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1995-08-29 (Report) (3) ... u PART 3. Summary of Subcommittee meeting with Jim Williams 3-] SUMMARY OF SUBCOMMITTEE MEETING JUNE 1995 The Housing Subcommittee, composed of Board Members Bond and Hano, met with staff' (Director Holder, Coordinator Brown, and Assistant City Manager Benson) and Consultant Jim Williams to discuss a housing program for the City. Issues were raised regarding the scope of the program, staffing requirements and methods of financing. The primary areas of the discussion were: . Primary citizen group to be assisted . Method of obtaining housing assistance programs . Private or public ownership . Methods of financing the housing program · Staffing requirements and City costs for a housing program. Citizen Group to be Assisted Rental housing programs can focus their assistance to families, senior citizens or both. When the focus is on families, the rental unitio are usually larger with a large proportion of three- and four- bedroom units in the mix to provide for families offour or more. Multi-family units require an overall greater number of parking spaces per bedroom, since there are usually two or more vehicles for each family unit. On-site amenities are usually oriented toward child care or play areas for the children. The proximity to services, such as markets, pharmacies, cleaners, and medical care facilities are not as critical as with senior housing. Senior housing requires one and two-bedroom units. Security is critical since a large number of the occupants may live alone. The proportion of women occupant$ is usually higher than men. The parking space requirement is less than one vehicle per bedroom. Depending on the area and availability of public transportation, the parking spaces can range from 0.5 to 0.75 per bedroom. As noted above, the proximity to medical, pharmacy and food market facilities is very important due to reduced mobility of residents. Most new senior units now being developed in Southern California provide a washer and dryer in the rental unit and, at least, an on-site laundry facility would be imperative. 3-~ Obtaining Housing Programs The options discussed for obtaining rental units for the City housing program were in the following general categories: · Housing Authority and/or private developer construct new housing. · Housing Authority acquires and rehabilitates existing rental units. · Housing Authority provides rehabilitation assistance to private owners of existing rental units. (City has rental rehabilitation program funded by CDBG ) ..,:11: New Construction - building and ownership The construction of new rental units will probably require some form of subsidy because of current rental rates in the area. The revenue generated from rents will not support the cost of land and construction as well as the associated miscellaneous costs, such as financing and desi~ costs. The following ownership options are possible: . Private profit or nonprofit developer builds and owns land and building. Assistance from the City or the Housing Authority can came from: 1. Direct cash grant or loan from CDBG or HOME (only nonprofit developer). 2. Developer can obtain low income housing tax credits in a joint project with the Housing Authority and the developer. City would be asked for additional subsidy. Developer could own all or part of the project. . Housing Authority owns the project. . Housing Authority owns the land and leases land on long term lease hold to the developer. The developer owns the building. Normal time on lease hold is 30-50 years. Acquire and rehabiiitate existing housing - how acquire and ownership The following ownership options are: . Housing Authority owns and contracts with a private housing management agency for operation of the units. One of the issues the City and the Authority will need to consider is the minimum number of units which would be acquired at a site. Most public projects are based on a minimum of 10 units at a site and some require a minimum of 25 in order to achieve a higher level of operating efficiency. . Housing Authority owns and manages units. . City would provide a loan or grant from CDBG or HOME to a nonprofit to acquire and rehabilitate existing housing. Private or Public Ownership Whether the Housing Authority owns the rental housing units or whether the City Council wishes to assist privately owned units is controlled primarily by the risks of ownership and the desire to retain control of the assisted property over a longer period oftime. The Housing Authority can enter into an agreement with a private agency for the management and operation of the units. The 3-3 .-,r.. ,..' . . , . J i J " . ..' ; '" . I .J, - . risks of ownership, the primary one being meeting the loan or bond payments, would continue to rest with the Authority. With the assistance of privately owned units, depending on the nature of financing the project, all or part of this risk may be eliminated. For example, rehabilitation 102l1s by the Authority may be secured by the underlying value of the property assisted which could be sold in a foreclosure proceeding if a default on the loan repayment occurred. Since the conditions of each potential housing project vary greatly, the evaluation of risk must occur with each project in order for the City Council to m~e the decision of public or private ownership. When the Authority or the City provides assistance to private owners, the conditions imposed for meeting low income assistance terminate within a specified period oftime usually controlled by the time during which the assistance or loan is in effect. When the Authority owns property, the conditions for low income assistance remain in effect so long as the Authority continues ownership. For this reason, some cities choose to retain property ownership through their housing authority. Methods of Financing 1. The City provides the developer either grants or loans. CDBG or HOME funds can be used for a nonprofit developer. The City can borrow money using future CDBG entitlement grants as collateral under Section 108. 2. The Housing Authority can fonn a nonprofit and develop a new construction project under Section 202 (HUD funded senior housing); or the City and/or the Housing Authority can assist a nonprofit in app,lying for Section 202 funding from HUD. 3. The Housing Authority, which will own the property, borrows funds through bonds or a bank. Usually housing assistance programs require some form of borrowing by the City or the Authority. This borrowing may, in some instances, take the form of bonds issued by the Authority with the debt service payments based in part on the rental income from the units and in part on grant or loan assistance programs of the state or federal governments. When bonds are issued by the Authority, the responsibility for repayment and, therefore the associated risk, remains with the Authority. There are ways to limit this risk through various bond insurance programs, through trust deeds against the assisted property, or through additional owner or developer guarantees of assets. This issue of financing risk is one which should be carefully evaluated and understood before establishing any housing program. For longer term borrowing, greater than 10 years, the usual financing method is public bonds; but for 10 years or less, the City may want to review a bank loan. The costs of borrowing for a bank loan are less than for a bond issue. With the City or its Housing Authority guaranteeing the loan, banks are usually receptive to providing loan quotations to cities to compare with tbe cost of issuing short term bonds or notes. Loan rates arl~ usually competitive with bond rates and, if the City reserve funds are deposited with the lending bank, better loan rates can sometimes be achieved. 4. The City issues mortgage revenue bonds for a, private for profit or nonprofit developer. 3-4 '. -. Risk considerations if the Housing Authority issues bonds lithe Housing Authority issues bonds and the project fails, the City has no responsibility for payment of the bonds. The default does not impact the bond rating of the City. However, the City would need to explain the situation the next time the City issues bonds. In practical tenns, the City Council may not want the Housing Authority to go into default on the bonds. They may determine to assist the Housing Authority on a voluntary basis. Staffing Requirements for a Housing Program Whether the City wishes to create a housing staff to manage a program will depend on the size of the program it adopts. If the City Council chooses to enter into a program of ownership and management ofa relatively large number of units, say 100 or more, then full time staff would be required, including positions for acquisition and project management. If, on the other hand, the City Council chooses to pursue a program with fewer units involved or with assistance to privately owned units, the program can probably be managed with existing staff. As discussed above, the Authority can contract with a private property management company if the rental units are publicly owned. Public ownership does not, of itself, require the addition to City staff. Most cities find that until the City or its Housing Authority own or assist 75 to 100 units or more, a minimal housing staffis required. Depending on the amount of time allowed for the establishment of the program, usually 1 to 1.5 positions are sufficient to create and manage the housing program. The staffing required for larger or more aggressive programs will depend entirely on the nature of the program, construction or rehabilitation, whether public or private management, and the time allowed to establish the program. Advantages and Disadvantages of the City having a Housing Authority A.dvantages: . The Housing Authority can issue housing revenue bonds. . The City cannot own or manage housing. A Housing Authority or Redevelopment Agency is needed to own and manage housing. Disadvantag~ . Technically, there are no disadvantages. The Housing Authority can be used as little or as much as the City wishes. However, the establishment of the Housing Authority and the subsequent approval of a five year plan for the provision of housing sets up production expectations by the Community. 3-5 ~ . . - , . . '. 'I'. P " . .."I PART 4. Low Income Housing Tax Credits Federal and State Low Income Tax Credits, Goldfarb & Lipman. Proposed Changes to the Allocation Process Allocation Process Target Areas 134 --I GOLDFARB & LIPMAN FEDERAL AND STATE LOW~INCOME HOUSING TAX CREDITS July, 1995 Copyright c 1995 by Goldfarb & Lipman (415) 788-6336 (213) 627-6336 B4-J. GOLDFARB & LIPMAN TABLE OF CONTENTS Page I. FEDERAL LOW-INCOME HOUSING TAX CREDIT ... ............. 1 A. .An1ount. . . II . . . .. .. . . II . .. ..... ..... II II . . . . .. 1 B. Set-Aside Requirement . .. .. . . . . . . . . . . . . . . . . . . .. 2 C. Rent Restriction .. . .... . . .. .............. 3 D. Other Restrictions ......... . .. ... ...,... II . . . . . .. 3 E. Penalty for Noncompliance. .. . .. ... ............... 4 F. Available Credits .. . .. ...... . ........... 5 G. Transferability... ... . .. .............. 5 H. Carryover Allocation. .. ... . .. ... ..... ..... 6 II. CALIFORNIA LOW-INCOME HOUSING TAX CREDIT . . .......... 