Brea City Council
August 18, 2026

Orange County Grand Jury 2025-2026
California State Housing Mandates

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California State Housing Mandates

Orange County Grand Jury 2025-2026

TABLE OF CONTENTS
SUMMARY.................................................................................................................................................... 5 BACKGROUND ............................................................................................................................................ 6 REASON FOR STUDY .................................................................................................................................. 9 METHOD OF STUDY.................................................................................................................................10 RESEARCH........................................................................................................................................... 10 INTERVIEWS ......................................................................................................................................... 10 OBSERVATIONS AND SITE VISITS ............................................................................................................... 10 PUBLIC FORUMS AND EVENTS .................................................................................................................. 11 GOVERNMENT MEETINGS ........................................................................................................................ 11 DOCUMENT REVIEW............................................................................................................................... 11 CITY SURVEY........................................................................................................................................ 11 INVESTIGATION AND ANALYSIS............................................................................................................ 11 STATE HOUSING MANDATES AND LOCAL IMPLEMENTATION ............................................................................. 11 ENVIRONMENTAL CONTEXT AND CEQA...................................................................................................... 13 REGIONAL HOUSING NEEDS ASSESSMENT PROCESS..................................................................................... 15 REGIONAL HOUSING NEEDS ANALYSIS CHALLENGES .................................................................................... 17 PENALTIES FOR NOT HAVING AN HCD-APPROVED HOUSING ELEMENT ............................................................. 19 PENALTIES FOR NOT MEETING HOUSING-PLAN CONSTRUCTION GOALS ............................................................ 20 FEASIBILITY OF HOUSING MANDATE IN ORANGE COUNTY............................................................................... 20 ONE SIZE DOES NOT FIT ALL.................................................................................................................... 22 CALIFORNIA AND ORANGE COUNTY POPULATION TRENDS.............................................................................. 23 6TH CYCLE (2021–2029) HOUSING ALLOCATIONS IN OC ............................................................................... 25 CITY CHALLENGES................................................................................................................................. 27 7TH CYCLE (2029-2037) CONCERNS ......................................................................................................... 31 CONCLUSION ............................................................................................................................................32 FINDINGS...................................................................................................................................................34 RECOMMENDATIONS ..............................................................................................................................36 RESPONSES CODE.....................................................................................................................................40 RESPONSES ................................................................................................................................................41 GLOSSARY AND ACRONYMS ...................................................................................................................45 BIBLIOGRAPHY.........................................................................................................................................49 APPENDIX..................................................................................................................................................55 APPENDIX A: MAJOR HOUSING LAWS & WHAT THEY TRIED TO DO................................................................. 55 APPENDIX B: ORANGE COUNTY HOUSING MANDATE SURVEY QUESTIONS...................................................... 65 APPENDIX C: RESPONSIBILITIES............................................................................................................ 65 Responsibilities of OCCOG........................................................................................................... 65 California State Housing Mandates

Responsibilities of SCAG .............................................................................................................. 66 Responsibilities of HCD................................................................................................................ 66 California State Housing Mandates

Orange County Grand Jury 2025-2026

SUMMARY
California’s perceived housing shortage has prompted the California Legislature to impose increasingly bureaucratic prescriptive State Housing Mandates (Housing Mandates) on local governments, with the stated goal of accelerating production across all income levels. Core frameworks such as the Housing Element and the Regional Housing Needs Allocation (RHNA) process require cities and counties to plan for significant increases in housing capacity. Many additional statutes have contributed to a streamlined development approval process and weakened local discretion with severe penalties for noncompliance. These measures are intended to overcome decades of the perceived underbuilding and restrictive zoning within cities, yet their cumulative effect has been to create unnecessary local government costs, confusion, inequity, and growing tension between state directives and local realities. All of these efforts have led to minimal housing being built.

In Orange County, a region defined by diverse cities, established neighborhoods, and distinct infrastructure constraints, as well as environmentally sensitive areas, these Housing Mandates operate as a one-size-fits-all system poorly suited to local conditions. Housing targets are derived from opaque formulas, that fail to account for land costs, land availability, funding limitations, labor shortages, construction costs, infrastructure capacity and accurate population projections. Without corresponding investments in transit, utilities, schools, parks, public safety, and affordable housing subsidies, the Housing Mandates themselves are largely impractical and difficult to achieve. In addition, because of the financial infeasibility of building low-income housing without subsidies, cities must approve developments with higher density to pay for and meet the affordable housing requirements. As a result, local cities face mounting pressure to comply with requirements that often lack economic and logistical feasibility.

The dissolution of local redevelopment agencies in 2012 eliminated a primary mechanism for financing and managing affordable housing at the local level. In response, the State layered new housing requirements through the Housing Mandates onto cities and counties without restoring comparable funding tools or infrastructure support. Although these laws are framed as solutions to homelessness and affordability, they have in fact caused unintended consequences that have not produced incremental housing production. This is primarily due to regulatory complexity, limited subsidies, and heavy reliance on private market forces. Over time, repeated legislative interventions to solve these challenges have only expanded state authority. This leaves local governments with fewer resources and diminished control.

Housing Mandates have significantly eroded local land-use authority, supplanting community-based planning with rigid, top-down rules. Residents experience a loss of California State Housing Mandates

meaningful input; even as local officials remain legally responsible for compliance.

Streamlined approvals frequently bypass public hearings and local design standards, shift liability to cities, and prioritize building over neighborhood character. The practical elimination of traditional single-family zoning and the widespread upzoning of existing neighborhoods threaten longstanding community character while limiting local oversight of height, density, parking, and environmental resilience.

The Southern California Association of Governments (SCAG) determines the RHNA housing allocation for most of Southern California. Within this framework, the Orange County Council of Governments (OCCOG) serves as the County’s representative to SCAG in the RHNA process. The RHNA methodology and resulting allocations have been widely criticized as unrealistic, inequitable, and insufficiently transparent.1 OCCOG’s level of influence with SCAG is critical to regional planning outcomes.

OCCOG needs substantial funding increases to better advocate in Sacramento and within SCAG to support OC jurisdictions.

Given the significant challenges and inequitable housing allocations experienced during the current RHNA 6th Cycle (2021-2029), it is imperative that Orange County begin strategic preparation for the upcoming 7th Cycle (2029-2037) process. Proactive planning will strengthen the County’s ability to advocate within SCAG for fair, data-driven, and achievable housing allocations in the next cycle.

This report examines how Housing Mandates operate in practice within Orange County, and how well-intended legislation has produced unintended consequences for cities, neighborhoods, and local governance. It evaluates the feasibility, effectiveness, and equity of current state policies, and highlights the growing disconnect between mandated housing goals and the capacity of communities to absorb them responsibly.

The report underscores the need for housing solutions that respect local conditions, restore meaningful public participation, and align development goals with infrastructure, funding, and community priorities.

BACKGROUND
California continues to experience some of the highest housing prices and rents in the nation, while some say housing production has not kept pace with population and employment growth2. State policymakers have concluded that fragmented local decision-making, restrictive zoning practices, and lengthy approval processes, have 1 New-Pathways-to-Encourage-Housing-Production-Evaluating-Californias-Recent-Housing-LegislationApril-2023-Final.pdf 2 California Housing in 2025 - Advocacy - California Chamber of Commerce California State Housing Mandates

Orange County Grand Jury 2025-2026
contributed to this imbalance3. In response, the California Legislature has pursued a more centralized and enforceable approach to housing policy such as Senate Bill (SB)9, SB10, SB35, SB79, SB131, SB330, and Assembly Bill (AB)1050, AB2011(see Appendix A), shifting significant authority from local jurisdictions to the State. Since 2017, the California Legislature has enacted more than one hundred housing-related bills designed to establish clearer production expectations, reduce procedural delays, and strengthen enforcement mechanisms for jurisdictions that do not comply with state housing requirements.

The Housing Element Law (Government Code 65580-65589.11), originally adopted in 1969, remains the foundation of California’s housing policy. The law requires every city and county to prepare a Housing Element as part of its General Plan that identifies how the jurisdiction will meet the housing needs of all income groups.4 The RHNA process implements these Housing Mandates by assigning each jurisdiction a specified number of housing units—categorized by income level. Compliance is tied to eligibility for state housing and transportation funding, creating substantial financial implications for the County of Orange and its 34 municipalities.

Zoning has long been a cornerstone of local government authority, guiding development, and shaping the physical form of cities.

First introduced in the late nineteenth and early twentieth centuries to address public safety concerns, zoning has since expanded into a sophisticated regulatory system governing land use, building height, setbacks, lot coverage, density, and numerous other development standards. These tools enable local governments to align growth with infrastructure capacity, environmental constraints, and long-term planning objectives, while simultaneously delivering broad public benefits. In addition to protecting public health and safety by distancing residential areas from heavy industrial activities and ensuring reliable emergency access, zoning helps preserve neighborhood character and property values. It also supports community cohesion by balancing residential, commercial, and civic uses, and guides growth in ways that correspond with available public services and facilities. Moreover, zoning plays a vital role in safeguarding environmentally sensitive areas and reducing exposure to wildfire risks, underscoring its enduring importance as a foundational instrument of urban planning.

In recent years, traditional zoning practices have been subject to increasing scrutiny.

Critics argue that low-density zoning and land-use restrictions have contributed to housing shortages, affordability challenges, socioeconomic segregation, 3 In California, statewide housing reforms brush against local resistance | Brookings 4 New-Pathways-to-Encourage-Housing-Production-Evaluating-Californias-Recent-Housing-LegislationApril-2023-Final.pdf California State Housing Mandates

automobile-dependent development, and exclusionary housing patterns.5 Housing advocates, civil rights organizations, and some policymakers have cited these concerns as justification for significant state intervention and reform of local land-use authority.6 State leaders have relied on these critiques to support a series of Housing Mandates that expand the State’s role in local planning decisions. These measures prioritize increased housing production as the central response to the State’s affordability challenges. The underlying assumption is that a significant increase in supply will help reduce housing costs. However, historical data reviewed by the 25-26 Orange County Grand Jury (OCGJ) indicate that periods of high housing production in Orange County, including during the 1990s, did not consistently result in improved affordability.7 This suggests that housing affordability is influenced by multiple factors other than housing supply, including land values, construction costs, wages, and regional economic conditions.

The dissolution of redevelopment agencies in 2012 further altered the local housing landscape. Redevelopment agencies had served as a significant source of financing for affordable housing and community revitalization projects through tax-increment financing and state-authorized planning powers. Their elimination removed a key funding mechanism for cities and counties.8 In subsequent years, the State imposed additional Housing Mandates without restoring revenue sources, leaving jurisdictions and builders responsible for meeting expanded obligations with reduced financial capacity.

The current generation of State Housing Mandates (6th Cycle) reflects multiple statewide policy objectives. Early legislative proposals referenced a goal of constructing approximately 3.5 million new housing units; later that figure was reduced to approximately 2.5 million units.9 Despite these goals, statewide production continues to fall short of identified need. To address this, state housing legislation has emphasized increased zoning density, reduced discretionary review, expanded ministerial approval pathways, strengthened density bonus incentives, and increased requirements for jurisdictions to facilitate affordable housing in lieu of government subsidies. Additional measures focus on locating new housing near employment centers and transit corridors to reduce commute times and greenhouse gas emissions.10 5 National Low Income Housing Coalition - Land Use Restrictions and Affordable Housing 6 Fixing California’s housing shortage requires new policy and new politics - Berkeley Economy & Society Initiative
7 Court Agrees Anaheim Violated State Law. Decision is a Big Win for Fair Housing in California | California Department of Housing and Community Development 8 California Post-RDA Affordable Housing Developer Survey: Analysis of Results - San Francisco Fed 9 New-Pathways-to-Encourage-Housing-Production-Evaluating-Californias-Recent-Housing-LegislationApril-2023-Final.pdf 10 California State Senate Recent Legislative Actions
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Orange County Grand Jury 2025-2026
Collectively, these policies mark a significant shift in California’s approach to land-use governance. While intended to address housing shortages and affordability concerns, they have also raised questions regarding feasibility, infrastructure capacity, public engagement, and the long-term effects on established communities. These issues are particularly relevant in Orange County, where many cities are fully built out, constrained by environmental concerns, geography, and infrastructure limitations, and seeking to balance statutory obligations with community priorities and public expectations. The impact on Orange County and its 34 cities in meeting these Housing Mandates deserves intense scrutiny.

REASON FOR STUDY
The expansion of Housing Mandates has provoked public awareness and challenged local governments. Media coverage has grown, reflecting divergent viewpoints regarding the Housing Mandates’ effectiveness, equity, and long-term consequences.

Cities across Orange County have responded in a variety of ways, adopting compliance strategies that differ widely in breadth, transparency, and community engagement.

Residents have expressed a similarly broad range of perspectives, from support for expanded housing opportunities to concerns regarding neighborhood impacts, infrastructure strain, loss of local control, and limitations on public participation in land-use decision-making.

Housing Mandates have the potential to significantly reshape the character of Orange County Communities.

Beyond requiring increased zoning density and higher residential densities, the Housing Mandates influence demographic patterns, neighborhood character, transportation systems, public services, and environmental concern. Local jurisdictions must absorb these impacts without corresponding state investment in infrastructure, affordable housing subsidies, or restoration of tools previously used to manage growth, such as redevelopment agency financing.

Given these conditions, this report attempts to evaluate both the intended and unintended consequences of Housing Mandates as they are applied within Orange County. It will identify where state requirements may conflict with local capacity and community needs and assess how recent legislative changes have shifted the balance between state authority and local governance. In addition, this report seeks to establish a strategic framework for influencing future housing allocations within SCAG by strengthening the role and effectiveness of OCCOG as we move into the next planning phase.

California State Housing Mandates

METHOD OF STUDY
In conducting this study, the OCGJ employed a multi-method approach designed to gather information from a broad range of governmental, professional, construction industry, and community perspectives. The methodology included research, interviews, observational site visits, document review, surveys, and participation in relevant public forums. This comprehensive approach allowed the OCGJ to evaluate how Housing Mandates are interpreted, implemented, and experienced across Orange County jurisdictions.

Research
The OCGJ conducted extensive background research using publicly available sources, including:
• Governmental and agency websites
• Online news and media sources
• Local and Community news outlets
Interviews
The OCGJ conducted interviews with representatives from the following organizations and groups:
• City leadership from multiple Orange County cities
• Sitting and former city officials
• Orange County Council of Governments (OCCOG)
• Orange County Public Works – Development Services
• Orange County Housing & Community Development
• Local housing program administrators
• American Institute of Certified Planners (AICP) – housing specialists • Private-sector builders and development professionals Observations and Site Visits
OCGJ members conducted guided site visits and observations of housing and mixed-use developments, including:

Multiple retail and housing developments (market rate, affordable and low income) in:
• Huntington Beach
• Midway City
• Anaheim
• Santa Ana
• Westminster
• Irvine
California State Housing Mandates

Orange County Grand Jury 2025-2026
• San Juan Capistrano
Public Forums and Events
The Members of the OCGJ attended:
• The 2025 Chapman Economic Forecast
• Newport Beach Community Forum
• Foothills Neighborhood Association Town Hall
Government Meetings
The Members of the OCGJ attended:
• Orange County Board of Supervisors
• Orange County Council of Governments (OCCOG)
• Technical Advisory Committee (TAC), a subcommittee of OCCOG • Monitored City Council meeting within the County
Document Review
• Complaints and correspondence submitted by Orange County residents. • Community Development Records from applicable jurisdictions City Survey
The OCGJ developed and distributed written survey questions to Orange County cities to gather information concerning:
• Housing Element compliance strategies
• Local responses to Housing Mandates
• Community engagement processes
• Infrastructure and resource constraints

INVESTIGATION AND ANALYSIS
State Housing Mandates and Local Implementation
The Housings Mandates, through the laws approved by the California Legislature, have pursued a more centralized and enforceable approach to housing policy (Appendix A), shifting significant authority from local jurisdictions to the State. Since 2017, the California Legislature has enacted more than one hundred housing related bills, designed to establish clearer production expectations, reduce procedural delays, and strengthen enforcement mechanisms for jurisdictions that do not comply with state housing requirements.

California State Housing Mandates

California’s housing statutes are not aspirational guidelines; they carry the force of law and impose affirmative legal obligations on local jurisdictions. Cities are therefore required to plan for, accommodate, and in many cases, approve housing development consistent with Housing Mandates, regardless of local political preferences, historic planning practices or public consensus.

According to California State policy guidance, the Housing Mandates are intended to address decades of housing underproduction that state policymakers identify as contributing to rising housing costs, overcrowding, displacement, reduced economic mobility and a lack of affordable housing.11 From the State’s perspective, reliance on regional and local discretion has not consistently generated housing at levels necessary to improve affordability, particularly for lower and moderate-income households.12 In response, the California Legislature and HCD have adopted a compliance driven model designed to ensure that every jurisdiction contributes to meeting statewide housing needs.

Orange County cities differ significantly. Th OCGJ’s investigation focused on areas where the state’s rapidly evolving legislative requirements conflicted with local zoning practices, infrastructure constraints, and past practices. It also examined how recent statutory reforms shifted authority away from local jurisdictions toward state oversight and enforcement, reshaping the governance methodology and altering both the practical and legal responsibilities of cities.

Within this context, this report does not question whether cities must comply with state housing law—they must—but rather this report’s objective is to assist Orange County jurisdictions and the public in understanding the framework within which they operate and enhance the possibility of good planning practices and design. During interviews, city officials and builders described to the OCGJ the benefits of citizen engagement, proactive and early coordination on planning, realistic site inventories, and timely engagement with state agencies to avoid punitive actions.

Public communication and civic education is essential. Several Orange County cities reported undertaking efforts to engage residents and explain how the Housing Mandates affect local decision-making authority, including reductions in traditional zoning discretion. Transparent public outreach was identified as an important practice for maintaining community trust and managing expectations in an era of constrained local control.

Through interviews, document review, site observations, and comparative analysis, several key themes emerged and are expanded on below:
11 Statewide Housing Plan
12 California Legislative Analyst's Office - California Housing California State Housing Mandates

Orange County Grand Jury 2025-2026
• Environmental Context and CEQA
• RHNA Process
• RHNA Challenges
• Penalties of Not Having an Approved HCA Housing Element • Penalties for Not meeting Approved Housing Plan
• Feasibility of Housing Mandate in Orange County
• One Size Does Not Fit All
• California and OC Population Trends
• 6th Cycle Housing Allocations in OC
• City Challenges
• 7th Cycle Concerns
Environmental Context and CEQA
In 1970, California enacted the California Environmental Quality Act (CEQA) with broad legislative support. These are the broad body of environment laws that attempt to protect California’s environment13. Its core purpose is to ensure that state and local government agencies identify and publicly disclose the environmental impacts of proposed projects before approving them.14 Importantly, CEQA does not prohibit development; it ensures development is done responsibly, with environmental protections, public notice, and accountability. It has played a key role in shaping California’s environmental standards for over five decades. Yet recent housing laws are chipping away at these hard-won environmental protections and may put our environment at risk.

Over time, the California Legislature has adopted amendments intended to streamline housing projects. Several interviewees asserted that recent statutes—including A130 and SB131—have the effect of narrowing CEQA’s environmental review for qualifying housing projects by expanding ministerial or exempt pathways15. Before CEQA and the Federal Clean Air Act, Southern California experienced severe air pollution, with the region enduring over 200 days each year of unhealthy ozone levels. 16 In the 1970s, this
led to frequent smog alerts and restrictions on outdoor activity for vulnerable residents17. Longtime residents recall this period as one when smog was so persistent it regularly obscured visibility and affected daily life. Today, air quality in Southern California is dramatically improved, with far fewer unhealthy-air days due to decades of 13 PPIC Statewide Survey: Californians and the Environment - Public Policy Institute of California 14 South Coast Air Quality Management District - CEQA
15 California Lawmakers Approve Major Overhaul of Landmark Environmental Law | KQED 16 How Los Angeles Began to Put its Smoggy Days Behind | History & Society | PBS SoCal 17 Los Angeles Historical Air Quality Analysis: AQI, PM, CO, SO2, NO2, O3 California State Housing Mandates

CEQA measures that have collectively transformed the air basin and made local conditions significantly cleaner and healthier than during the smog-filled 1970’s.18 A smoggy aerial view of downtown Los Angeles in January 1975.

Polling in California consistently shows strong public support for environmental protection, though some surveys also indicate support for regulatory changes aimed at increasing housing production and lowering costs.
19 Recent laws have made it simpler to construct housing by scaling back environmental controls.20 While this may accelerate development, it also threatens to weaken important environmental protections that California has relied on for decades. And importantly, there is no guarantee that these streamlined projects will provide affordable homes or meaningfully improve the housing crisis.
18 How Los Angeles Began to Put its Smoggy Days Behind | History & Society | PBS SoCal 19 PPIC Statewide Survey: Californians and the Environment - Public Policy Institute of California 20 In California, statewide housing reforms brush against local resistance | Brookings California State Housing Mandates

Orange County Grand Jury 2025-2026
Regional Housing Needs Assessment Process
RHNA is the State mandated process that determines the number of new housing units across various income levels that each city and county must plan for each 8-year cycle.
21 It requires local governments to zone adequate land to meet projected regional housing needs.22 RHNA is implemented through the HCD whose mission statement emphasizes safe, affordable homes and sustainable communities. 23 The RHNA process begins with HCD’s review of household growth projections to estimate future housing needs by region. The California Department of Finance shares demographic projections with regional planning bodies known as Councils of Governments (COGs). These projections form the basis for RHNA determinations among California regions, and each COG then develops suballocations for counties and cities within its jurisdiction. Each city is required to update a Housing Element as part of its General Plan, describing objectives, programs, and housing sites consistent with RHNA goals. In recent years, the California Legislature has enacted statutes expanding HCD’s authority in reviewing and enforcing RHNA related plans.24 SCAG is the largest COG in the State which includes Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura Counties. SCAG represents 197 jurisdictions across more than 38,000 square miles. SCAG develops RHNA allocations for its member jurisdictions and also engages at the state level on issues relevant to regional planning, including housing legislation.25
OCCOG, established as a joint power’s agency in 1996, serves as a representative of Orange County to SCAG on RHNA planning (and other issues, i.e., transportation). The organization emphasizes collaboration, transparency, and consistent advocacy to ensure Orange County’s interests are effectively represented in regional planning, areas where the OCGJ has identified deficiencies.26
OCCOG’s charter describes it as a voluntary advisory association of local governments seeking sub regional and regional planning, coordination, and technical assistance on issues of mutual concern. OCCOG has an Executive Director and minimal staff. A member of the Orange County Board of Supervisors serves on the OCCOG Board and is the SCAG representative for the County of Orange.
27 21 California Housing Element Law Explained – Legal Clarity 22 The California State of Real Estate - Realtor.com Economic Research 23 Welcome to HCD! | California Department of Housing and Community Development 24 Enforcement Authority | California Department of Housing and Community Development 25 About us | Southern California Association of Governments 26 Orange County Council of Governments
27 Orange County Council of Governments
California State Housing Mandates

SCAG adopted its 6th Cycle housing allocation plan for the period of October 2021 through October 2029. The plan assigns 1,341,827 additional housing units across the SCAG region—which includes most of Southern California—and distributes those units among cities and unincorporated areas, including those in Orange County.28 Stakeholders reported that the 6th Cycle methodology resulted in a significant housing unit increase compared with the 5th Cycle allocation to SCAG of 411,953 units; representing approximately a 300% increase. The dramatic increase prompted the municipalities to request reviews and appeals of their assigned housing requirements.

In response, HCD cited multiple reasons for the regional increases including unit overcrowding, affordability indicators, the ongoing effects of previously unbuilt housing units during the 2008 recession and the statutory adjustment factors under California Government Code § 65584.01 (statutory formula)29
28 Southern California COG Regional Housing Need Determination 29 Southern California COG Regional Housing Need Determination California State Housing Mandates

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Summarized are the five objectives that the COGs (i.e. SCAG) must further in their allocation methodology (Gov. Code § 65584(d)):30
• Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and counties within the region in an equitable manner, resulting in allocations for low and very low-income households, and providing for extremely low and acutely low-income allocations within the range prescribed by statute
• Promoting infill development and socioeconomic equity, protecting environmental and agricultural resources, encouraging efficient development patterns, and achieving greenhouse gas reduction targets pursuant to Government Code section 65080.
• Improving the intraregional relationship between jobs and housing, including balance between low wage jobs and housing affordable to low wage workers. • Allocating a lower proportion of housing need to an income category where a jurisdiction already has a disproportionately high share of households in that category relative to the countywide distribution.
• Affirmatively furthering fair housing.

These objectives are intended to support more economically diverse communities by assigning housing to high resource, job rich areas and by encouraging infill development while protecting environmental resources (CEQA). 31 RHNA assigns
targets to each jurisdiction by income category. For the 6th Cycle, the four income categories are: Very Low (≤ 50% of county median income), Low (50–80%), Moderate (80–120%), and Above Moderate (≥ 120%)32. Through HCD and RHNA, California instructs and enforces compliance with specific housing targets.

Regional Housing Needs Analysis Challenges
The cities’ leadership in Orange County offered multiple critiques of RHNA, including:
(1) allocation methodology at SCAG does not reflect local housing need, (2) concerns of fairness in allocation across jurisdictions, (3) the appeal process to SCAG by local governments were consistently denied, and (4) assigned housing goals do not consistently translate into actual permitting, especially for lower income households.33 HCD has stated that RHNA goals should not be interpreted as a production forecast but 30 California Department of Housing and Community Development | 31 The 5 Statutory Objectives of the RHNA Methodology
32 State Housing Law Program | California Department of Housing and Community Development 33 Best Practices for Allocating & Evaluating RHNA
California State Housing Mandates

as a planning objective.
34 Even with this planning objective, Orange County jurisdictions reported significant operational and fiscal challenges associated with implementation.

Jurisdictions described resource constraints that affect their ability to implement the Housing Mandates consistent with legislative intent, including staffing limitations, the need for specialized consultant support, and budget constraints. Several cities characterized RHNA determination and compliance as complex and costly. Some cities reported spending hundreds of thousands of dollars (sometimes reaching close to $1,000,000) to meet the reporting mandate. Taxpayer money spent on planning does not directly result in the construction of housing units.

Interviewees also reported that SCAG’s approved methodology is complex and difficult for elected officials to communicate their housing allocation and ultimate Housing Element to their constituents. HCD and SCAG should take steps to improve the RHNA processes, including enhancing communication transparency and simplifying data driven methodologies. Additionally, recognizing the compliance costs to taxpayers cannot be left unaddressed even as the 7th Cycle planning is currently underway.

In October 2021, the California State Joint Legislative Audit Committee approved an emergency audit of HCD’s regional determination process, citing limited public visibility of calculation methods and a need for independent review.35 Further, the audit identified errors in certain data calculations and raised concerns36. The California State Auditor subsequently issued findings that criticized aspects of HCD’s methodology indicating potential inflation of requirements by a substantial number of housing units.37 Some of the cited errors included the use of very outdated and inaccurate vacancy factor rates38. One report even suggests base information used was from the 1980’s39.

Others reported that HCD relied on population projections that differed from California Department of Finance forecasts, which generally show relatively modest long-term growth, and instead used assumptions that resulted in significantly higher projected housing needs.
40 HCD’s response, to the California State Auditor, and on their website, acknowledged there was room for improvement and addressed the allocation criticisms in very general terms but did not mention that the numbers had been or would be corrected.41
34 New-Pathways-to-Encourage-Housing-Production-Evaluating-Californias-Recent-Housing-LegislationApril-2023-Final.pdf 35 California Auditor Report 2021-125
36 California Auditor Report 2021-125
37 More Homes, Hardly Any Population Growth—So Why Is California Still So Expensive? 38 CA Auditor Bashes State’s Mandated Housing Numbers, Says Process Is Flawed, Lacks Oversight 39 CA Auditor Bashes State’s Mandated Housing Numbers, Says Process Is Flawed, Lacks Oversight 40 Court: 'Regional Housing Need' Determinations Aren’t Judicially Reviewable - Davis Vanguard 41 California State Auditor - Report 2021-125 Recommendation 3 Responses California State Housing Mandates

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Separately, in June 2021, OCCOG, on behalf of the Orange County cities, filed a judicial challenge to HCD’s regional housing determination, arguing that HCD failed to follow statutory requirements in developing the RHNA allocation.42 The trial court dismissed the petition in November 2021, and the Second District Court of Appeal affirmed that dismissal in July 2023, holding that neither OCCOG nor its member cities could challenge HCD’s methodology.43 On August 24, 2023, the OCCOG Board authorized counsel to petition the California Supreme Court for review, but the Court denied the petition on October 11, 2023, effectively ending OCCOG’s legal challenge. 44 During the
6th Cycle process, SCAG received 48 appeals from cities challenging their housing allocation within their 45-day appeal period. After SCAGs review, they quickly denied 47 of them.45 This demonstrates limited jurisdictional influence over the allocation and appeal process. This series of rulings confirms that HCD’s statutory authority has been upheld by the courts, and that any changes sought by local jurisdictions may be addressed better through the legislative process rather than litigation.

Penalties for Not Having an HCD-Approved Housing Element A city that fails to obtain certification of its Housing Element from the HCD is considered out of compliance with state Housing Element Law and becomes subject to a range of escalating enforcement actions.46 HCD’s Housing Accountability Unit (HAU) has authority to initiate enforcement, including referral to the California Attorney General for legal action when a jurisdiction does not meet statutory planning requirements.47 When a city is out of compliance, it can be exposed to severe statutory penalties, such as lawsuits by the Attorney General or outside entities, court-imposed fines ranging from $10,000 to $600,000 per month, and court orders that may mandate project approvals, require rezoning, suspend a city’s authority to issue building permits, or even strip the city council of land-use authority until compliance is achieved.48 The most concerning and widely known consequence of noncompliance is the Builder’s Remedy, which restricts a city’s ability to deny qualifying housing projects even when they conflict with the city’s General Plan or zoning rules.49 Under this provision, developers may propose larger, denser projects that bypass local zoning controls if at least 20% of the units are affordable to low-income households or if the project is 100% 42 OCCOG Press Release HCD
43 Orange Cnty. Council of Gov'ts. v. Velasquez - vLex United States 44 Orange County Council of Governments
45 Orange County Council of Governments
46 Analysis Finds Davis Not on Track to Meet Housing Requirements without Approval of Two Voter Projects - Davis Vanguard
4747 Analysis Finds Davis Not on Track to Meet Housing Requirements without Approval of Two Voter Projects - Davis Vanguard
48 Housing Open Data Tools | California Department of Housing and Community Development 49 “Builder's Remedy" Reform Bill Approved by Governor Newsom | Allen Matkins California State Housing Mandates

moderate-income.50 Cities without a compliant Housing Element lose their ability to regulate these projects through their typical zoning constraints unless they can demonstrate specific, adverse health or safety impacts.51 Additional consequences include loss of access to key state funding sources and being placed on a shorter four-year Housing Element update cycle rather than the standard eight-year schedule.52 As of this writing, some Orange County cities—such as Huntington Beach and Seal Beach—have not yet obtained certification of their Housing Elements for the 6th Cycle or have been subject to enforcement actions related to noncompliance, while others, such as Costa Mesa, have only achieved compliance after delays and state intervention.53
Penalties for Not Meeting Housing-Plan Construction Goals While RHNA production targets are planning requirements, not actual construction mandates – cities may face meaningful consequences if they fail to implement the programs and rezoning commitments included in their certified Housing Elements.

HCD’s HAU monitors compliance with both Housing Element commitments and state housing laws, and violations may prompt enforcement letters, monitoring actions, or legal referrals to the Attorney General.54 Courts have shown a willingness to override local discretion when a city’s failure to implement its Housing Element prevents the jurisdiction from accommodating its assigned RHNA allocation.55 In some cases, courts may mandate rezoning, invalidate local development restrictions, or require approval of specific projects to ensure that adequate housing capacity is created.56 Feasibility of Housing Mandate in Orange County
The feasibility of California’s Housing Mandates in Orange County raises significant practical concerns. HCD, during the 6th Cycle, has allocated 183,161 housing units to Orange County to be constructed by 2029 with 30% being considered ‘affordable’.

However, according to the US Census Bureau, Orange County is only producing an average of 5,000 units a year over the past 5 years.
57 Clearly this is a dilemma for the
County. While it is relatively easy for the California Legislature to pass ambitious housing laws, the actual construction of these units is far more challenging. The Housing Mandates may be well-intentioned but translating them into real-world development is complex, due to constraints in land availability and costs, infrastructure 50 Builder's Remedy Primer
51 The Builder's Remedy and Housing Elements
52 Housing Elements | California Department of Housing and Community Development 53 Appeals Court Orders Huntington Beach to Comply with State Housing Law - Davis Vanguard 54 Enforcement Process | California Department of Housing and Community Development 55 Appeals Court Orders Huntington Beach to Comply with State Housing Law - Davis Vanguard 56 Appeals Court Orders Huntington Beach to Comply with State Housing Law - Davis Vanguard 57 Index of /programs-surveys/popest/tables
California State Housing Mandates

Orange County Grand Jury 2025-2026
capacity, high construction and labor costs, community acceptance, and capital formation.

Capital formation for housing development in Orange County faces significant challenges. The cost of capital remains high, and the long timeline required to entitle, build, and eventually generate revenue increases financial risk for developers.

Interest-rate volatility further complicates financing, affecting both equity investment and construction loan terms. At the same time, affordable housing projects often struggle to qualify for limited government subsidies, leaving many developments financially infeasible. These pressures are intensified in Orange County, which has some of the highest land and construction costs in California, making lower-income housing especially difficult to deliver without substantial public support.58 59 60 61 Most parts of Orange County are already built out, leaving limited land available for new development. Substantial portions of the remaining undeveloped areas are further constrained by coastal regulations, floodplains, wildfire-prone zones, steep hillsides, protected open space, and other environmentally sensitive lands. These physical and regulatory barriers significantly reduce the amount of land that can realistically be developed. At the same time, the County faces substantial infrastructure limitations— including constraints on water and sewer systems, road capacity and traffic circulation, parking availability, schools, parks and recreation space, transit corridors, and even utilities such as electricity and natural gas. Taken together, these constraints sharply limit how much additional housing can be accommodated, even when zoning or Housing Mandates call for higher densities.

High construction costs remain a major obstacle to new housing production, driven by escalating prices for essential building materials such as lumber, steel, concrete, and electrical components. Persistent labor shortages across skilled trades further compound these costs, as limited labor supply leads to higher wages and project delays. Appliance costs have also risen significantly, especially for energy-efficient or higher-end models now commonly required by building codes or market expectations.

Additionally, the desired level of luxury or finish, such as premium flooring, countertops, fixtures, and community amenities, can substantially increase overall project budgets, making even modest housing developments expensive to deliver.

Reports indicate it cost approximately $500,000 to $800,000 to build a one-bedroom low-income rental unit in Orange County. Low Income units require rental subsidies. 58 Turner Center UC Berkeley Development Math
59 Interest Rates Impact Construction Project Funding
60 CHP State Housing Needs Report
61 The High Cost of Producing Multifamily Housing in California: Evidence and Policy Recommendations | RAND
California State Housing Mandates

With declining federal, state, and local funding subsidies, it is difficult to build affordable housing. Developer interest therefore is focused on market rate housing production.

In short, Housing Mandates are legally binding, yet remain extraordinarily difficult for many cities to achieve. While While RHNA serves a key role as a planning tool, requiring cities to zone for additional housing and align local policies with statewide objectives, meeting the full scale of assigned housing targets, especially for lower-income households, is often unrealistic without sustained public funding, expanded infrastructure, and ongoing State support. In practice, the Housing Mandates alone do not produce homes. Achieving HCD/SCAG goals in Orange County ultimately depends on market-responsive policies, and complementary funding strategies. It is not simply higher numerical requirements or punitive measures.

In practice, Housing Mandates alone do not build homes.

One Size Does Not Fit All
California’s statewide Housing Mandates are intended to address a persistent and perceived shortage of housing.62 However, the OCGJ found that the uniform statutory framework governing the RHNA process can function as a blunt instrument when applied across jurisdictions with widely differing conditions. City leadership consistently noted that a one-size-fits-all approach may not fully account for the unique character, environmental, infrastructural, economic, demographic, and geographic circumstances facing individual communities.

Several stakeholders noted that the RHNA process does not adequately differentiate among jurisdictions with varying levels of infrastructure capacity, longstanding physical or environmental constraints, or distinct development patterns. In particular, it fails to account for older, largely built-out cities—such as Garden Grove, Westminster, La Habra, and Fountain Valley, where available land is minimal and new housing can occur primarily through infill development. In these contexts, construction is typically more complex and costly, further challenging feasibility. As a result, some local governments face disproportionate burdens in accommodating housing allocations that do not fully reflect on-the-ground constraints and local conditions.

