getting into the industry, we didn't think we would be semi tax attorneys by the end of our careers, but we do a lot of analysis with our external law firms. We do not have firm lines in the sand, but we like to remain as close to the center of the fairway as possible.
MR. SONG: I echo that. We look at what the physical work is and the significance of the item to the project.
MR. MARTIN: Do you require a minimum dollar amount of physical work?
MR. PEEPLES: We do not.
MR. SONG: We don't either. It is a matter of knowing it is significant when you see it. Increasingly we are seeing the physical work done on site.
MR. MARTIN: A Supreme Court justice, Potter Stewart, said obscenity was too hard to define in words, but he knew it when he saw it. This is the Song corollary: you can feel it when the work is not enough.
Are all your tax equity partnerships today hybrid partnership flips where the partnership sells most or all of the tax credits?
MR. PEEPLES: We still do our traditional partnership flip structure. We can elect to sell the tax credits in conjunction with the sponsor. The bank likes the flexibility to decide later what share of the tax credits to sell. We have a robust team within the bank that does a lot of tax credit transfer transactions with corporate clients of the bank.
In the majority of our transactions, there is no liquidity or price risk to the sponsor when we sell the tax credits. We stand in front of the tax credit buyers, allowing them to rely on the bank versus the sponsor. There is no need to guess at the future price at which tax credits might be sold. It does not affect the sizing of our tax equity investment.
The transfer market is a little softer now than it was before. That is a risk that the bank wears.
MR. MARTIN: We are seeing tax credit prices come down by perhaps 2¢ per dollar of tax credit this year. What do you think is causing that?
MR. PEEPLES: There are a lot of credits for sale. There is a range of prices.
MR. MARTIN: So demand for credits is not keeping up with the supply? Reunion, a digital sales platform, checked the securities filings by the Fortune 1000 corporations and found that 8.5% of them bought tax credits last year compared to 4.9% the year before.
MR. PEEPLES: It is everything we have been talking about here. You have a CFO or treasurer who has to be educated about FEOC risk and construction-start issues. Understanding these risks is not their day job. They are taking personal reputational risk inside their companies, so there is a lot of education involved when transferring credits. The list of potential issues means it takes longer to bring a new buyer into the market.
MR. MARTIN: Rubiao Song, JPMorgan has its tax equity partnerships sell a large share of the tax credits. Are you seeing a softening in prices and, if so, how much?
MR. SONG: There are different flavors of hybrid deals. In some such deals, we go in knowing that a certain percentage of the tax credits will be sold and we view our tax equity investment to that extent as an advance against the future sale of those tax credits.
In some deals, the sponsor decides what tax credits it wants the partnership to sell and the cash sale proceeds are distributed largely to the sponsor.
The model chosen has a bearing on who takes the price risk for the tax credit sale.
It is a negotiation with the sponsor which model better fits into its overall financing strategy.
We see a difference in pricing between ITCs and PTCs. ITCs trade at lower prices because of the recapture risk. Prices are also affected by whether there is tax insurance or an investment-grade counterparty behind the indemnity. Some price gaps are due to different perceptions of risk among the buyers, particularly buyers that are new entrants.
MR. MARTIN: We are seeing a dozen cash investors get traction for preferred equity partnerships that have the effect of stepping up tax bases for ITC projects. How should a developer think about doing a hybrid partnership with you compared to a preferred equity partnership with a cash investor that cannot use the tax benefits?
MR. PEEPLES: Sponsors have certainty that tax equity will fund whether or not we transfer the tax credits. In many preferred equity partnerships, the onus is on the sponsor to find a buyer for the tax credits.
MR. MARTIN: So you will handle the tax credit sale?
MR. PEEPLES: We do it all on our side. There is no risk to the sponsor whether or not the tax credits are sold. We fund when a series of conditions precedent to financing have been met.
MR. MARTIN: Rubiao, why do the financing with you rather than with a preferred equity investor?
MR. SONG: It is an arbitrage play on step ups between the preferred equity investors and the traditional tax equity investors.
We do rigorous diligence. We have been in this business for more than 20 years. We have never had the IRS visit. We feel comfortable with the positions we take.
We like to do repeat deals with sponsors. We are not interested in one-off deals. Once you pass our sponsor due diligence, we will support you year in and year out. Our sponsors can count on us being there to provide the financing they need on a long-term basis.
MS. WATERS: Can preferred equity and tax equity be in the same deal? I could swear that I am in a couple tax equity deals where there is also some preferred equity.
