Tax Equity and Fiscal Responsibility Act (“TEFRA”)
Public Hearing related to 678 Ralston Avenue Affordable Housing April 28, 2026
What is TEFRA?
• Tax Equity and Fiscal Responsibility Act (1982)
Why a Public Hearing?
• TEFRA hearing is an IRS requirement for any non-profit borrower seeking tax-exempt bonds through a conduit issuer, such as the California Municipal Finance Authority (CMFA).
• The hearing is held to allow members of the public to comment, contest, oppose, or support the use of tax-exempt bonds for a nonprofit borrower that is providing a public benefit. 678 Ralston Ave Affordable Housing TEFRA
• Developer: CRP Affordable Housing
• 678 Ralston Ave (.36 acre) property consists of existing commercial/retail • 65 Affordable Residential Apartments, subterranean parking ancillary space (e.g., lobby, bike room, and office.
• Residential unit mix includes:
• 30 One-bedroom units
• 18 Two-bedroom units
• 17 Three-bedroom units
• Development Project Entitlements approved in May 2024; construction permits filed in October 2025; anticipated construction start in Spring 2026. 678 Ralston Ave Affordable Housing TEFRA
The Project-Public Benefit
678 Ralston Ave Affordable Housing TEFRA
Roles and Responsibilities
Borrower/Developer:
The Ridge at Ralston LP & CRP
Affordable Housing
Bond Issuer:
California Municipal Finance Authority (CMFA)
• Applied for $24,000,000, of tax-exempt
revenue bonds. Proceeds will be used to
finance or refinance the costs of the
acquisition, construction and development
of a multifamily rental housing project
located at 678 Ralston Avenue, Belmont,
California (the "Project") operated by CRP
Affordable.
• Joint Powers Authority
• Sole purpose is to provide
California’s local governments
with an effective tool for the
timely financing of communitybased public benefit projects. 678 Ralston Ave Affordable Housing TEFRA
City of Belmont’s Role & Responsibility
• Must hold a Tax Equity and Fiscal Responsibility Act (TEFRA) hearing and approve the bonds for state and federal tax law in order for the obligation to qualify as tax-exempt bonds
• Proposed bonds are not an obligation of the City
• City will have no financial, legal, or administrative obligations for the debt
1. Conduct the public hearing under the requirements of TEFRA and the Internal Revenue Code of 1986, as amended (the “Code”).
2. Adopt the resolution approving the issuance of the Bonds by the CMFA for the benefit of The Ridge at Ralston LP (the “Borrower”), to provide for the financing of the Project, such adoption is solely for the purposes of satisfying the requirements of TEFRA, the Code and the California Government Code Section 6500 (and following).
Action Requested of City Council
Staff Recommendation
Thank you!