6 A. .An1ount ..... .. ..... . .... ................... 6 B. Difficult to Develop Areas/Qualified Census Tracts . .......... 7 C. No Pro-Ration of First Year Credit. .. ... ... ........... 7 D. Restriction on Cash Distributions . . . .. .... ............. 7 E. Increase in Qualified Basis .. .... .. .......... 8 F. Total State Credit Authority. . . . . . . . . . . . .. . . . . . . . . .. 8 G. Carryover of State Allocation Authority .................. 8 H. Compliance Period . . .. .... ...... ............. 8 I. Regulatory Agreement ........................ '. . . . .. 9 III. TCAC ALLOCATION PROCESS. . . . . . .. ... ................. 9 IV. REGULATORY AGREEMENT . . . . . . . . . . . . . . .. ........ 10 INHSEIMM.PSO -i- 134-3 GOLDFARB & LIPMAN FEDERAL AND STATE LOW-INCOME HOUSING TAX CREDn:S I. FEDERAL LOW-INCOME HOUSING TAX CREDIT The' federal low-income housing tax credit is available to owners of low-income rental housing. It was originally enacted to replace tax incentives for low-income housing such as preferential depreciation schedules, five year amc::,....dzation of rehabilitation expenditures and special treatment of construction period interest and taxes. The Omnibus Budget Reconciliation Act of 1993 (HR 2264) signed on August 10, 1993 (the "Act") permanently extended the federal low-income housing tax credit. The permanent extension of the credit was dovetailed with the prior expiration date of June 30, 1992, so that the credit is continued as though no expiration of the credit occurred. The Act also made a number of modifications most of which were effective with the signing of the Act on August 10, 1993. A. Amount. The credit is claimed in annual installments over ten years. The maximum annual credit is 9% of eligible costs for new construction and rehabilitation. The maximum rate is 4% for the acquisition cost of existing housing which was placed in service more than 10 years before the present acquisition. The IRS may waive the 10-year rule for buildings which currently have low-income (but not tax credit) units that are at risk of being converted to market rate units and in the case of certain foreclosures. Project owners can also receive a 4% credit for the cost of new construction and rehabilitation if the building receives other federal subsidies, e.g., tax exempt bond financing or any federal loans (direct or indirect) with an interest rate below the applicable federal rate. HUD 221(d)(3) BMIR and 236 loans, as well as loans under the Farmers' Home Administration Section 515, are examples of federal subsidies. Loans of Community Development Block Grant funds are specifically excluded from consideration as federal subsidies. HOME funds are considered federal subsidies; however, under the Act HOME funds may be exempted from federal subsidy treatment if certain conditions discussed below are met. The credit amounts are intended to equal the present value of 70% and 30% of eligible costs, respectively; therefore, the actual rates are adjusted monthly to reflect changing interest rates. The actual percentage for computing the credit is generally detemlined and fixed in the month the building is placed in service, or if the appropriate election is made, when a project receives a carryover allocation. Projects eligible for the 4% credit with respect to acquisition costs may also qualify for the 9% rehabilitation credit. Rehabilitation expenditures claimed in INHSEIMM.PSO -1- BY-4 --.. GOLDFARB & LIPMAN connection with the acquisition of an existing building must average at least $3,000 per unit and must total at least 10% of the adjusted basis of the building to qualify for the 9% credit. 1, Oualified Basis. The "qualified" basis on which the credit is computed is equal to the proportion of "eligible" basis attributable to the low~income units. TlW proportion equals the lesser of (1) the proportion of the number of low~ income units to the total number of units, and (2) the proportion of floor space of low-income units to the total floor space of all units. The determination of this proportion is generally made at the end of the first taxable year after placement in service. However, if the number of low-income units or the floor space of low- income units increases after a building is placed in service, credits claimed on the additional "qualified" basis will be equal to two-thirds of the credit percentage allowed for the initial "qualified" basis for the remainder of the 15 year compliance period with respect to the additional "qualified" basis. 2. "Eligible" Basis. "Eligible" basis is the adjusted basis of a new building or any qualified existing building. The cost of land or any property which is not residential rental property is not included in eligible basis. But, the cost of common areas and amenities nonnally associated with residential rental property is included. "Eligible" basis must be reduced by the cost attributable to any market rate units in a project which are above the average quality standard of the low-income units. Likewise, rehabilitation expenditures which improve any unit above the standard of the low-income units cannot be included in eligible basis. Grants, to the extent funded by the federal government, such as Community Development Block Grants, and Rental Rehabilitation Grants, must be excluded from eligible basis. For buildings which are located in areas determined by HUD to be qualified census tracts or difficult to develop areas, the owner may elect to increase the otherwise eligible basis by 30%. This option is not available to buildings which are assisted by HOME funds, if an election is made to have the HOME funds not be considered a federal subsid~r, and to use the 9% credit. B. Set-Aside Requirement. Property is eligible for the credit if (1) at least 20% of the housing units in the project are occupied by individuals with incomes of 50% or less olf area median income, adjusted for family size, or (2) at least 40% of the units in the project are occupied by individuals with incomes of 600/0 or less of the area median, adjusted for family size. [n order to use HOME funds with the 9% credit, at least 40% of the housing units ll:.\. the project must be occupied by individuals with incomes of 50% or less of area median income. The owner must make the detennination that a tenant satisfies the income requirement at least lNHSE1MM.P50 -2~ B4-5 I GOLDFARB & LIPMAN annually. Under the Act the annual certification requirement may be waived if the building is 100% low-income. The minimum set-aside which will apply to the building or rehabilitated property must generally be elected when the building is placed in service. The set- aside requirements must be met by the close of the first year of the credit period (usually the year in which the building or rehabilitated property is placed in service, or by election, the following taxable year). The owner must agree to maintain this set-aside for the greater of 30 years or the period mandated by the state. (See discussion of Regulatory Agreement in Part IV below.) Each year the taxpayer will be required to certify to the IRS that the project has complied with the set-aside requirement, which is to be computed on the aggregate residential rental units in all existing buildings in a project. C. Rent Restriction. The rent charged' for the eligible units may not exceed 30% of the qualifying income limitations, adjusted for the size of the family deemed to occupy the unit. Prior to 1990, the rent restriction was 30% of gross income applicable to the specific number of individuals occupying the unit. To prevent the landlords from raising the rent by increasing the number of tenants, beginning in 1990 the law based the rent on an imputed number of occupants in a unit. A unit without a separate bedroom is deemed to house 1 person. Other units are deemed to house 1.5 persons per bedroom. Gross rent includes the cost of any utilities other than telephone. If the tenant is required to pay any utilities directly, the maximwn rent that may be charged must be reduced by a utility allowance prescribed by the IRS, which will take into consideration the procedures under Section 8 of the United States Housing Act of 1937 ("Section 8"). The gross rent limitation applies only to payments made directly by the tenant and does not apply to any rental assistance payments made on behalf of the tenant such as through Section 8 or certain other governmental payments for supportive services. The imputed limitation does not apply to determine if the set-aside is met, but is used !to determine if a unit is rent-restricted. The area median gross income for the purpose of detennining the set-aside, and the adjustment to art~a median gross income for the purpose of detennining the rent restriction are determined under Section 8 of the United States Housing Act of 1937. D. Other Restrictions. In addition to the requirement tnat tenants meet income limitations and the units be rent-restricted, there are other requirements in order to qualify as a low-income unit. The unit must be available to the general INHSEIMM.PSO -3- BY-b GOLDFARB & LIPMAN public, suitable for occupancy and not used on a transient basis. A unit is not considered "transient" if it contains sleeping, kitchen and bathroom facUities and is located in a building operating under a transitional housing for the homeless program. Single room occupancy units are not considered to be rented on a transient basis merely because they are rented on a month-to-month basis. Originally low-income units could not be occupied solely by students unless they were entitled to file a joint income tax return. The Act broadened the categories of students who may live in the units which qualify for credit. Individuals who are students and either receive assistance under Title IV of the Social Security Act, or are enrolled in job training programs receiving assistance under Federal, state or local laws such as Job Training Partnership Act, may occupy a tax credit unit. In addition, full-time students who are mamed and file a joint return, and single parent students (if neither the student nor the children residing with the student is a dependant of another individual) are qualified to occupy a tax credit unit. E. Penalty for Noncomplia~. The penalty for any building failing to comply with the minimum set -aside requirement or the gross rent requirement during the IS-year compliance period is disallowance of any further tax credit and recapture of the accelerated portion of the credit for all previous years (if noncompliance is corrected within a reasonable time, there will not be any recapture). The accelerated portion of the credit which is recaptured in the year of noncompliance is equal to one- third of the credit claimed each year if the violation occurs during the first 11 years, and is four-fifteenths for violations during the twelfth year, three-fifteenths for violations during the thirteenth year, two-fifteenths for violations during the fourteenth year, and one-fifteenth for violations during the fifteenth year. These amounts are recaptured with interest from the date the recapture amount is claimed. The interest rate will be the "overpayment" rate under IRe ~ 6621, which is equal to two percentage points above the short-tenn federal rate. If a project initially exceeds the minimum set-aside