The OCGJ notes that perspectives on this issue varied considerably. Interviewees from fast-growing or infrastructure-rich areas were more likely to support uniform standards, arguing that consistent requirements prevent jurisdictions from avoiding their fair share of housing obligations. Others expressed the view that Housing Mandates are necessary to overcome decades of underproduction and local resistance to growth. 62 California Department of Housing and Community Development | California Department of Housing and Community Development
California State Housing Mandates

Orange County Grand Jury 2025-2026
Ultimately, comments on the adequacy and fairness of California’s uniform approach depended heavily on local context and a jurisdiction’s capacity to absorb additional housing.

Data source: Cities’ responses to the 2526 Grand Jury’s survey California and Orange County Population Trends
Over the past three decades, California has undergone a profound demographic shift.

After more than a century of rapid population expansion (growing from under 20 million in 1970 to nearly 40 million by 2020) the State’s growth has slowed dramatically, and in recent years has turned negative.63 According to the Public Policy Institute of California, California lost 322,000 residents between July 2020 and July 2022 due largely to emigration, declining births, and reduced immigration.
64 And although modest growth
resumed between 2022 and 2025, the overall trend remains flat and well below historical norms. As previously noted, this validates the California State Auditor’s criticism of HCD, and its projections based on population. 63 CSUF - Center for Demographic Research 64 California's Population - Public Policy Institute of California California State Housing Mandates

Source Orange County Register 65
Historically, one of California’s fastest-growing regions, Orange County, exhibits similar trajectories – population stagnation and decline. The U.S. Census Bureau has documented recent population decreases, noting that Orange County's long-standing growth pattern began to reverse in the early 2020’s due in part, to an aging population, and reduced international migration and increased outmigration. 66 These trends
challenge long-held assumptions about continuous growth in Orange County and suggest that future planning should incorporate demographic stabilization rather than expansion.

Despite these emerging realities, population projections used during the 6th Cycle (2021–2029) relied on pre-pandemic models that assumed continued growth.67 HCD’s 6th Cycle regional determination began with population forecasts from the Department of Finance and applied upward adjustments for overcrowding, cost burden, and vacancy— factors that significantly inflated the region’s housing need calculation. However, by 2020–2025, many of these underlying drivers shifted in the opposite direction as 65 Infographic: Are people leaving California? Here’s what the numbers show us – Orange County Register
66 Infographic: Are people leaving California? Here’s what the numbers show us – Orange County Register
67 Presentation: Overview of Regional Growth Forecasting, Modeling Task Force May 25, 2022 Meeting California State Housing Mandates

Orange County Grand Jury 2025-2026
California entered a period of population decline, raising questions about the accuracy of the assumptions embedded in the 6th Cycle projections. SCAG has acknowledged concerns from stakeholders regarding the appropriateness of the population and household growth assumptions used during the 6th Cycle and has initiated discussions with HCD to reform the methodology.68
Looking ahead to the 7th Cycle, California’s demographic outlook is markedly different from the 6th Cycle. The Department of Finance’s newest long-range projections (2024 baseline) show significantly slower statewide and county-level growth through 2070, with some regions, including Orange County, projected to experience prolonged stagnation or decline.69 These updated projections, combined with post-2020 population losses, underscore the necessity for HCD and SCAG to recalibrate their methodologies so that the next RHNA Cycle reflects a more accurate and data-driven assessment of true housing need. Without incorporating the State’s new demographic trajectory, RHNA risks overestimating future household growth and imposing planning obligations disconnected from both California’s and Orange County’s actual population realities.

Data source: Orange County Progress Report 2025
Notes: This chart includes only cities, who responded to the 2526 Grand Jury’s survey. 6th Cycle (2021–2029) Housing Allocations in OC
California’s Housing Element Law requires every city and county to plan for its share of regional housing need. For the 6th Cycle (October 2021–October 2029), SCAG 68 PowerPoint Template for SCAG Presentations
69 Projections | California Department of Finance
California State Housing Mandates

assigned the Orange County subregion a total of 183,861 housing units, allocated across four income categories: Very Low, Low, Moderate, and Above Moderate.70 While RHNA establishes the minimum number of units each jurisdiction must plan for, this OCGJ finds that cities seeking to meaningfully expand affordable housing production must adopt local housing targets that exceed their RHNA assignment. This is largely because the cost of constructing deed-restricted affordable units—often approaching $700,000 per unit—is rarely economically feasible without substantial public subsidy, layered financing, and other creative development strategies. As a result, cities increasingly rely on density bonus incentives, allowing developers to build additional market-rate units in exchange for providing affordable units, to help close funding gaps and meet lower-income housing obligations.

The RHNA process begins with the HCD determining the amount of housing needed for each region, including affordability levels, and continues with a regional agency (here, SCAG) dividing that need among counties and cities. SCAG’s final 6th Cycle plan assigns Orange County jurisdictions a combined 183,861 total units for 2021–2029.71 SCAG’s allocation plan further distributes Orange County’s total to each city (and to the County’s unincorporated area). The largest allocations go to major employment and population centers, with substantial totals assigned to, among others:

City Units City Units
Irvine 23,610 Huntington Beach 13,368
Garden Grove 19,168 Costa Mesa 11,760
Anaheim 17,453 OC Unincorporated 10,340
These totals reflect the regional policy judgment—guided by state objectives—that jurisdictions must plan for additional housing capacity across income categories.

In summary, RHNA 6th Cycle allocations establish minimum planning obligations, but they do not, by themselves, overcome the structural feasibility barriers that constrain low-income housing delivery. This higher target is justified by (1) the anticipated attrition between zoning capacity and constructed projects, and (2) the necessity of leveraging private development to be incentivized to build affordable housing in a market where restricted rents cannot reliably support new construction without layered public assistance.
70 Regional Housing Needs Assessment | Southern California Association of Governments 71 Regional Housing Needs Assessment | Southern California Association of Governments California State Housing Mandates

Orange County Grand Jury 2025-2026
City Challenges
California’s increasingly prescriptive Housing Mandates have placed substantial pressure on local governments in Orange County, requiring cities to plan for significantly higher levels of housing capacity. The cumulative effect has been added local government costs, uncertainty in interpreting evolving state requirements, inequities among jurisdictions, and escalating tension between state directives and the longstanding expectation of local control over planning and zoning.

While the State has articulated policy goals and methodology behind its Housing Mandates, the top-down framework often overlooks the essential role of local communities in electing officials to ensure that planning and zoning decisions reflect the values and priorities of the electorate—the very reason most cities incorporated in the first place. This disconnect has contributed to considerable tension, community frustration, and political instability in many Orange County cities, not to mention the constituents’ lack of confidence that their elected officials are representing their interests.

To successfully meet the requirement of the Housing Mandates cities must file a Housing Element with HCD every eight years to meet the aggressive targets being mandated. Many local cities lack the internal expertise and staff time to draft such housing submissions and thus must hire costly external consultants to prepare appropriate legal documents. As previously noted, the costs to cities have been between $100,000 and over $1,000,000 for some of the larger cities. With 34 cities in Orange County and the County also required to provide a housing plan, the administrative costs are in the millions of dollars just to comply. With many local cities having budgetary challenges, this administrative burden is just another unfunded liability. These taxpayer dollars are spent to comply with the law and have no commensurate direct beneficial outcome for the community.

In Orange County, the Housing Mandates have substantially narrowed local land use discretion while increasing administrative, legal, and compliance risks for cities.

Although framed as a planning requirement, the Housing Mandates have expanded residential density and embedded enforceable state oversight into what were traditionally local planning functions. As a result, compliance and enforcement mechanisms have begun to reshape municipal governance and materially influenced developmental patterns across the county. The result of these impacts in Orange County includes but are not limited to the following:
• Reduced local land-use authority
• Administrative and staffing burdens
• Financial expense
• Infrastructure limitations
California State Housing Mandates

• Increased legal exposure
• Political and community conflict
• Unfair RHNA housing allocations across the cities
Each city in Orange County has had a variety of challenges based upon differences in geography, fiscal capacity, land availability, funding availability, development interest and conditions, local policy decisions and community responses. The impact of the Housing Mandates has had dramatic impacts and cannot be ignored.

For example:

Anaheim: As the largest (population) city in Orange County, Anaheim has a strong fiscal base, including significant tourist-based revenue, and has already permitted and constructed a large number of housing units especially in light of their massive OC Vibe residential, retail and entertainment district. This is not to say, however, that they do not have their challenges with developers pushing to increase density within Anaheim Hills and the City’s concern of density and building into a designated high-fire risk area. Due to its population of over 300,000, unlike most Orange County cities, Anaheim does have access to state and federal dollars, to assist in meeting the affordable housing requirements.

Costa Mesa: Costa Mesa is one of only three Orange County cities still without a compliant Housing Element. Its continued effort to defend local regulations on sober living homes—rules that HCD does not formally recognize—has already cost the city access to certain state low-income housing funding. The situation worsened when one of the City’s largest developers withdrew all of his properties from Costa Mesa’s Housing Element inventory, slashing projected housing capacity from roughly 17,000 units to the bare minimum of about 11,750 units needed to meet state requirements.72 This leaves the City with virtually no buffer to achieve compliance.

Fountain Valley: Fountain Valley is largely built out, with approximately 90% of its land already utilized. Limited available land and constrained financing capacity present major hurdles in Fountain Valley ever being able to meet the state requirements.

Huntington Beach: Huntington Beach has adopted a totally different strategy to address the Housing Mandates. They have aggressively pursued litigation in an effort as a "charter city" to preserve local land-use authority. This approach has resulted in substantial legal costs and financial exposure for the City for noncompliance. The City’s 72 Planning Commission Bombshell: Housing Element Update Crisis in Costa Mesa California State Housing Mandates

Orange County Grand Jury 2025-2026
legal challenges have all been denied including a final appeal to the US Supreme Court.
73 Consequences for non-compliance are pending.

Irvine: Irvine's response to the Housing Mandates differs from other Orange County cities. Being very progressive with available land currently under development, and two major developers active, the master planned community of Irvine has substantial flexibility. They have submitted to the State committing to build 56,000 additional units even though their allocation is approximately 26,000 units, the highest in Orange County. The original vision of Irvine being a residential community with commercial and residential balance runs the risk of being seriously eroded with high density apartments being vigorously constructed. This suggests Irvine might ultimately be more of an urban versus suburban community in the future. Residents are starting to be concerned as to the impact on traffic, parks, and schools. Furthermore, the current City council's recent move to rezone past open space commitments has created voter activism and resistance.

Newport Beach: Newport Beach has faced difficulty implementing the Housing Mandates due the concerns regarding community character, coastal constraints, and local values, contributing to resistance to higher density residential development. While elected officials worked hard at engaging and educating the community on the Housing Mandates, as development projects started to come on-line, major public resistance ensued. A recent ballot initiative was just approved to push back on the City's approved Housing Element.
74 Mission Viejo: In March 2026, hundreds of Mission Viejo residents rallied in opposition to a proposed expansion of the Vista Del Lago apartment complex off Marguerite Parkway. The developer’s plan called for demolishing 68 existing units and replacing them with 418 new units, resulting in a net increase of 350 units, as well as constructing a new parking structure. The expansion would bring the total number of units on the 33-acre property to 958 units, dramatically increasing density in an area surrounded primarily by single-family homes.

After hours of heated public testimony and debate, the City Council voted 3–2 to advance the project. A majority of councilmembers stated they felt they had no choice but to approve the development due to the Housing Mandates, which require cities to zone and plan for significantly higher housing densities regardless of local neighborhood opposition.75
73 Attorney General Bonta Celebrates U.S. Supreme Court’s Denial of Huntington Beach’s Challenge to State Housing Laws | State of California - Department of Justice - Office of the Attorney General 74 Newport Beach may dump state mandate as residents prep to vote on plan for far fewer housing units | LAist
75 Editorial: Mission Viejo’s needless angst over apartments – Orange County Register California State Housing Mandates

San Juan Capistrano: Due to its historical significance and geographic characteristics, the City has been challenged to meet the Housing Mandates. It is a tale of two communities – residents of great wealth and a large lower socioeconomic population requiring the need for more affordable housing. To date, City leadership appear to have built partnerships with low-income developers to build projects that maintain the community’s heritage and meet the needs of the City. As high-end development takes place, a "fee in lieu" is assessed that generates funds for affordable housing. Superb planning and design have led to across-the-board community support for well designed, low-income redevelopment projects completed or underway.

Santa Ana: Santa Ana is already considered by HCDs’ RHNA process to be a densely populated, lower socioeconomic community, and it has the lowest housing target in Orange County with only 3,137 units. Like Anaheim due to its population size, it has access to more federal and state housing dollars to meet its low-income housing compliance obligations.

The County of Orange: The County also has a RHNA requirement for its unincorporated areas. The County struggled to obtain certification of its Housing Element in 2025; it required multiple revisions due to the nature of small pockets of unincorporated areas it serves. Its largest development area in South Orange County, Rancho Mission Viejo of over 6,000 acres was entitled by the County before the Housing Mandates became law – few were affordable units. In addition, the largest track of undeveloped land is owned by the Federal Government (Cleveland National Forest) and not available for development.

The impacts of the Housing Mandates have disrupted governance and local control. In some communities it has created fierce resistance. The loss of local control impacts the traditions and norms within many Orange County cities. Community heritage, rightly or wrongly, is being seriously eroded.

The one-size-fits-all Housing Mandates has serious repercussions economically and politically only now coming into focus for the voters of Orange County as the implementation goes forward.

Community political activism has increased as housing projects move from approval to construction, but this engagement is often narrowly focused on individual developments rather than broader policy impacts. Cities should take a more proactive role in engaging residents in a comprehensive discussion about how RHNA implementation is affecting neighborhood character, infrastructure, and social cohesion. In addition, local elected officials have a responsibility to clearly communicate how state-directed housing policies, originating in Sacramento, shape local land-use decisions and limit municipal discretion.

California State Housing Mandates

Orange County Grand Jury 2025-2026
7th Cycle (2029-2037) Concerns
The 7th Cycle of the RHNA planning process has already started, addressing the period from 2029-2037. The OCGJ identified significant concerns related to transparency, data integrity, governance, and Orange County’s ability to competitively represent itself within the broader SCAG region. These concerns stem from documented issues in the 6th Cycle, particularly the lack of clarity of the allocation methodology, the complexity of the decision-making structure, and inadequate procedural safeguards to ensure that Orange County’s unique conditions are fully acknowledged.

The 6th Cycle methodology relied on numerous questionable inputs—including projected population, transit accessibility, job growth, vacancy adjustments, cost burden, and subjective social equity factors—derived from HCD and SCAG’s adopted methodology.76 These inputs were published but remained difficult for local jurisdictions to interpret due to their subjectivity, complexity and technical nature and the failure of HCD to clearly identify their methodology.
77 Given these findings, Orange County cities face a recurring risk, because the statewide RHNA determination feeds directly into SCAG allocations, any methodological deficiencies at the state level immediately cascade into subregional planning and ultimately influence the allocations assigned to Orange County jurisdictions.

Experiences from the 6th Cycle highlight several issues that continue to shape Orange County’s concerns heading into the 7th Cycle. The previous allocation process was marked by complexity, questionable data, late-stage modifications, and an overall lack of transparency. For example, SCAG’s 6th Cycle allocation was adopted in March 2021 and then modified only a few months later78, fueling confusion about how final numbers were determined. The process felt unfair to many local jurisdictions because the appeals window was extremely compressed, the methodology was difficult to replicate, and the relationship between data inputs—such as overcrowding, cost burden, or future transit accessibility—and final allocations was not easily understood. The appeals process was also futile and was not open to cities concerns.

Governance also played a role. SCAG and OCCOG rely on a large network of committees, working groups, and advisory bodies, which ensures broad participation but diffuses responsibility. With so many entities involved, accountability for data accuracy, timely inputs, and interpretation of the methodology becomes fragmented, making it difficult for any single entity to ensure the process is both rigorous and transparent.
76 SCAG Final RHNA Methodology, March 5, 2020
77 Best Practices for Allocating & Evaluating RHNA
78 Regional Housing Needs Assessment | Southern California Association of Governments California State Housing Mandates

The upcoming 7th Cycle is expected to be even more data-intensive.79 New state guidance calls for clearer and more prescriptive methodology factors, improved appeals procedures, new income categories, and stronger alignment with greenhouse-gas and transportation planning.80 Transit definitions are also being standardized statewide, meaning all Orange County Transportation Authority (OCTA) transit routes, frequencies, and hub locations must be fully validated and published early in the process. Without early coordination, the County risks being disadvantaged compared with regions that already have well-organized transit datasets.

Transparency remains a central concern. Orange County jurisdictions need access to all datasets used to calculate their allocations, ranging from growth projections to transit accessibility metrics, and must be able to replicate the calculations that lead to their assigned numbers. The California State Auditor has previously flagged gaps in how HCD documented its factors, reinforcing the need for a system that jurisdictions can audit and verify.

CONCLUSION
“We shape our buildings; thereafter they shape us.” (Winston Churchill) Housing Mandates and the RHNA allocation process are highly consequential for Orange County jurisdictions, particularly because the construction of low-income housing is rarely feasible without substantial subsidy. Interviewees consistently reported that funding streams to support deed-restricted housing remain limited, leaving cities responsible for planning large numbers of units that may never be financially viable without additional state or federal assistance. This gap between planning obligations and realistic development capacity has heightened local concern about the fairness and practicality of the current RHNA framework not to mention wasted tax dollars.

Against this backdrop, a recurring theme in interviews was the need for stronger regional coordination. Per the Joint Powers Agreement, OCCOG members pay dues to support operations, based on a 2009 adopted formula tied partly to each city’s share of the county population. However, dues have not been adjusted in many years, leading several stakeholders to question whether current funding levels adequately support OCCOG’s ability to coordinate subregional planning, respond to SCAG, and represent Orange County interests on matters as significant as RHNA. SCAG likewise uses population factors in its own dues structure, meaning jurisdictions with growing populations carry greater financial responsibility. Stakeholders noted that the overall 79 California’s Housing Future 2040: The Next Regional Housing Needs Allocation | California Department of Housing and Community Development
80 California’s Housing Future 2040: The Next Regional Housing Needs Allocation | California Department of Housing and Community Development
California State Housing Mandates

Orange County Grand Jury 2025-2026
resource base may still be insufficient for the level of technical engagement required.

Many jurisdictions expressed that increased support for OCCOG, both financial and participatory, would improve transparency around RHNA inputs and allow for more robust review of the assumptions that drive housing allocations.

The OCGJ believes that OCCOG is an underutilized regional asset that could play a significantly larger role in promoting equity, transparency, and public understanding of the RHNA process. Interviewees emphasized that consistent, proactive participation by city and county representatives in OCCOG and SCAG meetings is critical, especially early in the methodology-setting phase, when data inputs, assumptions, and distribution formulas are still in development. Without regular engagement, jurisdictions risk losing opportunities to influence decisions that later become binding obligations. Several interviewees suggested that cities consider enhancing their financial contributions so OCCOG can expand its analytical capacity, conduct independent research, and engage more effectively in SCAG’s technical and policy committees and at the state level.

As work begins on the 7th Cycle, the need for collaboration is more urgent than ever.

Cities cannot afford to be passive observers. Even if cities cannot directly change the final numbers issued by HCD or SCAG, their active involvement is essential to ensuring that Orange County’s unique circumstances are understood and represented.

Meaningful engagement can also help jurisdictions align their local planning strategies, clarify shared concerns, and coordinate responses to proposed methodological changes before they become final. A more empowered and better-resourced OCCOG would strengthen Orange County’s collective voice, improve regional planning outcomes, and ensure local governments are not navigating the California’s housing requirements in isolation.

Finally, the OCGJ notes that collaboration must extend beyond government agencies to the residents they serve. As Sacramento lawmakers continue to enact significant housing legislation, much of it with direct consequences for zoning, density, local control and neighborhood character development standards, the public must be informed and involved. Cities, working through OCCOG and SCAG, have an important role in educating residents about new laws, explaining their local impacts, and encouraging constituents to register their views with State Representatives. Improving public awareness not only strengthens transparency and trust but also ensures that community perspectives are included in shaping future housing policy.

By working together, jurisdictions, regional agencies, and the public, Orange County can more effectively navigate the challenges of Housing Mandates and advocate for a clearer, more equitable, and more locally responsive RHNA process.

California State Housing Mandates

FINDINGS In accordance with California Penal Code §933 and §933.05, the 2025-2026 Orange County Grand Jury requires (or, as noted, requests) responses from each agency and city affected by the “Findings” presented in this section. Responses are to be submitted to the Presiding Judge of the Superior Court.

Based on its investigation “California Housing Mandates” the 2025-2026 Orange County Grand Jury has arrived at 22 findings as follows:

F1 In recent years, the California Legislature has enacted an unusually large and burdensome volume of housing-related laws intended to strengthen compliance with State Housing Mandates.

F2 Housing Mandates are implemented through a RHNA process that often lacks transparency and relies on complex methodologies that are difficult for local officials and the public to understand or meaningfully challenge.

F3 OCCOG coordinates RHNA regional planning in partnership with the SCAG for Orange County. OCCOG lacks adequate influence with SCAG.

F4 Meaningful participation by Orange County cities in both OCCOG and SCAG meetings is critical to ensuring that local perspectives are represented during the development and implementation of Housing Mandates policies.

F5 SCAG’s 6th Cycle RHNA assigned Orange County a questionable total of 183,861 housing units for the 2021–2029 planning period, with higher allocations concentrated in cities with major population and employment centers.

F6 RHNA allocations are unrealistic and not attainable within the current planning cycle due to limited available land, built-out urban conditions, infrastructure constraints, environmental factors, and public health and safety requirements.

F7 Residents in Orange County consistently express a desire for local planning decisions to reflect community priorities, including but not limited to neighborhood character, safety considerations, the environment and open-space preservation.

F8 California’s regulatory construction costs (i.e. permitting fees) present substantial challenges for private housing developers—particularly those delivering affordable units.

California State Housing Mandates

Orange County Grand Jury 2025-2026
F9 The cost of constructing a single affordable housing unit in California typically ranges from approximately $500,000 to $800,000 per unit when fully complying with current state regulations. New low-income housing is generally not financially feasible without public subsidy.

F10 Prior to their dissolution in 2012, redevelopment agencies served as a primary mechanism for cities and counties to finance affordable housing and related infrastructure. The loss of redevelopment has reduced cities’ ability to support construction of affordable units.

F11 Because public subsidy is limited and highly competitive, cities seeking to produce meaningful quantities of low-income housing must rely in part on private development incentives, often resulting in higher overall development densities and unit counts than the RHNA allocation.

F12 The 6th Cycle RHNA methodology included numerous technical inputs published by SCAG and HCD; however, these inputs were highly complex and difficult for cities to interpret or independently verify.

F13 The California State Auditor’s 2022 review found significant deficiencies in HCD’s regional determination process—including inadequate documentation, data-entry errors, and insufficient justification for key assumptions—raising concerns that similar issues may affect the 7th Cycle process.

F14 OCCOG’s current resources and organizational structure are insufficient to fully advocate for Orange County jurisdictions during RHNA methodology development, especially when compared with larger or more heavily resourced regional councils of governments that also influence SCAG.

F15 Demands on HCD are anticipated to materially alter methodology for the 7th Cycle, but Orange County jurisdictions have not yet received clear guidance on how these allocations will be translated into SCAG policy or local impacts.

F16 The reliance on transit accessibility as a major RHNA consideration requires high-quality, early-released datasets from OCTA; however, these datasets are not currently consolidated or formally adopted for use in the 7th Cycle methodology.

F17 The large number of committees, subcommittees, and advisory groups involved in SCAG and OCCOG’s RHNA processes promotes broad participation but diffuses accountability, making it difficult to determine who is responsible for specific analytic inputs or process decisions.

California State Housing Mandates

F18 The City of Huntington Beach has been unsuccessful in its attempts to contest Housing Mandates. To date, Huntington Beach lacks an approved General Plan Housing Element related to RHNA Allocation.

F19 The City of Irvine has been progressive in submitting a housing plan that calls for twice the number of units mandated (56,000). However, this threatens the historical nature of a master plan community with substantial infrastructure challenges.

F20 Cities and other stakeholders encounter difficulty explaining RHNA outcomes to elected officials and the public due to a lack of clear, consolidated documentation describing how allocation decisions are derived from the underlying data.

F21 The absence of a clearly articulated and easily understandable description of the RHNA allocation algorithm contributes to perceptions that discretionary or political considerations may influence outcomes, even when allocations are made in compliance with state housing laws.

F22 Improved transparency and communication regarding RHNA methodology would enhance public confidence in the process and reduce misunderstandings among member jurisdictions.

RECOMMENDATIONS In accordance with California Penal Code §933 and §933.05, the 2025-2026 Orange County Grand Jury requires (or, as noted, requests) responses from each agency and city affected by the “Recommendations” presented in this section. Responses are to be submitted to the Presiding Judge of the Superior Court.

Based on its investigation described herein, the 2025-2026 Orange County Grand Jury makes the following 20 recommendations:

R1 OCCOG should expand its technical-assistance and training programs, by September 30, 2026, to ensure that all Orange County jurisdictions understand RHNA methodology, statutory obligations, and the implications of noncompliance. (F1, F2, F3, F4)
R2 OCCOG should coordinate a countywide review of sites identified in local Housing Elements, by December 31, 2026, to evaluate whether each site meets state requirements for realistic capacity and development feasibility, supported by a standardized, version-controlled change log. (F3, F4) California State Housing Mandates

Orange County Grand Jury 2025-2026
R3 OCCOG should develop and publish a comprehensive RHNA Inputs Catalog, by April 30, 2027, prior to drafting the 7th Cycle methodology, documenting all datasets used, their sources, methodological assumptions, and a version-controlled record of changes. (F3, F4) R4 OCCOG should create a public-facing RHNA Accountability Dashboard, by April 30, 2027, displaying deadlines, responsible agencies, dataset readiness, and upcoming SCAG decision points, to ensure transparency and timely action by jurisdictions. (F16)
R5 OCCOG should request that SCAG and HCD, by December 31, 2026, provide written guidance explaining how HCD’s recommendations will be applied in shaping the 7th Cycle RHNA methodology so that jurisdictions can prepare proactively. (F16)
R6 OCCOG should convene a 7th Cycle Technical Working Group, by December 31, 2026, composed of planners, data analysts, and transit experts to pre-evaluate methodology scenarios and deliver unified, countywide recommendations to SCAG. (F3, F6, F15)
R7 OCCOG, all Orange County cities and the County of Orange should reassess the current dues structure, by September 30, 2026, to ensure that OCCOG has the resources necessary to effectively represent Orange County jurisdictions in SCAG processes, including RHNA methodology development and appeals. (F3, F15)
R8 By December 31, 2026, the Orange County Board of Supervisors should partner with cities to evaluate countywide infrastructure capacity— including water, wastewater, flood control, transportation, and public-safety systems—and develop a coordinated regional plan capable of supporting the level of housing growth required under state law. (F6) R9 By September 30, 2026, the Orange County Board of Supervisors should strengthen its engagement with OCCOG and increase staff support to develop a shared, countywide database of potential housing sites and key development-feasibility factors. (F15)
R10 By June 30, 2027, the Orange County Board of Supervisors should evaluate whether the County should pursue its own independent Metropolitan Planning Organization (MPO) designation for purposes of regional housing planning. (F5, F6, F7, F15)
California State Housing Mandates

R11 The County of Orange and each city should ensure consistent participation in SCAG and OCCOG committees by September 30, 2026, including the Technical Advisory Committee (TAC), to strengthen regional representation during RHNA-methodology development. (F3, F4, F15) R12 The County of Orange and each city should designate a single technical representative, by September 30, 2026, along with an alternate, for all RHNA-related SCAG and OCCOG committees to ensure continuity of participation and eliminate gaps in representation across multiple decision-making bodies. (F4)
R13 OCTA should provide an official, data-frozen countywide transit dataset (GTFS + GIS), by September 30, 2026, to meet OCCOG’s analytical needs for 7th Cycle RHNA planning. (F17)
R14 By April 30, 2027, the County of Orange and each city should publish annual monitoring dashboards showing (a) entitlement pipeline conditions, (b) realistic site yield, (c) assembled funding sources for affordable units, and (d) conversion rates from planned capacity to issued permits and completed units, ensuring that County and city-determined capacity assumptions remain aligned with actual production. (F13) R15 By September 30, 2026, and ongoing, the County Board of Supervisors and all city councils should make a coordinated and sustained effort to educate their constituents about the RHNA process—its requirements, its impact on local planning and community character, and the role residents can play in shaping outcomes. Public education efforts should also include guidance on how community members can effectively engage with the California Legislature and advocate for more realistic, data-driven housing policies. (F1, F7)
R16 By December 31, 2026, all cities should look to enhance their relationships with not-for-profit affordable housing developers to increase the opportunity to develop more affordable housing. (F8, F10, F12) R17 By September 1, 2026, the City of Huntington Beach should evaluate submitting an appropriate Housing Element to reduce potential exposure to HCD penalties. (F18)
R18 By September 1, 2026, the City of Irvine should ascertain the level of community support for its housing element submission and its impact on the character of its master plan. (F19)
California State Housing Mandates

Orange County Grand Jury 2025-2026
R19 By September 1, 2026, SCAG should conduct a formal review of its RHNA allocation methodology and clearly document, in understandable language, the inputs, assumptions, weighting, and decision points used in the allocation algorithm. This documentation should be publicly released and designed to improve transparency, reduce perceptions of political influence, and enhance public understanding of how allocations are determined. (F21)
R20 By September 1, 2026, SCAG should revise its RHNA appeals process to improve procedural transparency and responsiveness by clearly defining appeal criteria, documenting staff analyses and recommendations, providing written explanations for appeal decisions, and ensuring jurisdictions have meaningful opportunities to present and respond to staff findings. (F22)
California State Housing Mandates

RESPONSES CODE The following excerpts from California Penal Code provide the requirements for public agencies to respond to the Findings and Recommendations of this Grand Jury’s report:

Penal Code §933
(c) No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its reviewing authority, the governing body of the public agency shall comment to the presiding judge of the superior court on the findings and recommendations pertaining to matters under the control of the governing body, and every elected county officer or agency head for which the grand jury has responsibility pursuant to Section 914.1 shall comment within 60 days to the presiding judge of the superior court, with an information copy sent to the board of supervisors, on the findings and recommendations pertaining to matters under the control of that county officer or agency head and any agency or agencies which that officer or agency head supervises or controls. In any city and county, the mayor shall also comment on the findings and recommendations. All these comments and reports shall forthwith be submitted to the presiding judge of the superior court who impaneled the grand jury. A copy of all responses to grand jury reports shall be placed on file with the clerk of the public agency and the office of the county clerk, or the mayor when applicable, and shall remain on file in those offices. One copy shall be placed on file with the applicable grand jury final report by, and in the control of the currently impaneled grand jury, where it shall be maintained for a minimum of five years.

Penal Code §933.05.
(a) For purposes of subdivision (b) of Section 933, as to each grand jury finding, the responding person or entity shall indicate one of the following:
(1) The respondent agrees with the finding.
(2) The respondent disagrees wholly or partially with the finding; in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefor.
(b) For purposes of subdivision (b) of Section 933, as to each grand jury recommendation, the responding person or entity shall report one of the following actions:
(1) The recommendation has been implemented, with a summary regarding the implemented action.
(2) The recommendation has not yet been implemented, but will be implemented in the future, with a timeframe for implementation.
(3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a timeframe for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of California State Housing Mandates

Orange County Grand Jury 2025-2026
the public agency when applicable. This timeframe shall not exceed six months from the date of publication of the grand jury report. (4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefor.
(c) However, if a finding or recommendation of the grand jury addresses budgetary or personnel matters of a county agency or department headed by an elected officer, both the agency or department head and the board of supervisors shall respond if requested by the grand jury, but the response of the board of supervisors shall address only those budgetary or personnel matters over which it has some decisionmaking authority. The response of the elected agency or department head shall address all aspects of the findings or recommendations affecting his or her agency or department.

RESPONSES The Orange County Grand Jury requires (or, as noted, requests) the following responses:

OCCOG 90 Day Response Required
Findings F3, F4, F5, F12, F13, F14, F15, F17
Recommendations R1, R2, R3, R4, R5, R6, R7, R9, R11, R13 County of Orange, 90 Day Response Required
Board of Supervisors
Findings F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12
Recommendations R7, R8, R9, R10, R11, R12, R14, R15, R16 OCTA 90 Day Response Required
Findings F16
Recommendations R13
SCAG 90 Day Response Required
Findings F3, F4, F5, F12, F13, F14, F15, F17, F20, F21, F22 Recommendations R5, R11, R19, R20
City of Aliso Viejo 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Anaheim 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Brea 90 Day Response Required
California State Housing Mandates

Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Buena Park 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Costa Mesa 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Cypress 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Dana Point 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Fountain Valley 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Fullerton 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Garden Grove 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Huntington Beach 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12, F18 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16, R17 City of Irvine 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12, F19 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16, R18 City of La Habra 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of La Palma 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
California State Housing Mandates

Orange County Grand Jury 2025-2026
City of Laguna Beach 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Laguna Hills 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Laguna Niguel 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Laguna Woods 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Lake Forest 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Los Alamitos 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Mission Viejo 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Newport Beach 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Orange 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Placentia 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Rancho Santa Margarita 90 Day Response Required Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
California State Housing Mandates

City of San Clemente 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of San Juan Capistrano 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Santa Ana 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Seal Beach 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Stanton 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Tustin 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Villa Park 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Westminster 90 Day Response Requested
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
City of Yorba Linda 90 Day Response Required
Findings: F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12 Recommendations: R7, R8, R9, R11, R12, R14, R15, R16
California State Housing Mandates

Orange County Grand Jury 2025-2026
GLOSSARY AND ACRONYMS ADU Accessory Dwelling Unit (ADU) is a secondary, independent housing unit located on the same lot as a primary residence. ADUs are sometimes called granny flats, in-law units, casitas, or backyard homes.

Builder’s
Remedy
Builder’s Remedy is a provision in California’s Housing Accountability Act (HAA) that limits a city or county’s ability to deny certain housing projects when the jurisdiction does not have a State-compliant Housing Element.

Charter City Charter City is a city governed by its own locally adopted charter rather than solely by California general law. Under the California Constitution, charter cities have greater authority over municipal affairs, including land use and zoning. However, this authority may be limited when the State determines that a matter, such as housing, is of statewide concern and subject to state law.

COG Council of Governments (COG) is a regional planning body made up of elected officials from cities and counties within a defined geographic area.

Deed-Restricted Deed-Restricted refers to a property that is subject to legally recorded limitations or conditions placed on its use, occupancy, or resale. In the housing context, deed restrictions are commonly used to ensure long-term affordability by limiting resale prices, rental rates, or eligible occupants based on income thresholds for a specified period, often several decades or longer.

Deed-in-Lieu Deed-in-Lieu (of foreclosure) is a voluntary transaction in which a property owner transfers ownership of a property to a lender to satisfy a mortgage debt and avoid foreclosure. While commonly used in the private lending context, the term may appear in discussions of property disposition, distressed assets, or redevelopment-related transactions.

Density Bonus
Incentives
Density Bonus Incentives are benefitting that California law (primarily Government Code § 65915) provides to housing developers in exchange for including affordable housing units within a residential or mixed-use project. These incentives make it easier and financially feasible to build affordable housing by allowing developers flexibility beyond local zoning limits.

Equity
Component
Equity Component is the requirement that housing need to be allocated in a way that promotes socioeconomic equity, reduces California State Housing Mandates

segregation, and balances disproportionate household income distributions across jurisdictions.

Fee-in-Lieu Fee-in-Lieu refers to a payment made as an alternative to fulfilling a low income housing requirements.

Federal Clean
Air Act
Federal Clean Air Act (CAA) is the primary U.S. federal law that regulates air pollution to protect public health and the environment. It authorizes the federal government, principally the U.S. Environmental Protection Agency (EPA), to set and enforce standards that limit harmful air pollutants from industrial facilities, power plants, and motor vehicles.

GIS Geographic Information System (GIS) is a type of software and data system used to map, analyze, and visualize geographic information.

Examples: ArcGIS, QGIS which integrates layers of spatial information such as: Parcels, Zoning maps, Transit lines (often imported from GTFS), Flood zones, Environmental constraints, Income and demographic data, RHNA site inventories.

Grand Jury Grand Jury (GJ) is a legal body empowered to conduct official proceedings to investigate potential criminal conduct and determine whether criminal charges should be brought.

Green State Green State generally refers to a government or jurisdiction, often a U.S. state, that prioritizes environmental protection, sustainability policies, and climate-focused governance. The term is descriptive, not legal.