MR. PEEPLES: You can have preferred equity structures behind tax equity. For those deals, we would have extra scrutiny in terms of overall step up.
For example, we see some joint venture structures where there is a transaction with a preferred equity investor before the assets are moved into tax equity partnership. Those deals require an initial conversation to understand the structure and whether it works for us. We would call that a stacked step up and introduce a lot more scrutiny into how we would finance it.
MR. MARTIN: Let me go to the lenders next. Beth, you heard that tax credit prices are softening. MUFG has been making tax credit bridge loans that assume for purposes of pricing that the tax credits can be sold for at least 90¢ on the dollar. Are you revisiting that assumption in the current market?
MS. WATERS: No.
MR. MARTIN: Greg, is Rabobank making tax credit bridge loans and, if so, are you revisiting the price assumption?
MR. HUTTON: We are making such loans, and we are not revisiting the pricing. We lend 75% of the projected sale proceeds assuming the credits will be sold for 90¢ per dollar of tax credit. This is the pricing for uncovered loans where the buyer has not been identified yet.
I have seen a case where the price assumption was slightly lower, but that was a reflection of the sponsor's inexperience in the transfer market. There was a further discount to the floor price of the transferable credit.
MR. PEEPLES: The softening we are talking about is a 1¢ to 2¢ difference. What happened in the second half of 2025 is corporate buyers were uncertain about their own tax liabilities in the wake of the One Big Beautiful Bill Act, so they waited. There was a softening in the second half of 2025.
We saw those buyers in the market in Q1 this year looking for 2025 tax credits. Some were disappointed because they could not find the right credit or right amount. We saw prices go up in Q1. We have not seen a further softening from the Q1 prices.
MR. MARTIN: Let's talk about the effect of data center demands for capital. The North American project finance debt market was a $260 billion market last year. Data centers were a growing part of that.
Oracle has a $300 billion contract with OpenAI to do data center construction. The banks that underwrote the first $38 billion loan against that contract have been having trouble placing the last bit of loan paper.
The voracious data center demand has to affect the ability of mid- and smaller-sized developers to raise capital. Are you seeing such an effect and, if so, what are the signs?
MS. WATERS: From a high level, we keep an eye at MUFG on our exposures to different sectors -- what you can call buckets of exposure. We like to be diversified. We have a data center bucket, a power bucket, a natural resources bucket, and so on. I have heard that some banks are getting close to their limits on exposure to the data center sector.
Our data center exposure does not affect the amount of capital we have allocated to the power sector. Lending to renewables and power remains very busy. There is lots of demand, and we and other lenders are more than happy to continue lending to finance power projects.
What starts to happen is that banks only have so much human capital and you can't spread yourself over all deals shown to you, so you look at the lowest hanging fruit that provides the biggest bang for the buck. That is what banks are starting to do by prioritizing the deals they want to pursue.
Our bank has a really big team. We can look at and work on a lot of deals, but most banks do not have that many people. They have to choose.
MR. MARTIN: Greg, is it becoming harder for smaller and midsize developers to get capital given the competition from data centers?
MR. HUTTON: I don't have statistics on it, but resource constraints are affecting how deals are selected. There is a commercial aspect. We want to bank bigger clients, use more products for those clients, help them do more and help them grow. A lot of the risks we have been talking about -- the permitting risks, FEOC risks and tariffs -- are risks that the bigger sponsors with the bigger balance sheets can weather a lot better.
From a credit risk perspective, even though we are financing on a non-recourse basis, we are also looking at the strength and the wherewithal of the sponsor to stand behind the projects if necessary.
So yes, I think I see the smaller and medium-sized developers struggle more to raise capital, but it is really a flight to bigger investors and scale rather than a flight to quality. There are lots of high-quality, small and medium developers.
MS. WATERS: The other factor that plays into this is the pipeline of opportunities. At the Infocast conference in Phoenix in March, I commented during a panel that we are happy to start business with smaller developers because we are going to grow with them and that is important. But having a pipeline is super important.
I have known one developer for 15 years. I helped educate the developer in the project financing side of the business, but the company has always been too small for us. It brought me a deal this year, and it was finally of a size that we could do. We are going to do the deal, but because we have so many other deals in front of us, I have to make a minimum income; otherwise, our management will insist we move on. So I told the client, we can do it, but this is what you will have to pay me. It was okay with the proposed fees, and we are now targeting to close at the end of the month.
MR. MARTIN: We ran an article in the Project Finance NewsWire years ago called "How to Lose a Banker in 10 Minutes." One way is to say we are a four-person development shop and we have a pipeline of 15 projects. Another is to use a gmail address. [Editor's note: the full article can be found here.]