requirement of 20% or 40%, and later the percentage of low-income units upon which the credit may be claimed decreases, recapture will be limited to that portion of the credit attributable to the basis which is no longer qualified if the project still continues to satisfy the minimum set-aside requirements. The recapture amount with regard to units which no longer qualify is computed as described above. For example, if a taxpayer claimed the credit for a project based on a "qualified" basis of 35% of the project allocated to units occupied by individuals with incomes of 50% of less of area median income, and during the first ten years the qualified basis dropped to 25% of the project because vacancies were filled by tenants with non-qualifying incomes, the minimum set-aside requirement of 20% still would be satisfied. Therefore, recapture would be triggered INHSEIMM.PSO .4- BY-7 GOLDFARB & LIPMAN only on the credit amount allocable to the 10% basis of the project no longer eligible for the credit. Under the Act, the IRS may waive de minimis errors in complying with the set- asides. Likewise, if there is a de minimis change in the amount of the qualifying basis which is attributable to changes in the floor space for low-income units, but the building continues to qualify as a low income building) no recapture will occur. A unit occupied by a household whose income increases above the limitation, will continue to be a low-income unit, if the unit remain\) rent-restricted. If the household's income increases to 140% of the income limitation, then the next available unit must be rented to a tenant whose income is above the limitation. Further, if a unit fails to comply because a tenant's income increases, the project owner is not _equired to evict tenant to return the project to compliance so long as the unit remains rent-restricted. The project owner, however, is required to rent each rental unit of comparable or smaller size that becomes vacant while the project is not in compliance to a tenant having a qualifying income. F. Available Credits. The total dollar amount of annual credits that may be issued by each state is equal to $1.25 per state resident. Ten percent of the credit authority must be reserved for projects developed by tax-exempt, non-profit organizations, which are not controlled by for-profit organizations and which have as an exempt purpose the fostering of low-income housing. Eligible housing financed with the proceeds of tax-exempt bonds receiving an allocation under the bond volume cap qualify for the credit without reducing a state's credit authority. The California Tax Credit Allocation Committee C'TCACIt) has been designated the State agency to administer Califonua's federal and State authority. States have the authority to allocate less than the maximum allowable credit percentages or to allow a smaller lIqualifiedlt basis on which the credit is computed. The credit agency's authority is reduced by the amount equal to the credit percentage multiplied by the qualified basis for which an allocation is granted by the agency. A state may carry oveI' any unused credit authority from one year to the next year; however, any amount not used in the subsequent year must be returned to the national pool. National pool credits are allocated to states which have used up their allocation in prior years. ~ G. Transferabilitt. Recapture is triggered if the taxpayer disposes of a building receiving the credit, unless the seller posts a bond to the IRS in an amount satisfactory to the IRS, and provided it can be reasonably expected that the building will continue to be in compliance for the 'remainder of the compliance period. INHSEIMM.P50 -5- BLj-'6 GOLDFARB & LIPMAN The purchaser of the building during the compliance period, who maintains the building as a low~income building, will be able to take the credit to the extent the seller could have taken it; provided, that the seller had been allowed a credit. The Code requires that the credit be divided between the buyer and the seller based upon the number of days the project was ovv'1led by each. However, the IRS may in the future issue regulations providing that the buyer and seller may agree to use either the exact number of days or th,~ mid-month convention to determine the division of the credit in the month of disposition. If the sale is a recapture, event, no credit is allowed to the seller in the year of sale. H. ~ml-Jver Allocation. Although the law generally provides that the building will be placed into service in the same year as it receives a tax credit allocation, in practice, most projects rely on the carryover allocation exception. In order to receive a carryover allocation, the owner must have incurred more than 10% of the reasonably expected basis in the project by the end of the year the allocation is received. For this purpose, basis in the project means basis in land and depreciable real property which, expected to be a part of the project. If a project receives a carryover allocation, the project may be placed in service within 2 years after the end of the year in which it receives the carryover allocation. Careful planning and consideration should be given to meeting this test, as it is critical to the validity of the tax credit allo\~ation itself. An allocation is invalid unless the ten per cent test is met. TCAC has imposed an earlier deadline to assure that the federal year end deadline is not violated. II. CALIFORNIA LOW-INCOME HOUSING TAX CREDIT In September 1987, California enncted the State low~ income housing tax credit, which is modeled after its federal counterpart with the following important exceptions: A. Amount. The credit period under tht~ State law is four years, and the amount of the credit for projects which are not "federally subsidiz,~d" totals 30% over the credit period. The amount of the annual credit for the first thtee years is the same as the applicable percentage established by the Internal Revenue Service for the federal "9% credit." The amount of the credit for tht~ fourth year equals 30% less the sum of the credits for the first three years. For a qualified low~income buildin'g which is either (a) a fedel'aUjl ~ubsidized new building or (b) an existing building that is "at risk of conversion": the ..unount of annual credit for the first three yean, is the same as the applicablt.~ perce,ntage INHSEIMM.PSO -6- BY-C) GOLDFARB & LIPMAN designated by the Internal Revenue Service for the federal "4% credit". The amount of credit for the fourth year equals 13% less the sum of credits for the first three years. A building which is "at risk of conversion" is an existh,g building which meets each of the following criteria: 1. It is not owned by a qualified nonprofit organization. A qualified nonprofit organization is tax exempt pursuant to Internal Revenue Code Section 501(c)(3) or (4), is not affiliated with or controlled by a for-profit organization and one of the exempt purposes of the organization is fostering low-income housing. 2. It is federally assisted, and the low-income use restrictions will tenninate if the mortgage is eligible for prepayment under Subtitle 13 of the Emergency Low Income Housing Act of 1987 or under Section 502(<:) of the Housing Act of 1949, within three calendar years after the year of application to TCAC. 3. The person acquiring the building agrees to enter into a regulatory agreement that requires the building to be operated pursuant to the State low-income housing credit provisions for the longer of 55 years or the life of the building. 4. The rehabilitation expenditures for the building meet the requirements of the federal tax credit law except that the expenditures do not need to total at least 10% of the adjusted basis in the building. There are special rules for pre-1990 projects which are not discussed in this brief overview. B. Difficult to Develop Areas/Qualified Census Tracts. Under the federal tax credit, buildings in difficult to develop areas or certain qualified census tracts are entitled to a 130% adjustment to the tax credit eligible basis. If TCAC allocates State tax credits to these buildings, the federal credit can only be allowed with regard to 100% of the basis. C. No Pro-Ration of First Year Credit. In the first taxable year in which a project is placed in service, the taxpayer will be eligible for a full credit regardless of when during that year the project is placed in service or occupied. For the federal credit, the first year's credit is pro-rated based on the number of months the project is occupied, and that portion of the first year's credit which cannot be used is carried over to the eleventh year. INHSEIMM.PSO -7- ~4 - 10 GOLDFARB & LIPMAN D. Restriction on Cash Ojstributiom. The amount of cash distributions that an investor in the project can receive from operations of a project, less lequired reserves, is limited to either of the following at the election of the taxpayer: 1. An amount not to exceed 8% of the lesser of (1) owner equity actually paid to date (not including any amounts not paid on an investor note); or (2) 20% of the adjusted basis of the building as of the close of the first income year of the credit period. h.1 amount allowed but not available for distribution under this formula during the first five years of the credit compliance may accumulate and be distributed in the first 15 years of compliance; or 2. The amount of cash flow from the units in the building which are not low~income units. Cash flow and operating costs shall be computed by using the proportion of floor space of low-income units to all units in the project. Any other net cash flow must be used to reduce the rents or increase the number of low-income units. The federal credit does not restrict the return an investor may receive. E. Increase in Qualified Basis. If the "qualified" basis of a building increases after the first compliance year, for instance if the number of low-income units or floor space for low-income units increases, then the project owner is eligible for a credit on the increased basis. The credit on the increase in basis is calculated by using the appropriate state percentage for the project. The project owner is entitled to take the credit on the increase in basis for a four-year perloW. beginning with the first year in which the increase in basis occurs; provided that the total credit cannot exceed the project's credit allocation. F. Total State Credit Authority. The total amount of State tax credit that may be granted annually cannot exceed $35 million, plus any carryover from a previous years plus the amount of returned housing credit in that year. The total amount of the credit allocated to a project for the four year credit period reduces the State's annual housing credit authority in the year the credit is allocated. G. Canvover of State Allocation Authority. Any unallocated State credit authority in one year may be carried over to subsequent years until fully allocated. H. Compliance Period. The statutory compliance period for the set-aside and rent requirements is 30 years with tne following exception: if a project is not economically feasible after the first 18 years of the compliance period, the project owner may remove, as necessary, one or more of the low-income units from the set- INHSEIMM.PSO -8- ~4-'\ GOLDFARB & LIPMAN aside and rent requirements of Section 42 of the Internal Revenue Code to enable the project to become economically feasible. The project owner must return the next available units to low-income use, subject to the set-aside and rent restrictions, if and when it is economically feasible to do so. I. Re~latory A~eement. The requirements for the credit are enforced through a regulatory agreement between TCAC and the project owner rather than recapture of the credit. The regulatory agreement is discussed in Part rv below. ur. TCAC ALLOCATION PROCESS Federal and State housing credit dollar amounts must be allocated by TCAC pursuant to a qualified allocation plan. The qualified allocation plan is amended from time to time and should be consulted for the latest procedures and qualifying criteria. The State law provides that TCAC shall allocate the federal and State housing credits up to three times a year, subject to adjustments due to changes in State or federal law. TCAC is presently in the process of revising the qualified allocation plan perhaps reducing the number of annual allocation rounds. TCAC is also required to evaluate each project taking into consideration sources and uses of funds and total project financing, proceeds to be generated by tax benefits, percentages of housing credit dollar amount used for project costs other than intermediaries and~ under the new Act, the reasonableness of operational and developmental costs. The standards of reasonableness are set by state agencies such as TCAC, based upon facts and circumstances including the location of the project. These determinations are made at the time of original application for tax credits, at the time of allocation and at the placed in service date. TCAC evaluates tax exempt bond projects to make certain that these projects comply with all the requirements of the plan. However, because credits for tax exempt bond projects do not count against the state's ceiling, such projects do not compete with other projects for tax credits. [n addition, the federal and State law provide that the following criteria must be met at the time an application is filed with TCAC and that the criteria be included in the qualified allocation plan (the ''Threshold Requiremeni:s"): (i) there is need in the community for low-income housing; (ii) sufficient funding is available to construct and opetate the housing project; (ill) the project sponsor must have secured either construction or pennanent financing commitments for at least one-half of the estimated financing of the project; (iv) the housing sponsor INHSEIMM.PSO -9- ~~- ,~ GOLDFARB & LIPMAN should have site control; (v) the project is in compliance with all local land use and zoning ordinances; (vi) the project development team is experienced and has the financial capacity to ensure project completion and operation through the compliance perlod; and (vii) the amount of the tax credit must be necessary for the financial f5asibility of the project throughout the compliance period taking into account certain financial factors, including a development fee as calculated pursuant to a factor detennined by TCAC. TCAC uses the following statutorily mandated criteria in allocating tax credits for projects that meet the Threshold Requirements. 1. Projects serving very low-income tenants; 2. Extending the maximum tompliance period to 55 years; and 3. Projects with public agency long-term financial support of at least 15%, or with owner equity of at least 30%, of total development cost. IV. REGUlATORY AGREEMENT The regulatory agreement incorporates the requirements of the State and the federal low-income housing tax credit provisions. The regulatory agreement is for a term at least as long as the 30-year compliance period but typically 55 years. It is recorded in the official records of the county where the project is located as a restrictive covenant binding on the project owner and its successors and provides for enforcement by certain State and local agencies as well as prospective, present, or future tenants of the project whose household incomes are within the applicable income limits for the project. The regulatory agreement prohibits the sale of a portion of the building to anyone who does not acquire the entire building and prohibits the discrimination against a prospective tenant on the basis of the tenants' status as a Section 8 certificate or voucher holder. The remedies available if a project owner does not comply with the conditions of the agreement include collection of rents from the project, taking possession of the project, specific performance, receivership, or any other relief available under the law. The regulatory agreement also provides that the project owner must give advance notice to those State and local agencies that can enforce the regulatory agreement if the project owner plans to remove low-income units from the set-aside and rent restrictions in order to achieve economic feasibility. [t requires that the project owner notify the relevant State and local agencies if there is an IRS determination that the project is not in compliance with federal low-income housing tax credit provision. The regulatory agreement may be subordinated to the encumbrances of institutional lenders financing the project. INHSEIMM.PSO -10- ]4-\~ \\J GOLDFARB & LIPMAN " ,"! housing tax credit provision. The regulatory agreement may be subordinated to the encumbrances of institutional lenders finan.cing the project. . INHSEIMM.PSO ~11- 8'1-/4 CALIFORNIA TAX CREDIT ALLOCATION COMMITTEE QUALIFIED ALLOCATION PLAN AND REGULA nONS SUMMARY OF PROPOSED CHANGES August 8, 1995 I. INTRODUCTION At its May meeting, the California Tax Credit Allocation Committee ("TCAC" or the "Committee") instructed its staff'to examine the current allocation criteria and process, and refine the tax credit distribution apparatus so it is: . Less Complicated; . More Objective; . More Predictable; . More Efficient; and . Good Public Policy. \, Furthermore, State Treasurer Matt Fong, the chairman of the Committee, described two specific goals the allocation criteria should accomplish: . Maximize the public benefit of the scarce housing resources TCAC distributes; and, . Clearly address the needs of as many low-income Californians as possible. Federal and state legislation provide specific direction as to allocation priorities and preferences. Program authorizers want TCAC to: . hold a competition among only those projects considered sound investments of public runds; . prioritize projects that produce housing for families and individuals who can least afford housing; . establish preferences for certain types of developers, project locations, tenants served, and unit compositions; and, . expend public funds in the minimum amount necessary to achieve program goals. n. POLICY OBJECTIVES Implementation of statutory intent require's adoption of state regulations and a detailed "Qualified Allocation Plan," or "QAP." A review of the goals and priorities noted above necessitate formulation of policy objectives before a detailed QAP can be developed. Staff recommends five primary policy objectives be adopted by the Committee to guide formulation of the allocation plan and regulations: 1;4 - 15 QAP & Regulations-Summary of Changes Page 2 August 8, 1995 . NEED.. neighborhoods with greater bousing need will receive the majority of the federal tax credit; . AFFORDABILITY - propos:!ls targeting households with the lowest average incomes will be awarded allocation before competing proposals targeting higher avef'age incomes; . UTILITY - proposals utilizing the least amount of federal tax credits per household served will be awarded allocation before competing proposals utilizing greater amounts of Cederal tax credits; . DISTRIBUTION - proposals targeting low-income populations - includilllg large families, transients, the economically displaced, persons with special needs, and senior citizens - wil! receive an apportionment of federal tax credits in amounts determined by the Committee. . DELIVERY - program administration will encourage projects be built alrld occupied quickly, so those in need can enjoy program benefits soon after credits aJre available. A. HousinS! "Need" Housing "need" may be viewed from a variety of perspectives. Primarily, "need," for purposes of subsidized housing programs, is a reflection of relative housing affordability. A case in point; the tax credit program allows a qualifying household to earn no more than 60% of the area median income, adjusted for family size, and allows the maximum rent payment charge, including utilities, not to exceed 30% of said income. Housing programs generally consider rent payments over 30% of income to be excessive rent burdens. Additionally, housing need may be linked to the relative "quality of life" enjoyed by households due to their housing accommodations. In particular, residents of substandard or overcrowded units may not enjoy a decent living standard, even though their rent burden may be at or below 30% of their income. To recognize that certain neighborhoods within California have greater housing needs than others, and that a primary goal of the Committee is to address the worst case needs of households within those neighborhoods, stafT recommends an apportionment 'of 50% of each years' federal tax credits be allocated to projects proposed in neighborhoods with high percentages of households possessing excessive rent burdens and overcrowded conditions. rhe following criteria is proposed for determining neighborhoods most in need: . "Excessive Rent Burden" - rental households paying 35% or more of their income to rent. . "Overcrowded" households - rental households with more than one occupant per room (bathrooms excluded). U. S. Census data will be used to quantify the percentage of households, within each census tract in California, that have excessive rent burdens and overcrowded conditions. For example, a tract in Los Angeles that includes the intersection of Slauson and Florence Avenues 'E>4 - lit, QAP & Re~lations-Summary of Changes Page 3 August 8, 1995 has 23% of its rental households living in overcrowded conditions, and 59% ofrentet households paying fent in amounts of 3 5% or more of their' income, for a combined total of 82%. This combined percentage will be called the census tract's "Need Quotient." The Need Quotient can then be used by the Committee to, distinguish between those areas of the state w:.h the greatest to least relative housing need. The Committee will then select a portion of the census tracts, say, the top 20% exhibiting the greatest Need Quotient, and apportion 50% of the federal tax credit allocation to projects proposed in the designated tracts. . B. A fforda bilitv Statutes authorizing'the federal and state tax credit programs provide an allocation preference to projects that serve the lowest-income households for the longest period of time. This preference can be implemented by comparing the average affordability and the "low-income use" period proposed by competing project applicants. Additionally, a minimum average affordability threshold can be established, thereby limiting allocation priority to applicants reaching the threshold. In order to serve the various population types that will occupy each type of housing, it is necessary to establish different affordability thresholds for each housing type. Encouraging deeper affordability also achieves public policy goals. Administratively, there is added risk if the depth of afford ability reduces project revenue to very low amounts. Placing a floor limit on the proposed level of affordability will reduce project operating risk. In consideration of the above factors, staff recommends er.tablishing a competition among applicants whereby the primary criteria shall be the spread between the threshold and the proposed average affordability for qualified project units, with a floor limit on the depth of the proposed average affordability. The average affordability will be expressed as a percentage of area median income. The recommended threshold average affordability and the corresponding floor limits are as follows for each housing type: Housing Types Threshold Amount Floor Limit . Large Family . Single Room Occupancy . Preservation · Special Needs . Senior . Non-targeted 56% 40% 56% 40% 56% 56% 46% 30% 46% 30% 46% 46% 1?