GTFS General Transit Feed Specification (GTFS) is a standardized, machine‑readable data format used to describe public transit systems, including Bus routes, Rail lines, Station and stop locations, Service schedules.

General Plan In California, a city General Plan is a comprehensive, long-term policy document that serves as the legal and policy foundation for all local land-use and development decisions within a city. Adopted by the city council pursuant to California Government Code § 65300 et seq., the General Plan expresses the community’s vision for physical development and conservation over time and guides zoning, public investment, and regulatory actions.

HAU Housing Accountability Unit (HAU) is a specialized enforcement and oversight unit within the California Department of Housing and Community Development created to ensure local governments comply with state housing and homelessness laws and to hold California State Housing Mandates

Orange County Grand Jury 2025-2026
jurisdictions accountable for meeting their Husing Element commitments.

HCD Housing and Community Development (HCD) is California state agency responsible for housing policy, building standards, and the administration of affordable housing and community development programs. It operates under the California Business, Consumer Services and Housing Agency (BCSH).

Housing
Element Law
(65580-65589.11)
Housing Element Law is California’s foundational land-use law requiring every city and county to plan for the housing needs of all economic segments of the community. It is part of each jurisdiction’s General Plan and must be regularly updated on a state-mandated cycle.

Joint Powers
Authority
A Joint Powers Authority (JPA) is a legal structure used in California (and some other states) that allows two or more public agencies to jointly exercise their powers through a separate, shared entity.

Layered
Financing
Layered Financing (sometimes called capital stacking) is a funding approach in which a project—most commonly a real estate or affordable housing development—is financed through multiple sources of capital, each with different requirements, risk levels, repayment terms, and priorities.

Ministerial
approval
Ministerial approvals are a type of land-use or development approval in which a government agency must issue the permit automatically once an application meets all the objective, pre-established standards. Because the approval is non-discretionary, officials do not exercise judgment or interpretation, hold public hearings, or evaluate subjective criteria such as neighborhood character or compatibility.

MPO Metropolitan Planning Organization (MPO) is a regional transportation-planning agency required by federal law in every urbanized area with 50,000 or more people.

OCGJ Orange County Grand Jury (OCGJ) refers 2025-2026 Orange County Grand Jury.

OCTA Orange County Transportation Authority (OCTA) is the county transportation planning commission, responsible for funding and implementing transit and capital projects for a balanced and sustainable transportation system.

RHNA Regional Housing Needs Allocations (RHNA) works with the California Department of Housing & Community Development (HCD) to allocate each jurisdiction’s share of required housing across income levels.

California State Housing Mandates

RTP Regional Transportation Plans (RTP) are utilized to coordinate regional transportation, land-use planning, and climate-related planning (e.g., reducing vehicle miles traveled). Data, forecasts, and long-range planning. They provide demographic forecasts, economic analyses, and collaborative regional policies.

State Housing
Mandates
State Housing Mandates (Housing Mandates) are legal requirements specifically the Housing Element Law in California, obligating local governments (cities/counites) to adopt plans facilitating the construction of housing across all income levels. These mandates require compliance with Regional Housing Needs Allocation (RNHA) targets forcing localities to zone for rather than necessarily build.

SCS In California, a Sustainable Communities Strategy (SCS) is a regional land-use, housing, and transportation planning framework prepared by a Metropolitan Planning Organization as part of its Regional Transportation Plan. Required by Senate Bill 375 (2008), the SCS is designed to integrate transportation investments, housing patterns, and land-use policies in a way that reduces greenhouse gas emissions from passenger vehicles while supporting economic development and public health.

Vacancy Factor
Rates
Vacancy Factor Rates refer to the percentage of housing units within a defined geographic area that are assumed to be vacant at any given time. In state housing planning, vacancy rates are used as an analytical adjustment to account for normal turnover in the housing market and to ensure availability for new households. Assumed vacancy rates directly affect housing need calculations and can influence required housing production targets.
5th Cycle,
6th Cycle,
7th Cycle
The 5th, 6th, and 7th Cycles refer to sequential eight-year planning periods of the Regional Housing Needs Allocation (RHNA) process mandated by California housing law.
• The 5th Cycle generally covered the period from 2013 to 2021 (with timing varying by region).
• The 6th Cycle generally covers the period from 2021 to 2029 and includes significantly higher housing allocations statewide. • The 7th Cycle will be the next allocation period following the 6th Cycle and is expected to further shape long-term housing planning requirements for cities and counties.

Each cycle establishes projected housing needs that jurisdictions must plan for through their Housing Elements.

California State Housing Mandates

Orange County Grand Jury 2025-2026
BIBLIOGRAPHY ABAG. “The “Builder’s Remedy” and Housing Elements”. Association of Bay Area Governments – Technical Assistance for Local Planning Housing, accessed on May 14, 2026. The Builder's Remedy and Housing Elements
Alameldin, Muhammad. “California Housing Laws That Go into Effect in 2025”. Terner Center for Housing Innovation – UC Berkeley, October 29, 2024. California Housing Laws That Go into Effect in 2025 - Terner Center
Biesiada, Noah. “CA Auditor Bashes State’s Mandated Housing Numbers, Says Process Is Flawed, Lacks Oversight”. Voice of OC, April 25, 2022. CA Auditor Bashes State’s Mandated Housing Numbers, Says Process Is Flawed, Lacks Oversight Biesiada, Noah. “Huntington Beach Reignites Fight Against State Housing Law”. Voice of OC, January 11, 2024. Huntington Beach Reignites Fight Against State Housing Law Biesiada, Noah. “How Are Orange County’s Cities Doing At Building Affordable Housing?”. Voice of OC, April 2, 2024. How Are Orange County’s Cities Doing At Building Affordable Housing?
Biesiada, Noah. “Irvine Grapples With Nearly 60,000 New Housing Unites in General Plan Proposal”. Voice of OC, May 21, 2024. Irvine Grapples With Nearly 60,000 New Housing Units in General Plan Proposal
Biesiada, Noah. “Federal Appeals Court Slaps Down Huntington Beach’s Anti Housing Lawsuit”. Voice of OC, October 30, 2024. Federal Appeals Court Slaps Down Huntington Beach’s Anti Housing Lawsuit
Bonta, Rob. “Attorney General Bonta Celebrates U.S. Supreme Court’s Denial of Huntington Beach’s Challenge to State Housing Laws”. State of California – Department of Justice, February 23, 2026. Attorney General Bonta Celebrates U.S. Supreme Court’s Denial of Huntington Beach’s Challenge to State Housing Laws | State of California - Department of Justice - Office of the Attorney General Business issues and Legislative Guide. “Leading the Way to a More Prosperous California”. Advocacy, accessed on May 14, 2026. California Housing in 2025 - Advocacy - California Chamber of Commerce
CA DOF. “Population Projections (Baseline 2024)”. State of California Department of Finance, accessed on May 14, 2026. Projections | California Department of Finance CALCOG. “What Regions Do”. California Association of Councils of Governments, 2026. Home - California Association of Councils of Governments California State Housing Mandates

CALCOG. “Housing Implementation Programs Exchange”. California Association of Councils of Governments, accessed in January 2026. Housing Exchange - California Association of Councils of Governments
California Department of Housing and Community Development. “Home Page”.

California HCD, 2026. California Department of Housing and Community Development | California Department of Housing and Community Development California Department of Housing and Community Development. “State Housing Law Program”. California HCD, 2026. State Housing Law Program | California Department of Housing and Community Development
California Department of Housing and Community Development. “California Reaches Settlement with City of Fullerton over Violations of Housing Element Law”. California HCD, January 18, 2024. California Reaches Settlement with City of Fullerton over Violations of Housing Element Law | California Department of Housing and Community Development
California Government Code §65584.01(b). California Government Code section 65584.01 (2025)
California State Senate. “Recent Legislative Actions to Increase Housing production in California”. Shou Senate California Government, February 2025. California State Senate Recent Legislative Actions
Case-Law. “Orange Cnty. Council of Gov’ts. v. Velasquez”. vlex, accessed on May 14, 2026. Orange Cnty. Council of Gov'ts. v. Velasquez - vLex United States CDHC. “A Home for Every Californian”, Statewide Housing Plan, accessed on May 14, 2026. Statewide Housing Plan
CDHCD. “California’s Housing Future 2040: The Next Regional Housing Needs Allocation”. California Department of Housing and Community Development, accessed on May 14, 2026. California’s Housing Future 2040: The Next Regional Housing Needs Allocation | California Department of Housing and Community Development CDHCD. “Enforcement Authority”. California Department of Housing and Community Development, accessed on May 14, 2026. Enforcement Authority | California Department of Housing and Community Development
CDHCD. “Housing Open Data Tools”. California Department of Housing and Community Development, accessed on May 14, 2026. Housing Open Data Tools | California Department of Housing and Community Development
Center for Demographic Research. “Orange County Progress Report”. Cal State Fullerton, April 9, 2026. products | CSUF - Center for Demographic Research California State Housing Mandates

Orange County Grand Jury 2025-2026
Chase, Caroline Guibert. ““Builder’s Remedy” Reform Bill Approved by Governor Newsom”. Allen Matkins, September 19, 2024. “Builder's Remedy" Reform Bill Approved by Governor Newsom | Allen Matkins
Chief Financial Officer. “FY 2024-2025 Adopted Budget with NCC Summary”. County of Orange, 2024-2025. FY 2024-25 Final Budget Summary
Christopher, Ben. “Gavin Newsom signs law overhauling local zoning to build more housing”. Cal Matters, October 10, 2025. New California law overrules local zoning to boost housing - CalMatters
Christopher, Ben. (2025, September 28). Why the housing shortage is so hard to quantify. Los Angeles Times (Sunday). PressReader.com | Why the housing shortage is so hard to quantify
Conte, Allaire. “California Added More Homes Than People – but Buyers and Renters Still Aren’t Getting Relief”. realtor.com, April 17, 2026. More Homes, Hardly Any Population Growth—So Why Is California Still So Expensive? Elmendorf, Christopher S. “A Primer on California’s “Builder Remedy” for HousingElement Noncompliance”. UCDavid School of Law, March 29, 2022. Builder's Remedy Primer
Espinoza, Pablo “Court Agrees Anaheim Violated State Law. Decision is a Big Win for Fair Housing in California”. California Department of Housing and Community Development, February 2, 2024. Court Agrees Anaheim Violated State Law. Decision is a Big Win for Fair Housing in California | California Department of Housing and Community Development
Farzan, Yusra. “Irvine considers waiving affordable housing requirements for developer in land swap deal”. LAist, December 8, 2025. Irvine considers waiving affordable housing requirements for developer in land swap deal | LAist Farzan, Yusra. “Major OC developer can skip affordable housing requirements after Irvine land swap approval”. LAist, December 11, 2025. Major OC developer can skip affordable housing requirements after Irvine land swap approval | LAist FRBSF, “California Post-RDA Affordable Housing Developer Survey: Analysis of Results”. Federal Reserve Bank of San Francisco, accessed on May 14, 2026.

California Post-RDA Affordable Housing Developer Survey: Analysis of Results - San Francisco Fed
Fulton, Bill. “New Pathways to Encourage Housing Production: A Review of California’s Recent Housing Legislation”. Terner Center for Housing Innovation – UC Berkeley, April California State Housing Mandates

2023. New-Pathways-to-Encourage-Housing-Production-Evaluating-CaliforniasRecent-Housing-Legislation-April-2023-Final.pdf Fulton, William. “Steps Local Governments Can Take to Unlock More Housing: Lessons from San Diego”. Terner Center for Housing Innovation – UC Berkeley, October 8, 2025. Steps Local Governments Can Take to Unlock More Housing: Lessons from San Diego - Terner Center
Garcia, David. “Making It Pencil: The Math Behind Housing Development (2023 Update)”. Terne Center for Housing Innovation – UC Berkeley, December 2023. Turner Center UC Berkeley Development Math
Goertzen, Jeff and Lansner, Jonathan. (2026, April 4) Infographic: Are people leaving California? Here’s what the numbers show us. The Orange County Register, online.

Infographic: Are people leaving California? Here’s what the numbers show us – Orange County Register
Greenwald, David. “Court: ‘Regional Housing Need’ Determinations Aren’t Judicially Reviewable”. Vanguard News Group, July 28, 2023. Court: 'Regional Housing Need' Determinations Aren’t Judicially Reviewable - Davis Vanguard Hale, Danielle and others. “The California State of Real State”. realtor.com, January 29, 2026. The California State of Real Estate - Realtor.com Economic Research Hicks, Angelina. “San Juan Capistrano With Mandated Housing Numbers”. Voice of OC, August 26, 2025. San Juan Capistrano Grapples With Mandated Housing Numbers Johnson, Hans and Mejia, Marisol Cuellar and McGhee, Eric. “California’s Population”.

PPIC, January 2026. California's Population - Public Policy Institute of California Johnson, Nikie and Collins, Jeff. (2021, January 31). Report Card: California cities, counties failing again on affordable housing goals. The Orange County Register, online.

Report card: California cities, counties failing again on affordable housing goals – Orange County Register
Julia Gill and Schuetz, Jenny. “In California, statewide housing reforms brush against local resistance”. Brookings, June 28, 2023. In California, statewide housing reforms brush against local resistance | Brookings
LegalClarity California. “California Housing Element Law Explained”. Search LegalClarity, December 14, 2025. California Housing Element Law Explained – Legal Clarity
LegiScan LLC. “California Legislature | 2025-2026 | Regular Session”. LigiScan – Bringing People to the Process, 2025-2026. California Legislature | 2025-2026 | Regular Session | LegiScan
California State Housing Mandates

Orange County Grand Jury 2025-2026
Mazzella, Danielle M. “California Affordable Housing Needs Report 2025”. California Housing Partnership, 2025. CHP State Housing Needs Report McDonald, Cynthia. “Planning Commission Meeting Bombshell!”. Costa Mesa First, February 13. Planning Commission Bombshell: Housing Element Update Crisis in Costa Mesa
Metcalf, Ben. “Testimony to the Select Committee on Housing Construction Innovation”.

Terner Center for Housing Innovation – UC Berkeley, January 6, 2026. Testimony to the Select Committee on Housing Construction Innovation - Terner Center Newsom, Garvin. “Final Regional Housing Need Assessment”. State of California – Department of Housing and Community Development, October 15, 2019. Southern California COG Regional Housing Need Determination
OCCOC. “Press Release June 1, 2021”. Orange County Council of Governments, June 1, 2021. OCCOG Press Release HCD
OCCOG. “We lead Orange County’s subregional planning”. Orange County Council of Governments, accessed in January 2026. Orange County Council of Governments Orange County Community. “Orange County Community Indicators - 25th Anniversary Report”. Orange County Business Council, 2024-2025. 1-150.

CommnityIndicators24_digital.pdf
Osterberg, Annelise. “Best Practices for Allocating and Evaluating RHNA”. Goldman School of UC, Spring 2020. Best Practices for Allocating & Evaluating RHNA Press Release. “California State Auditor Releases Scathing Report on RNA Process, Report Finds Housing Goals are Not Supported by Evidence”. Voice of OC, April 8, 2022. California State Auditor Releases Scathing Report on RHNA Process, Report Finds Housing Goals are Not Supported by Evidence
SCAG. “About Us”. Southern California Association of Governments, accessed on January 14, 2026. About us | Southern California Association of Governments SCAG. “Regional Housing Needs Assessment”. Southern California Association of Governments, accessed in January 2026. Regional Housing Needs Assessment | Southern California Association of Governments
South Coast AQMD. “Frequently Asked CEQA Questions”. South Coast Air Quality Management District, accessed on May 14, 2026. South Coast Air Quality Management District - CEQA
Tilden, Michael S. “Regional Housing Needs Assessments”. Auditor of the State of California, March 17, 2022. Report 2021-125
California State Housing Mandates

The Editorial Board (2026, March 11). Editorial: Mission Viejo’s needless angst over apartments. The Orange County Register, online. Editorial: Mission Viejo’s needless angst over apartments – Orange County Register
Trachtman, Samuel. “Fixing California’s housing shortage requires new policy and new politics”. BESI – Berkeley Economy & Society Initiative, April 22, 2025. Fixing California’s housing shortage requires new policy and new politics - Berkeley Economy & Society Initiative
Uhler, Brian. “LAO Housing Publications”. Legislative Analyst’s Office – The California Legislature’s Nonpartisan Fiscal and Policy Advisor, accessed on May 14, 2026.

California Legislative Analyst's Office - California Housing United States Census Bureau. “Parent Directory”. United States Government, accessed in April 2026. Index of /programs-surveys/popest/tables Varian, Ethan. (2023, June 25). Nuclear option’? Supersized housing projects are planned for Bay Area’s wealthiest cities. Is one coming to your neighborhood? The Mercury News, online. Is a supersized housing project coming to your Bay Area neighborhood?
Ward, Jason M. and Schlake, Luke. “The High Cost of Producing Multifamily Housing in California”. Rand, April 2, 2025. The High Cost of Producing Multifamily Housing in California: Evidence and Policy Recommendations | RAND
2024 Advocates Guide. “Land Use Restrictions and Affordable Housing”. National Low Income Housing Coalition, accessed on May 14, 2026. National Low Income Housing Coalition - Land Use Restrictions and Affordable Housing California State Housing Mandates

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APPENDIX
APPENDIX A: Major Housing Laws & What They Tried to Do81 Surplus Land Act (1968; strengthened by AB 1486 in 2019) Problem addressed: Local agencies often disposed of valuable public land without prioritizing affordable housing.

Solution: The Surplus Land Act requires local agencies to offer surplus sites to affordable housing developers first; AB 1486 (2019) expanded who must comply, added reporting, and created enforceable penalties. HCD now issues binding guidelines and may impose fines.

Role: A siting tool that converts public land near jobs/transit into affordable housing at scale (HCD reports thousands of units proposed/approved under SLA).

Housing Element Law & RHNA (1969; RHNA made mandatory by 1980 AB 2853; repeatedly strengthened)
Problem addressed: Cities historically under-planned for growth or zoned exclusionary, constraining supply across income levels.

Solution: Every city/county must adopt an 8-year Housing Element showing adequate, zoned sites to meet its RHNA allocation by income tier; HCD issues regional need determinations and certifies elements. Enforcement has tightened (HCD’s Housing Accountability Unit; fines; referrals to the AG).

Role: The spine of California housing policy—other laws (HAA, SB 35, SB 330, AFFH) enforce or operationalize these plans.

Density Bonus Law (1979; expanded often, incl. AB 1287 in 2023) Problem addressed: Mixed-income projects often do not pencil without zoning flexibility.

Solution: Grants extra units, incentives/waivers, and reduced parking in exchange for deed-restricted affordable homes; AB 1287 (2023) added a “stackable” bonus on top of the 50% base, enabling up to ~100% bonus with additional very-low/moderate units.

Role: A ubiquitous feasibility lever to deliver affordability in market-rate projects.

Housing Accountability Act (HAA) (1982; strengthened 2017–2019) Problem addressed: Cities used subjective discretion (e.g., “neighborhood character”) to deny otherwise compliant housing.

Solution: Limits denial, density reduction, or infeasible conditions for projects meeting objective standards, unless the city makes specific, evidence-based health/safety findings. 2017–2019 updates raised the burden of proof, added fees/attorney’s fees, and clarified “objective standards.” Role: A litigation-backed guardrail ensuring code-compliant housing moves forward—the State’s classic “anti-NIMBY” tool.

Redevelopment Agencies (RDAs): Termination and Loss of Local Affordable Housing Funds (2011–2012)
Problem addressed (pre-2012): RDAs used tax-increment financing with a 20% housing set-aside to fund affordable housing; the State later sought budget relief.

Solution: The Legislature passed ABx1 26 (2011); the California Supreme Court affirmed dissolution 81 Housing Statutes were summarized Microsoft Co-Pilot May 2025 version California State Housing Mandates

effective Feb 1, 2012, shifting property-tax increment, and creating successor agencies to wind down obligations.

Role: Ended a major local funding stream, increasing reliance on density bonus, public land, tax credits, and state programs.

SB 375 (2008) & SB 743 (2013; statewide VMT implementation 2020) Problem addressed: Sprawl drove VMT and GHGs; CEQA’s Level of Service (LOS) metric discouraged infill.

Solution: SB 375 requires Sustainable Communities Strategies (SCS) aligning land use and transportation to cut GHGs; SB 743 replaced LOS with VMT in CEQA, favoring infill and multimodal access, with statewide implementation by 2020.

Role: Climate + housing siting framework; housing near jobs/transit faces fewer CEQA hurdles than sprawl.

ADUs (2016–2025 waves): Legalizing “Gentle Density”
Problem addressed: Single-family-only rules and local barriers (parking, minimums) impeded backyard cottages/garage conversions near jobs.

Solution: Successive bills created 60-day ministerial approval, broad parking relief, and standardized rules; HCD’s 2025 ADU Handbook consolidates guidance and updates.

Role: A distributed, lower-cost production engine—large, scalable homeowner-led supply statewide.

HCD Law §16884.01 (2017): Establishes Housing Element Compliance Consequences and State Enforcement Authority
Problem addressed: For decades, many cities and counties failed to adopt or maintain HCD-compliant Housing Elements, resulting in chronic under-production of housing, exclusionary zoning practices, and resistance to RHNA obligations. Prior housing law lacked clear, enforceable consequences for noncompliance, allowing jurisdictions to delay, obstruct, or ignore housing planning requirements with minimal risk. This undermined statewide housing policy, fair housing objectives, and public accountability.

Solution: HCD Law §16884.01 clarifies and operationalizes the legal consequences of Housing Element non-compliance, explicitly linking failure to adopt or implement a compliant Housing Element to loss of local land-use discretion and enhanced state oversight. The law affirms HCD’s authority to make formal findings of noncompliance and triggers statutory remedies under related housing laws, including limits on down-zoning, exposure to the Housing Accountability Act, and eligibility for “builder’s remedy” projects when required conditions are met. It strengthens the enforceability of Housing Element Law by making compliance legally consequential rather than aspirational.

Role: A state enforcement backbone for California’s housing planning system, §16884.01 functions as a compliance-triggering provision that gives real effect to RHNA and Housing Element Law. It shifts housing policy from a negotiation-based model to a rule-of-law framework, ensuring that local governments that refuse to plan for housing face predictable, uniform consequences while compliant jurisdictions retain local control. The statute is central to California’s modern “Yes In My Backyard” enforcement regime.

SB 35 (2017): Streamlined Ministerial Approval
Problem addressed: Lengthy discretionary review and CEQA litigation stalled production, especially where jurisdictions lagged RHNA.

Solution: Creates a ministerial (CEQA-exempt) pathway in cities not meeting RHNA progress for qualifying infill projects that meet objective standards, affordability, and labor provisions; HCD issued binding guidelines.

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Role: A fast lane that translates zoning into approvals within 90–180 days; HCD publishes which jurisdictions are subject.

AB 686 (2018): Affirmatively Furthering Fair Housing (AFFH) Problem addressed: Persistent segregation and unequal access to opportunity despite fair-housing statutes.

Solution: Requires all public agencies to affirmatively further fair housing and adds new Housing Element duties (analysis of segregation, access to opportunity, displacement risk, equitable siting).

Role: Embeds civil-rights obligations into RHNA/Housing Elements, pushing lower-income housing into high-opportunity areas.

SB 330 (2019; extended by SB 8 to 2030): Housing Crisis Act Problem addressed: Moving goalposts (new subjective standards), downzoning, unlimited hearings, and loss of protected units increased entitlement risk.

Solution: Freezes new subjective design rules, caps hearings, creates preliminary application vesting, and requires replacement/relocation when protected units are impacted.

Role: Stabilizes entitlements, preserves capacity, and protects renters.

SB 9 (2021): Duplexes & Urban Lot Splits
Problem addressed: Large single-family parcels constrained capacity; owners lacked simple legal paths to add units.

Solution: Requires ministerial approval of up to two units on most single-family lots and allows urban lot splits (with guardrails). Implementation and litigation have been mixed, but SB 9 continues to operate statewide.

Role: Incremental densification in high-opportunity areas (uptake has been modest vs. ADUs).

SB 10 (2021): Local Rezoning for “Missing Middle” Housing Problem addressed: CEQA-exposed rezonings and voter-approved limits made modest upzoning slow and risky.

Solution: Voluntary tool letting cities zone up to 10 units/parcel on transit-rich or urban infill sites with the rezoning action itself exempt from CEQA; may override local initiative restrictions with a 2/3 council vote.

Role: A local-option upzoning mechanism; note it does not streamline the project approvals that follow.

AB 2011 (2022): Affordable Housing and High Road Jobs Act Problem addressed: Vast commercially-zoned land sat underused while housing faced discretionary review and CEQA.

Solution: Creates ministerial, CEQA-exempt approvals for qualifying multifamily on commercial corridors via two paths: 100% affordable or mixed-income meeting corridor, site, and labor standards. Effective July 1, 2023.

Role: A production-focused pathway converting retail/office/parking sites into housing statewide.

SB 6 (2022): Middle Class Housing Act (Companion to AB 2011) Problem addressed: Housing often not allowed on commercial parcels absent a rezoning.

Solution: Allows residential use in many commercial zones (by right as a permitted use) with labor standards; not ministerial/CEQA-exempt on its own (but can combine with other tools). Effective July 1, 2023.

Role: Opens more sites to housing when AB 2011 is not available.

California State Housing Mandates

AB 2097 (2022): Eliminating Parking Minimums Near Transit Problem addressed: Mandatory parking minimums near transit raised costs and reduced housing feasibility.

Solution: Prohibits minimum parking requirements for most projects within ½ mile of a major transit stop (with narrow exceptions); HCD issued a 2025 Technical Advisory for implementation.

Role: Lowers costs and removes a common barrier to infill housing.

SB 423 (2023): Extends & Expands SB 35 Through 2036
Problem addressed: SB 35’s 2026 sunset and exclusions (e.g., much of the Coastal Zone) limited reach; many cities still failed RHNA or lacked certified elements.

Solution: Extends SB 35 to 2036, applies streamlining to more jurisdictions and sites (incl. parts of the Coastal Zone), ties eligibility to Housing-Element compliance, and updates affordability/labor standards; allows DGS to administer on State-owned land.

Role: A statewide production accelerator, making the SB 35 fast lane broader and longer-lived.

SB 131 + AB 130 (2025): CEQA & Housing Streamlining (Budget Trailer Bills) Problem addressed: Infill housing still faced CEQA delays, litigation risk, and inconsistent timelines.

Solution: Establishes new CEQA exemptions for qualifying infill housing (e.g., up to 20 acres, or 5 acres for builder’s-remedy sites), streamlined review, and—via the broader package—a temporary freeze on code updates to improve predictability. Effective June 30, 2025.

Role: A modernized CEQA framework that complements HAA/SB 330/SB 35 to speed compliant housing.

Builder’s Remedy under HAA (codified/updated 2024–2025) Problem addressed: Some cities delayed or adopted non-compliant Housing Elements to preserve restrictive zoning.

Solution: AB 1893 (2024) and AB 1886 (2024) formalize and clarify the Builder’s Remedy: where a jurisdiction lacks a certified element, qualifying projects with required affordability may proceed (with new standards and protections effective Jan 1, 2025).

Role: A blunt enforcement backstop—if a city does not plan properly, it loses discretion to reject compliant affordable projects.

SB 79 (2025): Overrides Local Zoning to Enable Higher-Density Housing Near Transit Problem addressed: Local zoning caps on height and density near transit stops prevented production of transit-oriented housing even in regions with extensive rail and bus networks.

Solution: Preempts local zoning within ½ mile of qualifying transit stops to legalize multi-story multifamily housing, allowing substantially greater height and density. Creates a statewide TOD framework that can be combined with SB 35, SB 330, the Housing Accountability Act, and the State Density Bonus Law to streamline approvals at lower affordability thresholds.

Role: A land-use preemption tool establishing “as-of-right” higher density near transit so state streamlining laws (e.g., SB 35) can actually deliver buildable transit-oriented projects. It operationalizes California’s TOD objectives and supports pro-housing production goals.

AB 507 (2025): Establishes Adaptive Reuse as Use-by-Right With Streamlined Approval Problem addressed: High commercial vacancy rates and slow, discretionary local approval processes made it difficult to convert underutilized office/retail buildings into housing—despite acute statewide housing shortages.

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Solution: Declares adaptive reuse a use-by-right in all zones except non-residential industrial areas and provides ministerial, streamlined approval for eligible projects in existing buildings (generally <50 years old or meeting historic-preservation requirements). Requires income-restricted units (e.g., 8% very low + 5% extremely low, or 15% lower-income for rentals) and allows mixed-use conversions if ≥50% of floor area is residential. Waives parking for portions of buildings without existing on-site parking.

Role: A conversion-focused production tool enabling rapid, CEQA-bypassed adaptive reuse of commercial buildings into housing. Pairs with local incentive programs (e.g., tax-increment-funded Adaptive Reuse Investment Funds starting FY 26-27) to subsidize affordability and unlock large-scale urban reuse.

AB 648 (2025): Exempts Community College Housing from Local Zoning Problem addressed: Community college districts (CCDs) face severe barriers building student, faculty, and staff housing because local zoning ordinances—unlike UC/CSU—block or delay projects, worsening housing insecurity for the 2M+ community college students, over half of whom experience housing instability.

Solution: Exempts CCD-built student, faculty/staff, and university housing projects on CCD-owned or leased property from local city/county zoning regulations. Requires certain projects with faculty/staff units to include extremely low- and lower-income affordable units. Declares the exemption a matter of statewide concern applying to all cities, including charter cities.

Role: A state-level preemption tool enabling rapid production of student and workforce housing on community college land, eliminating local zoning barriers and aligning CCD authority with UC/CSU to address student homelessness and workforce affordability.

AB 1021 (2025): Expands and Streamlines Workforce Housing on School District Property Problem addressed: High housing costs prevent school districts from recruiting and retaining teachers and staff; thousands of acres of school-owned land remain underutilized due to zoning barriers, procedural hurdles, and limits on allowable uses.

Solution: Revises and expands the law deeming workforce housing an allowable use on any property owned by a local educational agency (LEA). Requires qualifying projects (≥10 units) to prioritize renting to school employees and the public under a set hierarchy, with a majority of units deed-restricted for lower- or moderate-income households. Applies Housing Accountability Act protections, enables density bonuses, and extends the program to 2036.

Role: A major workforce-housing production tool that cuts red tape, activates school district land for affordable educator housing, and strengthens school staffing stability—particularly in high-need communities where housing costs drive turnover.

AB 253 (2025): Creates a Private Pathway to Speed Up Residential Permit Plan-Checking Problem addressed: Local building departments often take more than 30 days to complete residential plan checks, creating permitting backlogs that slow housing production, increase project costs, and leave small-scale infill projects stalled.

Solution: Establishes the California Residential Private Permitting Review Act, requiring cities/counties to publish residential permit fee schedules and provide applicants with estimated plan-check timelines. If the estimated timeframe exceeds 30 business days (or if no determination is provided within 30 days), applicants may hire a licensed private professional (“private professional provider”) to perform the plan check. Applies to 1–10 unit projects ≤40 ft tall and allows private reviewers to certify compliance via affidavit.

California State Housing Mandates

Role: A post-entitlement acceleration tool that cuts through municipal bottlenecks by letting homeowners and builders use certified private reviewers, moving small-scale housing through permitting faster while maintaining local agency oversight.

AB 1308 (2025): Imposes an Inspection “Shot Clock” and Allows Private Inspectors Problem addressed: Unpredictable and months-long delays in final inspections—framing, electrical, plumbing, final occupancy sign-off—prevent newly built or renovated homes from being occupied, increasing holding costs and slowing the delivery of small-scale housing.

Solution: Requires local building departments to conduct inspections for 1–10-unit projects (≤40 ft) within 10 business days after receiving notice of completion. If the estimated inspection window exceeds 30 days—or no inspection occurs within 30 days—applicants may hire a licensed private professional inspector to complete the inspection and submit an affidavit attesting to code compliance. Also requires cities/counties to post residential permit fee schedules.

Role: A post-entitlement enforcement and delivery tool that ensures housing is not delayed at the final inspection stage. Speeds up occupancy, adds accountability to local inspection offices, and allows builders to default to vetted third-party inspectors when jurisdictions are too slow.

AB 712 (2025): Strengthens Enforcement of State Housing Laws Against Noncompliant Cities Problem addressed: Local agencies routinely delay, obstruct, or illegally deny housing projects despite state housing reform laws; enforcement is weak, costly for applicants, and slow, enabling jurisdictions to continue violating State Mandates without consequence.

Solution: Creates a robust enforcement framework requiring courts to award attorney’s fees and costs to prevailing housing applicants and to impose mandatory fines on violating local agencies. Extends statutes of limitation by 60 days when applicants issue a notice of intent to sue, and bars agencies from requiring applicants to indemnify them for litigation arising from the agency’s own violations. Defines “housing reform law” broadly to cover laws protecting housing applicants or limiting local discretion.

Role: A statewide compliance tool that finally gives housing applicants meaningful remedies—and gives local governments financial and legal consequences for ignoring state housing law, thereby enabling real enforcement of the State’s pro-housing framework.

SB 808 (2025): Fast-Tracks Judicial Review of Housing Permit Denials Problem addressed: Cities continue denying compliant housing projects, forcing applicants into a slow judicial review process where litigation delays—often lasting years—kill projects, escalate costs, or allow permits to expire.

Solution: Establishes an expedited writ-of-mandate process for housing permit denials. Requires:
• Local agencies to compile and certify the administrative record within 15 days. • Courts to set hearings within 45 days and issue decisions within 30 days of submission (or 75 days from filing, whichever comes first).
• Priority scheduling for appeals.

Allows the applicant, Attorney General, or HCD to file the petition; authorizes temporary judicial assignments to meet deadlines.

Role: A litigation-acceleration tool that prevents local agencies from using procedural delay to kill housing projects, ensuring that California housing laws have immediate, enforceable consequences.

Complements AB 712 by enforcing housing rights on the judicial side.

California State Housing Mandates

Orange County Grand Jury 2025-2026
SB 786 (2025): Clarifies Housing Element Law and Strengthens Court Remedies Against Noncompliant Cities
Problem addressed: Conflicts between General Plan elements, vague housing-element rules, and slow litigation processes create uncertainty for cities, courts, and developers—leading to delays, stalled rezoning, and litigation bottlenecks that block housing production.

Solution: Establishes clear hierarchy rules: when General Plan elements conflict—including quantified development standards—the most recently adopted, HCD-certified Housing Element controls. Tightens judicial timelines in Housing-Element challenges:
• Limits continuances to 60 days,
• Requires temporary relief whenever continuances occur, • Requires HCD to conduct substantial-compliance reviews when local jurisdictions miss required Housing-Element deadlines,
• Extends rezoning compliance timelines to 120 days and mandates sanctions if jurisdictions fail to comply.

Applies general-plan challenge rules to charter cities.

Role: A statewide governance-and-compliance tool ensuring that Housing Elements actually function as the controlling document, reducing litigation gamesmanship, and compelling jurisdictions to implement rezoning and Housing-Element obligations on enforceable timelines. Complements AB 712 and SB 808 as part of the Attorney General’s statewide enforcement strategy.

SB 340 (2025): Expands Emergency Shelter Requirements in Housing Elements Problem addressed: Emergency shelter planning requirements were outdated and limited, failing to reflect modern shelter models (e.g., navigation centers, recuperative care) and the full range of onsite supportive services needed for effective homelessness response.

Solution: Updates the definition of “emergency shelter” to require housing with supportive services (not minimal services) and requires Housing Elements to account for all onsite services consistent with written, objective standards. Imposes new obligations on cities/counties in shelter planning and broadens the Emergency Housing and Assistance Program definition.

Role: A homelessness-response modernization tool ensuring jurisdictions plan realistically for service-rich shelter models within their Housing Elements and zoning designations.

AB 610 (2025): Requires Disclosure of New Local Governmental Constraints in Housing Elements Problem addressed: Cities and counties were adopting new land-use constraints (fees, ordinances, zoning rules) during Housing-Element cycles without disclosure, undermining RHNA compliance and increasing barriers to housing production.

Solution: Requires a governmental constraints disclosure statement in each Housing Element (7th Cycle onward), identifying all new or amended constraints adopted since the last Housing Element. Prohibits adoption of new constraints unless they were disclosed and the jurisdiction has completed all required programs to remove past constraints (except when mandated by state/federal law). Applies to charter cities.

Role: A transparency and anti-backsliding tool ensuring local governments cannot quietly increase barriers to housing once RHNA obligations are set.

AB 670 (2025): Allows Converted Affordable Units to Count Toward RHNA Reporting Problem addressed: Cities lacked credit in their Annual Progress Reports (APRs) for preserving or converting multifamily buildings into long-term deed-restricted affordable housing, despite this being a major preservation strategy.

