Now is the time, she says, to invest with the expectation of maximum tax benefits. "It doesn't preclude you from investing after 2019," she adds, "but the value of the benefit will be diminished enough that it may lessen the pool of willing investors."

KeyBank's own $50-million Qualified Opportunity Fund closed at the end of 2018. To date, "we've invested in four affordable housing projects, in Colorado, Ohio, Connecticut and Massachusetts."

The bank invested on its own account, with "a capital gain from the sale of a business unit," she says. "We don't generate capital gains in the ordinary course of business, so our ability to actively contribute to this space as an investor is limited going forward. Where Key can provide value is project level debt financing as well as acting in an advisory capacity to refer interested investors to reputable firms that are putting together funds."

Seamons reports that a lot of the activity she sees is in the form of funds created, but not a lot of deals closed. "The deals we've seen close have been deals that have been baking for a while in which the principals realized that they're in an opportunity zone and could qualify for this incentive."

While estimates vary from over $2 trillion to over $6 trillion in untapped capital gain potential from 2018, the deployment of that capital toward opportunity zone investment is really a question of the investor's appetite for risk. Interested investors should always seek tax and legal advice before investing.

And therein, she says, lies one of the greatest misconceptions about the opportunities in opportunity-zone investment. "It doesn't make a bad deal good," she says. "If the deal doesn't pencil, it's not going to move forward. Just the mere fact that it's in an opportunity zone is not going to make the deal work."

There are essentially two potential market participants, she explains. "You have the developer, who's trying to put a project into the ground and they need third-party capital to get it moving, and you have the investor that has the capital available to invest"

In terms of the latter group, there is a bit more clarity now that new Treasury guidance has been proposed. "Early on there was some confusion about what type of gain could be included, for example," she says. The emergence of the second tranche of guidance has provided further clarification and flexibility to help get investors off the sidelines.

Going forward, Seamons sees market activity ramping up, especially given the above-mentioned deadlines. "I expect the second half of this year will see a flurry of activity."