>4 - J 7 QAP & Regulations-Summary of Changes Page 4 August 8, 1995 An application's "score," in the "Affordability" competition described above, is the differenc~ between the threshold and the proposed average affordability for qualified project units (e.g., 56% less 46% = 10). As noted above, authorizing statutes of the federal and state tax credit programs state a preference for projects that provide assistance for the longest period of time. The authorized minimum "low-income use" period for all approved projects is a term of 30 years. The current QAP encourages low-income use agreements of up to 55 years. But, a preliminary projection ofTCAC monitoring costs, and monitoring fees collected to cover those costs, indicates that 55-year use periods may require an increase in the monitoring fees currently charged. This added cost would negatively impact the ability to produce affordable housing. Therefore, staff recommends a threshold low-income use period of 40 years for "Targeted Projects," and 30 years for "Non-Targeted Projects. C. Utilitv of Limited Public Resources A basic tenet of administering publicly-funded programs is to maximize the utility of resources available. This principle, applied in its most fundamental form, purports that a program that assists, equivalently, the most people or households for the least cost is the most desirable program. This principle is readily applied to housing programs for California, since the need for affordable housing far exceeds the supply ofhousi!lg assistanc,e offered by government. Wholesale application of this principle may limit the ability of project sponsors, and the tax credit program, from accomplishing goals not addressed by statute. To allow for state and local goals, federal regulations declare that tax credit awards should be made in light of local conditions and state housing priorities. Nevertheless, there are often conflicts when attempting to simultaneously maximize utility and reach other goals. A "geographic distribution" goal is a good example of one that may conflict with a goal to maximize the number of households serv'ed. For example, an above recommendation, which attempts to reach households in neighborhoods with the greatest need, may result in project selections that are more costly, thereby sacrificing some number of additional households the program could otherwise serve. For that reason, staff recommended only 50% of the allocation be allotted to projects based upon housing need. Simila~ly, deeper Affordability is a program goal that may at times conflict with the goal to maximize the number ofhouseho!ds served, or expand the geographic distribution of assistance. This is because deeper Affordability will most often require "soft money" loans or grants that are c:h'11y available in specific localities, and vary greatly in terms of available amounts. ~4-lg QAP & Regulations-Summary of Changes Pagc 5 August 8, 1995 To address these conflicts, expand the ~eographic distribution of allocation and maximize the utility ofits limited resources, staff recommends establishing a competition among applicants whereby the primary criteria shall be the requested amount of eligible project basis per "Unit-Cost Factor."tfle UUnit Cost'l competition will be held in addition to the U Atfordability" competition. The recommendation to use only the requested eligible basis when comparing proposals allows for local and state governments to accomplish goals that reach beyond the tax credit program, without being penalized for higher per-unit development costs. Additional goals often require larger per-unit expenditures. By requesting a lower eligible basis, for purposes of calculating tax credits, than that reflected by the cost of the project, the applicant will be better positioned to compete against proposals that dOIl't have additional goals to accomplish. In effect, this "cost" comparison is most directly an effort to reduce the amount of tax credits allocated per unit, thereby serving more needy families per allocation dollar. To appropriately compare proposals based upon cost, recognition of the unit configuration must be taken into consideration. Using either "cost-per-unit" or "cost-per-bedroom" can skew the comparison towards smaller or larger units, respectively. Therefore, a "Unit-Cost Factor" must be established that more accurately addresses the cost of additional bedroom units. Staff recommends the following Unit-Cost Factors be used: Number of Bedrooms o 1 2 3 4 5 Unit-Cost Factor 0.60 0.75 1.00 1.25 1.45 1.65 The number and bedroom-size of all qualified units in the project will determine the Unit- Cost Factor. The requested eligible basis divided by the Unit-Cost Factor will determine the "score" the application will receive. An additional project cost control, beyond that which will be realized by the competition, is believed by staff to be necessary to maximize the utilization of tax credits. Staff recommends an eligible basis cap (for purposes of calculating maximum allocable tax credits) equal to the maximum allowable mortgage limits published by the U. S. Department of Housing and Urban Development for the 221(d)(3) Non-profit program. Different maximums have been established for each area of the state based upon the relative costs of developing housing. ~4- 19 QAP & Regulations~Summary of Changes . Page 6 August 8, 1995 D. Distribution Arnone Housin~TvDf.s Both federal and state tax credit program authorizers have directed the Committee to allocate resources to population& of families and individuals with the most pervasive affordable housing needs. Additionally, studies of California households cite major affordability gaps for specific populations, not able to increase their income to improve their economic situation. In light of the fact that some populations have greater needs than others, and housing product can be tailored to appropriately suit those needs, staff recommends that the following groups -large families, transients, persons economically displaced, persons with special needs, and senior citizens - receive an a"pportionment of federal tax credits in an amount determined by the Committee. Targeted categories of housing types to serve these populations are Large Family Projects, SRO Projects, At-Risk Projects, Special Needs Projects, aild Senior Projects. As a stop-gap measure, the "Non-targeted Projects" category will be continued, but staff will recommend to the Committee that no apportionment be made to Non-targeted Projects at this time. The "AcquisitionlRehabilitation Projects" category will be discontinued. Projects acquired and rehabilitated will apply as either Targeted Projects, or Non-targeted Projects. To qualify as a "Targeted Project," various threshold criteria must be met by the applicant. Complete details on minimum requirements for threshold categories will be provided at the end of August, when a draft QAP is made available for comment. At this time, staff recommends for all Targeted Projects the following minimum thresholds be met: · A demonstrated need for the project must be evident; · The sponsor must demonstrate experience owning and operating the type of ho~sing proposed; · Minimum construction standards, tied to the length of the applicant-proposed low-income use period (details to be provided in the draft QAP); · Resident services requiring third-party funding sources must have finnly committed contracts in place at tax credit application; · A public agency must provide direct or indirect long-term financial support for at least 15 percent of the total project development costs, or the owner's equity must constitute at least 30 percent of the total project development costs; and, · Adequate laundry facilities must be available on the project premises. Additional minimum 'thresholds for Large Family Projects include: · A minimum of30 percent of the units have three or more bedrooms; and, · The project must provide outdoor play/recreational facilities suitable for children of all ages. If a rehabilitation project, with no possibility of providing outdoor recreation, indoor play/recreation facilities must be provided for children of all ages. '. 'B4-~O QAP & Regulations-Summary of Changes Page 7 August 8, 1995 Additional minimum thresholds for SRO Projects include: · Units may be efficiency units, but the project must include at least one bathroom and one kitchen for every eight units; · The project configuration must meet the needs"ofthe population; and, · A vacancy rate of at least ten percent must be used for detennining feasibility. The current QAP description of requirements for At-Risk Projects will remain in its entirety for the time being. It is anticipated that Congress will adopt new guidelines for at-risk properties. At that time, ti1odifications to this section may be required. Additional minimum thresholds for Special Needs Projects include: · The project configuration must meet the needs of the population; and, · A vacancy rate of at least ten percent must be used for determining feasibility. Additional minimum thresholds for Senior Projects include: · Age restrictions are required (the specific provisions are under review); ~ Access to basic services must be available by other than resident-owned transportation; · Projects over two stories must provide elevator access; . · No more than 20 percent of the targeted units in the project are two-bedroom units; · Emergency call systems must be included in all units, with 24-hour monitoring; and, · Appropriately-sized community room(s) must be provided o.n site, or within immediate proximity to the project site. E. Product Deliverv The following additional changes are proposed to increase the readiness of applications, thereby decreasing the time between TCAC's receipt of tax credit allocation authority and the delivery of housing Ullits to program beneficiaries. Staff recommends for Targeted Projects: · Disallowing additional soft second fund sources (amounts may change) not identified in the application (e.g., cannot pledge owner resources and substitute HOME funds); · Soft second financing must be "committed" at application, evidenced by a resolution or firm (not preliminary) commitment letter from the authorized public or private entity providing the funding; · If