California State Housing Mandates

Solution: Expands APR reporting starting in 2027 to allow units converted to affordable housing—with 55-year covenants for low, very low, extremely low, or acutely low income households—to count toward a jurisdiction’s RHNA-creditable progress, if they meet specified criteria. Includes detailed new reporting requirements for demolitions, replacement units, and affordable conversions.

Role: A preservation-credit tool aligning RHNA reporting with long-term affordable housing conversion strategies, encouraging cities to preserve expiring-affordability stock.

AB 726 (2025): Allows Cities to Count Substantial Rehabilitation of Affordable Units in APRs Problem addressed: Deeply affordable older units (often 15+ years old) need major rehabilitation but cities receive zero RHNA/APR credit for investing in repairs—causing cities to prioritize new construction instead of preserving aging stock.

Solution: Allows jurisdictions to include substantially rehabilitated deed-restricted affordable units (≥15 years old, ≤45% AMI average affordability, ≥$60k local investment per unit) in APRs. These units cannot be counted toward eligibility for streamlining under SB 35. Updates references to the Office of Land Use and Climate Innovation.

Role: A preservation-incentive tool enabling cities to earn APR credit for rehabilitating deeply affordable units, helping maintain long-term housing quality and prevent affordable-stock losses.

AB 1275 (2025): Extends RHNA Timelines and Aligns Housing Needs with Transportation Plans Problem addressed: Regional Housing Needs Determinations (RHND) were rushed due to tight timelines (2-year lead time), leading to disputes, insufficient data review, and disconnects between transportation planning and housing allocations.

Solution: Extends RHND timeline from 2 to 3 years before a Housing-Element update (with special rules for 2027–2029 cycles), requires earlier consultation between HCD and councils of governments (COGs), and mandates that RHNA methodology be informed by Sustainable Communities Strategy (SCS) patterns in regional transportation plans. Strengthens integration of job-housing balance, mobility patterns, and fair housing objectives.

Role: A regional-planning alignment tool ensuring RHNA allocations better reflect transportation, climate, and job-housing realities, improving the planning accuracy of future housing cycles.

SB 233 (2025): Requires Earlier State–Regional Consultation for RHNA Determinations Problem addressed: During prior RHNA cycles, HCD provided regional housing need numbers too late (26-month timeline), leaving councils of governments (COGs) and cities with insufficient time to plan, contributing to widespread late Housing-Element adoption.

Solution: Requires HCD to meet and consult with each COG at least 38 months before a Housing-Element revision (one year earlier than prior law), with special rules for the 7th Cycle. Ensures earlier agreement on RHNA assumptions, methodologies, and data inputs.

Role: A regional-planning coordination tool that expands the planning window for local governments, reducing delays, improving RHNA accuracy, and increasing likelihood of timely Housing-Element compliance.

AB 920 (2025): Requires Centralized Online Portals for Housing Permit Applications Problem addressed: Local permitting processes were opaque, slow, and inconsistent across cities; applicants could not easily track housing development permits, resulting in delays, confusion, and high administrative burdens.

Solution: Requires cities/counties with populations ≥150,000 to create a centralized online application portal for housing development projects, allowing electronic submissions and real-time status tracking.

California State Housing Mandates

Orange County Grand Jury 2025-2026
Jurisdictions may delay implementation until 2030 only if they begin procurement by 2028. Applies to charter cities.

Role: A statewide digital-permit modernization tool that increases transparency, reduces processing delays, and standardizes how applicants navigate housing approvals.

SB 358 (2025): Reduces Traffic Impact Fees for Transit-Oriented Housing Problem addressed: Traffic impact fees—often 20% of project cost—were applied using outdated auto-trip assumptions, inflating costs for infill and transit-oriented housing that generates fewer vehicle trips.

Solution: Reforms the Mitigation Fee Act to:
• Require at least 50% fee reductions for qualifying transit-oriented housing, • Update eligibility criteria (parking maximums, proximity to ≥3 amenities, transit-priority locations), • Require fee-denial findings to be supported by substantial evidence, • Remove outdated convenience-retail requirements and proportional-fee provisions.

Role: A cost-reduction and TOD-incentive tool that aligns traffic fees with actual impacts, supporting infill and climate-oriented housing production.

AB 752 (2025): Makes Child Daycare Centers in Multifamily Housing a Use-by-Right Problem addressed: Cities treated daycare centers co-located with multifamily housing as commercial uses—triggering zoning barriers, business license fees, CEQA review, and inconsistent local requirements, reducing childcare capacity near where families live.

Solution: Makes daycare centers co-located with multifamily housing or community amenities a residential use by right; prohibits business license fees; exempts such centers from CEQA; bars stricter standards on them than those applied to the co-located housing or amenity. Maintains all California licensing and safety requirements.

Role: A childcare-access and land-use integration tool that reduces barriers to collocated daycare centers, supporting housing-adjacent amenities and family-serving communities.

SB 415 (2025): Refines Statewide Warehouse & Logistics Development Standards (Not a housing production bill but affects land-use and zoning environments related to freight-adjacent communities.)
Problem addressed: AB 98 (2024) established statewide warehouse standards but included ambiguous definitions and inconsistent requirements, creating confusion for local governments, developers, and environmental-justice communities in logistics-heavy regions.

Solution: SB 415 clarifies key definitions (“logistics use development,” “sensitive receptor”), narrows exemptions, updates siting and truck-route standards, refines buffer requirements, and ensures 21st-century warehouses meet applicable sustainable-design standards at permit issuance. Also clarifies where warehouse concentration regions apply.

Role: A land-use-governance and environmental-mitigation tool improving clarity and enforceability of statewide logistics-facility regulations—reducing conflicts between freight operations, housing, and community health.

AB 98 (2024–2025): Establishes Statewide Design, Siting & Environmental Standards for Logistics Facilities
Problem addressed: Warehouse and logistics developments—especially in the Inland Empire—were producing severe air-quality, noise, traffic, and public-health impacts on nearby residential areas, schools, and other sensitive receptors, while local regulations were inconsistent or ineffective.

California State Housing Mandates

Solution: Creates California’s first statewide design, siting, and operational standards for logistics facilities, including:
• Mandatory buffers (500–900 feet) from sensitive receptors, • Truck-route and loading-bay orientation requirements, • Anti-idling measures and cold-storage plug-ins,
• Title 24–level building efficiency standards (solar, EV-readiness), • 2:1 replacement requirement for recently occupied affordable units demolished, • Applicability to large new facilities and expansions ≥20% of floor area.

Compliance required for applications submitted after Sept. 30, 2024, with most standards fully effective Jan. 1, 2026.

Role: A statewide environmental-mitigation and freight-land-use tool aimed at protecting communities while aligning logistics growth with sustainability and public-health goals. AB 98 is foundational to later cleanup legislation (SB 415).

AB 1007 (2025): Cuts Responsible-Agency Permit Deadlines in Half Problem addressed: Even after cities approved housing projects, state and regional “responsible agencies” (e.g., air districts, water boards) could take months to issue secondary permits, causing ballooning timelines and costs. Shot-clocks for these agencies (90 days) were much longer than those for lead agencies.

Solution: Amends the Permit Streamlining Act to require responsible agencies to approve/disapprove residential, mixed-use, supportive, or farmworker housing permits within 45 days of project approval or application completeness—cutting the prior 90-day deadline in half. Applies statewide, including charter cities.

Role: A permitting-acceleration tool ensuring faster post-entitlement approvals and reducing interagency delays that frequently stall housing construction.

AB 1050 (2025): Allows Removal of Private Covenants Blocking Housing on Commercial Properties
Problem addressed: Commercial parcels often have old CC&Rs and reciprocal easement agreements (REAs) that prohibit residential uses or limit density, preventing commercial-to-housing adaptive-reuse projects—even when allowed under State housing laws like AB 2011.

Solution: Expands existing restrictive-covenant-modification law (previously limited to affordable housing) to all qualifying housing developments located on commercial sites, allowing developers to:
• Invalidate covenants that restrict residential use, density, unit count, or occupancy, • Apply the process to REAs as well as CC&Rs,
• Record a Restrictive Covenant Modification Document after county counsel review.

Does not authorize projects inconsistent with state housing laws.

Role: A statewide barrier-removal tool enabling adaptive reuse of commercial corridors and shopping centers into housing by preempting private land-use restrictions.

SB 92 (2025): Closes Loopholes in the Density Bonus Law for Mixed-Use Projects Problem addressed: Developers exploited the Density Bonus Law to exceed commercial FAR and build oversized hotel-heavy or visitor-serving mixed-use projects with minimal housing (e.g., San Diego “Project Vela”).

Solution: Reforms Density Bonus Law by:
• Limiting commercial FAR increases under DBL to ≤2.5× base zoning, • Prohibiting incentives/waivers for transient lodging (hotels, motels, B&Bs) except residential hotels,
California State Housing Mandates

Orange County Grand Jury 2025-2026
• Requiring ≥2/3 of mixed-use square footage to be residential to qualify, • Maintaining full affordability thresholds for bonus eligibility.

Effective Jan. 1, 2026 (with grandfathering for pre-application projects).

Role: A guardrail tool ensuring Density Bonus Law is used to build actual housing—not oversized hotel or commercial space leveraged through affordable-unit “tokenism.” AB 87 (2025): Prevents Density Bonus Incentives for Hotel Components of Mixed-Use Projects Problem addressed: Developers were using DBL concessions (height, FAR, parking waivers) to benefit hotel components of mixed-use projects, diluting the State’s housing incentives and enabling visitor-serving developments that undermined local zoning.

Solution: Clarifies that DBL incentives may not be applied to hotel/motel/visitor-serving portions of a mixed-use project. Makes parallel conforming amendments to align with SB 92 if both bills are enacted.

Applies statewide, including charter cities.

Role: A housing-priority tool reinforcing that density bonuses are for residential production—not for hospitality or tourism development.

APPENDIX B: Orange County Housing Mandate Survey Questions Q1 What is your city’s 6th-cycle RHNA allocation, and does your Housing Element plan exceed that number? If so, by how much, and what factors influenced the decision to exceed the allocation? Q2 If the RHNA mandate were not in place, how would your housing plan differ? Would it still meet the demand for low-income housing?
Q3 What strategies has your city used to inform and engage residents about the state housing mandate? How do you measure the effectiveness of these outreach efforts? Q4 What are the implications of recent state legislation on R-1 single-family zoning for your city’s land-use policies and community character?
Q5 What are the most significant challenges your city faces in meeting RHNA requirements? In what ways has OCCOG supported your efforts to overcome these challenges? Q6 Do you anticipate achieving your approved Housing Element goals by the end of the 6th cycle in 2030? What factors will most influence your success or shortfall? Q7 What additional information would you like to provide us regarding this topic? APPENDIX C: Responsibilities
Responsibilities of OCCOG
Mission Statement:

The Orange County Council of Governments (OCCOG) convenes jurisdictions throughout Orange County to collaboratively address land use, housing, mobility, energy, air quality, and water issues, and to ensure that Orange County is effectively represented in regional and state decision-making. Through sound governance, impartial analysis, and regional coordination, OCCOG delivers value to its member agencies and the residents of Orange County.

Core Responsibilities:

1. Sub-Regional Planning and Coordination
a. Serves as Orange County’s official sub-regional planning organization within the six-county SCAG region.

California State Housing Mandates

b. Leads the preparation of required regional and sub-regional planning documents that allow Orange County jurisdictions to compete for state and federal funding. [occog.com], [occog.com]

2. Regional Representation and Advocacy
a. Ensures Orange County’s interests are represented in regional policy development by coordinating the county’s representation on the SCAG Regional Council and committees. b. Works to align countywide perspectives on policy issues affecting transportation, housing, sustainability, and infrastructure.

3. Housing, Transportation, and Sustainable Communities Planning a. Supports housing and transportation planning coordination, including RHNA-related activities and implementation discussions.
b. May serve as the lead agency for a sub-regional Sustainable Communities Strategy if Orange County elects to pursue one under SB 375, consistent with SCAG’s Regional Transportation Plan.

4. Technical Analysis, Studies, and Data Support
a. Conducts countywide and sub-regional studies, prepares technical reports, and provides data-driven analysis to support policymaking by member agencies. b. Develops best-practice guidance (e.g., Complete Streets, mobility and infrastructure tools) for voluntary adoption by cities and the County.

5. Intergovernmental Collaboration and Consensus-Building a. Functions as a forum for cooperation among cities, the County, and special districts on issues of shared concern.
b. Facilitates coordination on funding strategies, infrastructure planning, and policy alignment without supplanting local land-use authority.82
Responsibilities of SCAG
Mission Statement
The Southern California Association of Governments (SCAG) serves as the regional planning agency for Southern California, coordinating among local, regional, state, and federal partners to advance transportation, housing, land-use, and environmental planning that supports sustainable growth, economic vitality, social equity, and improved quality of life for the region’s diverse communities.

SCAG’s mission is to lead collaborative regional planning by developing and implementing integrated transportation, housing, and sustainability strategies; allocating regional housing needs; ensuring compliance with state and federal planning requirements; and providing data, technical assistance, and policy guidance to its member jurisdictions to address Southern California’s long-term growth challenges.83
Responsibilities of HCD
Mission Statement (Primary)
The California Department of Housing and Community Development (HCD) works to ensure safe, affordable, and sustainable housing opportunities for Californians by administering housing programs, 82 Orange County Council of Governments
83 Home | Southern California Association of Governments California State Housing Mandates

Orange County Grand Jury 2025-2026
shaping statewide housing policy, and enforcing housing laws to promote equity, environmental quality, and community stability across the state.

HCD’s mission is to lead and implement California’s housing policy by determining regional housing needs, reviewing and enforcing Housing Element compliance, administering state and federal housing funds, and holding local jurisdictions accountable for fulfilling their obligations under state housing law.84 84 California Department of Housing and Community Development Cecilia Hupp Marty Simonoff Christine Marick Blair Stewart Steven Vargas Mayor Mayor Pro Tem Council Member Council Member Council Member City of Brea • 1 Civic Center Circle • Brea, California 92821-5732 • 714-990-7600 • FAX 714-990-2258 • www.cityofbrea.gov August 18, 2026
The Honorable Sheila F. Hanson
Presiding Judge of the Superior Court
Orange County Grand Jury
700 Civic Center Drive West
Santa Ana, CA 92701
RE: City of Brea Response to 2025-2026 Orange County Grand Jury Report, California Housing Mandates, The Unintended Reshaping of Orange County Neighborhoods Dear Presiding Judge Hanson,
In accordance with Section 933.05 (a) and (b) of the California Penal Code, this letter contains the response on behalf of Mayor Hupp and the Brea City Council to the Orange County Grand Jury report, dated May 21, 2026, titled “California Housing Mandates, The Unintended Reshaping of Orange County Neighborhoods”. The responses included correspond to Findings F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12, in addition to Recommendations R7, R8, R9, R11, R12, R14, R15, and R16, as requested by the Orange County Grand Jury.

RESPONSES TO FINDINGS F1, F2, F4, F5, F6, F7, F8, F9, F10, F11, F12:

F1. In recent years, the California Legislature has enacted an unusually large and burdensome volume of housing-related laws intended to strengthen compliance with State Housing Mandates.

Response: The City of Brea agrees with the finding.

F2. Housing Mandates are implemented through a RHNA process that often lacks transparency and relies on complex methodologies that are difficult for local officials and the public to understand or meaningfully challenge.

Response: The City of Brea agrees with the finding.

Honorable Sheila F. Hanson
August 18, 2026

F4. Meaningful participation by Orange County cities in both OCCOG and SCAG meetings is critical to ensuring that local perspectives are represented during the development and implementation of Housing Mandates policies.

Response: The City of Brea agrees with the finding.

Explanation: The City of Brea maintains representation within OCCOG and SCAG through appointed representatives serving on regional boards and committees. In addition, a City staff member serves on the OCCOG Technical Advisory Committee (TAC), ensuring the City of Brea’s participation in the development and implementation of Housing Mandates policies.

F5. SCAG’s 6th Cycle RHNA assigned Orange County a questionable total of 183,861 housing units for the 2021–2029 planning period, with higher allocations concentrated in cities with major population and employment centers.

Response: The City of Brea partially agrees with the finding.

Explanation: The City of Brea focuses on addressing its assigned RHNA allocation, which increased from the prior planning period and refrains from commenting on the allocations assigned to other jurisdictions.

F6. RHNA allocations are unrealistic and not attainable within the current planning cycle due to limited available land, built-out urban conditions, infrastructure constraints, environmental factors, and public health and safety requirements.

Response: The City of Brea agrees with the finding.

F7. Residents in Orange County consistently express a desire for local planning decisions to reflect community priorities, including but not limited to neighborhood character, safety considerations, the environment and open-space preservation.

Response: The City of Brea partially agrees with the finding.

Explanation: The City of Brea recognizes that neighborhood character, safety considerations, the environment and open-space preservation are important topics that are frequently raised by residents during local planning processes. However, the City of Brea cannot comment on residents countywide.

F8. California’s regulatory construction costs (i.e. permitting fees) present substantial challenges for private housing developers—particularly those delivering affordable units.

Response: The City of Brea disagrees with the finding.

Explanation: The City of Brea recognizes that regulatory construction costs, including permitting fees, development impact fees, and environmental review compliance costs, are a consideration in affordable housing development. However, these costs vary by project and are one of several Honorable Sheila F. Hanson
August 18, 2026

factors affecting development feasibility. The City of Brea cannot conclude that regulatory construction costs significantly influence project feasibility and developer interest. The City of Brea has successfully supported ten apartment developments through various forms of development assistance, including loans for seven affordable apartment developments, approval of density bonuses to qualifying developments, and waiver of development fees.

F9. The cost of constructing a single affordable housing unit in California typically ranges from approximately $500,000 to $800,000 per unit when fully complying with current state regulations. New low-income housing is generally not financially feasible without public subsidy.

Response: The City of Brea partially agrees with the finding.

Explanation: The City of Brea agrees that the development of affordable housing is financially complex and that construction costs in California are significant. Affordable housing projects often require multiple funding sources and factors, such as land availability, infrastructure needs, and regulatory requirements that can increase development costs. Despite these challenges, the City of Brea has successfully facilitated affordable housing developments through strategic partnerships and effective use of available funding sources, including loans for seven affordable apartment developments and approving density bonuses to qualifying developments.

F10. Prior to their dissolution in 2012, redevelopment agencies served as a primary mechanism for cities and counties to finance affordable housing and related infrastructure. The loss of redevelopment has reduced cities’ ability to support construction of affordable units.

Response: The City of Brea agrees with the finding.

F11. Because public subsidy is limited and highly competitive, cities seeking to produce meaningful quantities of low-income housing must rely in part on private development incentives, often resulting in higher overall development densities and unit counts than the RHNA allocation.

Response: The City of Brea agrees with the finding.

Explanation: The City of Brea recognizes that public funding for affordable housing is limited and that private development incentives play an important role in facilitating affordable housing projects. These incentives have supported the production of affordable housing within the City of Brea.

F12. The 6th Cycle RHNA methodology included numeroustechnical inputs published by SCAG and HCD; however, these inputs were highly complex and difficult for cities to interpret or independently verify.

Response: The City of Brea agrees with the finding.

Honorable Sheila F. Hanson
August 18, 2026

RESPONSES TO RECOMMENTATIONS R7, R8, R9, R11, R12, R14, R15, and R16:

R7. OCCOG, all Orange County cities and the County of Orange should reassess the current dues structure, by September 30, 2026, to ensure that OCCOG has the resources necessary to effectively represent Orange County jurisdictions in SCAG processes, including RHNA methodology development and appeals. (F3, F15)
Response: Disagree; the recommendation will not be implemented.

Explanation: OCCOG’S dues structure is established by its own processes, and changes to the dues structure cannot be independently initiated by the City of Brea. Although the recommendation will not be implemented, the City of Brea will continue to participate in OCCOG and SCAG discussions related to RHNA and regional housing planning and is open to participating in OCCOGled reassessment of its dues structure.

R8. By December 31, 2026, the Orange County Board of Supervisors should partner with cities to evaluate countywide infrastructure capacity— including water, wastewater, flood control, transportation, and public-safety systems—and develop a coordinated regional plan capable of supporting the level of housing growth required under state law. (F6) Response: Disagree; the recommendation will not be implemented.

Explanation: Although the recommendation will not be implemented, the City of Brea is open to partnering with the Orange County Board of Supervisors to develop a coordinated regional plan to support anticipated housing growth.

R9. By September 30, 2026, the Orange County Board of Supervisors should strengthen its engagement with OCCOG and increase staff support to develop a shared, countywide database of potential housing sites and key development-feasibility factors. (F15)
Response: Disagree; the recommendation will not be implemented.

Explanation: The City of Brea respectfully declines to implement this recommendation as this recommendation is directed to the Orange County Board of Supervisors.

R11. The County of Orange and each city should ensure consistent participation in SCAG and OCCOG committees by September 30, 2026, including the Technical Advisory Committee (TAC), to strengthen regional representation during RHNA-methodology development. (F3, F4, F15) Response: Agree, the recommendation is implemented.

Explanation: The City of Brea maintains representation within OCCOG and SCAG through appointed representatives serving on regional boards and committees. In addition, a City staff member serves on the OCCOG TAC, ensuring the City of Brea’s participation in regional housing and planning discussions.

Honorable Sheila F. Hanson
August 18, 2026

R12. The County of Orange and each city should designate a single technical representative, by September 30, 2026, along with an alternate, for all RHNA-related SCAG and OCCOG committees to ensure continuity of participation and eliminate gaps in representation across multiple decision-making bodies. (F4)
Response: Agree, the recommendation is implemented.

Explanation: The City of Brea has designated a Senior Planner as its primary technical representative for RHNA-related SCAG and OCCOG committees, with an alternate designee to ensure continuity of participation. City staff continues to participate in RHNA-related processes, including the OCCOG TAC, and continues to engage in regional housing and planning discussions through OCCOG and SCAG.

R14. By April 30, 2027, the County of Orange and each city should publish annual monitoring dashboards showing (a) entitlement pipeline conditions, (b) realistic site yield, (c) assembled funding sources for affordable units, and (d) conversion rates from planned capacity to issued permits and completed units, ensuring that County and city-determined capacity assumptions remain aligned with actual production. (F13)
Response: Agree, the recommendation is implemented.

Explanation: The City of Brea already makes publicly-available information related to entitlement pipeline conditions, realistic site yield, assembled funding sources for affordable units, and conversion rates from planned capacity to issued permits and completed unitsthrough its General Plan, Housing Element, and other reporting requirements. While the City of Brea does not currently publish this information in the form of an annual monitoring dashboard, existing reporting addresses many of the recommended monitoring elements. Additionally, the California Department of Housing and Community Development (HCD) maintains a monitoring dashboard of California jurisdictions’ housing data pertaining to housing progress reports.

R15. By September 30, 2026, and ongoing, the County Board of Supervisors and all city councils should make a coordinated and sustained effort to educate their constituents about the RHNA process—its requirements, its impact on local planning and community character, and the role residents can play in shaping outcomes. Public education efforts should also include guidance on how community members can effectively engage with the California Legislature and advocate for more realistic, data-driven housing policies. (F1, F7)
Response: Agree, the recommendation is implemented.

Explanation: The City of Brea supports public education regarding the housing planning process and conducted outreach as part of the latest Housing Element update process. The City of Brea also relies on the educational resources and outreach provided by OCCOG to help inform residents about RHNA requirements and regional housing planning.

Honorable Sheila F. Hanson
August 18, 2026

R16. By December 31, 2026, all cities should look to enhance their relationships with not-for-profit affordable housing developers to increase the opportunity to develop more affordable housing. (F8, F10, F12)
Response: Agree, the recommendation is implemented.

Explanation: The City of Brea has successfully partnered with affordable housing developers, including non-for-profit organizations, and remains committed to supporting future affordable housing opportunities.

The City of Brea values the Grand Jury’s report, “California Housing Mandates, The Unintended Reshaping of Orange County Neighborhoods”, and appreciates the opportunity to respond to the report. Should you have any questions, please contact City Manager Kristin Griffith by telephone at (714) 990-7711 or email at [email protected].

Sincerely,
Cecilia Hupp
Mayor
Cc: Brea City Council
Terence Boga, City Attorney
Kristin Griffith, City Manager
Jason Killebrew, Assistant City Manager/Community Development Director CITYofBREA
City Council Regular Meeting
Communication
August 18, 2026
Item No. 3K.

Memorandum of Agreement between the City of Brea and the County of Orange Regarding Receiving Regional Housing Needs Assessment Allocations Progress Credits for the Mercury Senior Apartments Project

TO PREPARED BY
Honorable Mayor and City Council Members Marie Dao, Senior Management Analyst

DEPARTMENT HEAD APPROVAL CITY MANAGER APPROVAL
Jason Killebrew, Assistant City Manager/Community
Development Director
Kristin Webster, City Manager

RECOMMENDATION
Staff recommends that the City Council take the following actions:

1. Find the Memorandum of Agreement with the County of Orange Regarding Receiving Regional Housing Needs Assessment Allocations Progress Credits for the Mercury Senior Apartments Project ("Memorandum of Agreement") exempt from the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines Section 15061(b)(3);

2. Approve the Memorandum of Agreement (Attachment A); and

3. Authorize the City Manager, or their designee, to make non-substantive changes and execute the Memorandum of Agreement.

BACKGROUND/DISCUSSION
The Southern California Association of Governments (“SCAG”) periodically adopts and assigns a Regional Housing Needs Assessment (“RHNA”) allocation for each county and city. The current RHNA is identified by SCAG as the 6th Cycle, 2021-2029 housing element planning period (“2021-2029 Planning Period”), which allocated 2,365 units for the City of Brea (“City”). Typically, the local jurisdiction authorized to issue building permits for residential development is generally the jurisdiction eligible to receive RHNA allocation credit for units approved, permitted, and/or constructed during the applicable RHNA planning period. However, County funding can be a critical element to create affordable residential units; therefore, the County established a policy in Section 2.08 of a 2026 Supportive Housing Notice of Funding Availability (“2026 NOFA”) that requires cities to share RHNA credit for projects that receive County funding. Currently, the County is seeking RHNA credit for the future affordable Mercury Senior Apartments Project (“Project”) in Brea.

On August 19, 2025, the City Council approved an Affordable Housing Agreement, Density Bonus Agreement, Environmental Impact Report Addendum, and funding commitments for the 85-unit affordable Project, located at the southeast corner of Mercury Lane and Berry Street. Additional background on the Project and its developer, Brea Mercury LP (“Developer”), is available in the August 19, 2025 City Council Staff Report:
https://portal.laserfiche.com/Portal/DocView.aspx?id=220217&repo=r-7237a073.

On February 10, 2026, the Orange County Board of Supervisors (“BOS”) approved policy and process changes to the 2026 NOFA, offering up to $20.9 million and up to 100 Project-Based Vouchers (“PBVs”) for development of extremely low-income housing. The Developer applied for $1,375,000 in Orange County Housing Successor Agency (“HSA”) funds and eight PBVs for the Project.

On May 12, 2026, the Project received a low-income housing tax credit allocation from the California Tax Credit Allocation Committee. Subject to BOS and Orange County Housing Authority approval of the HSA funding and PBVs on August 25, 2026, the Developer intends to close on the tax credit and bond financing in October 2026.

In accordance with Section 2.08 of the County’s 2026 NOFA, the County is proposing a RHNA transfer of nine units from the Project. However, the Project’s units have been reported as entitled in the City’s 2025 Housing Element Annual Progress Report, and, as such, transferring the County-desired units from the City could jeopardize the City’s accuracy in RHNA reporting, compliance with California Department of Housing and Community Development (“HCD”) law, the City’s certified Housing Element, and commitments as an HCD Prohousing Designated City.

To support the Project’s ability to secure essential gap financing, staff recommends the following conditions, which are included in the proposed Memorandum of Agreement for the City Council’s consideration:

In the event that the Project provides a surplus to the 6th Cycle 2021-2029 Planning Period RHNA allocation for the City in the projected acutely low, extremely low, very low, or low-income categories, as reported to HCD, the City would consider sharing credits with the County for affordable units permitted using the $1,375,000 County funds, not to exceed a maximum of five units, whichever is less.

If the potential share of RHNA credit between the City and the County does not get effectuated in the 6th Cycle 2021-2029 Planning Period, the County and the City agree to discuss a potential transfer of the County’s RHNA allocation obligation to the City for the 7th Cycle 2029-2037 housing element planning period (“2029-2037 Planning Period”), as allowed under Government Code Section 65584.07 or any successor statute. The transfer would apply only to the unit production supported by the $1,375,000 in County funding assigned to the Project.

City staff would like to note, as of the drafting of this staff report, the proposed Memorandum of Agreement has not been presented to the BOS and staff does not yet know that the BOS will approve it. As such, City staff recommends that the City Council approve the proposed Memorandum of Agreement, with execution pending BOS approval at their August 25, 2026 meeting.

ENVIRONMENTAL ASSESSMENT
The proposed Memorandum of Agreement is exempt from the requirements to prepare environmental documentation per CEQA Guidelines Section 15061(b)(3), because it is limited to executing an agreement that would specify the terms of a proposed RHNA allocation sharing or transfer for an affordable housing project and as such, the proposed agreement will not result in a direct or reasonably foreseeable indirect physical change in the environment and will not have a significant effect on the environment. Therefore, no further environmental review is necessary.

FISCAL IMPACT/SUMMARY
Execution of the Memorandum of Agreement will have no fiscal impact to the General Fund (110).

Attachments
Attachment A - Memorandum of Agreement.pdf
3287096.2

MEMORANDUM OF AGREEMENT

BETWEEN THE COUNTY OF ORANGE AND

THE CITY OF BREA REGARDING RECEIVING

REGIONAL HOUSING NEEDS ASSESSMENT ALLOCATIONS PROGESS CREDITS This Memorandum of Agreement ("MOA”) between the COUNTY OF ORANGE, a political subdivision of the State of California (“County") and the CITY OF BREA, a municipal corporation ("City"), is dated, for the convenience of the parties, as the first date upon which it is executed by both the County and the City, as shown by the signatures of their authorized representatives below, and the various obligations established hereby shall take effect as provided herein.

RECITALS
A. The Orange County Board of Supervisors (“Board”) and the Board acting as the Board of Commissioners to the Orange County Housing Authority, acting in its capacity as Housing Successor Agency, approved a loan in the amount of up to $1,375,000 on August 25, 2026, toward the completion of 85 units within the Mercury Senior Apartments housing project (the "Project") on that certain real property located on the southeast corner of Mercury Lane and Berry Street (“Housing Site”) within the City of Brea, County of Orange, State of California.

B. The Board, acting as the Board of Commissioners to the Orange County Housing Authority, also approved the selection of the Project for the utilization of eight Project-Based Housing Choice Vouchers (“PBVs”), supplied by the U.S. Department of Housing and Urban Development (“HUD”), and administered as a pass-through assistance by the County, to further support the success of this Project.

C. The County desires to rely on housing proposed as part of the Project to meet certain affordable housing obligations imposed on the County by state law. Pursuant to Article 10.6 (the "Housing Element Law") (Government Code sections 65580 - 65589.8) of Chapter 3 of the Planning and Zoning Law, the Southern California Association of Governments ("SCAG") periodically adopts and assigns a Regional Housing Needs Assessment ("RHNA") allocation for each county and city in the County of Orange, including Orange County and the City of Brea. The current RHNA is designated as the sixth required revision by Government Code Section 65588 and is identified by SCAG as the 6
th Cycle, 2021-2029 housing element planning period ("2021- 2029 Planning Period"). The next required revision to the housing elements of the City and the County will be designated as the seventh required revision by Government Code Section 65588 and is identified by SCAG as the 2029-2037 housing element planning period (“2029-2037 Planning Period”). In Section 2.08 of the 2026 Supportive Housing Notice of Funding Availability (“2026 NOFA”) issued by the County, the 2026 NOFA requires RHNA transfers for development funded by County local and regional revenue.

D. The City’s RHNA allocation for the 6th Cycle 2021-2029 Planning Period is 2,365 units. This Project, in association with a Development Agreement approved by the Brea City Council for a 179-unit market-rate, for-sale project (“Greenbriar Project”), accounts for an offsite affordable housing obligation, and shall be counted towards the City’s 6th Cycle 2021-2029 unit production.
2 3287096.2
E. The City has an adopted and certified by the California Department of Housing and Community Development (“HCD”) housing element addressing an assortment of housing programs and policies that achieve meeting the goals of the State and the City’s RHNA obligation.

Both the Greenbriar Project and this Project would be recorded in future Housing Element Annual Progress reports within the 6th Cycle 2021-2029 Planning Period. Since these units have already been reported as entitled in the 2025 Housing Element Annual Progress report, transferring the County-desired units from this Project from the City could jeopardize the City’s accuracy in RHNA reporting, compliance with Housing Element Law, the City’s certified Housing Element, and commitments as an HCD Prohousing Designated City.

F. In the event that the Project provides a surplus to the 6 th Cycle 2021-2029 Planning
Period RHNA allocation for the City in the projected acutely low, extremely low, very low, or low categories, as reported to HCD, the City would consider sharing credits with the County for affordable units permitted using the $1,375,000 County Funds, not to exceed a maximum of five units, whichever is less.

G. Approval and successful implementation of this MOA would support the County’s and the City’s progress towards meeting their respective 2021-2029 RHNA allocations for the 6th Cycle 2021-2029 Planning Period, while complying with the various programs, policies, and obligations set forth in their certified housing elements. The City and the County agree that, notwithstanding any prior communications regarding this matter, this MOA is the final agreement concerning this matter and is binding.

H. If the potential share of RHNA credit between the City and the County does not get effectuated in the 6th Cycle 2021-2029 Planning Period, the County and the City agree to discuss potential transfer of the County’s RHNA allocation obligation to the City for the 7th Cycle 2029- 2037 Planning Period, as allowed under Government Code Section 65584.07 or any successor statute ("Section 65584.07"). The transfer would apply only to the unit production supported by the $1,375,000 in County funding assigned to this Project.

NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements contained herein, the Parties hereto mutually agree as follows:

1. Housing Site. The "Housing Site" is incorporated by reference and is identified as the southeast corner of Berry Street and Mercury Lane in the City of Brea. The City will issue residential building permits for construction of affordable housing on the Housing Site during the 2021-2029 Planning Period. Issuance of building permits is subject to compliance with City and Building Code regulations. Occupancy permits will also be issued for affordable housing on the Housing Site during the 2021-2029 Planning Period. Issuance of occupancy permits is subject to compliance with City and Building Code regulations. The Housing Site remains in the City's jurisdiction, within the corporate boundaries of the City of Brea.

2. RHNA Transfer.
a. All 85 housing units within the Project will be reported by the City in its respective Annual General Plan Progress Report during the 2021-2029 Planning Period, as 3 3287096.2
appropriate.
b. Share of Regional Housing Needs Assessment. For the 2029-2037 Planning Period (or as that planning period may be adjusted by SCAG, HCD, or statute), upon SCAG’s adoption of a final RHNA, the County and City may jointly apply to SCAG to transfer up to five units from the County’s RHNA allocation to the City.

The County’s share of low-, very low, extremely low, and acutely low-income housing may be reduced in proportion to the amount by which the County’s share of moderate- and above moderate-income housing is reduced attributable to up to five County-assisted units from the Project, as allowed under Section 65584.07 and contingent upon County approval of 2026 NOFA funds and PBVs for the Project. c. The Parties agree that the financial commitment from the Housing Successor Agency, including an approved loan in the amount of up to $1,375,000 is full and adequate consideration for the County to potentially receive RHNA transfer for up to five County-assisted units contemplated in this Section 2.

3. Cooperation. The City and the County shall take all steps reasonably necessary to comply with and implement this MOA.

4. Indemnification.
a. The City shall, to the extent permitted by law, indemnify, defend, and hold harmless the County and it officers, agents, and employees, from and against any claim, action, suit, proceeding, loss, cost, damage, liability, deficiency, fine, penalty, punitive damage, or expense (including, without limitation, attorneys' fees), resulting from, arising out of, or based upon the negligence or wrongful act or omission of the City or its City Council, boards and commissions, officers, agents, volunteers, or employees, in approving this MOA.
b. The County shall, to the extent permitted by law, indemnify, defend, and hold harmless the City and its officers, agents, and employees, from and against any claim, action, suit, proceeding, loss, cost, damage, liability, deficiency, fine, penalty, punitive damage, or expense (including, without limitation, attorney's fees), resulting from, arising out of, or based upon the negligence or wrongful act or omission of the County or its Board of Supervisors, committees and commissions, officers, agents, volunteers, or employees, in approving this MOA.