We have covered a lot of ground this afternoon. What else would a developer who was last in the market for financing two years ago notice has changed when coming back into the market this year?
MR. HUTTON: It is everything we talked about on this panel. There are more diligence requirements. There is more scrutiny on the issues we discussed.
MR. MARTIN: Beth Waters, same answer?
MS. WATERS: Deals take longer. A loan will take a minimum of 12 weeks to close. We have some deals that have been in process for a year. I create a very detailed timeline for clients that says you need to do this in order to do that. We create a Gantt chart. It is a series of deadlines that helps guide everyone.
MR. MARTIN: Has there been any change since January in spreads above SOFR for borrowing or in the required debt service coverage ratios for loans?
SOFR itself was 3.75% at the start of January and is down slightly at 3.63% today. [Editor's note: the spreads and required debt service coverage ratios in January can be found here.]
MR. HUTTON: You would think there would have been some change given the competition for capital from data centers and the growing complexity with tariffs, FEOC and all the other things we have been talking about. It is also no secret that some operating projects are having issues. A lot of banks are seeing that.
You would think that spreads would increase relative to other types of assets, but they have not.
The debt service coverage ratios have also not moved.
Banks are holding the pricing steady for the larger, more experienced developers.
The differences are coming in the nuances of structure, in the diligence, the way risks are handled through additional covenants and other things like that.
MR. MARTIN: Beth, same answer?
MS. WATERS: The best sponsors can sometimes push the envelope on the starting margins. The more complicated the deal and the smaller the sponsor, the more likely that pricing will be at the higher end of the range.
I checked the numbers before coming here today because you always ask this question and found nothing has really changed in the last six months.
MR. MARTIN: Let's go back to a few general questions for the group as we wrap up. Last year was exhausting. We have talked about how busy this year is. What do you expect for 2027?
MR. PEEPLES: I expect it to be the same.
MR. SONG: I expect it to be busy.
MR. HUTTON: That's the first time someone has asked me about 2027 and it is only early June. I expect it to be the same. There are still a lot of projects on which legacy tax credits will be claimed.
MR. MARTIN: Crux, another digital platform, estimated that there are 170,000 megawatts of solar and wind projects that will have been grandfathered for tax credits and will be rushing to finish by as late as the end of 2030, which is two years past the Trump administration.
When do you think gas-fired power projects will start to account for a large share of the new capacity additions?
MS. WATERS: There are already such deals being done, mostly with data centers. Our bank is financing them, sometimes as part of data center financings and sometimes as separate financings. There are eight of us managing directors heading US power deal teams within MUFG. I think almost everybody has already closed a gas-fired deal.
MR. MARTIN: I assume these are with gas reciprocating engines or fuel cells rather than large turbines?
MS. WATERS: Yes. We are transitioning to the larger gas turbines. They take up to five years to receive after signing the purchase order, so we will not start to see those until 2029 or 2030. Some projects start with reciprocating engines with the plan to replace them with larger gas turbines later.
MR. PEEPLES: We just closed our first gas-fired deal in a long time. It was project finance debt rather than tax equity.
MR. MARTIN: When do you expect to see small modular nuclear reactors?
MR. SONG: We are not expecting them until the mid-2030s. We expect to see repowerings of large nuclear plants or even some new construction with AP1000 reactors before we see any large-scale SMRs.
MR. MARTIN: Some developers have shifted focus and are developing power sites that offer a power supply where a new data center can plug in. Are you financing power sites?
MR. HUTTON: We are seeing that kind of one-stop shop development, but we are not involved in any early-stage financings of power sites. There is room for a full solution including the data center. We would finance that with the right credit behind it.
MR. MARTIN: Does it matter if the power source is fully behind the meter and not grid connected?
MR. HUTTON: We do an analysis of the resilience of the system and the redundancy to get comfortable that the power will be there to support the data center.
MR. MARTIN: All of you are feeling overworked because there so many different types of assets and transaction structures that you are having to spend time studying.
Is there anything else interesting about the market that we failed to mention? We have less than a minute left.
MR. SONG: You asked the question earlier about what a sponsor coming back after two years would notice has changed. There is a more complicated tax qualification story.
Our investment committee spends the first 15 minutes just understanding which tax credit is involved. For example, it is a legacy credit, there are wage and apprentice requirements, there are issues around bonus credits, and so on. We need the sponsors to have done their homework fully and get experienced counsel who can demonstrate that their projects qualify for these credits. This not just important, it is critical.