project has a reservation or allocation of tax credits, must return at application to reapply for tax credits; and, . · Within one year, or less if necessary to meet other deadlines, of receiving a reservation of tax credits, all proceeds necessary to complete project construction must be deposited in escrow, or the reservation or allocation of tax credits will be revoked. Extensions will be granted only in cases of natural disasters or law suits directly thwarting the start of construction. ~4- ~\ ~ - QAP & Regulations-Summary of Changes Page 8 August 8, 1995 m. ADDITIONAL CHANGES Additional changes to the QAP and regulations will be available when draft QAP and regulations are released at the end "of August. The application form is incorporated as part of the regulations. In addition to changes outlined above, staff recommends the following: · Eliminate the "Large Project Additional Thresholds" and limit project size to 175 units. Two-phase projects will not be aliowed to receive forwarcl commitments of tax credits; · Eliminate points for "Physical Facility and Services Featul'es." Additional amenity requirements have been incorporated into Targeted Project thresholds; · Eliminate "Bonus Points;" · Limit Developer Fees to the lower of 15% of non-adjusted req:uested eligible basis, 10% of Total Development Cost, or $1.2 million. IV. THE ALLOCATION COMPETITION To compete for tax credits, applicants need to prepare a project proposal that reduces project rents to the greatest extent possible, requires the least amount of tax credits possible, and is economically feasible. Additional decisions applicants must make include: · Selecting either the "Affordability" competition, or the "Unit-Cost" competiHon; · Selecting either the "Non-profit," "Rural," or "Small Development" set-aside, or competing as a "General Pool" project; and, e Selecting either a Targeted Project category or a Non-Targeted Project category. As noted above, staff recommends that applications proposing a Non-Targeted Project category will only be considered in the absence of applications for any of the Targeted Project categories. Once applications are received, TCAC staff's first task will be to rank projects applying in the Affordability competition. As noted above in the "B. Affordability" section of this document, the highest ranked projects will be those committing to the greatest spread between the threshold and the proposed average affordnbility for qualified project units, with a floor' limit on the depth of the proposed avernge affordability. TCAC will concurrently r,ank projects applying in the Unit-Cost competition. As noted above in the "C. Ut.ility of Limited Public Resources" section, the highest ranked projects will be those committing to the lowest' "quested amount of eligible pr'oject basis per "Unit-Cost Factor." . -"BL\-~~ - QAP. & Regulations-Summary of Changes Page 9 August 8, 1995 Staff will rank the projects based solely on the above criteria, but will not evaluate applications beyond those criteria until later' in the process. Ti.e-breakers currently under consideration tor purposes of the ranking under the two categories include the following: · Applicnt~ons requesting a final reservation; · Total Dev,~lopment Cost per Unit-Cost Factor; · Proposals offering specific public benefits, including housing/mass transit linkages, and employment and training opportunities for disadvantaged youth; and, · For the Affordability competition only, the lowest requested amount of eligible project basis per Unit-Cost Factor. Following the ranking of projects in the two categories, staffwill combine the two "lists" into one list by alternating projects between the categories. In other words, the highest ranking proposal in the Affordability competition will receive Rank Position # 1, the highest ranl..dng proposal in the Unit-Cost competition will receive Rank Position #2, the second highest proposal in the Affordability competition will receive Rank Position #3, the second highest proposal in the Unit-Cost competition will receive Rank Position #4, etc. It shoulci be noted that this method 'of alternating between the top-ranked projects in the two categories will not result in pre-determined amounts of allocation for each competition. Once all applications have been assigned a Rank Position, the set-aside categories will be filled. Beginning with the application that holds Rank Position #1, staff will look to see if the applicant has applied for the Non-Profit set-aside. If so, staff will assign credits for the application. Ifnot, the application that holds Rank Position #2 will be examined to see if the applicant applied for the Non-Profit set-aside. Staffwill continue to go down the list, in rank order, until such time that the amount of credits required by the Non-Profit set-aside has been completely assigned (if necessary, the amount of all set-asides will be surpassed in order to fblly subscribe them). Once the Non-Profit set-aside has been filled, the Rural set-aside will be filled by starting with the application in Rank Position #1. If the application has already been assigned credits in tht.' Non-Profit set-aside, then it is skipped. Staff will continue to go down the list until the Rural set-aside is filled. For the Small Development set-aside the same process will apply; beginning with Rank Position #1, etc. Once credits are assigned to all of the mandated set-aside categories, staff will assign credits to projt:cts to reach the apportionment described above under the "A. Housing Need" ~4-;l~ QAP & Regulations-Summary of Changes Page 10 August 8, 1995 section of this document. Projects located in targeted census tracts will be assigned credits until the apportionment is reached. For this apportionment, and all of the following apportionments, the applications already assigned credits will be counted toward the apportionment ifit qualifies for the apportionment: As an example, if a project was assigned credits in the Non-Profit set- aside, and the project was located in a targeted census tract, the amount of the credits previously assigned in the Non-Profit set-aside will be counted toward the 50% apportionment recommended for targeted census tracts. Once again, to fulfill the apportionment, staff will first look at Rank Position # 1. After reaching the appOltionment for Housing Need, staffwill assign credits to projects to reach each apportionment described under uD. Distribution Among Housing Types." As noted above, the Committee will apportion amounts (in quantities to be recommended by staff at the end of August) to each Targeted Project category, As noted immediately above, applications already assigned credits, in any set-aside or apportionment. will be counted toward the subsequent apportioned categories. Staffwill begin assigning credits, as bl;;fore, by starting at the top of the list with the application in Rank Position #1, until each apportionment is fulfilled. Staff recommends' assigning credits to remaining apportionment categories in the following priority order: Large Family, SRO~ At-Risk, Special Needs, Seniors. It should be noted that if an apportionment is exceeded, staff will skip over projects in the ranking. But it is further noted that if the filling of a set-aside or apportionment, say the Non- Profit set-aside, results in an excess apportionment in, say SRO, the application will still receive an assignment of credits, because the Non-Profit set-aside is filled before consideration of the Housing Type apportionments. After all credits have been assigned, staff will begin analyzing the applications for all other threshold requirements. Should an application not meet threshold, it will be re-ranked accordingly and the assignment of tax credits to the set-asides or apportionments will be adjusted. In the event that reallocation is required after the second round, waiting list projects will be assigned credits after adjusting the set-asides and apportionments. For the Housing Type apportionments, staff recommends reallocated amounts be divided evenly between Large Family and SRO applications. B4- J..4 \tl ~ ,,,,,,,~,.L ./~ Renter Occupied Housing Gross Rent Unit" ,'oI\h asa%of . Rental 1. f~. '/ Household combined Occupied more Income Renter O\l'8l'DOWd- Census Housing persons Renter Over- High Rent Ing end rem County Tr-r:ct Units cer room Occupied crowd/no Burden blldtn , 35% or more 35% or more 35% or more San Bemardlno 59.00 194 91 89 4e.0196 45.8896 02.7896 San Bemardlno 85.00 1275 334 599 2e.2096 4e.0896 73.1'" San Bernardino 69.00 370 104 177 28.11" 47.8496 75.05" San Bemardlno 70.00 1028 329 403 32. OO'J(, 30.2"" 71.2196 San Bemardlno 75.00 13 13 13 100.009(, 100.~ 2oo.00'J(, San Bemardlno 98.00 982 306 410 31.1696 41.7596 72.0196 San Bemardlno 104.05 543 73 305 13.4496 56.1796 eo. 81" San Bemardlno 117.00 197 82 68 41.62% 34.5296 7e.1496 San 01800 22.00 2387 843 1121 35.3296 46.0696 82.2'" San Diego 23.00 2649 627 1182 23.6796 44.6296 68.2996 San Oleao 24.00 2619 731 1214 27.9196 46.3596 74.2696 San Diego 25.01 1041 338 537 32.47% 51.59% 84.05" San Diego 26.00 2483 930 1281 37.4596 51.5996 89.0596 San 01600 27.01 3395 1076 1621 31.6996 47.7596 70.4496 San 01600 27.04 1509 530 908 35.1296 60.17" 05.29" San 01800 28.01 504 57 348 11.3196 69.0596 80.3696 San Diego 29.02 1058 167 599 15.8196 Se.7296 72.5496 San 01800 29.03 400 55 218 13.7596 54.50CJ6 tSB.25" San 01800 30.02 1068 384 467 35.9696 43.73% 70.~ San 0/800 31.02 1232 355 643 28.8196 52.1096 81.01" San 0/800 31.03 318 104 137 32.7"" 43.0'" 75.7096 San 0/800 31.05 193 68 82 34.2"" 42.4096 7e.8ft San 0/800 31.09 104 48 45 4e.1596 43.2796 80.4296 San 0/800 32.02 300 80 145 26.6796 48.3396 75. ()()fJ(,. San O/egO 33.00 2826 1068 1630 37.7996 57. e8'J(, 05.47" San 01800 34.02 1365 525 714 38.4696 52.3196 go. n" San 0/800 35.00 1402 560 616 30.9496 43.9496 83.8896 San 0/800 36.00 1484 843 715 56.8196 48.1896 104.0996 San 01800 39.00 1569 766 819 48.8296 52.2"" 101.0296 San Oi8Oo 40.00 883 403 ....0 46. 7096 50.0896 07.~ San 0/800 41.00 1391 ' 407 639 29.2696 45.0496 75.2"" San 01800 45.00 1807 672 729 37.1996 40.3496 n.5396 San Oi8Oo 46.00 996 310 ....1 31.1296 44.28CJ6 75.4096 San O/egO 47.00 573 351 296 61.2696 51.6696 112.9196 San 0/800 4113.00 958 496 406 51. n" 42.3896 94.1596 San Di800 49.00 955 505 388 52.8896 40.63" 03.5196 San Diego 50.00 428 226 235 53.0596 55. 16" 108.2296 San Diego 51.00 352 127 176 36.0896 50. OO'J(, 8e.0896 San Oi8Oo 86.00 1050 461. 451 44.4896 42.9596 87.4396 San Oi8Oo 88.00 1202 493 422 41.0196 35.1196 76.1296 San Diego 90.00 724 261 259 36.0596 35. n" 71.8296 San Diego 1 00.01 288 63 143 21.88% 49.6596 . 71.5396 San Diego 100.02 903 359 263 39.7696 29. 1396 68.8896 San Diego 100.07 170 126 66 74.1296 38.8296 112.9496 San Dieco 100.08 2264 1114 947 49.2096 41.83% 91.0396 San Oieoo' 100.09 985 532 552 54.0196 56.0496 110.05% Page 21 m-~S- Rent.r Occupied Housing Gross Rent Units with asa%of Rental 1.01 or Household Combined Occupied more Income Renter overr:rowd- Census Housing persons Renter Over- High Rent Ing end rent County Trac::t Units Der room Occupied aowdina Burden bllTlen 35% or more 35% or more 35% or more San Dleao 101.06 1070 394 397 36.82% 37.1()fJ(, 73. Q3" SIn 01800 1 01.07 553 186 214 33.83% 36.7()fJ(, 72.33% San 01800 101.09 335 119 111 35.52" 33.13" 08.00" San 01800 114.00 323 188 142 57.59" 43.Q6~ 101.55" San 01800 116.00 2132 747 808 35.04" 37. Q()fJ(, 72.Q4" San Diego 118.00 1971 734 945 37.24" 47.95" 65.19" San 01800 121.00 801 267 355 33.33" 44.32" 77.05" San Diego 122.00 . 