5. Time. Time is of the essence in this MOA.

6. Management. Except as otherwise provided in this MOA, the approval of both the City and the County shall be required for decisions regarding management of the Project during the term of the Project’s affordability.

7. Successors and Assigns. This MOA shall be binding upon and shall inure to the benefit of the County and the City and their respective heirs, personal representatives, successors 4 3287096.2
and assigns. Neither Party shall have the right to assign this MOA or any interest or right under this MOA without the prior written consent of the other Party.

8. No Attorneys' Fees. In any action between the Parties to interpret, enforce, award, modify or rescind any of the terms or provisions of this MOA, or any action otherwise commenced or taken in connection with this MOA, both Parties shall be responsible for their respective litigation costs and attorneys' fees, except as provided in Section 4, above, regarding indemnity.

9. Jurisdiction and Venue. This MOA shall be construed under the laws of the State of California in effect at the time of the signing of this MOA. The Parties consent to the jurisdiction of the California courts with venue in County of Orange.

10. Titles and Captions. Titles and captions are for convenience of reference only and do not define, describe or limit the scope or the intent of this MOA or of any of its terms. Reference to section numbers in this MOA, unless expressly stated otherwise.

11. Interpretation. As used in this MOA, masculine, feminine or neuter gender and the singular or plural numbershall each be deemed to include the others where and when the context so dictates. The word "including" shall be construed as if followed by the words "without limitation." This MOA shall be interpreted as though prepared jointly by both Parties.

12. No Waiver. A waiver by either Party of a breach of any of the covenants, conditions or agreements under this MOA to be performed by the other Party shall not be construed as a waiver of any other such breach or succeeding breach or of the same or other covenants, agreements, restrictions or conditions of this MOA.

13. Modifications. Any alteration, change or modification of or to this MOA, to become effective, shall be made in writing and in each instance signed on behalf of each Party.

14. Severability. If any term, provision, condition or covenant of this MOA or its application to any Party or circumstances shall be held, to any extent, invalid or unenforceable, the remainder of this MOA, and the application of the term, provision, condition or covenant to persons or circumstances other than those as to whom or which it is held invalid or unenforceable, shall not be affected, and shall be valid and enforceable to the fullest extent permitted by law.

15. Cooperation. Each Party agrees to cooperate with the other in the execution of this MOA and, in that regard, to sign any and all documents which may be reasonably necessary, helpful, or appropriate to carry out the purposes and intent of this MOA including, but not limited to, releases or additional agreements.

16. Counterparts. This MOA may be signed in multiple counterparts which, when signed by all Parties, shall constitute a binding agreement.

17. Notices. Any notice requirement set forth herein shall be in writing and delivered to the appropriate party at the address listed in this subparagraph. Addresses for notice may be changed from time to time by written notice to the other party. All communications shall be effective when actually received; provided, however, that nonreceipt of any communication as the 5 3287096.2
result of a change in address of which the sending party was not notified or asthe result of a refusal to accept delivery shall be deemed receipt of such communication.

To County: County of Orange
Attn: OC Public Works, Development Services
601 N. Ross Street
Santa Ana, CA 92701
To City: City of Brea
Attn: City Manager, Kristin Griffith
1 Civic Center Circle
Brea, CA 92821
IN WITNESS WHEREOF, the Parties hereto have caused this MOA to be executed by their respective governing bodies on the dates set forth opposite their signatures.

COUNTY:

COUNTY OF ORANGE,
a political subdivision of the State of
California
By:

Dated:

Name:

Title:

APPROVED AS TO FORM:

OFFICE OF COUNTY COUNSEL

ORANGE COUNTY, CALIFORNIA
By:
5 CITY:

CITY OF Brea, a municipal corporation
By:

Kristin Griffith, City Manager
Dated:

ATTEST:

Victoria Popescu, City Clerk
APPROVED AS TO FORM:

Terence Boga
City Attorney
CITYofBREA
City Council Regular Meeting
Communication
August 18, 2026
Item No. 3L.

Approve Amendments for Additional As-Needed Arovista Park Services

TO PREPARED BY
Honorable Mayor and City Council Members Michael Ho, Public Works Director

DEPARTMENT HEAD APPROVAL CITY MANAGER APPROVAL
Michael Ho, Public Works Director Kristin Webster, City Manager

RECOMMENDATION
Staff recommends that the City Council take the following actions:

1. Approve Amendment No. 4 with BKF Engineers in the amount not-to-exceed $30,000 resulting in a total contract amount not-to-exceed $134,100 for as-needed civil engineering services.

2. Approve Amendment No. 1 with David Volz Design in the amount not-to-exceed $30,000 resulting in a total contract amount not-to-exceed $105,000 for as-needed landscape design services.

3. Approve Amendment No. 2 with Shucri Yaghi Consulting Engineers, Inc. in the amount not-to-exceed $30,000 resulting in a total contract amount not-to-exceed $170,300 for as-needed structural engineering services.

4. Approve Amendment No. 2 with Telacu Construction Management in the amount not-to-exceed $80,000 resulting in a total contract amount not-to-exceed $969,479 for as-needed construction management services.

BACKGROUND/DISCUSSION
On March 19, 2024, the City Council awarded a construction contract for the Arovista Park Modernization Project, CIP No. 7978 (Project), for $16,511,884.55, along with eight on-call, as-needed support services for consultants for $1,295,479, for a total approved project budget of $24,126,602. The professional services agreement for David Volz Design (DVD) was included in this item and was awarded $75,000 for as-needed landscape design services.

The as-needed support services were budgeted based on a Project completion time of Fall 2025.

On June 17, 2025, the City Council approved additional funding of $168,000 to Geocon West, Inc.'s (Geocon) previously awarded amount of $250,000, and $32,100 to BKF Engineers' (BKF) previously awarded amount of $42,000 due to soft soil conditions near the flood control channel, necessitating changes to the retaining wall and footing design and additional materials testing, soils inspection, and engineering services. Staff required these oncall service agreements to support the Project as it progressed, managing, answering, clarifying, approving, and providing daily inspections throughout construction, as they are the consulting engineers who designed the plans.

On December 16, 2025, the City Council approved contract amendments totaling $302,300. Amendments included $100,000 for Geocon, $92,300 for Shucri Yaghi Consulting Engineers (Yaghi), $30,000 for BKF, and $80,000 for Telacu Construction Management (Telacu) to continue providing various services necessary to progress the project due to delays that occurred, pushing the planned completion to 2026. Primary challenges included the relocation of a Southern California Edison (SCE) power pole that conflicted with the proposed series of Americans with Disabilities Act (ADA) walkways leading to and from the Project, and the contractor's challenges in constructing over 50 walls.

The Project's original construction schedule allowed 250 working days, commencing on April 29, 2024, and ending on May 14, 2025. Based on actual holidays, weather days, and approved change-order days, the new allowed contract completion date was late August 2026. The contractor has submitted a new completion schedule and estimates a completion date in late Fall 2026. The contractor is committed to completing the remaining work as quickly and efficiently as possible; therefore, staff is requesting additional funds for the previously approved consultants. Staff will pursue recovery of these additional funds at the end of the Project.

Staff requests additional funding to amend existing contracts for several project consultants. Contract amendments will ensure oversight of the project is supported by a team of professionals with first-hand knowledge of challenges faced in the field. Each of these amendments will be billed on an as-needed basis only. Descriptions of their services are as follows:

BKF serves as the civil engineer of record, clarifying and providing direction to the contractor.

DVD serves as the Architect of Record, reviewing RFIs, change orders, and claims, overseeing project inspection to ensure compliance with plans and specs, and providing cost reduction alternatives.

Yaghi serves as the structural engineer of record, reviewing the contractor's plan submittals, field inspections, and design change orders.

Telacu serves as the Construction Management firm, serving and has been the primary conduit for day-to-day Project operations. They have been instrumental in facilitating efforts between the contractor and consultant team and have a broad understanding of the project’s complex history.

COMMISSION/COMMITTEE RECOMMENDATION
The Finance Committee reviewed staff's recommendation at their August 11, 2026, meeting and recommended for City Council approval.

FISCAL IMPACT/SUMMARY
The Project is approximately 65% complete, however challenges with the contractor have led to delays, pushing the planned completion to the end of Fall 2026. Challenges include lack of project understanding, inadequate personnel due to turnover, and sequencing issues. These challenges have led to workplace incidents including improper shoring, improper wall construction, reconstruction of pavement, reconstruction of court foundation, and stop-work orders.

Previous on-call agreements were awarded to BKF for $104,100, DVD for $75,000, Telacu for $889,479, and to Yaghi for $140,300 to provide various support services for answering, clarifying, approving, and conducting inspections throughout the construction process. The additional funding request includes $30,000 for BKF, $30,000 for DVD, $80,000 for Telacu, and $30,000 for Yaghi to continue their services. The combined additional request is $170,000.

On March 19, 2024, the City Council appropriated $12,668,602 to the Project budget, bringing the total to $24,126,602. One line-item in the Project budget was for the installation of the west side restroom/storage facilities for $500,000. The funding for this item is no longer needed as the City has the $2M Federal grant from the Department of Housing and Urban Development for Arovista Park. These grant funds will install the new west side restroom/storage facilities at Arovista Park. At the December 16, 2025, City Council meeting, $302,300 of the unused $500,000 was allocated to contract amendments for BKF, Geocon, Yaghi, and Telacu.

The combined additional request of $170,000 will draw down from the remaining $197,700 of the unused $500,000.

Any unspent funds will return to the Project budget. No additional funding is requested for these contract amendments, as sufficient funding is available within the existing Capital Improvement Project budget. Staff intend to pursue recovery of these additional funds at the end of the Project.

Attachments
Attachment A - Amendment No. 4 with BKF
Attachment B - Amendment No. 1 with DVD
Attachment C - Amendment No. 2 with Yaghi
Attachment D - Amendment No. 2 TELACU Partially Executed 081326 Tuesday 1

Tuesday 1
10 CITYofBREA
City Council Regular Meeting
Communication
August 18, 2026
Item No. 3M.

Amend CIP 7946 Western Extension to the Tracks at Brea FY2026-27 Budget

TO PREPARED BY
Honorable Mayor and City Council Members Wade Whitman, Management Analyst I

DEPARTMENT HEAD APPROVAL CITY MANAGER APPROVAL
Michael Ho, Public Works Director Kristin Webster, City Manager

RECOMMENDATION
Staff recommends that the City Council take the following action:

1. Adopt a resolution amending the FY 2025-27 Operating and Capital Improvement Program Budget for the Western Extension to the Tracks at Brea (CIP 7946).

BACKGROUND/DISCUSSION
City staff have been negotiating with Union Pacific Railroad (UPR) since 2018 for the purchase of property through the railroad corridor to extend CIP 7946 Western Extension to the Tracks at Brea (Project) from the existing terminus at the Brea Canyon Flood Channel to the western city limits at Palm Street. While negotiations have progressed, City staff have worked diligently to secure funding to acquire the property and extend the Tracks at Brea 1.3 miles to complete the City’s segment of the greater OC Loop project. The results of these efforts include the following:

City Staff prepared an ATP grant application in 2020 for the fifth cycle of the program. A program supplement authorizing the use of $1,787,000 for right of way (ROW) acquisition was received in 2023.

Grant agreement 3825-RMC21013 for $225,000 of State Park funds was executed at the November 16, 2021, City Council meeting. The scope of the grant included concept design and community outreach activities and the project was certified complete at the November 19, 2024, City Council meeting. Final reimbursement for the project has already been received and the funding was not included in the table below for this staff report.

In 2022, City staff collaborated with Townsend Public Affairs and the offices of Senator Feinstein, Senator Padilla, and Congresswoman Kim to secure $2,000,000 in Congressionally Directed Spending funds for the acquisition. The grant agreement for this funding was executed at the October 10, 2023, City Council meeting and has already been appropriated in the project budget.

The City has received four installments of Congestion Mitigation and Air Quality (CMAQ) funding for the Project. For the preliminary engineering (PE) phases and ROW phases, these include one installment of $237,000 for PE, one installment of $3,592,000 for ROW, which was previously appropriated in the project budget, and a second installment of $2,219,000 for ROW. A program supplement authorizing the use of the funding was received in July of 2026.

In 2025, the City received an opportunity to repurpose the remaining $85,624 of earmark funding to the ROW phase of the Project from cost savings realized by CIP 7251 Lambert/57 Interchange Improvements. This funding was also authorized for use by the aforementioned program supplement.

In addition to the ROW funds, the City has also received the following awards for the construction (CON) phase of the Project:

The fourth installment of CMAQ funding includes $1,320,000 for CON activities. The use of this funding has not yet been authorized through a program supplement.

In May of 2025, City staff applied for an additional $1,771,000 of CON funding through the FY2026-27 & 2027-28 Surface Transportation Block Grant (STBG)/CMAQ program. The funding recommendation was approved by the Southern California Association of Governments (SCAG) Regional Council at their December 4, 2025 meeting. The use of this funding has not yet been authorized through a program supplement.

In October of 2025, Orange County Transportation Authority (OCTA) staff notified City staff that they would be submitting the Project on behalf of the City for $6,149,000 in CON funding through the 2026 State Transportation Improvement Program (STIP). The Project was recommended for funding and the STIP was adopted by the California Transportation Commission (CTC) at the March 19, 2026 meeting. City staff are currently waiting for additional information regarding funding allocation.

City Staff intend to return at a later date to appropriate funding for CON once PE and ROW activities have been completed and authorization to use CON funding has been received.

Table 1: ROW and PE funding per SCAG Federal Transportation Improvement Program Amendment #25-28 Phase Funding Type Value Match
PE CMAQ $ 237,000 $ 88,000
ROW 2022 HUD Appropriations $ 2,000,000 $ -
ROW ATP Cycle 5 $ 1,787,000 $ -
ROW CMAQ $ 3,592,000 $ 718,000
ROW CMAQ $ 2,219,000 $ 255,000
ROW Earmark Repurposing $ 85,624 $ -
Total $ 9,920,624 $ 1,061,000
*Funding was appropriated in a previous fiscal year.

For PE and ROW acquisition, the City has received $9,920,624 of grant funding with a required match of $1,061,000 for a total of $10,981,624. Negotiations with Union Pacific Railroad were finalized this year, and the purchase of a 2.8-acre easement for $10,190,491 was approved by a unanimous vote at the June 16, 2026 City Council meeting. Additional closing costs associated with the purchase total $17,682, bringing the total to $10,208,173. An allocation of $1,000,000 from Fund 250, Park Development, was previously appropriated to meet the required local match. As of late May, there is $804,431 of Fund 250 remaining in the Project budget due to legal, appraisal, and project management costs incurred over the last few years.

City staff recommends adopting a resolution to amend the FY 2025-27 Capital Improvement Program Budget to appropriate $4,628,624 for CIP 7946 Western Extension to the Tracks at Brea to fund the acquisition of a 2.8-acre easement from the Brea Canyon Flood Channel to Palm Street. The funding will come from an additional appropriation of $300,000 of Fund 250 to ensure the required local match is met for PE and ROW phases, and the recognition of State/Federal grant awards of $2,456,000; $1,787,000; and $85,624 through the Congestion Mitigation and Air Quality (CMAQ), Active Transportation Program (ATP), and Earmark Repurposing programs, respectively. The recommended adjustments are provided in Attachment B - Exhibit A.

The funding for this gap closure will contribute to the completion of a 20-mile off-street corridor serving Orange County residents throughout Brea, La Habra, and Placentia. The completion of the City’s segment of the OC Loop will improve mobility, accessibility, and safety for bicyclists and pedestrians within the City and neighboring communities, and achieve a long-term goal identified in the City’s Active Transportation Plan.

COMMISSION/COMMITTEE RECOMMENDATION
The Finance Committee reviewed staff's recommendation at their August 11, 2026, meeting and recommended for City Council approval.

FISCAL IMPACT/SUMMARY
The City of Brea's local match will come from Fund 250, Park Development. A majority of the match was appropriated in a previous fiscal year and City staff are requesting an additional $300,000 to ensure the required match is met. There is sufficient funding in Fund 250 to cover this shortfall. The grant funding for PE and ROW activities is reimbursement-based, and the initial purchase of the property amount of $10,208,173 will be made with General Fund monies. City staff expects reimbursement within the 2026-27 Fiscal Year.

Attachments
Attachment A - Resolution.pdf
Attachment B - Exhibit A.pdf
Attachment C - Executed Program Supplement.pdf
Attachment D - Executed Finance Letter.pdf
Attachment E - Executed Earmark Repurposing.pdf
Attachment F - Vicinity Map.pdf
Attachment G - SCAG Amendment 25-28.pdf
RESOLUTION NO. 2026-XXX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF BREA
AMENDING FISCAL YEARS 2025-27 OF THE CAPITAL

IMPROVEMENT PROGRAM AND OPERATING BUDGET

A. RESOLUTION:

The City Council of the City of Brea does hereby find, determine and resolve that Fiscal Year 2025-26 and 2026-27 of the Capital Improvement Program Budget, Resolution No. 2025-047 and the Fiscal Year 2025-26 and FY 2026-27 Operating Budget, Resolution No. 2025-045, as heretofore amended, be further amended as set forth in Exhibit A, attached.

APPROVED AND ADOPTED this 18th day of August, 2026.
________________________________
Mayor
ATTEST: _____________________________
I, Victoria Popescu, City Clerk of the City of Brea, do hereby certify that the foregoing Resolution was adopted at a regular meeting of the City Council of the City of Brea, held on the 18th day of August, 2026, by the following vote:

AYES: COUNCIL MEMBERS:

NOES: COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:

DATED: _________________________
________________________________
City Clerk
CIP - Exhibit A
Current Amended Funding Current Amended Funding
Account Budget Budget Required Budget Budget Required Description PARK DEVELOPMENT FUND (250)
250909510 5985 (TEXP) Transfer-in from Park
Development Fund (250)
$ 2,050,101 2,050,101 $ $ - $ 300,000 - $ $ 300,000
Change in Fund Revenues $ - $ -
Change in Transfers-In - -
Change in Fund Expenditures - -
Change in Transfers-Out - 300,000
Net Change in Revenues over Expenditures $ - $ (300,000) CAPITAL IMPROVEMENT PROGRAM FUND (510)
510909250 3985 (TREV) Transfer-in from Park
Development Fund (250)
$ 2,050,101 2,050,101 $ $ - $ 300,000 - $ $ 300,000
510707946 4098 (EXP) Tracks at Brea Western
Extension Project
$ 6,260,404 6,260,404 $ $ - $ 4,628,624 - $ $ 4,628,624 510707946 3549 (REV) State Grants - Other 3,406,635 $ 3,406,635 $ $ - $ 1,787,000 - $ $ 1,787,000 ATP Cycle 5 Award 510707946 3569 (REV) Federal Grants - Other 2,019,931 $ 2,019,931 $ $ - $ 2,456,000 - $ $ 2,541,624 CMAQ Award and DEMO funding Change in Fund Revenues $ - $ 4,328,624
Change in Transfers-In - 300,000
Change in Fund Expenditures - 4,628,624
Change in Transfers-Out - -
Net Change in Revenues over Expenditures $ - $ -
City of Brea

BUDGET ADJUSTMENTS

CAPITAL IMPROVEMENT PROGRAM (CIP) BUDGET
August 18, 2026
Fiscal Year 2025-26 Fiscal Year 2026-27

OPERATING AND

Ferdinand A. Batatan (Jul 22, 2026 11:22:02 PDT)
Ferdinand A. Batatan For:
07/22/2026

SPECIAL COVENANTS OR REMARKS
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ATPCML-5237(033)

1. A. This PROJECT will be administered in accordance with the applicable CTC STIP guidelines and the Active Transportation Program guidelines as adopted or amended, the Local Assistance Procedures Manual (LAPM), the Local Assistance Program Guidelines (LAPG), and this PROGRAM SUPPLEMENT.

B. This PROJECT is programmed to receive State funds from the Active Transportation Program (ATP). Funding may be provided under one or more components. A component(s) specific fund allocation is required, in addition to other requirements, before reimbursable work can occur for the component(s) identified. Each allocation will be assigned an effective date and identify the amount of funds allocated per component(s).

This PROGRAM SUPPLEMENT has been prepared to allow reimbursement of eligible PROJECT expenditures for the component(s) allocated. Unless otherwise determined, the effective date of the component specific allocation will constitute the start of reimbursable expenditures.

C. STATE and ADMINISTERING AGENCY agree that any additional funds made available by future allocations will be encumbered on this PROJECT by use of a STATE-approved Allocation Letter and STATE Finance Letter. ADMINISTERING AGENCY agrees that STATE funds available for reimbursement will be limited to the amount allocated by the California Transportation Commission (CTC) and/or the STATE.

D. Upon ADMINISTERING AGENCY request, the CTC and/or STATE may approve supplementary allocations, time extensions, and fund transfers between components. Funds transferred between allocated project components retain their original timely use of funds deadlines, but an approved time extension will revise the timely use of funds criteria for the component(s) and allocation(s) requested. Approved supplementary allocations, time extensions, and fund transfers between components made after the execution of this PROGRAM SUPPLEMENT will be documented and considered subject to the terms and conditions thereof.

Documentation will consist of a STATE approved Allocation Letter, Fund Transfer Letter, Time Extension Letter, and Finance Letter, as appropriate.

E. This PROJECT is subject to the timely use of funds provisions enacted by the Active Transportation Program guidelines, as adopted or amended, and by approved CTC and State procedures as outlined below.

Funds allocated for the environmental & permits (E&P), plan specifications & estimate (PS&E), and right-of-way components are available for expenditure until the end of the second fiscal year following the year in which the funds were allocated.

Funds allocated for the construction component are subject to an award deadline and contract completion deadline. ADMINISTERING AGENCY agrees to award the contract within 6 months of the construction fund allocation and to complete and accept the construction within 36 months of award.

Program Supplement 12-5237F15-F029-R2- ISTEA Page 2 of 9

SPECIAL COVENANTS OR REMARKS
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F. Award information shall be submitted by the ADMINISTERING AGENCY to the District Local Assistance Engineer immediately after project contract award and prior to the submittal of the ADMINISTERING AGENCY'S first invoice for the construction contract. Failure to do so will cause a delay in the State processing of invoices for the construction phase.

G. The ADMINISTERING AGENCY shall invoice STATE for environmental & permits (E&P), plans specifications & estimate (PS&E), and right-of-way costs no later than 180 days after the end of last eligible fiscal year of expenditure. For construction costs, the ADMINISTERING AGENCY has 180 days after project completion or contract acceptance to make the final payment to the contractor prepare the final Report of Expenditures and final invoice, and submit to STATE for verification and payment.

H. ADMINISTERING AGENCY agrees to submit the final report documents that collectively constitute a "Report of Expenditures" within one hundred eighty (180) days of PROJECT completion. Failure of ADMINISTERING AGENCY to submit a "Final Report of Expenditures" within 180 days of PROJECT completion will result in STATE imposing sanctions upon ADMINISTERING AGENCY in accordance with the current LAPM and the Active Transportation Program (ATP) Guidelines.

I. ADMINISTERING AGENCY indirect costs, as defined in 2 CFR, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, to be claimed must be allocated in accordance with an Indirect Cost Allocation Plan (ICAP), submitted, reviewed, and approved in accordance with Caltrans Audits and Investigations requirements which may be accessed at: www.dot.ca.gov/hq/audits/.

ADMINISTERING AGENCY agrees to comply with, and require all sub-recipients and project sponsors to comply with 2 CFR, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, and all applicable Federal and State laws and regulations.

ADMINISTERING AGENCY agrees, and will assure that its contractors and subcontractors will be obligated to agree, that Contract Cost Principles and Procedures, 48 CFR, Federal Acquisition Regulations System, Chapter 1, Part 31, et seq., and all applicable Federal and State laws and regulations, shall be used to determine the allowability of individual PROJECT cost items.

Any Fund expenditures for costs for which ADMINISTERING AGENCY has received payment or credit that are determined by subsequent audit to be unallowable under 2 CFR, Part 200, or 48 CFR, Chapter 1, Part 3, are subject to repayment by ADMINISTERING AGENCY to STATE. Should ADMINISTERING AGENCY fail to reimburse Funds due STATE within 30 days of demand, or within such other period as may be agreed in writing between the Parties hereto, STATE is authorized to intercept and withhold future payments due ADMINISTERING AGENCY from STATE or any third-party source, including, but not limited to, the State Treasurer, the State Controller, and the California Transportation Commission.

J. By executing this PROGRAM SUPPLEMENT, ADMINISTERING AGENCY agrees to Program Supplement 12-5237F15-F029-R2- ISTEA Page 3 of 9

SPECIAL COVENANTS OR REMARKS
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comply with all reporting requirements in accordance with the Active Transportation Program guidelines, as adopted or amended.

K. This PROJECT has received funds from Active Transportation Program (ATP). The ADMINISTERING AGENCY agrees to administer the project in accordance with the CTC Adopted SB1 Accountability and Transparency Guidelines.

2. The ADMINISTERING AGENCY shall construct the PROJECT in accordance with the scope of work presented in the application and approved by the California Transportation Commission. Any changes to the approved PROJECT scope without the prior expressed approval of the California Transportation Commission are ineligible for reimbursement and may result in the entire PROJECT becoming ineligible for reimbursement.

3. A. The ADMINISTERING AGENCY will advertise, award and administer this project in accordance with the current published Local Assistance Procedures Manual.

B. ADMINISTERING AGENCY agrees that it will only proceed with work authorized for specific phase(s) with an "Authorization to Proceed" and will not proceed with future phase(s) of this project prior to receiving an "Authorization to Proceed" from the STATE for that phase(s) unless no further State or Federal funds are needed for those future phase(s).

C. STATE and ADMINISTERING AGENCY agree that any additional funds which might be made available by future Federal obligations will be encumbered on this PROJECT by use of a STATE-approved "Authorization to Proceed" and Finance Letter. ADMINISTERING AGENCY agrees that Federal funds available for reimbursement will be limited to the amounts obligated by the Federal Highway Administration.

D. Award information shall be submitted by the ADMINISTERING AGENCY to the District Local Assistance Engineer within 60 days of project contract award and prior to the submittal of the ADMINISTERING AGENCY'S first invoice for the construction contract.

Failure to do so will cause a delay in the State processing invoices for the construction phase.

Attention is directed to Section 15.6 "Award Package" of the Local Assistance Procedures Manual.

E. ADMINISTERING AGENCY agrees, as a minimum, to submit invoices at least once every six months commencing after the funds are encumbered for each phase by the execution of this Project Program Supplement Agreement, or by STATE's approval of an applicable Finance Letter. STATE reserves the right to suspend future authorizations/obligations for Federal aid projects, or encumbrances for State funded projects, as well as to suspend invoice payments for any on-going or future project by ADMINISTERING AGENCY if PROJECT costs have not been invoiced by ADMINISTERING AGENCY for a six-month period.

If no costs have been invoiced for a six-month period, ADMINISTERING AGENCY agrees to submit for each phase a written explanation of the absence of PROJECT activity along with target billing date and target billing amount.

Program Supplement 12-5237F15-F029-R2- ISTEA Page 4 of 9

SPECIAL COVENANTS OR REMARKS
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ADMINISTERING AGENCY agrees to submit the final report documents that collectively constitute a "Report of Expenditures" within one hundred eighty (180) days of PROJECT completion. Failure of ADMINISTERING AGENCY to submit a "Final Report of Expenditures" within 180 days of PROJECT completion will result in STATE imposing sanctions upon ADMINISTERING AGENCY in accordance with the current Local Assistance Procedures Manual.

F. Administering Agency shall not discriminate on the basis of race, religion, age, disability, color, national origin, or sex in the award and performance of any Federal-assisted contract or in the administration of its DBE Program Implementation Agreement. The Administering Agency shall take all necessary and reasonable steps under 49 CFR Part 26 to ensure nondiscrimination in the award and administration of Federal-assisted contracts. The Administering Agency's DBE Implementation Agreement is incorporated by reference in this Agreement. Implementation of the DBE Implementation Agreement, including but not limited to timely reporting of DBE commitments and utilization, is a legal obligation and failure to carry out its terms shall be treated as a violation of this Agreement. Upon notification to the Administering Agency of its failure to carry out its DBE Implementation Agreement, the State may impose sanctions as provided for under 49 CFR Part 26 and may, in appropriate cases, refer the matter for enforcement under 18 U.S.C. 1001 and/or the Program Fraud Civil Remedies Act of 1986 (31 U.S.C. 3801 et seq.).

G. Any State and Federal funds that may have been encumbered for this project are available for disbursement for limited periods of time. For each fund encumbrance the limited period is from the start of the fiscal year that the specific fund was appropriated within the State Budget Act to the applicable fund Reversion Date shown on the State approved project finance letter.

Per Government Code Section 16304, all project funds not liquidated within these periods will revert unless an executed Cooperative Work Agreement extending these dates is requested by the ADMINISTERING AGENCY and approved by the California Department of Finance.

ADMINISTERING AGENCY should ensure that invoices are submitted to the District Local Assistance Engineer at least 75 days prior to the applicable fund Reversion Date to avoid the lapse of applicable funds. Pursuant to a directive from the State Controller's Office and the Department of Finance; in order for payment to be made, the last date the District Local Assistance Engineer can forward an invoice for payment to the Department's Local Programs Accounting Office for reimbursable work for funds that are going to revert at the end of a particular fiscal year is May 15th of the particular fiscal year. Notwithstanding the unliquidated sums of project specific State and Federal funding remaining and available to fund project work, any invoice for reimbursement involving applicable funds that is not received by the Department's Local Programs Accounting Office at least 45 days prior to the applicable fixed fund Reversion Date will not be paid. These unexpended funds will be irrevocably reverted by the Department's Division of Accounting on the applicable fund Reversion Date.

H. As a condition for receiving federal-aid highway funds for the PROJECT, the Administering Program Supplement 12-5237F15-F029-R2- ISTEA Page 5 of 9

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ATPCML-5237(033)
Agency certifies that NO members of the elected board, council, or other key decision makers are on the Federal Government Exclusion List. Exclusions can be found at www.sam.gov.

4. A. ADMINISTERING AGENCY shall conform to all State statutes, regulations and procedures (including those set forth in the Local Assistance Procedures Manual and the Local Assistance Program Guidelines, hereafter collectively referred to as "LOCAL ASSISTANCE PROCEDURES") relating to the federal-aid program, all Title 23 Code of Federal Regulation (CFR) and 2 CFR Part 200 federal requirements, and all applicable federal laws, regulations, and policy and procedural or instructional memoranda, unless otherwise specifically waived as designated in the executed project-specific PROGRAM SUPPLEMENT.

B. Invoices shall be formatted in accordance with LOCAL ASSISTANCE PROCEDURES.

C. ADMINISTERING AGENCY must have at least one copy of supporting backup documentation for costs incurred and claimed for reimbursement by ADMINISTERING AGENCY. ADMINISTERING AGENCY agrees to submit supporting backup documentation with invoices if requested by State. Acceptable backup documentation includes, but is not limited to, agency's progress payment to the contractors, copies of cancelled checks showing amounts made payable to vendors and contractors, and/or a computerized summary of PROJECT costs.

D. Indirect Cost Allocation Plan/Indirect Cost Rate Proposals (ICAP/ICRP), Central Service Cost Allocation Plans and related documentation are to be prepared and provided to STATE (Caltrans Audits & Investigations) for review and approval prior to ADMINISTERING AGENCY seeking reimbursement of indirect costs incurred within each fiscal year being claimed for State and federal reimbursement. ICAPs/ICRPs must be prepared in accordance with the requirements set forth in 2 CFR, Part 200, Chapter 5 of the Local Assistance Procedural Manual, and the ICAP/ICRP approval procedures established by STATE.

E. STATE will withhold the greater of either two (2) percent of the total of all federal funds encumbered for each PROGRAM SUPPLEMENT or $40,000 until ADMINISTERING AGENCY submits the Final Report of Expenditures for each completed PROGRAM SUPPLEMENT PROJECT.

F. Payments to ADMINISTERING AGENCY for PROJECT-related travel and subsistence (per diem) expenses of ADMINISTERING AGENCY forces and its contractors and subcontractors claimed for reimbursement or as local match credit shall not exceed rates authorized to be paid rank and file STATE employees under current State Department of Personnel Administration (DPA) rules. If the rates invoiced by ADMINISTERING AGENCY are in excess of DPA rates, ADMINISTERING AGENCY is responsible for the cost difference, and any overpayments inadvertently paid by STATE shall be reimbursed to STATE by ADMINISTERING AGENCY on demand within thirty (30) days of such invoice.

G. ADMINISTERING AGENCY agrees to comply with 2 CFR, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards.

H. ADMINISTERING AGENCY agrees, and will assure that its contractors and Program Supplement 12-5237F15-F029-R2- ISTEA Page 6 of 9

SPECIAL COVENANTS OR REMARKS
12-ORA-0-BRE
ATPCML-5237(033)
subcontractors will be obligated to agree, that Contract Cost Principles and Procedures, 48 CFR, Federal Acquisition Regulations System, Chapter 1, Part 31, et seq., shall be used to determine the allowability of individual PROJECT cost items.

I. Every sub-recipient receiving PROJECT funds under this AGREEMENT shall comply with 2 CFR, Part 200, 23 CFR, 48 CFR Chapter 1, Part 31, Local Assistance Procedures, Public Contract Code (PCC) 10300-10334 (procurement of goods), PCC 10335-10381 (non-A&E services), and other applicable STATE and FEDERAL regulations.

J. Any PROJECT costs for which ADMINISTERING AGENCY has received payment or credit that are determined by subsequent audit to be unallowable under 2 CFR, Part 200, 23 CFR, 48 CFR, Chapter 1, Part 31, and other applicable STATE and FEDERAL regulations, are subject to repayment by ADMINISTERING AGENCY to STATE.

K. STATE reserves the right to conduct technical and financial audits of PROJECT WORK and records and ADMINISTERING AGENCY agrees, and shall require its contractors and subcontractors to agree, to cooperate with STATE by making all appropriate and relevant PROJECT records available for audit and copying as required by the following paragraph:

ADMINISTERING AGENCY, ADMINISTERING AGENCY'S contractors and subcontractors, and STATE shall each maintain and make available for inspection and audit by STATE, the California State Auditor, or any duly authorized representative of STATE or the United States all books, documents, papers, accounting records, and other evidence pertaining to the performance of such contracts, including, but not limited to, the costs of administering those various contracts and ADMINISTERING AGENCY shall furnish copies thereof if requested.

All of the above referenced parties shall make such AGREEMENT, PROGRAM SUPPLEMENT, and contract materials available at their respective offices at all reasonable times during the entire PROJECT period and for three (3) years from the date of submission of the final expenditure report by the STATE to the FHWA.

L. ADMINISTERING AGENCY, its contractors and subcontractors shall establish and maintain a financial management system and records that properly accumulate and segregate reasonable, allowable, and allocable incurred PROJECT costs and matching funds by line item for the PROJECT. The financial management system of ADMINISTERING AGENCY, its contractors and all subcontractors shall conform to Generally Accepted Accounting Principles, enable the determination of incurred costs at interim points of completion, and provide support for reimbursement payment vouchers or invoices set to or paid by STATE.

M. ADMINISTERING AGENCY is required to have an audit in accordance with the Single Audit Act of 2 CFR 200 if it expends $750,000 or more in Federal Funds in a single fiscal year of the Catalogue of Federal Domestic Assistance.

N. ADMINISTERING AGENCY agrees to include all PROGRAM SUPPLEMENTS adopting the terms of this AGREEMENT in the schedule of projects to be examined in ADMINISTERING AGENCY's annual audit and in the schedule of projects to be examined under its single audit prepared in accordance with 2 CFR, Part 200.

Program Supplement 12-5237F15-F029-R2- ISTEA Page 7 of 9

SPECIAL COVENANTS OR REMARKS
12-ORA-0-BRE
ATPCML-5237(033)
O. ADMINISTERING AGENCY shall not award a non-A&E contract over $5,000, construction contracts over $10,000, or other contracts over $25,000 [excluding professional service contracts of the type which are required to be procured in accordance with Government Code sections 4525 (d), (e) and (f)] on the basis of a noncompetitive negotiation for work to be performed under this AGREEMENT without the prior written approval of STATE. Contracts awarded by ADMINISTERING AGENCY, if intended as local match credit, must meet the requirements set forth in this AGREEMENT regarding local match funds.

P. Any subcontract entered into by ADMINISTERING AGENCY as a result of this AGREEMENT shall contain provisions B, C, F, H, I, K, and L under Section 2 of this agreement.

