1. developer decides to build houses, or units.
2. developer approaches an Approved Participant to assist in placing a submission/tender to FAHCSIA to have some of their developments allocated an NRAS approval. ( developers cant approach or apply for NRAS allocations themselves- all submissions must be done by an approved participant. You'll understand why when you read points 5 and 6) The approved participant charges the developer a fee for this service.
3. Approved participant tenders for X amount of NRAS allocations in one of the tender rounds.( ie round 1, 2, 3 , 4 etc... ) on behalf of the developers who have approached them and paid them to do so.
4. FAHCSIA allocates X amount of NRAS allocations to whichever development projects is determines to be suitable for the scheme. This is an ongoing process as each round of the tender process takes months to run its course and for the Govt to announce which developments it will allocate NRAS to. This is why you keep seeing new NRAS properties appear, and its why there is no single website where all NRAS stock can be viewed.
5. This is where it gets confusing so read this bit twice..
Once the NRAS allocations are awarded by FAHCSIA, there is no prescribed model for how they must be sold to investors. So, some developers retain the services of the approved participant to market and sell their NRAS stock for them. Some developers do not. Instead, they retain real estate agents or property marketing firms or do direct sales themselves. This is why you are seeing a wide variety of companies popping up on google searches, selling NRAS property. BUT remember, just because they are selling NRAS property does not mean they are an approved participant.
6. Meanwhile, whether you buy the property through an agent, a marketing firm, from the developer directly, or from an approved participant...someone must make sure the scheme is administered and someone must make sure the NRAS property remains legally compliant so that the investor can collect their NRAS tax incentive at the end of the financial year. Once again, this is the role of the approved participant. Not the developer, not the selling agent. Only an approved participant is authorised to administer the scheme and advice the Govt which properties have been compliant. ( ie- rented at 20% below market value, and tenanted by people who are within the prescribed income thresholds to qualify for discounted NRAS accomodation)
Obviously, this is why the approved participants need additional documentation signed by the borrower/investor, when purchasing the property... as they are effectively partners in the transaction. This led to different models evolving- ie head lease agreements, managed investment schemes and non entity joint ventures... and this in turn led to confusion amongst lenders, as there are just so many different models amongst the approved participants, and its why you have seen banks not want to get involved in NRAS lending.
However, the good news is that most the approved participants have figured out that a Head Lease is basically useless, and they need to go with a NEJV. banks are starting to look at NRAS again as a result, and just last week ST G announced they will take NRAS deals to 70% LVR without LMI, and 85% with LMI for one consortium/approved participant based in Qld. Again, I wont name names, but if you google Queensland NRAS there arent many results to choose from, so it wont take you long to figure it out.
Hope this clarifies most or all of your questions...