329 127 153 38. 6()fJ(, 4CS.5O% 85.11" San Dleao 132.04 460 142 176 30.87" 38.26" CSQ.13" San Dleao 1Q.75" - 4Q.25" eQ.~ 139.01 1458 288 718 San Diego 182.00 1814 721 854 39.75" 47.089(, 8CS.82" San Dleao 184.00 1061 316 558 29.78" 52.59" 82.3B'J(, San Dleao 185.01 2426 591 1122 24.36" 46.25" 70.01", San Diego 186.03 613 276 348 45.02" 56.77" 101.7Q" San 01800 189.02 1715 ....5 758 25.95" 44. Ow, 70.03" San Diego 192.02 1164 244 602 20.96% 51.72" 72.08" San 01800 195.00 2290 644 . 1000 28.1296 43.67" 71.79" San 01800 199.02 523 167 191 31.93" 36.52" 08.45" Ssn 01800 200.06 800 248 246 41.33" 41.~ 82.33" San 01800 200.09 1862 568 713 30.50'J6 38.29" CS8.8~ San 01800 202.98 2091 622 936 29.75" 44.76" 74.51" San 01800 205.00 820 - 292 375 35.61" 45.73" 81.34" San 01800 206.01 921 316 401 34.31" 43.54" 17.85'1(, san Francisco 114.00 1388 518 512 37.32" 36.89" 74.21" San Francisco 176.98 1406 285 786 20.27% 55.Q()fJ(, 76.17'1(, San Francisco 177.00 532 147 231 27.63" 43.42" 71.05" San Francisco 180.00 222 57 108 25.68" 48. CS5" 74.32" San Francisco 201.98 1559 489 664 31.37" 42.59" 73.Q6" San Francisco 208.00 2090 829 965 39. CS7" 46.17" 85.84" San Francisco 209.00 1415 500 505 35.34" 35. CS9" 71.02" San Francisco 229.00 2353 883 982 37.53" 41.73" 7Q.26" San Francisco 232.00 402 97 258 24.13" 64. 1B'J(, 88.31" San Francisco 233.00 126 50 47 39.68" 37.3"" 76.Q8" San Francisco 25a.00 158 38 78 24.05" 4Q.37" 73.42" San Francisco 262.00 602 221 223 36.71" 37.04" 73.75" San Francisco 263.00 907 338 3'13 37.27" 41.12" 78.39" San Francisco 264.00 1482 482 539 32.52" 3CS.37" 08.80" San Francisco 314.00 461 142 181 30.8()fJ(, 39.26" 70.07" San Francisco 605.00 811 305 . 257 37.61" 31.CS9" 69.3()'J(, San Joaauin 1.00 1873 576 812 30.75% 43.35" 74.11" San Joaquin 3.00 395 214 136 54.18% 34.43" 88.CS1" San Joaquin 4.00 2369 558 1205 23.55% 50.87% 74.42% San Joaquin 5.00 607 283 282 46.62% 46.46% 93.08% San Joaquin 6.00 423 255 149 60.28" 35.22" 95.51% San JoaQuin 7.00 839 307 317 36.59% 37.78% 74.37% Page 22 Ell -;l ~ LOW INCOME HOUSING TAX CREDIT ALLOCATION PROCESS FOR PROPOSED ALLOCATION PLAN 1. Rank all proposals based on atfordability criteria. 2. Rank aU proposals based on cost categories. 3. Blend the two lists. 4. Go down the consolidated list and take out the set asides for rural, small developments (under 1 0 units), and 10% nonprofits. 5. Out of the remaining proposals select those in the targeted census tracts. (Encinitas has ~.) 6. Portion the proposals in the target census tracts into large family, special needs, and senior projects. ~4 - ;4 ~ " . '\ I PART 5. Escondido Study Comoarisons of Affordable Housino Strateaies: New Construction and ACQuisition/Rehabilitation "Cost Effectiveness" " 'B~ - I ") .... ATTACHMENT 4 COMPARISONS OF AFFORDABLE HOUSING STRATEGIES: NEW CONSTRUCTION AND ACQUlSITIONIREHABILITATION October, 1994 City of Escondido Department of Planning and Building Charles D. Grimm, Director Housing Division Patricia Getzel, Housing Manager Desiree Scott, HOME Program Consultant Telephone: (619) 741-4841 FAX: (619) 738...4313 ~-~ - COMPARISONS OF AFFORDABLE HOUSING STRATEGIES: NEW CONSTRUCTION AND ACOUTSITION/REHABILITATIO.M With the number of existing multifamily properties currently available in the City of Escondido at relatively low per-unit purchase costs, provision of low-income units through the acquisition and rehabilitation of existing multifamily units appears to be a better use of public funds than the construction of new low-income units. A comparison of the per-unit costs for new construction versus those of acquisition of existing units favors the purchase of existing units. However: there are other important considerations which should be factored into the discussion of new construction versus acquisition of housing for the purpose of providing affordable housing. Both new construction and acquisition and rehabilitation have a number of associated costs and benefits which should be taken into account when funding agencies consider subsidizing a specific project. The considerations that' are discussed here are based on the conditions generally found in San Diego County, and specifically, in the City of Escondido, California. Assessment of the HODsin!! Need In the City of Escondido, the greatest housing need is found among low-income renters. A substantial proportion of low-income households pay an excessive amount of their income for rent payments. Census data for Escondido shows that in 1990, fully sixty-three percent of the City's renter households who earn fifty percent or less of the area median income were paying more than fifty percent of their income for rent. Overcrowding of rental units is also on the rise among low-income households. Due in large part to housing payments that are out of proportion with household incomes, an increasing number of families have been forced to oc~upy units that are much smaller than they need, or to "double-up" with other families. According to census data, 846 of the City's renter households (seven percent) were classified as overcrowded in 1980. By 1990, however, that figure had jumped to 3,227 households, which was equal to seventeen percent of all renter households. The market research and experience of developers of low-income rent-restricted housing in Escondido indicates that there is a strong demand for secure, well-managed affordable units. In addition, there is a particular need among low-income families with children for affordable three and four bedroom units. Although the City's overall average multifamily vacancy rate now stands at about 8.7% 1, recently completed affordable units have achieved full occupancy in a very short time period. The 21-unit Daybreak Grove and Sunrise Place development, where 48% of the units have three bedrooms, achiev~d rent-up in less than two months from its official opening and currently maintains a waiting list of about 150 families, the majority of which require three bedroom units. Only one unit has turned over since initial occupancy. Rent levels range from $275 to $300 for very low-income families and $450 to $500 for low-income households, which are significantly below current market-rate rents in Escondido. The substantially lower rent levels of low-income units keep the one and two bedroom units at full occupancy and in high demand also. I Aparlm~nt R~l1y & Managemt!nl N~wslell~r. July-August 1994. ~-3 City of Escondido Affordable Housing Strategies Page 2 Experience at a recently completed acquisition and rehabilitation project in Escondida also clearly demonstrates the demand for larger units. The forty units in the first phase of the opening of the Paseo del Prado project, which contains 33 % townhouse-style three bedroom units, were fully leased within three weeks of opening. Although not all of the units contained in the final phase of the project have been leased, all of the three bedroom units are occupied and there is a waiting list of 16 families for the three bedroom units. According t.o the developer, the demand for the larger units is primarily froin families with children. Shortal!e of Suitable Units iJ:l the Existine Rental Stock The problem of overcrowding is compounded by a lack of suitable units in Escondido's existing multifamily housing, especially by the 'unavailability of a variety of unit sizes. The private housing market in Escondido does not provide sufficient multifamily units with three or more bedrooms to accommodate households of five or more. The vast majority of multifamily housing in Escondido consists primarily of studios and one and two bedroom units. A survey of twenty-one multifamily properties that changed ownership in Escondido in 1993 and 1994 showed that of the 1,676 units in those complexes, only four percent had three bedrooms and none had four bedrooms. Due to the shortage of larger units, there are relatively few existing multifamily buildings that are suitable for rehabilitation for families. In light of the need for larger units, use of existing units to provide affordable housing results in the need to reconfigure and enlarge them. The costs involved in reconstructing existing units add up quickly and are considerably higher than simply renovating units in their current configuration. Desien Considerations Escondido's existing multifamily housing has generally been poorly designed for families. Much of the existing rental housing lacks amenities such as open space for children's play areas or common meeting spaces for residents. Sufficient parking and security features are also often lacking. New construction projects allow the opportunity to design secure housing that is ,specifically suited to the market for which it is intended. However, there is a cost tradeoff associated with including such amenities. As an example, the City recently gave preliminary approval to a 31-unit low-income limited equity..., cooperative on a vacant site which allows a maximum of 41 units. The developer of the project V\ has deliberately elected to develop only 31 units in order to design a project which promotes a /,( sense of ownership among residents and fosters stability in the neighborhood. All of the units"" will be townhouses with, according to the developer, "front and back porches, individual unit City of Escondido Affordable Housing Strategies Page 3 identity and other features intended to make families feel like they live in homes, not temporary apartments." Because larger families are expected to reside in the project, ample open space and a playground will also be included on the site. The development will also incorporate a community building for neighborhood residents. These design features obviously carry a higher cost but, because of their inclusion, it is more likely that the project will contribute to overall neighborhood improvement than would a standard apartment design. Costs to Relocate Existin~ Tenants There are other factors associated with the rehabilitation of existing housing units that are often masked when considering just per-unit purchase costs. State and federal laws require that when public funds are used for a rehabilitation project, existing tenants must be given relocation assistance, either temporarily while rehabilitation is being completed, or for permanent relocation. Relocation costs on a per-unit basis are often as much, or more, than the rehabilitation. As an example, the relocation consultant for a current 8-unit rehabilitation project in Escondida has estimated the relocation costs to average abom $19,000 per family. Before the rehabilitation project was started, four of the eight units in the project were occupied by seven families, while the other four units were vacant, thus making the average relocation costs $33,500 per occupied unit. The rehabilitation costs for the project are estimated to total $100,000, or only $12,500 per unit. Having to expend project funds on relocation benefits for existing tenants does not result in any lasting benefit to the project or to the City. Remaininl! Useful Life and Condition of Existinl! Housinl! Stock Other factors can impose additional costs