5. Appendix E of the Title VI Assurances (US DOT Order 1050.2A) During the performance of this agreement, the ADMINISTERING AGENCY, ADMINISTERING AGENCY'S contractors and subcontractor, (hereinafter referred to as the "contractor") agrees to comply with the following nondiscrimination statutes and authorities; including but not limited to:

Pertinent Nondiscrimination Authorities:

A. Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d et seq., 78 stat. 252), (prohibits discrimination on the basis of race, color, national origin); and 49 CFR Part 21.

B. The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, (42 U.S.C. 4601), (prohibits unfair treatment of persons displaced or whose property has been acquired because of Federal or Federal-aid programs and projects); C. Federal-Aid Highway Act of 1973, (23 U.S.C. 324 et seq.), (prohibits discrimination on the basis of sex);
D. Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. 794 et seq.), as amended, (prohibits discrimination on the basis of disability); and 49 CFR Part 27; E. The Age Discrimination Act of 1975, as amended, (42 U.S.C. 6101 et seq.), (prohibits discrimination on the basis of age);
F. Airport and Airway Improvement Act of 1982, (49 U.S.C. 4 71, Section 4 7123), as amended, (prohibits discrimination based on race, creed, color, national origin, or sex); G. The Civil Rights Restoration Act of 1987, (PL 100-209), (Broadened the scope, coverage and applicability of Title VI of the Civil Rights Act of 1964, The Age Discrimination Act of 1975 and Section 504 of the Rehabilitation Act of 1973, by expanding the definition of the terms "programs or
activities" to include all of the programs or activities of the Federal-aid recipients, subrecipients and contractors, whether such programs or activities are Federally funded or not);
H. Titles II and III of the Americans with Disabilities Act, which prohibit discrimination on the basis of disability in the operation of public entities, public and private transportation systems, places of public accommodation, and certain testing entities (42 U.S.C. 12131-12189) as implemented by Department of Transportation regulations at 49 C.F.R. parts 37 and 38; Program Supplement 12-5237F15-F029-R2- ISTEA Page 8 of 9

SPECIAL COVENANTS OR REMARKS
12-ORA-0-BRE
ATPCML-5237(033)
I. The Federal Aviation Administration's Nondiscrimination statute (49 U.S.C. 47123) (prohibits discrimination on the basis of race, color, national origin, and sex); J. Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency, and resulting agency guidance, national origin discrimination includes discrimination because of limited English proficiency (LEP). To ensure compliance with Title VI, you must take reasonable steps to ensure that LEP persons have meaningful access to your programs (70 Fed. Reg. at 74087 to 74100);
K. Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating because of sex in education programs or activities (20 U.S.C. 1681 et seq).

Program Supplement 12-5237F15-F029-R2- ISTEA Page 9 of 9

5237033 PSA R2
Final Audit Report 2026-07-22
Created: 2026-07-22
By: Gregory Nannini ([email protected])
Status: Signed
Transaction ID: CBJCHBCAABAAw2W0qsiKbqTjrodQTSbUe9BQISO8SAR- "5237033 PSA R2" History
Document created by Gregory Nannini ([email protected]) 2026-07-22 - 6:01:25 PM GMT- IP address: 149.136.17.253 Document emailed to Ferdinand Batatan ([email protected]) for signature 2026-07-22 - 6:01:54 PM GMT
Email viewed by Ferdinand Batatan ([email protected]) 2026-07-22 - 6:20:54 PM GMT- IP address: 149.136.17.248 Signer Ferdinand Batatan ([email protected]) entered name at signing as Ferdinand A. Batatan 2026-07-22 - 6:22:00 PM GMT- IP address: 149.136.17.248 Document e-signed by Ferdinand A. Batatan ([email protected]) Signature Date: 2026-07-22 - 6:22:02 PM GMT - Time Source: server- IP address: 149.136.17.248 - Signature Appearance Selected: TYPE Agreement completed.
2026-07-22 - 6:22:02 PM GMT

FINANCE LETTER
07/22/202612-ORA-0-BREATPCML-5237(033)1214000048
DEPARTMENT OF TRANSPORTATIONTo: City of Brea
Date:

D_CO_RT:

Project No:

Adv. Project Id:

Project End Date: 12/31/2028
EA No:

Est Tot Proj Costs: $20,952,000

PRO RATA OR

LUMP SUM

FINANCE ITEMS FEDERAL STATE (ATP) LOCAL
Agency Preliminary Engineering Pro Rata $267,706.00 $267,706.00 88.53% $237,000.00 $0.00 $0.00 $0.00 $30,706.00 $0.00 Right of Way Pro Rata $9,098,494.00 $6,563,876.00 88.53% $0.00 $5,811,000.00 $0.00 $0.00 $752,876.00 $2,534,618.00Right of Way $2,656,000.00 $2,656,000.00 0.00% $0.00 $0.00 $0.00 $1,787,000.00 $869,000.00 $0.00Right of Way Pro Rata $107,500.00 $107,500.00 79.65% $0.00 $0.00 $85,624.00 $0.00 $21,876.00 $0.00 Totals: $12,129,700.00 $9,595,082.00 $237,000.00 $5,811,000.00 $85,624.00 $1,787,000.00 $1,674,458.00 $2,534,618.00 FEDERAL PART.

COST
OTHER (NONPARTICIPATING) TOTAL COST OF FED. REIMB % WORK FEDERAL FEDERAL M400 Y400 RPS8
Participation Ratio: 79.1% This Finance Letter was created based on specific financial information provided by the responsible local agency. The following encumbrance history is prepared by Local Assistance Accounting Office and is provided here for local agency's information and action.

Signature:

Title: HQ Sr. Area Engineer
Req #1: CTC allocated $1,787,000 of State Only Fund ATP for RW at the March 22-23, 2023 meeting. PPNo. 12-1303.Note: This PROJECT is subject to the Timely Use of Funds (TUF) provisions enacted by the Active Transportation Program guidelines, as adopted or amended, and by approved CTC andState procedures. Timely Use of Fund rules supersed the Federal Reversion Dates.Seq #1: This Finance Letter reflects the obligation of $237,000 (via EPSP of $137,000) for Preliminary Engineering using CMAQ funds programmed under ORA190906 for FY 23/24 & 24/25in Administrative Modification #23-25 approved on 04/17/2024 to SCAG's 2023 FTIP.Emission benefit reduction calculation: CO 0.486 kg/day, NOx 0.020 kg/day. PM2.5 0.002 kg/day, PM10 0.008 kg/day.Seq #2: This sequence reflects the obligation of $3,592,000 for Right of Way (Acq) using CMAQ funds under ORA190906 programmed in Amendment #25-01 approved on 12/20/2024 toSCAG's 2025 FTIP.Seq #3: This Finance Letter reflects the additional obligation of $2,304,624 for Right of Way (Acq) using CMAQ ( $2,219,000) & Earmark Repurpose ($85,624) funds under ORA190906programmed in Amendment #25-24 approved on 05/22/2026 to SCAG's 2025 FTIP. DEMO ID: CA130. (279 ) 599-2032
Printed Name: Ferdinand A. Batatan
Telephone No:

Remarks: _________________________________ Page 1 of 2
Ferdinand
A
. Batatan
(Jul 22
, 2026
1 1
:20
:39 PDT
)
Ferdinand
A
. Batatan

FINANCE LETTER
07/22/202612-ORA-0-BREATPCML-5237(033)1214000048
DEPARTMENT OF TRANSPORTATIONTo: City of Brea
Date:

D_CO_RT:

Project No:

Adv. Project Id:

Project End Date: 12/31/2028
EA No:

Est Tot Proj Costs: $20,952,000
ADV. PROJECT ID APPROP. UNIT STATE PROG. FED/ STATE ENCUMBRANCE AMOUNT APPROP YEAR EXPENDITURE AMOUNT ENCUMBRANCE BALANCE REVERSION DATE* APPROVED AMOUNT EXPIRATION DATE Cooperative Work Agreement ACCOUNTING INFORMATION ATPCML-5237(033) 1214000048 26102F 2030010680 F $85,624.00 2526 $0.00 $85,624.00 06/30/20311214000048 26102F 2030010820 F $2,219,000.00 2526 $0.00 $2,219,000.00 06/30/20311214000048 25102F 2030010820 F $3,592,000.00 2425 $0.00 $3,592,000.00 06/30/20301214000048 24102F 2030010820 F $237,000.00 2324 $19,970.80 $217,029.20 06/30/20291214000048 22102 2030720100 $1,787,000.00 2122 $0.00 $1,787,000.00 06/30/2027 *Please submit invoices to the appropriate Districts by April 1st to avoid funds lapsing on the June 30th reversion date listed above and to allow sufficient timefor Accounting and SCO year-end closing procedures. *Please refer to the applicable CTC Guidelines for Timely Use of Funds (TUF) Provisions. Also refer to your allocation notification letter(s) for allocation-specific TUF deadlines.

ALLOCATION
DATE
(Cost Incurred) CONTRACT
AWARD

COMPLETION PROJECT

END DATE

ALLOCATION
AMOUNT
FED/

PPNO PHASE STATE
Timely Use of Funds (TUF) Dates Fed Funds

ALLOCATION INFORMATION ALLOCATION DEADLINES
Allocations Information – Allocation Deadlines (Data excludes extensions and funding shifts)

EXPENDITURE

DEPARTMENT OF TRANSPORTATION

PROJECT DEADLINES
Date:

D_CO_RT:

Project No:

Adv. Project Id:

PPNO:

Agency:
07/22/2026ATPCML-5237(033)12-13031214000048
5237 Brea
12-ORA-0-BRE
Project End Date: 12/31/2028

PSA REQMT

LAST INVOICING

OPPORTUNITY ACTION
03/23/2023 CTC 12-1303 ROW S $1,787,000.00 06/30/2025 12/27/2025 12/31/2028 * The Project Deadline/Allocation Information table reflects the amount(s) originally allocated by the CTC. See the current finance letter for the correspondingencumbrance amounts after any required federal obligation.* Allocation funding shifts (if any) are reflected on the Finance Letter. Note, If any "Const" Allocation is divided between CON and CE, it must be separated on thefinance letter.* Please refer to the applicable CTC Guidelines for Timely Use of Funds (TUF) provisions. Also refer to your allocation notification letter(s) for allocation-specificdeadlines/extensions. .. 5237033 S3 FL 07.22.2026
Final Audit Report 2026-07-22
Created: 2026-07-22
By: Gregory Nannini ([email protected])
Status: Signed
Transaction ID: CBJCHBCAABAA6SOcrbu8dvpMUh9ILo4OldrYh4cpyp9V "5237033 S3 FL 07.22.2026" History
Document created by Gregory Nannini ([email protected]) 2026-07-22 - 6:02:08 PM GMT- IP address: 149.136.17.253 Document emailed to Ferdinand Batatan ([email protected]) for signature 2026-07-22 - 6:02:47 PM GMT
Email viewed by Ferdinand Batatan ([email protected]) 2026-07-22 - 6:18:53 PM GMT- IP address: 149.136.17.248 Signer Ferdinand Batatan ([email protected]) entered name at signing as Ferdinand A. Batatan 2026-07-22 - 6:20:37 PM GMT- IP address: 149.136.17.248 Document e-signed by Ferdinand A. Batatan ([email protected]) Signature Date: 2026-07-22 - 6:20:39 PM GMT - Time Source: server- IP address: 149.136.17.248 - Signature Appearance Selected: TYPE Agreement completed.
2026-07-22 - 6:20:39 PM GMT

FOUND 9 PROJECTS
2025 Federal Transportation Improvement Program
Administrative Modification #25-28
Orange County
Project Listing
(in $000`s)

FTIP ID LEAD AGENCY COUNTY CONFORM CATEGORY AIR BASIN SYSTEM

MODELING

PROJECT COST

FTIP AMENDMENT
RTP ID
ORA190906 Brea, City of Orange TCM Committed SCAB $20,952 2L220 Local 25-28

PROJECT LIMITS
NCN26 - BICYCLE FACILITY-NEW From North Palm Street to Brea Canyon Channel

PRIMARY PROGRAM CODE
SCAG_APPROVED
N/A
STATE_APPROVED
N/A
FEDERAL_APPROVED
OC Loop Segment B - Brea Gap Closure - Class I, 1.30-mile bikeway along the existing railroad ROW between North Palm Street and the Brea Canyon Channel in the City of Brea.

DESCRIPTION
PHASE FUND SOURCE PRIOR 24/25 25/26 26/27 27/28 28/29 29/30 FUTURE TOTAL PE CITY - City Funds $88 $0 $0 $0 $0 $0 $0 $0 $88
PE CMAQ - Congestion
Mitigation Air Quality
$237 $0 $0 $0 $0 $0 $0 $0 $237
PE S-PARK - State Park
Funds
$225 $0 $0 $0 $0 $0 $0 $0 $225
ROW 2022

APPROPRIATIONS
$2,000 $0 $0 $0 $0 $0 $0 $0 $2,000
ROW ATP - Active
Transportation Program
$1,787 $0 $0 $0 $0 $0 $0 $0 $1,787
ROW CITY - City Funds $0 $718 $255 $0 $0 $0 $0 $0 $973
ROW CMAQ - Congestion
Mitigation Air Quality
$0 $3,592 $2,219 $0 $0 $0 $0 $0 $5,811
ROW Earmark Repurposing
FY 2025
$0 $0 $86 $0 $0 $0 $0 $0 $86
CON CITY - City Funds $0 $0 $0 $0 $505 $0 $0 $0 $505
CON CMAQ - Congestion
Mitigation Air Quality
$0 $0 $0 $0 $1,320 $0 $0 $0 $1,320
CON STBG-C2 $0 $0 $0 $0 $1,771 $0 $0 $0 $1,771
CON STIP AC RIP $0 $0 $0 $0 $0 $0 $6,149 $0 $6,149
TOTAL TOTAL $4,337 $4,310 $2,560 $0 $3,596 $0 $6,149 $0 $20,952

FTIP ID LEAD AGENCY COUNTY CONFORM CATEGORY AIR BASIN SYSTEM

MODELING

PROJECT COST

FTIP AMENDMENT
RTP ID
ORA230804 Various Agencies Orange EXEMPT - 93.126 SCAB $71,699 2L220 Local 25-28

PROJECT LIMITS
LUM04 - TRANS. ENHANCEMT ACTIVITIES- ELIGIBLE ITEMS
ONLY
From Various to Various

PRIMARY PROGRAM CODE
SCAG_APPROVED
N/A
STATE_APPROVED
N/A
FEDERAL_APPROVED
Grouped Projects for Bicycle and pedestrian facilities. Projects are consistent with 40 CFR Part 93.126 Exempt Tables 2 and Table 3 categories - Bicycle and pedestrian facilities (both motorized and non-motorized).

DESCRIPTION
PHASE FUND SOURCE PRIOR 24/25 25/26 26/27 27/28 28/29 29/30 FUTURE TOTAL CON CITY - City Funds $465 $2,003 $2,803 $4,419 $560 $1,526 $0 $0 $11,776 CON CMAQ - Congestion
Mitigation Air Quality
$0 $2,608 $2,960 $32 $0 $0 $0 $0 $5,600
CON CMAQ-C2 $0 $0 $0 $14,723 $2,816 $2,083 $0 $0 $19,622 CON STBG-C2 $0 $0 $0 $11,722 $1,294 $6,516 $0 $0 $19,532 CON STPL-R - STP Local
Regional
$1,215 $4,749 $5,411 $3,794 $0 $0 $0 $0 $15,169
TOTAL TOTAL $1,680 $9,360 $11,174 $34,690 $4,670 $10,125 $0 $0 $71,699

FTIP ID LEAD AGENCY COUNTY CONFORM CATEGORY AIR BASIN SYSTEM

MODELING

PROJECT COST

FTIP AMENDMENT
RTP ID
ORA270002 Various Agencies Orange EXEMPT - 93.126 SCAB $48,992 7120001 Local 25-28

PROJECT LIMITS
LUM02 - REHABILITATION AND RECONSTRUCTION From Various to Various

PRIMARY PROGRAM CODE
SCAG_APPROVED
N/A
STATE_APPROVED
N/A
FEDERAL_APPROVED
Grouped Projects for STBG/CMAQ Call Local System Rehab Projects - Projects are consistent with 40 CFR Part 93.126 Exempt Tables 2 and Table 3 categories - Pavement resurfacing and/or rehabilitation

DESCRIPTION

CITYofBREA
City Council Regular Meeting
Communication
August 18, 2026
Item No. 3N.

Monthly Report of Investments for the City of Brea for Period Ended July 31, 2026

TO PREPARED BY
Honorable Mayor and City Council Members Faith Madrazo, Financial Services Manager, Revenue

DEPARTMENT HEAD APPROVAL CITY MANAGER APPROVAL
Monica Lo, Administrative Services Director Kristin Webster, City Manager

RECOMMENDATION
Staff recommends that the City Council take the following action:

1. Receive and file the Monthly Report of Investments.

BACKGROUND/DISCUSSION
The current Monthly Report of Investments is prepared in accordance with Government Code Sections 41004 and 53607 and contains information on the City's investment activities for the month of July. On June 6, 2023, upon the recommendation of the Investment Advisory Committee, the City Council authorized the use of U.S. Treasury Bills and other short-term investments—referred to as the City’s Liquidity Account—as an alternative to the Local Agency Investment Fund (LAIF). The LAIF is used for short-term investments and functions like a savings account.

Whereas cash for day-to-day activities is deposited in Demand and Interest-Bearing checking accounts. This Liquidity Account was closed in July 2025, as LAIF had consistently outperformed it over several months. The remaining cash balance was subsequently transferred to the City’s main investment portfolio. The City’s investment portfolio is for long-term investments and is managed through Chandler Asset Management (Chandler).

Together, the short and long-term investment accounts represent the City’s investment portfolio.

Attachment A includes an Investment Information Summary and a Monthly Account Statement prepared by Chandler. The book value represents the cost of investments, plus or minus amortization/accretion. As of July 31, 2026, the total market value of the managed investment portfolio, including accrued interest, was $81,533,036 as compared to $91,639,372 at June 30, 2026. The weighted average investment yield for July 31, 2026 was 4.11%, which was sligthly lower than the prior month. The City’s LAIF had a total market value, including accrued interest, of $1,133,516 at July 31, 2026, which brings the total value of the City’s investment portfolio as of July 31, 2026, to $82,666,552, as compared to the balance of $115,720,578 at June 30, 2026.

The City has restricted cash and investments held in the post-employment benefits trust accounts for both Pension and Other Post Employment Benefits (OPEB), administered by PARS, which are managed by PFM Asset Management (PFM), and the City's various bond reserve accounts, which are managed by Chandler. Attachment A includes monthly statements from US Bank for the PARS accounts, as well as a portfolio report from Chandler for each bond reserve account that is invested. As of July 31, 2026, the market value of the PARS pension account, including short-term cash and accrued interest, was $14,811,442 as compared to $14,878,842 from the prior month. The OPEB account had a market value of $523,767 as compared to $526,842 from the prior month. All other restricted cash investments (bond reserve accounts), including short-term cash and accrued interest, were $684,825 in comparison to $682,795 from the prior month.

Pursuant to the City's investment policy, except for LAIF, direct time certificates of deposit, and money market mutual funds, all City investments are held by third-party custodians. The Bank of New York Mellon Trust Company, N.A. (BNY) holds accounts managed by Chandler, and US Bank holds the PARS accounts managed by PFM, which acts as an agent of the City. All securities are held in the name of the City of Brea. The City of Brea has sufficient cash flow to meet its expected expenditures for the next six months.

FISCAL IMPACT/SUMMARY
In July, the City’s managed investment portfolio decreased by $33,054,026. This decrease was primarily attributable to annual operating and one-time expenditures, including the Unfunded Accrued Liability (UAL) payment of $15.5 million, water purchases in excess of entitlement totaling $3.34 million, annual insurance premiums of $1.8 million, progress payments of $985,000 for the Arovista Park renovation project, water consumption and connection fees of $880,000, and golf course management and incentive payments of $631,000.

In addition, the City withdrew $10 million from its investment portfolio to provide sufficient operating cash over the next several months.

The City's PARS investment accounts decreased by $70,475 during the month, primarily due to weakness in the equity markets, which was partially offset by modest gains in the fixed-income portfolio. Despite the monthly decline, the PARS portfolio continues to generate strong year-to-date returns. Additionally, bond reserve account balances increased by $2,030 during the month.

Attachments
Attachment A - City - July 2026.pdf
City of Brea
Cash and Investment Information
Book Market
Value Value*
Demand and Interest-Bearing Checking Accounts Citizen's Bank $ 13,600,487.84 $ 13,600,487.84 Local Agency Investment Fund LAIF $ 1,078,928.83 $ 1,133,515.91 Managed Investment Portfolio - CHANDLER Chandler/BNY $ 81,779,890.39 $ 81,533,036.39 PARS Post-Employment Benefits Trust - Pension** PFM/US Bank $ 12,852,045.42 $ 14,811,441.57 PARS Post-Employment Benefits Trust - OPEB** PFM/US Bank $ 473,840.63 $ 523,767.18 Fiscal Agent Cash & Investments**
2017 Brea Plaza Public Improvements CFD Bonds (CFD 2008-2) Chandler/BNY $ 684,771.51 $ 682,736.83 2019 Olinda Ranch Public Improvements CFD Bonds (CFD 1997-1) Chandler/BNY $ 253.54 $ 253.54 2019 Water Revenue Bonds Chandler/BNY $ 902.97 $ 902.97 2020 Water Revenue Refunding Bonds Chandler/BNY $ 573.16 $ 573.16 2021 Lease Revenue Refunding Bonds Chandler/BNY $ 358.41 $ 358.41 Sub-total - Fiscal Agent Cash & Investments $ 686,859.59 $ 684,824.91 Report Grand Total $ 110,472,052.70 $ 112,287,073.80
* Includes accrued interest on invested funds
** Reserve Fund
July 31, 2026
ATTACHMENT A Page 1 of 186
City of Brea
Cash and Investment Information
Fiscal Agent Cash & Investments Detail
10600 2017 Brea Plaza Public Improvements CFD Bonds (CFD 2008-2) - CHANDLER $ 671,407.80 $ 669,373.12 Short-Term Treasury Funds - BNY $ 13,363.71 $ 13,363.71 Sub-total $ 684,771.51 $ 682,736.83
2019 Olinda Ranch Public Improvements Bonds (CFD 1997-1) - CHANDLER $ - $ - Short-Term Treasury Funds - BNY $ 253.54 $ 253.54
Sub-total $ 253.54 $ 253.54
2019 Water Revenue Bonds - CHANDLER $ - $ -
Short-Term Treasury Funds - BNY $ 902.97 $ 902.97
Sub-total $ 902.97 $ 902.97
2020 Water Revenue Refunding Bonds - CHANDLER $ - $ -
Short-Term Treasury Funds - BNY $ 573.16 $ 573.16
Sub-total $ 573.16 $ 573.16
Report Grand Total $ 686,859.59 $ 684,824.91
Book
Value
Market
Value
July 31, 2026
ATTACHMENT A Page 2 of 186

MONTHLY ACCOUNT STATEMENT
City of Brea LAIF | Account #10164 | As of July 31, 2026 CHANDLER ASSET MANAGEMENT | chandlerasset.com
Information contained herein is confidential. We urge you to compare this statement to the one you receive from your qualified custodian. Please see Important Disclosures at the end of the statement.

Chandler Team:

For questions about your account, please call (800) 317-4747, or contact [email protected]
Custodian:

ATTACHMENT A Page 3 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

PORTFOLIO SUMMARY
Portfolio Characteristics
Sector Allocation
Performance Review
Account Summary
Maturity Distribution
Top Issuers
Credit Quality*
Total Rate of Return** 1M 3M YTD 1YR 2YRS 3YRS 5YRS 10YRS Since Inception (03/01/12)
City of Brea LAIF 0.37% 1.05% 2.36% 4.23% 4.43% 4.40% 3.23% 2.33% 1.71% Average Modified Duration 0.00
Average Coupon 3.66%
Average Purchase YTM 3.85%
Average Market YTM 3.85%
Average Credit Quality* AAA
Average Final Maturity 0.00
Average Life 0.00
End Values as of
06/30/2026
End Values as of
07/31/2026
Market Value 24,081,206.18 1,133,515.91
Accrued Interest 0.00 0.00
Total Market Value 24,081,206.18 1,133,515.91
Income Earned 0.00 202,564.89
Cont/WD 2,500,000.00 (23,000,000.00)
Par 24,081,206.18 1,133,515.91
Book Value 24,081,206.18 1,133,515.91
Cost Value 24,081,206.18 1,133,515.91
LAIF 95.18%
**Periods over 1 year are annualized.

Benchmark: NO BENCHMARK REQUIRED
*The average credit quality is a weighted average calculation of the highest of S&P, Moody’s and Fitch.

ATTACHMENT A Page 4 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

RECONCILIATION SUMMARY
Accrual Activity Summary
Fair Market Activity Summary
Month to Date Fiscal Year to Date
(07/01/2026)
Beginning Book Value 24,081,206.18 24,081,206.18
Maturities/Calls 0.00 0.00
Principal Paydowns 0.00 0.00
Purchases 202,564.89 202,564.89
Sales (23,000,000.00) (23,000,000.00)
Change in Cash, Payables, Receivables (150,255.16) (150,255.16) Amortization/Accretion 0.00 0.00
Realized Gain (Loss) 0.00 0.00
Ending Book Value 1,133,515.91 1,133,515.91
Month to Date Fiscal Year to Date
(07/01/2026)
Beginning Market Value 24,081,206.18 24,081,206.18
Maturities/Calls 0.00 0.00
Principal Paydowns 0.00 0.00
Purchases 202,564.89 202,564.89
Sales (23,000,000.00) (23,000,000.00)
Change in Cash, Payables, Receivables (150,255.16) (150,255.16) Amortization/Accretion 0.00 0.00
Change in Net Unrealized Gain (Loss) 0.00 0.00
Realized Gain (Loss) 0.00 0.00
Ending Market Value 1,133,515.91 1,133,515.91
Maturities / Calls
Month to Date 0.00
Fiscal Year to Date 0.00
Principal Paydowns
Month to Date 0.00
Fiscal Year to Date 0.00
Purchases
Month to Date 202,564.89
Fiscal Year to Date 202,564.89
Sales
Month to Date (23,000,000.00)
Fiscal Year to Date (23,000,000.00)
Interest Received
Month to Date 202,564.89
Fiscal Year to Date 202,564.89
Purchased / Sold Interest
Month to Date 0.00
Fiscal Year to Date 0.00
ATTACHMENT A Page 5 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration
CASH
CCYUSD Receivable 54,587.08 -- 54,587.08
54,587.08

1.00 54,587.08

0.00 4.82%

0.00 Aaa/AAA
AAA

0.00 0.00
Total Cash 54,587.08
54,587.08
54,587.08

1.00 54,587.08

0.00 4.82%

0.00 0.00

0.00 LAIF
90LAIF$00 Local Agency Investment Fund
State Pool 1,078,928.83 --3.85%
1,078,928.83
1,078,928.83

1.00 3.85%
1,078,928.83

0.00 95.18%

0.00 NA/NA
NA

0.00 0.00
Total LAIF 1,078,928.83 3.85%
1,078,928.83
1,078,928.83

1.00 3.85%
1,078,928.83

0.00 95.18%

0.00 0.00

0.00 Total Portfolio 1,133,515.91 3.85%
1,133,515.91
1,133,515.91

1.00 3.85%
1,133,515.91

0.00 100.00%

0.00 0.00

0.00 Total Market Value
+ Accrued 1,133,515.91
ATTACHMENT A Page 6 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss

ACQUISITIONS
Purchase 07/15/2026 90LAIF$00 202,564.89
Local Agency
Investment Fund State
Pool

1.000 3.84% (202,564.89) 0.00 (202,564.89) 0.00
Total Purchase 202,564.89 (202,564.89) 0.00 (202,564.89) 0.00 TOTAL
ACQUISITIONS 202,564.89 (202,564.89) 0.00 (202,564.89) 0.00

DISPOSITIONS
Sale 07/09/2026 90LAIF$00 (5,000,000.00)
Local Agency
Investment Fund State
Pool

1.000 3.84% 5,000,000.00 0.00 5,000,000.00 0.00
Sale 07/23/2026 90LAIF$00 (18,000,000.00)
Local Agency
Investment Fund State
Pool

1.000 3.85% 18,000,000.00 0.00 18,000,000.00 0.00
Total Sale (23,000,000.00) 23,000,000.00 0.00 23,000,000.00 0.00 TOTAL
DISPOSITIONS (23,000,000.00) 23,000,000.00 0.00 23,000,000.00 0.00 OTHER

TRANSACTIONS
Cash Transfer 07/09/2026 CCYUSD (5,000,000.00) Cash 0.00% (5,000,000.00) 0.00 (5,000,000.00) 0.00 Cash Transfer 07/23/2026 CCYUSD (18,000,000.00) Cash 0.00% (18,000,000.00) 0.00 (18,000,000.00) 0.00 Total Cash
Transfer (23,000,000.00) (23,000,000.00) 0.00 (23,000,000.00) 0.00 Dividend 07/15/2026 90LAIF$00 0.00
Local Agency
Investment Fund State
Pool

3.84% 5,139.04 0.00 5,139.04 0.00
Total Dividend 0.00 5,139.04 0.00 5,139.04 0.00

TOTAL OTHER
TRANSACTIONS (23,000,000.00) (22,994,860.96) 0.00 (22,994,860.96) 0.00 ATTACHMENT A Page 7 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income

CASH & EQUIVALENTS
CCYUSD Receivable
54,587.08
204,842.24

0.00 0.00
54,587.08

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 Total Cash & Equivalents 54,587.08
204,842.24

0.00 0.00
54,587.08

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00 0.00
LAIF
90LAIF$00 Local Agency Investment
Fund State Pool 1,078,928.83
23,876,363.94
202,564.89
(23,000,000.00)
1,078,928.83

0.00 202,564.89

0.00 202,564.89

0.00 0.00

0.00 202,564.89
202,564.89
Total LAIF 1,078,928.83
23,876,363.94
202,564.89
(23,000,000.00)
1,078,928.83

0.00 202,564.89

0.00 202,564.89

0.00 0.00

0.00 202,564.89 202,564.89
TOTAL PORTFOLIO 1,133,515.91
24,081,206.18
202,564.89
(23,000,000.00)
1,133,515.91

0.00 202,564.89

0.00 202,564.89

0.00 0.00

0.00 202,564.89 202,564.89
ATTACHMENT A Page 8 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount OCTOBER 2026
10/15/2026 Dividend 90LAIF$00 1,078,928.83 Local Agency Investment Fund State Pool 54,587.08 54,587.08 October 2026 Total 54,587.08 54,587.08
Grand Total 1,078,928.83 54,587.08 54,587.08
ATTACHMENT A Page 9 of 186
City of Brea LAIF | Account #10164 | As of July 31, 2026 Execution Time: 08/06/2026 08:47:12 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

IMPORTANT DISCLOSURES
Chandler Asset Management, Inc. (“Chandler”) is an SEC registered investment adviser. For additional information about our firm, please see our current disclosures (Form ADV).

To obtain a copy of our current disclosures, you may contact your client service representative by calling the number on the front of this statement or you may visit our website at www.chandlerasset.com.

Information contained in this monthly statement is confidential and is provided for informational purposes only and should not be construed as specific investment or legal advice. The information contained herein was obtained from sources believed to be reliable as of the date of this statement, but may become outdated or superseded at any time without notice.

Custody: Your qualified custodian bank maintains control of all assets reflected in this statement and we urge you to compare this statement to the one you receive from your qualified custodian. Chandler does not have any authority to withdraw or deposit funds from/to the custodian account.

Valuation: Prices are provided by IDC, an independent pricing source. In the event IDC does not provide a price or if the price provided is not reflective of fair market value, Chandler will obtain pricing from an alternative approved third party pricing source in accordance with our written valuation policy and procedures. Our valuation procedures are also disclosed in Item 5 of our Form ADV Part 2A.

Performance: Performance results are presented gross-of-advisory fees and represent the client’s Total Return. The deduction of advisory fees lowers performance results. These results include the reinvestment of dividends and other earnings. Past performance may not be indicative of future results. Therefore, clients should not assume that future performance of any specific investment or investment strategy will be profitable or equal to past performance levels. All investment strategies have the potential for profit or loss. Economic factors, market conditions or changes in investment strategies, contributions or withdrawals may materially alter the performance and results of your portfolio.

Source ICE Data Indices, LLC (“ICE”), used with permission. ICE PERMITS USE OF THE ICE INDICES AND RELATED DATA ON AN “AS IS” BASIS; ICE, ITS AFFILIATES AND

THEIR RESPECTIVE THIRD PARTY SUPPLIERS DISCLAIM ANY AND ALL WARRANTIES AND REPRESENTATIONS, EXPRESS AND/OR IMPLIED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE, INCLUDING THE INDICES, INDEX DATA AND ANY DATA INCLUDED IN, RELATED TO, OR DERIVED THEREFROM.

NEITHER ICE DATA, ITS AFFILIATES OR THEIR RESPECTIVE THIRD PARTY PROVIDERS GUARANTEE THE QUALITY, ADEQUACY, ACCURACY, TIMELINESS OR COMPLETENESS OF THE INDICES OR THE INDEX DATA OR ANY COMPONENT THEREOF, AND THE INDICES AND INDEX DATA AND ALL COMPONENTS THEREOF ARE PROVIDED ON AN “AS IS” BASIS AND LICENSEE’S USE IS AT LICENSEE’S OWN RISK. ICE DATA, ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY DO NOT SPONSOR, ENDORSE, OR RECOMMEND CHANDLER, OR ANY OF ITS PRODUCTS OR SERVICES.

Index returns assume reinvestment of all distributions. Historical performance results for investment indexes generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment management fee, the incurrence of which would have the effect of decreasing historical performance results. It is not possible to invest directly in an index.

Ratings: Ratings information have been provided by Moody’s, S&P and Fitch through data feeds we believe to be reliable as of the date of this statement, however we cannot guarantee its accuracy.

Security level ratings for U.S. Agency issued mortgage-backed securities (“MBS”) reflect the issuer rating because the securities themselves are not rated. The issuing U.S. Agency guarantees the full and timely payment of both principal and interest.

LGIP Yields: Reported yields for local government investment pools may be presented as either the 30-day yield or the monthly distribution yield, as applicable. For certain funds, the 30-day yield is calculated using reported daily yield data. Yield calculations are subject to change and may not be directly comparable across funds.

LAIF Yields: Additional Disclosure for CA Clients - As a result of a reporting lag from the Local Agency Investment Fund (LAIF), reported LAIF yields represent the most recently available Daily Effective Yield and may reflect data from approximately 7–10 days prior to month-end.

ATTACHMENT A Page 10 of 186

MONTHLY ACCOUNT STATEMENT
City of Brea | Account #120 | As of July 31, 2026
CHANDLER ASSET MANAGEMENT | chandlerasset.com
Information contained herein is confidential. We urge you to compare this statement to the one you receive from your qualified custodian. Please see Important Disclosures at the end of the statement.

Chandler Team:

For questions about your account, please call (800) 317-4747, or contact [email protected]
Custodian:

Bank of New York Mellon

ATTACHMENT A

City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

PORTFOLIO SUMMARY
Portfolio Characteristics
Sector Allocation
Performance Review
Account Summary
Maturity Distribution
Top Issuers
Credit Quality*
Total Rate of Return** 1M 3M YTD 1YR 2YRS 3YRS 5YRS 10YRS Since Inception (05/01/96)
City of Brea (0.11%) 0.07% 0.54% 3.09% 3.93% 4.56% 1.79% 1.95% 3.44% Benchmark Return (0.04%) 0.05% 0.39% 2.81% 3.59% 4.19% 1.44% 1.64% 3.12% Average Modified Duration 2.55
Average Coupon 3.86%
Average Purchase YTM 4.11%
Average Market YTM 4.47%
Average Credit Quality* AA
Average Final Maturity 3.06
Average Life 2.83
End Values as of
06/30/2026
End Values as of
07/31/2026
Market Value 90,931,350.97 80,907,564.72
Accrued Interest 708,021.14 625,471.67
Total Market Value 91,639,372.11 81,533,036.39
Income Earned 442,570.68 311,277.61
Cont/WD 0.00 (10,000,000.00)
Par 92,084,921.54 82,400,542.14
Book Value 91,387,383.83 81,779,890.39
Cost Value 91,053,494.15 81,506,738.38
United States 43.66%
Federal Home Loan Mortgage Corp 12.97%
Chase Issuance Trust 2.06%
American Express Credit Master Trust 1.87%
Hyundai Auto Receivables Trust 1.34%
Berkshire Hathaway Inc. 1.32%
Florida Power & Light 1.25%
Nat Rural Util Coop Fin Corp 1.24%
**Periods over 1 year are annualized.

Benchmark: ICE BofA 1-5 Year Unsubordinated US Treasury & Agency Index *The average credit quality is a weighted average calculation of the highest of S&P, Moody’s and Fitch.

ATTACHMENT A Page 12 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

RECONCILIATION SUMMARY
Accrual Activity Summary
Fair Market Activity Summary
Month to Date Fiscal Year to Date
(07/01/2026)
Beginning Book Value 91,387,383.83 91,387,383.83
Maturities/Calls 0.00 0.00
Principal Paydowns (159,237.65) (159,237.65)
Purchases 13,184,828.70 13,184,828.70
Sales (22,649,454.63) (22,649,454.63)
Change in Cash, Payables, Receivables 1,150.16 1,150.16 Amortization/Accretion 17,690.66 17,690.66
Realized Gain (Loss) (2,470.68) (2,470.68)
Ending Book Value 81,779,890.39 81,779,890.39
Month to Date Fiscal Year to Date
(07/01/2026)
Beginning Market Value 90,931,350.97 90,931,350.97
Maturities/Calls 0.00 0.00
Principal Paydowns (159,237.65) (159,237.65)
Purchases 13,184,828.70 13,184,828.70
Sales (22,649,454.63) (22,649,454.63)
Change in Cash, Payables, Receivables 1,150.16 1,150.16 Amortization/Accretion 17,690.66 17,690.66
Change in Net Unrealized Gain (Loss) (416,292.80) (416,292.80) Realized Gain (Loss) (2,470.68) (2,470.68)
Ending Market Value 80,907,564.72 80,907,564.72
Maturities / Calls
Month to Date 0.00
Fiscal Year to Date 0.00
Principal Paydowns
Month to Date (159,237.65)
Fiscal Year to Date (159,237.65)
Purchases
Month to Date 13,184,828.70
Fiscal Year to Date 13,184,828.70
Sales
Month to Date (22,649,454.63)
Fiscal Year to Date (22,649,454.63)
Interest Received
Month to Date 263,388.23
Fiscal Year to Date 263,388.23
Purchased / Sold Interest
Month to Date 112,748.19
Fiscal Year to Date 112,748.19
ATTACHMENT A Page 13 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration
ABS
36269WAD1 GMALT 2024-2 A3 5.39
07/20/2027 2,821.80 05/07/20245.85%
2,821.63
2,821.75
100.08

3.76%
2,824.00

4.65 0.00%

2.25 NA/AAA
AAA

0.97 0.05
58770JAD6 MBALT 2024-A A3 5.32
01/18/2028 138,775.82 05/17/20245.73%
138,759.59
138,769.32
100.32

3.95%
139,225.74
328.13

0.17%
456.42
Aaa/NA
AAA

1.47 0.23
362962AD4 GMALT 2025-2 A3 4.58
05/22/2028 440,000.00 05/20/20254.84%
439,992.70
439,995.58
100.19

4.29%
440,828.08
615.76

0.54%
832.50
NA/AAA
AAA

1.81 0.56
161571HT4 CHAIT 2023-1 A 5.16 09/15/2028 965,000.00 09/07/2023

5.23%
964,732.50
964,886.38
100.15

3.90%
966,447.50
2,213.07

1.19%
1,561.12
NA/AAA
AAA

2.13 0.11
437930AC4 HAROT 2024-2 A3 5.27
11/20/2028 176,330.45 05/14/20245.27%
176,309.02
176,319.47
100.56

4.25%
177,326.01
335.57

0.22%
1,006.54
NA/AAA
AAA

2.31 0.52
096919AD7 BMWOT 2024-A A3 5.18
02/26/2029 233,296.82 06/04/20245.18%
233,261.38
233,277.46
100.50

4.29%
234,461.67
201.41

0.29%
1,184.21
Aaa/AAA
NA

2.57 0.53
47786WAD2 JDOT 2024-B A3 5.2 03/15/2029 358,475.92 06/11/2024

5.81%
358,405.83
358,437.17
100.59

4.49%
360,573.36
828.48

0.45%
2,136.19
Aaa/NA
AAA

2.62 0.76
43813YAC6 HAROT 2024-3 A3 4.57
03/21/2029 413,756.15 08/09/20244.66%
413,691.15
413,718.74
100.20

4.28%
414,598.15
525.24

0.51%
879.41
Aaa/NA
AAA

2.64 0.60
02582JKH2 AMXCA 2024-1 A 5.23
04/16/2029 720,000.00 04/16/20245.30%
719,852.40
719,919.75
100.71

4.23%
725,132.88
1,673.60

0.90%
5,213.13
NA/AAA
AAA

2.71 0.67
05522RDJ4 BACCT 2024-1 A 4.93
05/15/2029 460,000.00 06/06/20244.93%
459,974.19
459,985.43
100.58

4.22%
462,648.68
1,007.91

0.57%
2,663.25
Aaa/AAA
NA

2.79 0.75
89240JAD3 TAOT 2025-A A3 4.64
08/15/2029 565,000.00 01/22/20254.69%
564,977.34
564,984.84
100.27

4.32%
566,519.29
1,165.16

0.70%
1,534.45
Aaa/NA
AAA

3.04 0.73
47800DAD6 JDOT 2025 A3 4.23 09/17/2029 460,000.00 03/04/2025

5.09%
459,971.07
459,979.97

99.74 4.47%
458,824.24
864.80

0.57%
(1,155.73)
Aaa/NA
AAA

3.13 1.29
92970QAE5 WFCIT 2024-2 A 4.29
10/15/2029 515,000.00 10/17/20244.29%
514,923.47
514,950.68

99.97 4.36%
514,825.42
981.93

0.64%
(125.26)
Aaa/AAA
NA

3.21 1.14
44935CAD3 HART 2025-A A3 4.32
10/15/2029 575,000.00 03/04/20254.84%
574,915.19
574,940.82
100.02

4.34%
575,093.73
1,104.00

0.71%
152.91
NA/AAA
AAA

3.21 0.86
437921AD1 HAROT 252 A3 4.15 10/15/2029 300,000.00 04/29/2025

4.15%
299,966.49
299,975.79

99.78 4.39%
299,342.70
553.33

0.37%
(633.09)
Aaa/NA
AAA

3.21 1.07
362955AD8 GMCAR 2025-1 A3 4.62
12/17/2029 363,113.26 01/09/20255.03%
363,086.28
363,094.73
100.26

4.28%
364,054.08
698.99

0.45%
959.35
Aaa/NA
AAA

3.38 0.67
58773DAD6 MBART 2025-1 A3 4.78
12/17/2029 545,000.00 01/14/20254.84%
544,884.08
544,920.04
100.38

4.34%
547,067.19
1,157.82

0.68%
2,147.14
Aaa/NA
AAA

3.38 0.78
ATTACHMENT A Page 14 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration
02582JKP4 AMXCA 2025-2 A 4.28
04/15/2030 790,000.00 05/06/20254.28%
789,985.70
789,989.24

99.81 4.44%
788,478.46
1,502.76

0.97%
(1,510.78)
NA/AAA
AAA

3.71 1.60
44935KAD5 HART 26B A3 4.51 02/18/2031 510,000.00 06/09/2026

4.86%
509,938.44
509,940.06

99.99 4.56%
509,968.89
1,022.27

0.63%

28.83 NA/AAA
AAA

4.55 2.17
161571JA3 CHAIT 2026-1 A 4.4 05/15/2029 700,000.00 05/21/2026

4.45%
699,834.38
699,844.32

99.69 4.56%
697,799.90
1,368.89

0.86%
(2,044.42)
NA/AAA
AAA

2.79 2.56
14041NGJ4 COMET 2026-1 A 4.48
07/16/2029 930,000.00 07/09/20264.53%
929,783.87
929,787.03

99.87 4.57%
928,830.99
1,736.00

1.15%
(956.04)
NA/AAA
AAA

2.96 2.70
Total ABS 10,161,570.21 4.83%
10,160,066.70
10,160,538.56
100.13

4.34%
10,174,870.93
19,889.75

12.58%
14,332.37

2.95 1.15
AGENCY
3133EPGW9

FEDERAL FARM CREDIT
BANKS FUNDING CORP 3.875
04/25/2028
950,000.00 05/05/2023

3.55%
963,775.00
954,806.82

99.35 4.26%
943,854.45
9,816.67

1.17%
(10,952.37)
Aa1/AA+
AA+

1.74 1.64
Total Agency 950,000.00 3.55%
963,775.00
954,806.82

99.35 4.26%
943,854.45
9,816.67

1.17%
(10,952.37)

1.74 1.64

AGENCY CMBS
3137BXQY1 FHMS K-064 A2 3.224
03/25/2027 1,000,000.00 05/06/20223.23%
997,929.69
999,749.91

99.37 4.13%
993,726.00
2,686.67

1.23%
(6,023.91)
Aa1/AAA
AA+

0.65 0.47
3137FEZU7 FHMS K-076 A2 3.9 04/25/2028 1,200,000.00 04/20/2023

4.12%
1,187,062.50
1,195,630.10

98.96 4.44%
1,187,538.00
3,900.00

1.47%
(8,092.10)
Aa1/AA+
AAA

1.74 1.53
3137H5YC5 FHMS K-748 A2 2.26 01/25/2029 1,500,000.00 03/25/2024

4.61%
1,350,820.31
1,424,209.86

94.72 4.57%
1,420,815.00
2,825.00

1.76%
(3,394.86)
Aa1/AA+
AAA

2.49 2.28
3137FLMV3 FHMS K-090 A2 3.422
02/25/2029 1,000,000.00 07/29/2024

4.46%
957,070.31
976,150.17

97.15 4.58%
971,507.00
2,851.67

1.20%
(4,643.17)
Aa1/AAA
AA+

2.57 2.35
3137FRUT6 FHMS K-106 A2 2.069
01/25/2030 1,000,000.00 06/06/20254.37%
905,039.06
928,765.04

91.87 4.63%
918,659.00
1,724.17

1.14%
(10,106.04)
Aa1/AA+
AAA

3.49 3.25
3137F83Q4 FHMS K-121 A2 1.547
10/25/2030 2,000,000.00 01/07/20263.98%
1,790,000.00
1,814,497.97

88.17 4.67%
1,763,348.00
2,578.33

2.18%
(51,149.97)
Aa1/AA+
AAA

4.24 3.98
3137HBC51 FHMS K-754 A2 4.94 11/25/2030 2,323,557.00 06/02/2026

4.38%
2,370,663.49
2,368,995.74
100.83

4.68%
2,342,884.35
9,565.31

2.90%
(26,111.40)
Aa1/AA+
AAA

4.32 3.76
3137FXZ35 FHMS K-127 A2 2.108
01/25/2031 1,000,000.00 02/03/20264.11%
910,937.50
919,694.48

89.75 4.68%
897,535.00
1,756.67

1.11%
(22,159.48)
Aa1/AA+
AAA

4.49 4.14
ATTACHMENT A Page 15 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration
Total Agency CMBS 11,023,557.00 4.19%
10,469,522.86
10,627,693.27

95.45 4.57%
10,496,012.35
27,887.81

12.97%
(131,680.92)

3.20 2.89
CASH
CCYUSD Receivable 1,624.63 -- 1,624.63
1,624.63

1.00 1,624.63

0.00 0.00%

0.00 Aaa/AAA
AAA

0.00 0.00
Total Cash 1,624.63
1,624.63
1,624.63

1.00 1,624.63

0.00 0.00%

0.00 0.00

0.00 CORPORATE
87612EBM7 TARGET CORP 1.95 01/15/2027 535,000.00 01/19/2022

1.99%
534,090.50
534,916.41

99.04 4.11%
529,873.10
463.67

0.65%
(5,043.31)
A2/A
NA

0.46 0.44
084664CZ2 BERKSHIRE HATHAWAY FINANCE
CORP 2.3 03/15/2027 1,080,000.00 03/07/20222.30%
1,079,794.80
1,079,974.60

98.92 4.10%
1,068,284.16
9,384.00

1.32%
(11,690.44)
Aa2/AA
A+

0.62 0.60
341081GT8 FLORIDA POWER & LIGHT CO

5.15 06/15/2029 1,000,000.00 06/13/20244.82%
1,013,864.64
1,007,769.86
101.41

4.62%
1,014,088.00
6,580.56

1.25%
6,318.14
Aa2/A+
AA2.872.48
713448FX1 PEPSICO INC 4.5 07/17/2029 830,000.00 07/15/2024

4.53%
828,713.50
829,238.39

99.97 4.51%
829,758.47
1,452.50

1.03%
520.08
A1/A+
NA

2.96 2.73
171239AL0 CHUBB INA HOLDINGS LLC 4.65
08/15/2029 505,000.00 08/12/2024

4.52%
507,853.00
506,714.98

99.79 4.72%
503,933.95
10,828.04

0.62%
(2,781.03)
A2/A
A

3.04 2.74
69371RT48 PACCAR FINANCIAL CORP 4.0
09/26/2029 600,000.00 --4.02%
599,541.65
599,710.84

98.43 4.54%
590,587.80
8,333.33

0.73%
(9,123.04)
A1/A+
NA

3.16 2.88
61748UAK8 MORGAN STANLEY 4.133
10/18/2029 695,000.00 10/17/20254.25%
695,087.10
695,064.53

98.45 4.79%
684,217.77
8,218.36

0.85%
(10,846.76)
A1/AA+3.22

2.06 38141GD27 GOLDMAN SACHS GROUP INC

4.153 10/21/2029 735,000.00 --4.29%
735,090.00
735,066.68

98.41 4.81%
723,332.61
8,479.04

0.89%
(11,734.07)
A2/BBB+
A

3.22 2.07
95000U4D2 WELLS FARGO & CO 4.182
01/23/2030 580,000.00 01/15/20264.24%
580,000.00
580,000.00

98.39 4.75%
570,659.68
539.01

0.71%
(9,340.32)
A1/BBB+
A+

3.48 2.31
63743HFX5

NATIONAL RURAL UTILITIES

COOPERATIVE FINANCE CORP

4.95 02/07/2030
1,000,000.00 --

4.88%
1,002,776.40
1,002,145.48
100.31

4.85%
1,003,124.00
23,925.00

1.24%
978.52
A2/NA
A

3.52 3.05
00287YDZ9 ABBVIE INC 4.875 03/15/2030 1,000,000.00 --

4.64%
1,009,826.00
1,007,382.46
100.29

4.79%
1,002,876.00
18,416.67

1.24%
(4,506.46)
A2/ANA3.62

3.15 571748CA8

MARSH & MCLENNAN
COMPANIES INC 4.65
03/15/2030
1,000,000.00 --

4.59%
1,002,366.00
1,001,785.23

99.28 4.87%
992,807.00
17,566.67

1.23%
(8,978.23)
A3/AA3.62

3.23 ATTACHMENT A Page 16 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration
743315AW3 PROGRESSIVE CORP 3.2
03/26/2030 1,000,000.00 11/14/20254.16%
962,050.00
968,184.06

94.55 4.85%
945,522.00
11,111.11

1.17%
(22,662.06)
A2/A
A

3.65 3.34
857477DB6 STATE STREET CORP 4.834
04/24/2030 1,000,000.00 --4.64%
1,008,346.00
1,006,346.03
100.14

4.79%
1,001,388.00
13,024.94

1.24%
(4,958.03)
Aa3/A
AA3.733.33
828807DK0 SIMON PROPERTY GROUP LP

2.65 07/15/2030 1,000,000.00 08/19/20254.32%
926,690.00
940,860.54

92.17 4.85%
921,718.00
1,177.78

1.14%
(19,142.54)
A3/A
NA

3.96 3.67
24422EYF0 JOHN DEERE CAPITAL CORP

4.375 10/15/2030 1,000,000.00 11/04/20254.21%
1,007,320.00
1,006,229.10

98.54 4.76%
985,404.00
12,881.94

1.22%
(20,825.10)
A1/A
A+

4.21 3.74
30303MAB8 META PLATFORMS INC 4.2
11/15/2030 750,000.00 11/12/2025

4.11%
753,000.00
752,569.99

96.92 5.01%
726,921.75
6,650.00

0.90%
(25,648.24)
Aa3/AANA4.29

3.83 717081FD0 PFIZER INC 4.2 11/15/2030 900,000.00 12/16/2025

4.10%
903,906.00
903,403.07

97.77 4.78%
879,943.50
7,980.00

1.09%
(23,459.57)
A2/A
NA

4.29 3.83
665859AY0 NORTHERN TRUST CORP 4.15
11/19/2030 850,000.00 11/12/20254.16%
849,583.50
849,641.66

97.53 4.79%
828,995.65
7,055.00

1.02%
(20,646.01)
A2/A+
A+

4.30 3.85
74456QCX2 PUBLIC SERVICE ELECTRIC AND
GAS CO 4.2 01/01/2031 750,000.00 01/06/20264.20%
749,970.00
749,973.40

97.28 4.89%
729,618.00
2,625.00

0.90%
(20,355.40)
A1/A
NA

4.42 3.96
14913UBH2 CATERPILLAR FINANCIAL
SERVICES CORP 4.15 01/08/2031 880,000.00 01/05/20264.16% 879,683.20
879,718.77

97.58 4.76%
858,740.08
2,333.22

1.06%
(20,978.69)
A1/A
A+

4.44 3.98
89236TPH2 TOYOTA MOTOR CREDIT CORP

4.2 01/10/2031 475,000.00 01/07/20264.21%
474,852.75
474,868.98

97.42 4.85%
462,724.10
1,163.75

0.57%
(12,144.88)
A1/A+
A+

4.45 3.98
756109AX2 REALTY INCOME CORP 3.25
01/15/2031 1,000,000.00 01/14/20264.27%
954,510.00
959,442.65

93.24 4.96%
932,435.00
1,444.44

1.15%
(27,007.65)
A3/ANA4.46

4.06 92826CAZ5 VISA INC 4.1 02/12/2031 590,000.00 02/03/2026

4.13%
589,209.40
589,283.00

98.08 4.58%
578,649.58
11,355.86

0.72%
(10,633.42)
Aa3/AANA4.54

4.00 02079KBK2 ALPHABET INC 4.1 02/15/2031 1,000,000.00 02/12/2026

4.10%
1,000,058.52
1,000,052.82

96.94 4.86%
969,400.00
19,133.33

1.20%
(30,652.82)
Aa2/AA+
NA

4.54 4.00
46647PBJ4 JPMORGAN CHASE & CO 4.493
03/24/2031 1,000,000.00 05/19/20264.74%
989,350.00
989,789.49

98.37 5.50%
983,732.00
15,850.31

1.22%
(6,057.49)
A1/A
AA4.653.26
532457DL9 ELI LILLY AND CO 4.375
05/20/2031 310,000.00 05/06/20264.40%
309,668.30
309,681.56

98.23 4.79%
304,503.70
2,674.83

0.38%
(5,177.86)
Aa3/AANA4.80

4.24 023135EC6 AMAZON.COM INC 4.8
07/09/2031 1,010,000.00 07/07/20264.83%
1,008,717.30
1,008,733.46

99.05 5.02%
1,000,419.14
2,962.67

1.24%
(8,314.32)
A1/AA
AA4.944.33
Total Corporate 23,075,000.00 4.24%
22,955,918.56
22,968,548.01

98.09 4.78%
22,623,657.03
233,611.03

27.96%
(344,890.98)

3.70 3.19
ATTACHMENT A Page 17 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration

MONEY MARKET
FUND
316175884 FIDELITY IMM:TRS III 373,790.30 --

3.35%
373,790.30
373,790.30

1.00 3.35%
373,790.30

0.00 0.46%

0.00 Aaa/
AAAm
AAA

0.00 0.00
Total Money
Market Fund 373,790.30 3.35%
373,790.30
373,790.30

1.00 3.35%
373,790.30

0.00 0.46%

0.00 0.00

0.00 MUNICIPAL
BONDS
13063EGT7 CALIFORNIA STATE 4.5
08/01/2029 965,000.00 10/30/20244.38%
970,085.55
968,221.83
100.09

4.47%
965,828.94
21,712.50

1.19%
(2,392.89)
Aa2/AAAA3.00

2.77 Total Municipal
Bonds 965,000.00 4.38%
970,085.55
968,221.83
100.09

4.47%
965,828.94
21,712.50

1.19%
(2,392.89)

3.00 2.77

US TREASURY
91282CCZ2 UNITED STATES TREASURY 0.875
09/30/2026 1,150,000.00 --1.08%
1,138,565.08
1,149,620.98

99.54 3.80%
1,144,676.65
3,381.66

1.41%
(4,944.33)
Aa1/AA+
AA+

0.17 0.16
91282CEW7 UNITED STATES TREASURY 3.25
06/30/2027 2,250,000.00 --3.12%
2,263,417.97
2,252,470.23

99.21 4.14%
2,232,276.75
6,358.70

2.76%
(20,193.48)
Aa1/AA+
AA+

0.91 0.88
91282CFB2 UNITED STATES TREASURY 2.75
07/31/2027 600,000.00 08/22/20223.12%
589,828.13
597,946.44

98.62 4.19%
591,717.00

44.84 0.73%
(6,229.44)
Aa1/AA+
AA+

1.00 0.96
91282CGC9 UNITED STATES TREASURY 3.875
12/31/2027 300,000.00 03/14/20233.91%
299,519.53
299,858.14

99.50 4.24%
298,500.00
1,010.87

0.37%
(1,358.14)
Aa1/AA+
AA+

1.42 1.35
91282CGH8 UNITED STATES TREASURY 3.5
01/31/2028 2,500,000.00 02/16/20234.05%
2,438,378.91
2,481,333.13

98.92 4.26%
2,472,950.00
237.77

3.06%
(8,383.13)
Aa1/AA+
AA+

1.50 1.44
91282CGP0 UNITED STATES TREASURY 4.0
02/29/2028 2,500,000.00 --4.07%
2,491,714.85
2,497,399.11

99.61 4.25%
2,490,332.50
41,847.83

3.08%
(7,066.61)
Aa1/AA+
AA+

1.58 1.49
91282CHE4 UNITED STATES TREASURY 3.625
05/31/2028 2,425,000.00 --

4.03%
2,381,062.51
2,408,646.55

98.87 4.27%
2,397,624.18
14,891.22

2.96%
(11,022.37)
Aa1/AA+
AA+

1.84 1.73
91282CJN2 UNITED STATES TREASURY 4.375
11/30/2028 625,000.00 12/28/20233.83%
640,234.38
632,218.96
100.14

4.31%
625,854.38
4,632.00

0.77%
(6,364.59)
Aa1/AA+
AA+

2.33 2.17
91282CJR3 UNITED STATES TREASURY 3.75
12/31/2028 2,100,000.00 --3.98%
2,078,330.08
2,089,467.99

98.72 4.31%
2,073,094.80
6,847.83

2.56%
(16,373.19)
Aa1/AA+
AA+

2.42 2.27
91282CJW2 UNITED STATES TREASURY 4.0
01/31/2029 1,500,000.00 02/16/20244.31%
1,479,375.00
1,489,561.88

99.24 4.32%
1,488,633.00
163.04

1.84%
(928.88)
Aa1/AA+
AA+

2.50 2.34
ATTACHMENT A Page 18 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

HOLDINGS REPORT
Cusip Security Description Par Value/
Units
Purchase Date
Purchase Yield
Cost Value
Book Value
Mkt Price
Mkt YTM
Market Value
Accrued Int.
% of Port.

Gain/Loss
Moody's/
S&P/
Fitch
Maturity
Duration
91282CKG5 UNITED STATES TREASURY 4.125
03/31/2029 2,300,000.00 --4.47%
2,264,699.22
2,281,022.51

99.50 4.32%
2,288,500.00
31,884.22

2.83%
7,477.49
Aa1/AA+
AA+

2.67 2.46
91282CKP5 UNITED STATES TREASURY 4.625
04/30/2029 2,150,000.00 --4.47%
2,164,254.89
2,157,871.85
100.76

4.33%
2,166,376.55
25,129.59

2.68%
8,504.70
Aa1/AA+
AA+

2.75 2.52
91282CKX8 UNITED STATES TREASURY 4.25
06/30/2029 1,000,000.00 07/18/20244.09%
1,007,070.31
1,004,163.15

99.75 4.34%
997,539.00
3,695.65

1.23%
(6,624.15)
Aa1/AA+
AA+

2.91 2.70
91282CLK5 UNITED STATES TREASURY 3.625
08/31/2029 2,000,000.00 09/11/20243.45%
2,015,703.13
2,009,752.74

97.95 4.34%
1,958,906.00
30,339.67

2.42%
(50,846.74)
Aa1/AA+
AA+

3.08 2.83
91282CLN9 UNITED STATES TREASURY 3.5
09/30/2029 1,000,000.00 10/04/2024

3.76%
988,125.00
992,453.27

97.52 4.35%
975,195.00
11,762.30

1.21%
(17,258.27)
Aa1/AA+
AA+

3.17 2.92
91282CGQ8 UNITED STATES TREASURY 4.0
02/28/2030 1,000,000.00 04/10/20254.00%
1,000,000.00
1,000,000.00

98.79 4.37%
987,852.00
16,739.13

1.22%
(12,148.00)
Aa1/AA+
AA+

3.58 3.24
91282CGS4 UNITED STATES TREASURY 3.625
03/31/2030 1,500,000.00 --3.76%
1,491,250.00
1,493,350.84

97.46 4.38%
1,461,913.50
18,273.57

1.81%
(31,437.34)
Aa1/AA+
AA+

3.67 3.34
91282CNK3 UNITED STATES TREASURY 3.875
06/30/2030 1,200,000.00 07/09/20253.95%
1,195,875.00
1,196,754.06

98.15 4.39%
1,177,780.80
4,043.48

1.46%
(18,973.26)
Aa1/AA+
AA+

3.91 3.57
91282CNX5 UNITED STATES TREASURY 3.625
08/31/2030 2,250,000.00 --3.70%
2,242,382.81
2,243,728.32

97.11 4.41%
2,184,961.50
34,132.13

2.70%
(58,766.82)
Aa1/AA+
AA+

4.08 3.68
91282CPN5 UNITED STATES TREASURY 3.5
11/30/2030 2,500,000.00 12/16/20253.70%
2,477,050.78
2,479,930.53

96.43 4.41%
2,410,742.50
14,822.40

2.98%
(69,188.03)
Aa1/AA+
AA+

4.33 3.93
91282CQD6 UNITED STATES TREASURY 3.5
02/28/2031 2,000,000.00 04/21/20263.87%
1,967,187.50
1,969,056.68

96.27 4.41%
1,925,312.00
29,293.48

2.38%
(43,744.68)
Aa1/AA+
AA+

4.58 4.11
91282CQG9 UNITED STATES TREASURY 3.875
03/31/2031 1,000,000.00 04/08/20263.92%
997,929.69
998,059.58

97.72 4.42%
977,188.00
13,022.54

1.21%
(20,871.58)
Aa1/AA+
AA+

4.67 4.15
Total US Treasury 35,850,000.00 3.82%
35,611,954.77
35,724,666.96

98.56 4.31%
35,327,926.10
312,553.91

43.66%
(396,740.86)

2.71 2.49
Total Portfolio 82,400,542.14 4.11%
81,506,738.38
81,779,890.39

97.80 4.47%
80,907,564.72
625,471.67
100.00%
(872,325.66)

3.06 2.55
Total Market Value
+ Accrued 81,533,036.39
ATTACHMENT A Page 19 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss

ACQUISITIONS
Purchase 07/01/2026 316175884 15,225.00 FIDELITY IMM:TRS III 1.000 3.30% (15,225.00) 0.00 (15,225.00) 0.00 Purchase 07/02/2026 316175884 474.47 FIDELITY IMM:TRS III 1.000 3.31% (474.47) 0.00 (474.47) 0.00 Purchase 07/08/2026 316175884 18,260.00 FIDELITY IMM:TRS III 1.000 3.29% (18,260.00) 0.00 (18,260.00) 0.00 Purchase 07/09/2026 023135EC6 1,010,000.00 AMAZON.COM INC 4.8 07/09/2031 99.873 4.83% (1,008,717.30) 0.00 (1,008,717.30) 0.00 Purchase 07/10/2026 316175884 9,864.17 FIDELITY IMM:TRS III 1.000 3.27% (9,864.17) 0.00 (9,864.17) 0.00 Purchase 07/15/2026 316175884 886,101.66 FIDELITY IMM:TRS III 1.000 3.32% (886,101.66) 0.00 (886,101.66) 0.00 Purchase 07/15/2026 316175884 65,787.19 FIDELITY IMM:TRS III 1.000 3.32% (65,787.19) 0.00 (65,787.19) 0.00 Purchase 07/16/2026 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 99.977 4.53% (929,783.87) 0.00 (929,783.87) 0.00 Purchase 07/17/2026 316175884 18,675.00 FIDELITY IMM:TRS III 1.000 3.30% (18,675.00) 0.00 (18,675.00) 0.00 Purchase 07/20/2026 316175884 2,708.57 FIDELITY IMM:TRS III 1.000 3.30% (2,708.57) 0.00 (2,708.57) 0.00 Purchase 07/20/2026 316175884 54,275.26 FIDELITY IMM:TRS III 1.000 3.30% (54,275.26) 0.00 (54,275.26) 0.00 Purchase 07/21/2026 316175884 32,760.56 FIDELITY IMM:TRS III 1.000 3.32% (32,760.56) 0.00 (32,760.56) 0.00 Purchase 07/21/2026 316175884 1,700.48 FIDELITY IMM:TRS III 1.000 3.32% (1,700.48) 0.00 (1,700.48) 0.00 Purchase 07/23/2026 316175884 12,127.80 FIDELITY IMM:TRS III 1.000 3.33% (12,127.80) 0.00 (12,127.80) 0.00 Purchase 07/27/2026 316175884 10,011,245.57 FIDELITY IMM:TRS III 1.000 3.32% (10,011,245.57) 0.00 (10,011,245.57) 0.00 Purchase 07/27/2026 316175884 35,121.80 FIDELITY IMM:TRS III 1.000 3.32% (35,121.80) 0.00 (35,121.80) 0.00 Purchase 07/31/2026 316175884 82,000.00 FIDELITY IMM:TRS III 1.000 3.35% (82,000.00) 0.00 (82,000.00) 0.00 Total Purchase 13,186,327.53 (13,184,828.70) 0.00 (13,184,828.70) 0.00 TOTAL
ACQUISITIONS 13,186,327.53 (13,184,828.70) 0.00 (13,184,828.70) 0.00

DISPOSITIONS
Sale 07/09/2026 316175884 (239,027.54) FIDELITY IMM:TRS III 1.000 3.27% 239,027.54 0.00 239,027.54 0.00 Sale 07/09/2026 316175884 (22,138.51) FIDELITY IMM:TRS III 1.000 3.27% 22,138.51 0.00 22,138.51 0.00 Sale 07/09/2026 808513BY0 (750,000.00) CHARLES SCHWAB
CORP 2.45 03/03/2027 98.816 2.73% 741,120.00 (6,431.25) 747,551.25 (7,591.36) Sale 07/15/2026 91282CCZ2 (850,000.00)

UNITED STATES
TREASURY 0.875
09/30/2026

99.398 1.08% 844,886.72 (2,154.03) 847,040.75 (4,753.77) ATTACHMENT A Page 20 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss
Sale 07/16/2026 316175884 (886,101.66) FIDELITY IMM:TRS III 1.000 3.31% 886,101.66 0.00 886,101.66 0.00 Sale 07/16/2026 316175884 (30,351.72) FIDELITY IMM:TRS III 1.000 3.31% 30,351.72 0.00 30,351.72 0.00 Sale 07/27/2026 3137FGR31 (1,300,000.00) FHMS K-078 A2 3.854 06/25/2028 98.695 5.02% 1,283,039.06 (3,618.48) 1,286,657.54 6,303.68 Sale 07/27/2026 89236TMF9 (500,000.00) TOYOTA MOTOR CREDIT CORP 5.05 05/16/2029 100.897 5.00% 504,485.00 (4,979.86) 509,464.86 3,899.54 Sale 07/27/2026 437076DC3 (950,000.00) HOME DEPOT INC 4.75 06/25/2029 100.372 4.88% 953,534.00 (4,011.11) 957,545.11 6,688.45 Sale 07/27/2026 17275RBR2 (490,000.00) CISCO SYSTEMS INC

4.85 02/26/2029 100.567 4.86% 492,778.30 (9,968.10) 502,746.40 2,867.01 Sale 07/27/2026 91282CJF9 (600,000.00)

UNITED STATES
TREASURY 4.875
10/31/2028
101.141 4.79% 606,843.75 (6,994.57) 613,838.32 5,814.67 Sale 07/27/2026 3137FJKE8 (600,000.00) FHMS K-082 A2 3.92 09/25/2028 98.527 4.74% 591,164.06 (1,698.67) 592,862.73 566.55 Sale 07/27/2026 91282CHX2 (400,000.00)

UNITED STATES
TREASURY 4.375
08/31/2028
100.098 4.62% 400,390.63 (7,085.60) 407,476.23 2,184.95 Sale 07/27/2026 91282CMG3 (1,000,000.00)

UNITED STATES
TREASURY 4.25
01/31/2030

99.609 4.41% 996,093.75 (20,780.39) 1,016,874.14 1,076.16 Sale 07/27/2026 79466LAQ7 (595,000.00) SALESFORCE INC 4.5 03/15/2028 99.569 4.37% 592,435.55 (9,966.25) 602,401.80 (3,727.44) Sale 07/27/2026 91282CMA6 (1,500,000.00)

UNITED STATES
TREASURY 4.125
11/30/2029

99.266 4.25% 1,488,984.38 (9,636.27) 1,498,620.65 (5,197.25) Sale 07/27/2026 459058LN1 (1,000,000.00)

INTERNATIONAL BANK

FOR RECONSTRUCTION
AND DEVELOPM 3.875
10/16/2029

98.494 4.25% 984,940.00 (10,871.53) 995,811.53 (4,222.01) Sale 07/27/2026 459058LR2 (1,000,000.00)

INTERNATIONAL BANK

FOR RECONSTRUCTION
AND DEVELOPM 4.125
03/20/2030

99.114 4.20% 991,140.00 (14,552.08) 1,005,692.08 (6,379.82) ATTACHMENT A Page 21 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss
Sale 07/28/2026 316175884 (10,000,000.00) FIDELITY IMM:TRS III 1.000 3.35% 10,000,000.00 0.00 10,000,000.00 0.00 Total Sale (22,712,619.43) 22,649,454.63 (112,748.19) 22,762,202.82 (2,470.67) TOTAL
DISPOSITIONS (22,712,619.43) 22,649,454.63 (112,748.19) 22,762,202.82 (2,470.67) OTHER

TRANSACTIONS
Cash Transfer 07/28/2026 CCYUSD (10,000,000.00) Cash 0.00% (10,000,000.00) 0.00 (10,000,000.00) 0.00 Total Cash
Transfer (10,000,000.00) (10,000,000.00) 0.00 (10,000,000.00) 0.00 Coupon 07/01/2026 3137FGR31 0.00 FHMS K-078 A2 3.854
06/25/2028 5.02% 4,175.17 0.00 4,175.17 0.00
Coupon 07/01/2026 3137FJKE8 0.00 FHMS K-082 A2 3.92
09/25/2028 4.74% 1,960.00 0.00 1,960.00 0.00
Coupon 07/01/2026 3137H5YC5 0.00 FHMS K-748 A2 2.26
01/25/2029 4.61% 2,825.00 0.00 2,825.00 0.00
Coupon 07/01/2026 3137FLMV3 0.00 FHMS K-090 A2 3.422
02/25/2029 4.46% 2,851.67 0.00 2,851.67 0.00
Coupon 07/01/2026 3137HBC51 0.00 FHMS K-754 A2 4.94
11/25/2030 4.38% 9,565.31 0.00 9,565.31 0.00
Coupon 07/01/2026 3137FRUT6 0.00 FHMS K-106 A2 2.069
01/25/2030 4.37% 1,724.17 0.00 1,724.17 0.00
Coupon 07/01/2026 74456QCX2 0.00

PUBLIC SERVICE

ELECTRIC AND GAS CO

4.2 01/01/2031

4.20% 15,225.00 0.00 15,225.00 0.00
Coupon 07/01/2026 3137FEZU7 0.00 FHMS K-076 A2 3.9
04/25/2028 4.12% 3,900.00 0.00 3,900.00 0.00
Coupon 07/01/2026 3137FXZ35 0.00 FHMS K-127 A2 2.108
01/25/2031 4.11% 1,756.67 0.00 1,756.67 0.00
Coupon 07/01/2026 3137F83Q4 0.00 FHMS K-121 A2 1.547
10/25/2030 3.98% 2,578.33 0.00 2,578.33 0.00
Coupon 07/01/2026 3137BXQY1 0.00 FHMS K-064 A2 3.224
03/25/2027 3.23% 2,686.67 0.00 2,686.67 0.00
ATTACHMENT A Page 22 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss
Coupon 07/08/2026 14913UBH2 0.00