on rehabilitation projects. The law requires that when public funds are used for acquisition and/or rehabilitation, all lead-based paint and asbestos must be abated. Lead-based paint is typically found in pre-1978 buildings, and almost all buildings more than ten years old contain asbestos. Further, much of the existing housing has a limited remaining useful life. Many of the existing apartment complexes in Escondido were ori~inally constructed for a quick return on investment and have, consequently, been poorly constructed. Extending the life of such buildings to the length of the affordability period required for subsidized projects (40 to 55 years) entails substantial expenditures as well as a higher level of ongoing maintenance and repair. In addition, major systems repair and replacement are required in an existing building much sooner than they are in a newly constructed one. It is also not unusual for actual rehabilitation costs to be higher than initially projected because it is difficult to determine the true condition of a building until after work has begun. '&S"-5 Housfng-Autnority WorKsnop 8/29/95 0 2r3~IOT507-221 2 of 2 o City of Escondido Affordable Housing Strategies Page 4 Hieher Costs and Fees for New Constructl.n.n There are also costs which are specifically associated with new construction of affordable housing units. As previously noted, lowwincome housing projects typically contain a significantly higher percentage of three and four bedroom units than do market-rate projects, which results directly in higher construction costs on a per-unit basis. It is also important for the developers of housing projects with long-term affordability restrictions to minimize the costs of maintenance and repairs over the expected life of the project. That concern demands a higher quality of construction than is typically found in existing market-rate multifamily buildings that are constructed with a shorter project life expectancy, resulting again in higher overall construction costs. (A list of the typical line items found in the development budgets of acquisition and rehabilitation projects and new construction projects has been included in Attachment A.) Other costs that are much higher for new construction than rehabilitation are the development fees charged by the City. Because the City does not have a policy of waiving or reducing fees for affordable housing projects, developers of low-income housing are charged fees at the same rate as develof.ers of market-rate units. For example, total City development fees for the Daybreak Grove/Sunrise Place development added up to $351,000, or about $16,700 per unit. Development fees, however, 3hould not be viewed negatively because they 'are used to help pay for public facilities such as schools, parks, and other infrastructure improvements. Thus, while development fees contribute to higher per-unit development costs, the fees also benefit the City in that they help to offset the costs that are generated by the development. Levera2inl! of Outside Sources of Fundine Focus on the per-unit costs of low-income units ignores another important aspect of the financing of affordable housing projects. The City's housing policies have placed a priority on leveraging other public and private sources of funding in City-subsidized projects in order to increase the public benefit achieved with the City's funds. New construction has the advantage of being more competitive in leveraging outside sources of funding than acquisition and rehabilitation. Developments involving new construction almost always qualify for a higher proportion of conventional loan financing than rehabilitation projects. Additionally, state and federal low-income housing tax credits, which are among the most significant sources of equity investment for affordable housing projects, are targeted predominantly for new construction projec:ts. Rehabilitation of existing units can qualify for tax credit financing in only exceptional cases. While tax credit financing is inefficient because of the associated costs, it is nevertheless, at present, one of the most important financing mechanisms available to developers of affordable housing units. ~s - (p City of Escondido Affordable Housing Strategies Page 5 Leveraging of other financing sources, such as tax credits, brings outside funds to City- subsidized developments. Those are funds that would, in all likelihood, go to housing developments in other cities if not used in Escondido. The addition of tax. credit financing and other private sources of funding can result in a lower required local subsidy to a project and a higher quality housing development. It is a common misconception that low-income housing projects are completely paid for with local tax dollars. In fact, the City makes every effort to obtain the highest quality development while keeping its contribution to the lowest required to make a project feasible and to keep it financially healthy over the long-term. Additionally, the City's subsidy is almost always in the form of a loan, which is repaid when, and if, project cash flow permits repayment. --. Alternative Measures of Efficient Use of Public Funds Those who are involved in the financing and development of low-income housing units typically use additional standards to measure the efficiency of the use of public fnnds in subsidizing affordable projects, whether new construction or rehabilitation. Because affordable housing projects in the state of California usually include a higher number of three and four bedroom units, project costs on a per-bedroom basis rather than a per-unit basis can provide a more accurate measure of the cost efficiency of a project. A per-bedroom cost analysis provides a better measure of the total number of residents housed. The cost of new construction is competitive with the cost of acquisition and rehabilitation when compared on a per-bedroom basis. Attachment B includes information on the development costs and local public subsidy for several current and recently completed low-income projects located within Escondido and other cities in the San Diego region. The analysis in Attachment B shows that, while new construction costs are typically higher on a per-unit basis, that difference diminishes when compared on a per- bedroom basis. It is also useful to measure the efficiency of the use of the City's housing funds by looking specifically at the local contribution required for a project on a per-unit and per-bedroom basis. The figures in the last two columns of Attachment B show that, in spite of generally lower total development costs, acquisition and rehabilitation projects often require a larger local subsidy than new construction on both a per-unit and a per-bedroom basis because of a lessened ability to leverage outside sources of fundin~. Attachment C shows an analysis of the total costs and the public costs in present value to obtain affordable rent It.vels over forty years in three approaches to providing affordable housing units: construction of new units, acquisition and rehabilitation of existing units, and rental subsidy which allows lowwincome households to rent a market-rate unit at an affordable rent. When looking at the total cost of each of these approache~ over forty years, this analysis demonstrates that the construction of new units is competitive with the two other approaches. Comparing the present value of the total public cost over the forty year period demonstrates that 7 new construction requires a much lower subsidy to obtain the same benefit. ~5"' - City of Escondida Affordable Housing Strategies Page 6 While the present value comparison for forty years of affordability in each of these three approaches shows that they are fairly comparable in total cost, it could be argued that new con:;truction in fact produces a greater long-term benefit. That is because at the end of the forty year affordability period, the value of the improvements remain as an asset to the community. Rehabilitation, on the other hand, contributes less investment to the community, and does not allow as much opportunity to design projects that are of long-term benefit to the City. Finally, at the end of forty years of rental subsidy, no remaining asset has been achieved other than maintenance and repair of the subsidized units over that time. Benefits Associated with Acquisition and Rehabilitation and New Construction The benefits that are obtained with acquisition and rehabilitation and new construction make it difficult to determine that one particular strategy is always the best one for providing affordable housing units. For example, new construction can further the City's goal to promote infill development on vacant parcels in developed areas. Rehabilitation of troubled properties, on the other hand, can significantly improve neighborhood stability. Both types of developments can provide highly visible new investment in areas that have been experiencing disinvestment. These kinds of neighborhood benefits, however, are not as easily quantified as total development costs. Nevertheless, these benefits are real and are carefully weighed when the City considers support of a housing development with public funds. Over the past few years, the City has made a commitment to participate in the new construction of 211 low-income units by subsidizing the Daybreak Grove/Sunrise Place and the Terraces developments. Both of these projects gained substantial outside funding commiltments. The City has also contributed recently to the rehabilitation of the 8-unit Aster Street projiect, the 16-unit 15th Street Cooperative, 78 units in the Paseo d~l Prado project and numerous other individual rehabilitation projects. In deciding whether to participate in the financing of each of these housing developments, obtaining the maximum public benefit for the City's investment within the context of specific neighborhood needs was an overall goal, not simply minimizing total per-unit costs. Each of these projects has contributed to improvement of Escondida's neighliorhoods in addition to creating much needed affordable housing for lower-income households. In summary, the City is best served by pursuing opportunities to rehabilitate existing housing alli! to construct new units for lower-income households. The City views these two appr.o::l.ches as integral and complementary strategies in its progress toward revitalizing neighborhoods while also expanding housing opportunities for all residents. ~s- -~ ", ATTACHMENT A TYPICAL DEVELOPMENT BUQGET ITEMS ACQui si tion/Rehabi 1 i tati on ~w Construction Site Acquisition Land Acquisition Rehabilitation Hard Costs Building Construction Design and Engineering Fees Design and Engineering Fees Relocation Costs Sitework Asbestos and Lead-Based Paint Abatement City Development Fees Legal Fees Legal Fees Reserves Reserves Financing Costs Financing Costs Development Fee Development Fee Marketing Costs Marketing Costs Syndication Costs (with use of tax credits only) -r5-Cj . = ~ w ::E :c {,J <( ~ > ~ is >8 n 5~ =< ~o ;s S~ ~~ <~ E ~~ ~f g.,e,:, o~ ..:lCJ:l ~s ~= ~~ o~ Z(iS ~r:.: ;~ ~< ::E~ 8~ ~ B >. '0 ] =' en u 2i If ] e ~ "2 a:l , .. cf - ~ ~ cf CI:I ~ e ~ -g a:l ~ <<) j:l., c ~ 8- 1 Q - 'a ;:) ~ cf N ~ e N ~ ~! _ CI:I .! 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