CATERPILLAR

FINANCIAL SERVICES
CORP 4.15 01/08/2031

4.16% 18,260.00 0.00 18,260.00 0.00
Coupon 07/10/2026 89236TPH2 0.00 TOYOTA MOTOR CREDIT
CORP 4.2 01/10/2031 4.21% 9,864.17 0.00 9,864.17 0.00
Coupon 07/15/2026 47786WAD2 0.00 JDOT 2024-B A3 5.2
03/15/2029 5.81% 1,625.96 0.00 1,625.96 0.00
Coupon 07/15/2026 58770JAD6 0.00 MBALT 2024-A A3 5.32
01/18/2028 5.73% 714.18 0.00 714.18 0.00
Coupon 07/15/2026 02582JKH2 0.00 AMXCA 2024-1 A 5.23
04/16/2029 5.30% 3,138.00 0.00 3,138.00 0.00
Coupon 07/15/2026 161571HT4 0.00 CHAIT 2023-1 A 5.16
09/15/2028 5.23% 4,149.50 0.00 4,149.50 0.00
Coupon 07/15/2026 47800DAD6 0.00 JDOT 2025 A3 4.23
09/17/2029 5.09% 1,621.50 0.00 1,621.50 0.00
Coupon 07/15/2026 05522RDJ4 0.00 BACCT 2024-1 A 4.93
05/15/2029 4.93% 1,889.83 0.00 1,889.83 0.00
Coupon 07/15/2026 44935KAD5 0.00 HART 26B A3 4.51
02/18/2031 4.86% 1,788.97 0.00 1,788.97 0.00
Coupon 07/15/2026 44935CAD3 0.00 HART 2025-A A3 4.32
10/15/2029 4.84% 2,070.00 0.00 2,070.00 0.00
Coupon 07/15/2026 58773DAD6 0.00 MBART 2025-1 A3 4.78
12/17/2029 4.84% 2,170.92 0.00 2,170.92 0.00
Coupon 07/15/2026 89240JAD3 0.00 TAOT 2025-A A3 4.64
08/15/2029 4.69% 2,184.67 0.00 2,184.67 0.00
Coupon 07/15/2026 161571JA3 0.00 CHAIT 2026-1 A 4.4
05/15/2029 4.45% 4,021.11 0.00 4,021.11 0.00
Coupon 07/15/2026 828807DK0 0.00

SIMON PROPERTY
GROUP LP 2.65
07/15/2030

4.32% 13,250.00 0.00 13,250.00 0.00
Coupon 07/15/2026 92970QAE5 0.00 WFCIT 2024-2 A 4.29
10/15/2029 4.29% 1,841.13 0.00 1,841.13 0.00
Coupon 07/15/2026 02582JKP4 0.00 AMXCA 2025-2 A 4.28
04/15/2030 4.28% 2,817.67 0.00 2,817.67 0.00
ATTACHMENT A Page 23 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss
Coupon 07/15/2026 756109AX2 0.00 REALTY INCOME CORP

3.25 01/15/2031 4.27% 16,250.00 0.00 16,250.00 0.00
Coupon 07/15/2026 437921AD1 0.00 HAROT 252 A3 4.15
10/15/2029 4.15% 1,037.50 0.00 1,037.50 0.00
Coupon 07/15/2026 87612EBM7 0.00 TARGET CORP 1.95
01/15/2027 1.99% 5,216.25 0.00 5,216.25 0.00
Coupon 07/16/2026 362955AD8 0.00 GMCAR 2025-1 A3 4.62
12/17/2029 5.03% 1,443.75 0.00 1,443.75 0.00
Coupon 07/17/2026 713448FX1 0.00 PEPSICO INC 4.5
07/17/2029 4.53% 18,675.00 0.00 18,675.00 0.00
Coupon 07/18/2026 437930AC4 0.00 HAROT 2024-2 A3 5.27
11/20/2028 5.27% 844.95 0.00 844.95 0.00
Coupon 07/20/2026 36269WAD1 0.00 GMALT 2024-2 A3 5.39
07/20/2027 5.85% 184.29 0.00 184.29 0.00
Coupon 07/20/2026 362962AD4 0.00 GMALT 2025-2 A3 4.58
05/22/2028 4.84% 1,679.33 0.00 1,679.33 0.00
Coupon 07/21/2026 43813YAC6 0.00 HAROT 2024-3 A3 4.57
03/21/2029 4.66% 1,700.48 0.00 1,700.48 0.00
Coupon 07/23/2026 95000U4D2 0.00 WELLS FARGO & CO

4.182 01/23/2030 4.24% 12,127.80 0.00 12,127.80 0.00
Coupon 07/25/2026 096919AD7 0.00 BMWOT 2024-A A3

5.18 02/26/2029 5.18% 1,098.81 0.00 1,098.81 0.00
Coupon 07/31/2026 91282CJW2 0.00

UNITED STATES
TREASURY 4.0
01/31/2029

4.31% 30,000.00 0.00 30,000.00 0.00
Coupon 07/31/2026 91282CGH8 0.00

UNITED STATES
TREASURY 3.5
01/31/2028

4.05% 43,750.00 0.00 43,750.00 0.00
Coupon 07/31/2026 91282CFB2 0.00

UNITED STATES
TREASURY 2.75
07/31/2027

3.12% 8,250.00 0.00 8,250.00 0.00
Total Coupon 0.00 262,913.76 0.00 262,913.76 0.00
Dividend 07/31/2026 316175884 0.00 FIDELITY IMM:TRS III 3.34% 1,624.63 0.00 1,624.63 0.00 Total Dividend 0.00 1,624.63 0.00 1,624.63 0.00
ATTACHMENT A Page 24 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

TRANSACTION LEDGER
Transaction Type Settlement
Date CUSIP Quantity Security Description Price
Acq/
Disp
Yield
Amount Interest Pur/
Sold Total Amount Gain/Loss
Principal Paydown 07/15/2026 47786WAD2 16,744.48 JDOT 2024-B A3 5.2 03/15/2029 5.81% 16,744.48 -- 16,744.48 (0.00)
Principal Paydown 07/15/2026 58770JAD6 22,316.43 MBALT 2024-A A3 5.32 01/18/2028 5.73% 22,316.43 -- 22,316.43 0.00
Principal Paydown 07/16/2026 362955AD8 11,886.74 GMCAR 2025-1 A3 4.62 12/17/2029 5.03% 11,886.74 -- 11,886.74 (0.00)
Principal Paydown 07/18/2026 437930AC4 16,068.48 HAROT 2024-2 A3 5.27 11/20/2028 5.27% 16,068.48 -- 16,068.48 0.00
Principal Paydown 07/20/2026 36269WAD1 38,206.78 GMALT 2024-2 A3 5.39 07/20/2027 5.85% 38,206.78 -- 38,206.78 (0.00)
Principal Paydown 07/21/2026 43813YAC6 32,760.56 HAROT 2024-3 A3 4.57 03/21/2029 4.66% 32,760.56 -- 32,760.56 (0.00)
Principal Paydown 07/25/2026 096919AD7 21,254.18 BMWOT 2024-A A3

5.18 02/26/2029 5.18% 21,254.18 -- 21,254.18 0.00
Total Principal
Paydown 159,237.65 159,237.65 -- 159,237.65 (0.01)

TOTAL OTHER
TRANSACTIONS (9,840,762.35) (9,576,223.96) 0.00 (9,576,223.96) (0.01) ATTACHMENT A Page 25 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income

CASH & EQUIVALENTS
316175884 FIDELITY IMM:TRS III
373,790.30
305,082.20
11,246,327.53
(11,177,619.43)
373,790.30

0.00 474.47

0.00 474.47

0.00 0.00

0.00 474.47
474.47
CCYUSD Receivable
1,624.63
474.47

0.00 0.00
1,624.63

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 Total Cash & Equivalents 375,414.93
305,556.67
11,246,327.53
(11,177,619.43)
375,414.93

0.00 474.47

0.00 474.47

0.00 0.00

0.00 474.47 474.47

FIXED INCOME
00287YDZ9 ABBVIE INC 4.875
03/15/2030 1,000,000.00
1,007,559.32

0.00 0.00
1,007,382.46
14,354.17

0.00 18,416.67
4,062.50

0.00 (176.86)
(176.86)
3,885.64
3,885.64
02079KBK2 ALPHABET INC 4.1
02/15/2031
02/12/2026
02/17/2026
1,000,000.00
1,000,053.89

0.00 0.00
1,000,052.82
15,716.67

0.00 19,133.33
3,416.67

3.43 (4.50)
(1.07)
3,415.60
3,415.60
023135EC6 AMAZON.COM INC 4.8
07/09/2031
07/07/2026
07/09/2026
1,010,000.00

0.00 1,008,717.30

0.00 1,008,733.46

0.00 0.00
2,962.67
2,962.67

16.16 0.00

16.16 2,978.82
2,978.82
02582JKH2 AMXCA 2024-1 A 5.23
04/16/2029
04/16/2024
04/23/2024
720,000.00
719,917.23

0.00 0.00
719,919.75
1,673.60
3,138.00
1,673.60
3,138.00

2.52 0.00

2.52 3,140.52
3,140.52
02582JKP4 AMXCA 2025-2 A 4.28
04/15/2030
05/06/2025
05/13/2025
790,000.00
789,988.99

0.00 0.00
789,989.24
1,502.76
2,817.67
1,502.76
2,817.67

0.25 0.00

0.25 2,817.92
2,817.92
ATTACHMENT A Page 26 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
05522RDJ4 BACCT 2024-1 A 4.93
05/15/2029
06/06/2024
06/13/2024
460,000.00
459,984.99

0.00 0.00
459,985.43
1,007.91
1,889.83
1,007.91
1,889.83

0.44 0.00

0.44 1,890.27
1,890.27
084664CZ2

BERKSHIRE HATHAWAY
FINANCE CORP 2.3
03/15/2027
03/07/2022
03/15/2022
1,080,000.00
1,079,971.12

0.00 0.00
1,079,974.60
7,314.00

0.00 9,384.00
2,070.00

3.48 0.00

3.48 2,073.48
2,073.48
096919AD7 BMWOT 2024-A A3 5.18
02/26/2029
06/04/2024
06/11/2024
233,296.82
254,529.18

0.00 (21,254.18)
233,277.46
219.76
1,098.81
201.41
1,080.46

2.46 0.00

2.46 1,082.92
1,082.92
13063EGT7 CALIFORNIA STATE 4.5
08/01/2029
10/30/2024
11/05/2024
965,000.00
968,312.96

0.00 0.00
968,221.83
18,093.75

0.00 21,712.50
3,618.75

0.00 (91.13)
(91.13)
3,527.62
3,527.62
14041NGJ4 COMET 2026-1 A 4.48
07/16/2029
07/09/2026
07/16/2026
930,000.00

0.00 929,783.87

0.00 929,787.03

0.00 0.00
1,736.00
1,736.00

3.16 0.00

3.16 1,739.16
1,739.16
14913UBH2

CATERPILLAR FINANCIAL
SERVICES CORP 4.15
01/08/2031
01/05/2026
01/08/2026
880,000.00
879,713.39

0.00 0.00
879,718.77
17,549.89
18,260.00
2,333.22
3,043.33

5.38 0.00

5.38 3,048.71
3,048.71
161571HT4 CHAIT 2023-1 A 5.16
09/15/2028
09/07/2023
09/15/2023
965,000.00
964,881.84

0.00 0.00
964,886.38
2,213.07
4,149.50
2,213.07
4,149.50

4.54 0.00

4.54 4,154.04
4,154.04
161571JA3 CHAIT 2026-1 A 4.4
05/15/2029
05/21/2026
05/28/2026
700,000.00
699,839.58

0.00 0.00
699,844.32
2,823.33
4,021.11
1,368.89
2,566.67

4.74 0.00

4.74 2,571.41
2,571.41
171239AL0 CHUBB INA HOLDINGS LLC

4.65 08/15/2029
08/12/2024
08/15/2024
505,000.00
506,764.25

0.00 0.00
506,714.98
8,871.17

0.00 10,828.04
1,956.88

0.00 (49.27)
(49.27)
1,907.60
1,907.60
ATTACHMENT A Page 27 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
17275RBR2 CISCO SYSTEMS INC 4.85
02/26/2029
02/21/2024
02/26/2024

0.00 489,908.85

0.00 (489,911.29)

0.00 8,251.74
9,968.10

0.00 1,716.36

2.44 0.00

2.44 1,718.80
1,718.80
24422EYF0 JOHN DEERE CAPITAL CORP

4.375 10/15/2030
11/04/2025
11/05/2025
1,000,000.00
1,006,354.81

0.00 0.00
1,006,229.10
9,236.11

0.00 12,881.94
3,645.83

0.00 (125.72)
(125.72)
3,520.12
3,520.12
30303MAB8 META PLATFORMS INC 4.2
11/15/2030
11/12/2025
11/17/2025
750,000.00
752,621.86

0.00 0.00
752,569.99
4,025.00

0.00 6,650.00
2,625.00

0.00 (51.87)
(51.87)
2,573.13
2,573.13
3133EPGW9

FEDERAL FARM CREDIT
BANKS FUNDING CORP 3.875
04/25/2028
05/05/2023
05/08/2023
950,000.00
955,042.23

0.00 0.00
954,806.82
6,748.96

0.00 9,816.67
3,067.71

0.00 (235.41)
(235.41)
2,832.30
2,832.30
3137BXQY1 FHMS K-064 A2 3.224
03/25/2027
05/06/2022
05/11/2022
1,000,000.00
999,713.34

0.00 0.00
999,749.91
2,686.67
2,686.67
2,686.67
2,686.67

36.57 0.00

36.57 2,723.24
2,723.24
3137F83Q4 FHMS K-121 A2 1.547
10/25/2030
01/07/2026
01/12/2026
2,000,000.00
1,810,719.68

0.00 0.00
1,814,497.97
2,578.33
2,578.33
2,578.33
2,578.33
3,778.29

0.00 3,778.29
6,356.62
6,356.62
3137FEZU7 FHMS K-076 A2 3.9
04/25/2028
04/20/2023
04/25/2023
1,200,000.00
1,195,407.65

0.00 0.00
1,195,630.10
3,900.00
3,900.00
3,900.00
3,900.00
222.44

0.00 222.44
4,122.44
4,122.44
3137FGR31 FHMS K-078 A2 3.854
06/25/2028
09/18/2023
09/21/2023

0.00 1,275,839.26

0.00 (1,276,735.38)

0.00 4,175.17
7,793.65

0.00 3,618.48
896.12

0.00 896.12
4,514.60
4,514.60
3137FJKE8 FHMS K-082 A2 3.92
09/25/2028
11/28/2023
12/01/2023

0.00 590,278.78

0.00 (590,597.51)

0.00 1,960.00
3,658.67

0.00 1,698.67
318.73

0.00 318.73
2,017.40
2,017.40
ATTACHMENT A Page 28 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
3137FLMV3 FHMS K-090 A2 3.422
02/25/2029
07/29/2024
07/30/2024
1,000,000.00
975,342.15

0.00 0.00
976,150.17
2,851.67
2,851.67
2,851.67
2,851.67
808.03

0.00 808.03
3,659.70
3,659.70
3137FRUT6 FHMS K-106 A2 2.069
01/25/2030
06/06/2025
06/11/2025
1,000,000.00
926,997.00

0.00 0.00
928,765.04
1,724.17
1,724.17
1,724.17
1,724.17
1,768.04

0.00 1,768.04
3,492.21
3,492.21
3137FXZ35 FHMS K-127 A2 2.108
01/25/2031
02/03/2026
02/06/2026
1,000,000.00
918,152.06

0.00 0.00
919,694.48
1,756.67
1,756.67
1,756.67
1,756.67
1,542.42

0.00 1,542.42
3,299.09
3,299.09
3137H5YC5 FHMS K-748 A2 2.26
01/25/2029
03/25/2024
03/28/2024
1,500,000.00
1,421,552.06

0.00 0.00
1,424,209.86
2,825.00
2,825.00
2,825.00
2,825.00
2,657.80

0.00 2,657.80
5,482.80
5,482.80
3137HBC51 FHMS K-754 A2 4.94
11/25/2030
06/02/2026
06/05/2026
2,323,557.00
2,369,902.76

0.00 0.00
2,368,995.74
9,565.31
9,565.31
9,565.31
9,565.31

0.00 (907.02)
(907.02)
8,658.29
8,658.29
341081GT8 FLORIDA POWER & LIGHT CO

5.15 06/15/2029
06/13/2024
06/17/2024
1,000,000.00
1,008,013.65

0.00 0.00
1,007,769.86
2,288.89

0.00 6,580.56
4,291.67

0.00 (243.79)
(243.79)
4,047.88
4,047.88
36269WAD1 GMALT 2024-2 A3 5.39
07/20/2027
05/07/2024
05/16/2024
2,821.80
41,027.79

0.00 (38,206.78)
2,821.75

67.57 184.29

4.65 121.37

0.74 0.00

0.74 122.10
122.10
362955AD8 GMCAR 2025-1 A3 4.62
12/17/2029
01/09/2025
01/15/2025
363,113.26
374,980.39

0.00 (11,886.74)
363,094.73
721.88
1,443.75
698.99
1,420.87

1.09 0.00

1.09 1,421.96
1,421.96
362962AD4 GMALT 2025-2 A3 4.58
05/22/2028
05/20/2025
05/29/2025
440,000.00
439,995.37

0.00 0.00
439,995.58
615.76
1,679.33
615.76
1,679.33

0.21 0.00

0.21 1,679.54
1,679.54
ATTACHMENT A Page 29 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
38141GD27 GOLDMAN SACHS GROUP
INC 4.153 10/21/2029 10/21/2025
735,000.00
735,069.22

0.00 0.00
735,066.68
5,935.33

0.00 8,479.04
2,543.71

0.00 (2.55)
(2.55)
2,541.17
2,541.17
437076DC3 HOME DEPOT INC 4.75
06/25/2029
06/17/2024
06/25/2024

0.00 946,768.47

0.00 (946,845.55)

0.00 752.08
4,011.11

0.00 3,259.03

77.08 0.00

77.08 3,336.11
3,336.11
437921AD1 HAROT 252 A3 4.15
10/15/2029
04/29/2025
05/08/2025
300,000.00
299,975.15

0.00 0.00
299,975.79
553.33
1,037.50
553.33
1,037.50

0.64 0.00

0.64 1,038.14
1,038.14
437930AC4 HAROT 2024-2 A3 5.27
11/20/2028
05/14/2024
05/21/2024
176,330.45
192,386.51

0.00 (16,068.48)
176,319.47
366.15
844.95
335.57
814.37

1.44 0.00

1.44 815.81
815.81
43813YAC6 HAROT 2024-3 A3 4.57
03/21/2029
08/09/2024
08/21/2024
413,756.15
446,475.04

0.00 (32,760.56)
413,718.74
566.83
1,700.48
525.24
1,658.89

4.26 0.00

4.26 1,663.15
1,663.15
44935CAD3 HART 2025-A A3 4.32
10/15/2029
03/04/2025
03/12/2025
575,000.00
574,939.25

0.00 0.00
574,940.82
1,104.00
2,070.00
1,104.00
2,070.00

1.57 0.00

1.57 2,071.57
2,071.57
44935KAD5 HART 26B A3 4.51
02/18/2031
06/09/2026
06/17/2026
510,000.00
509,938.94

0.00 0.00
509,940.06
953.98
1,788.97
1,022.27
1,857.25

1.12 0.00

1.12 1,858.37
1,858.37
459058LN1

INTERNATIONAL BANK FOR

RECONSTRUCTION AND
DEVELOPM 3.875 10/16/2029
12/12/2024
12/13/2024

0.00 988,922.60

0.00 (989,162.01)

0.00 8,070.00
10,871.53

0.00 2,801.53
239.41

0.00 239.41
3,040.94
3,040.94
459058LR2

INTERNATIONAL BANK FOR

RECONSTRUCTION AND
DEVELOPM 4.125 03/20/2030
03/14/2025
03/20/2025

0.00 997,471.41

0.00 (997,519.82)

0.00 11,572.92
14,552.08

0.00 2,979.16

48.41 0.00

48.41 3,027.58
3,027.58
ATTACHMENT A Page 30 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
46647PBJ4 JPMORGAN CHASE & CO

4.493 03/24/2031
05/19/2026
05/20/2026
1,000,000.00
989,602.85

0.00 0.00
989,789.49
12,106.14

0.00 15,850.31
3,744.17
186.63

0.00 186.63
3,930.80
3,930.80
47786WAD2 JDOT 2024-B A3 5.2
03/15/2029
06/11/2024
06/18/2024
358,475.92
375,178.53

0.00 (16,744.48)
358,437.17
867.18
1,625.96
828.48
1,587.26

3.12 0.00

3.12 1,590.39
1,590.39
47800DAD6 JDOT 2025 A3 4.23
09/17/2029
03/04/2025
03/11/2025
460,000.00
459,979.43

0.00 0.00
459,979.97
864.80
1,621.50
864.80
1,621.50

0.54 0.00

0.54 1,622.04
1,622.04
532457DL9 ELI LILLY AND CO 4.375
05/20/2031
05/06/2026
05/20/2026
310,000.00
309,675.93

0.00 0.00
309,681.56
1,544.62

0.00 2,674.83
1,130.21

5.63 0.00

5.63 1,135.84
1,135.84
571748CA8

MARSH & MCLENNAN
COMPANIES INC 4.65
03/15/2030 1,000,000.00
1,001,828.00

0.00 0.00
1,001,785.23
13,691.67

0.00 17,566.67
3,875.00

0.00 (42.77)
(42.77)
3,832.23
3,832.23
58770JAD6 MBALT 2024-A A3 5.32
01/18/2028
05/17/2024
05/23/2024
138,775.82
161,084.26

0.00 (22,316.43)
138,769.32
380.89
714.18
328.13
661.41

1.48 0.00

1.48 662.90
662.90
58773DAD6 MBART 2025-1 A3 4.78
12/17/2029
01/14/2025
01/23/2025
545,000.00
544,918.03

0.00 0.00
544,920.04
1,157.82
2,170.92
1,157.82
2,170.92

2.01 0.00

2.01 2,172.93
2,172.93
61748UAK8 MORGAN STANLEY 4.133
10/18/2029
10/17/2025
10/22/2025
695,000.00
695,067.00

0.00 0.00
695,064.53
5,824.66

0.00 8,218.36
2,393.70

0.00 (2.47)
(2.47)
2,391.22
2,391.22
63743HFX5

NATIONAL RURAL UTILITIES

COOPERATIVE FINANCE CORP

4.95 02/07/2030 1,000,000.00
1,002,198.93

0.00 0.00
1,002,145.48
19,800.00

0.00 23,925.00
4,125.00

18.70 (72.16)
(53.46)
4,071.54
4,071.54
ATTACHMENT A Page 31 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
665859AY0 NORTHERN TRUST CORP 4.15
11/19/2030
11/12/2025
11/19/2025
850,000.00
849,634.59

0.00 0.00
849,641.66
4,115.42

0.00 7,055.00
2,939.58

7.07 0.00

7.07 2,946.65
2,946.65
69371RT48 PACCAR FINANCIAL CORP 4.0
09/26/2029 09/26/2024
600,000.00
599,703.05

0.00 0.00
599,710.84
6,333.33

0.00 8,333.33
2,000.00

10.87 (3.09)

7.78 2,007.78
2,007.78
713448FX1 PEPSICO INC 4.5 07/17/2029
07/15/2024
07/17/2024
830,000.00
829,216.55

0.00 0.00
829,238.39
17,015.00
18,675.00
1,452.50
3,112.50

21.84 0.00

21.84 3,134.34
3,134.34
717081FD0 PFIZER INC 4.2 11/15/2030
12/16/2025
12/17/2025
900,000.00
903,471.75

0.00 0.00
903,403.07
4,830.00

0.00 7,980.00
3,150.00

0.00 (68.68)
(68.68)
3,081.32
3,081.32
743315AW3 PROGRESSIVE CORP 3.2
03/26/2030
11/14/2025
11/17/2025
1,000,000.00
967,444.15

0.00 0.00
968,184.06
8,444.44

0.00 11,111.11
2,666.67
739.91

0.00 739.91
3,406.57
3,406.57
74456QCX2 PUBLIC SERVICE ELECTRIC
AND GAS CO 4.2 01/01/2031
01/06/2026
01/07/2026
750,000.00
749,972.88

0.00 0.00
749,973.40
15,225.00
15,225.00
2,625.00
2,625.00

0.51 0.00

0.51 2,625.51
2,625.51
756109AX2 REALTY INCOME CORP 3.25
01/15/2031
01/14/2026
01/15/2026
1,000,000.00
958,670.37

0.00 0.00
959,442.65
14,986.11
16,250.00
1,444.44
2,708.33
772.28

0.00 772.28
3,480.62
3,480.62
79466LAQ7 SALESFORCE INC 4.5
03/15/2028
03/12/2026
03/13/2026

0.00 596,216.22

0.00 (596,162.99)

0.00 8,032.50
9,966.25

0.00 1,933.75

0.00 (53.24)
(53.24)
1,880.51
1,880.51
808513BY0 CHARLES SCHWAB CORP 2.45
03/03/2027
03/09/2022
03/11/2022

0.00 748,667.86

0.00 (748,711.36)

0.00 6,022.92
6,431.25

0.00 408.33

43.50 0.00

43.50 451.83
451.83
ATTACHMENT A Page 32 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
828807DK0 SIMON PROPERTY GROUP LP

2.65 07/15/2030
08/19/2025
08/20/2025
1,000,000.00
939,590.92

0.00 0.00
940,860.54
12,219.44
13,250.00
1,177.78
2,208.33
1,269.61

0.00 1,269.61
3,477.95
3,477.95
857477DB6 STATE STREET CORP 4.834
04/24/2030 1,000,000.00
1,006,493.84

0.00 0.00
1,006,346.03
8,996.61

0.00 13,024.94
4,028.33

0.00 (147.80)
(147.80)
3,880.53
3,880.53
87612EBM7 TARGET CORP 1.95
01/15/2027
01/19/2022
01/24/2022
535,000.00
534,900.89

0.00 0.00
534,916.41
4,810.54
5,216.25
463.67
869.38

15.52 0.00

15.52 884.89
884.89
89236TMF9 TOYOTA MOTOR CREDIT
CORP 5.05 05/16/2029
05/21/2024
05/23/2024

0.00 500,600.33

0.00 (500,585.46)

0.00 3,156.25
4,979.86

0.00 1,823.61

0.00 (14.87)
(14.87)
1,808.74
1,808.74
89236TPH2 TOYOTA MOTOR CREDIT
CORP 4.2 01/10/2031
01/07/2026
01/12/2026
475,000.00
474,866.47

0.00 0.00
474,868.98
9,365.42
9,864.17
1,163.75
1,662.50

2.50 0.00

2.50 1,665.01
1,665.01
89240JAD3 TAOT 2025-A A3 4.64
08/15/2029
01/22/2025
01/29/2025
565,000.00
564,984.41

0.00 0.00
564,984.84
1,165.16
2,184.67
1,165.16
2,184.67

0.42 0.00

0.42 2,185.09
2,185.09
91282CCZ2 UNITED STATES TREASURY

0.875 09/30/2026 1,150,000.00
1,999,000.28

0.00 (849,640.49)
1,149,620.98
4,398.91
2,154.03
3,381.66
1,136.78
261.19

0.00 261.19
1,397.97
1,397.97
91282CEW7 UNITED STATES TREASURY

3.25 06/30/2027 2,250,000.00
2,252,700.19

0.00 0.00
2,252,470.23
198.71

0.00 6,358.70
6,159.99

0.00 (229.96)
(229.96)
5,930.03
5,930.03
91282CFB2 UNITED STATES TREASURY

2.75 07/31/2027
08/22/2022
08/23/2022
600,000.00
597,771.55

0.00 0.00
597,946.44
6,882.60
8,250.00

44.84 1,412.24
174.89

0.00 174.89
1,587.13
1,587.13
ATTACHMENT A Page 33 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
91282CGC9 UNITED STATES TREASURY

3.875 12/31/2027
03/14/2023
03/16/2023
300,000.00
299,849.63

0.00 0.00
299,858.14

31.59 0.00
1,010.87
979.28

8.51 0.00

8.51 987.79
987.79
91282CGH8 UNITED STATES TREASURY 3.5
01/31/2028
02/16/2023
02/17/2023
2,500,000.00
2,480,277.16

0.00 0.00
2,481,333.13
36,498.62
43,750.00
237.77
7,489.15
1,055.97

0.00 1,055.97
8,545.13
8,545.13
91282CGP0 UNITED STATES TREASURY 4.0
02/29/2028 2,500,000.00
2,497,259.38

0.00 0.00
2,497,399.11
33,423.91

0.00 41,847.83
8,423.91
230.46
(90.72)
139.74
8,563.65
8,563.65
91282CGQ8 UNITED STATES TREASURY 4.0
02/28/2030
04/10/2025
04/11/2025
1,000,000.00
1,000,000.00

0.00 0.00
1,000,000.00
13,369.57

0.00 16,739.13
3,369.57

0.00 0.00

0.00 3,369.57
3,369.57
91282CGS4 UNITED STATES TREASURY

3.625 03/31/2030 1,500,000.00
1,493,196.79

0.00 0.00
1,493,350.84
13,668.03

0.00 18,273.57
4,605.53
154.72
(0.67)
154.05
4,759.59
4,759.59
91282CHE4 UNITED STATES TREASURY

3.625 05/31/2028 2,425,000.00
2,407,888.76

0.00 0.00
2,408,646.55
7,445.61

0.00 14,891.22
7,445.61
757.78

0.00 757.78
8,203.39
8,203.39
91282CHX2 UNITED STATES TREASURY

4.375 08/31/2028
09/25/2023
09/26/2023

0.00 398,144.78

0.00 (398,205.68)

0.00 5,849.18
7,085.60

0.00 1,236.42

60.90 0.00

60.90 1,297.32
1,297.32
91282CJF9 UNITED STATES TREASURY

4.875 10/31/2028
10/27/2023
10/31/2023

0.00 601,061.44

0.00 (601,029.08)

0.00 4,927.99
6,994.57

0.00 2,066.58

0.00 (32.35)
(32.35)
2,034.23
2,034.23
91282CJN2 UNITED STATES TREASURY

4.375 11/30/2028
12/28/2023
12/29/2023
625,000.00
632,481.62

0.00 0.00
632,218.96
2,316.00

0.00 4,632.00
2,316.00

0.00 (262.66)
(262.66)
2,053.34
2,053.34
ATTACHMENT A Page 34 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
91282CJR3 UNITED STATES TREASURY

3.75 12/31/2028 2,100,000.00
2,089,098.23

0.00 0.00
2,089,467.99
213.99

0.00 6,847.83
6,633.83
369.75

0.00 369.75
7,003.59
7,003.59
91282CJW2 UNITED STATES TREASURY 4.0
01/31/2029
02/16/2024
02/21/2024
1,500,000.00
1,489,207.85

0.00 0.00
1,489,561.88
25,027.62
30,000.00
163.04
5,135.42
354.03

0.00 354.03
5,489.45
5,489.45
91282CKG5 UNITED STATES TREASURY

4.125 03/31/2029 2,300,000.00
2,280,417.89

0.00 0.00
2,281,022.51
23,848.36

0.00 31,884.22
8,035.86
604.63

0.00 604.63
8,640.49
8,640.49
91282CKP5 UNITED STATES TREASURY

4.625 04/30/2029 2,150,000.00
2,158,115.15

0.00 0.00
2,157,871.85
16,753.06

0.00 25,129.59
8,376.53

0.00 (243.30)
(243.30)
8,133.23
8,133.23
91282CKX8 UNITED STATES TREASURY

4.25 06/30/2029
07/18/2024
07/19/2024
1,000,000.00
1,004,284.44

0.00 0.00
1,004,163.15
115.49

0.00 3,695.65
3,580.16

0.00 (121.29)
(121.29)
3,458.87
3,458.87
91282CLK5 UNITED STATES TREASURY

3.625 08/31/2029
09/11/2024
09/13/2024
2,000,000.00
2,010,021.25

0.00 0.00
2,009,752.74
24,232.34

0.00 30,339.67
6,107.34

0.00 (268.50)
(268.50)
5,838.83
5,838.83
91282CLN9 UNITED STATES TREASURY 3.5
09/30/2029
10/04/2024
10/07/2024
1,000,000.00
992,250.89

0.00 0.00
992,453.27
8,797.81

0.00 11,762.30
2,964.48
202.38

0.00 202.38
3,166.86
3,166.86
91282CMA6 UNITED STATES TREASURY

4.125 11/30/2029
12/16/2024
12/17/2024

0.00 1,494,057.84

0.00 (1,494,181.63)

0.00 5,240.78
9,636.27

0.00 4,395.49
123.80

0.00 123.80
4,519.29
4,519.29
91282CMG3 UNITED STATES TREASURY

4.25 01/31/2030
02/13/2025
02/14/2025

0.00 994,916.70

0.00 (995,017.59)

0.00 17,727.90
20,780.39

0.00 3,052.49
100.89

0.00 100.89
3,153.38
3,153.38
ATTACHMENT A Page 35 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
91282CNK3 UNITED STATES TREASURY

3.875 06/30/2030
07/09/2025
07/10/2025
1,200,000.00
1,196,683.65

0.00 0.00
1,196,754.06
126.36

0.00 4,043.48
3,917.12

70.42 0.00

70.42 3,987.54
3,987.54
91282CNX5 UNITED STATES TREASURY

3.625 08/31/2030 2,250,000.00
2,243,597.92

0.00 0.00
2,243,728.32
27,261.38

0.00 34,132.13
6,870.75
130.40

0.00 130.40
7,001.15
7,001.15
91282CPN5 UNITED STATES TREASURY 3.5
11/30/2030
12/16/2025
12/17/2025
2,500,000.00
2,479,537.26

0.00 0.00
2,479,930.53
7,411.20

0.00 14,822.40
7,411.20
393.27

0.00 393.27
7,804.47
7,804.47
91282CQD6 UNITED STATES TREASURY 3.5
02/28/2031
04/21/2026
04/22/2026
2,000,000.00
1,968,482.97

0.00 0.00
1,969,056.68
23,396.74

0.00 29,293.48
5,896.74
573.71

0.00 573.71
6,470.45
6,470.45
91282CQG9 UNITED STATES TREASURY

3.875 03/31/2031
04/08/2026
04/09/2026
1,000,000.00
998,024.26

0.00 0.00
998,059.58
9,740.44

0.00 13,022.54
3,282.10

35.32 0.00

35.32 3,317.43
3,317.43
92826CAZ5 VISA INC 4.1 02/12/2031
02/03/2026
02/12/2026
590,000.00
589,269.58

0.00 0.00
589,283.00
9,340.03

0.00 11,355.86
2,015.83

13.42 0.00

13.42 2,029.26
2,029.26
92970QAE5 WFCIT 2024-2 A 4.29
10/15/2029
10/17/2024
10/24/2024
515,000.00
514,949.37

0.00 0.00
514,950.68
981.93
1,841.13
981.93
1,841.13

1.31 0.00

1.31 1,842.44
1,842.44
95000U4D2 WELLS FARGO & CO 4.182
01/23/2030
01/15/2026
01/23/2026
580,000.00
580,000.00

0.00 0.00
580,000.00
10,645.51
12,127.80
539.01
2,021.30

0.00 0.00

0.00 2,021.30
2,021.30
Total Fixed Income 82,025,127.21
91,081,827.16
1,938,501.17
(11,633,543.53)
81,404,475.46
708,021.14
375,661.95
625,471.67
293,112.48
21,233.30
(3,542.65)
17,690.66
310,803.14 310,803.14
ATTACHMENT A Page 36 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

INCOME EARNED
Cusip Security Description
Trade Date
Settle Date
Units
Book Value: Begin
Book Value: Acq
Book Value: Disp
Book Value: End
Prior Accrued
Inc. Received
Ending Accrued
Total Interest
Accr. Of Discount
Amort. Of Premium
Net Accret/Amort
Income Earned
Total Income
TOTAL PORTFOLIO 82,400,542.14
91,387,383.83
13,184,828.70
(22,811,162.96)
81,779,890.39
708,021.14
376,136.42
625,471.67
293,586.95
21,233.30
(3,542.65)
17,690.66
311,277.61 311,277.61
ATTACHMENT A Page 37 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount AUGUST 2026
08/03/2026 Coupon 13063EGT7 0.00 CALIFORNIA STATE 4.5 08/01/2029 21,712.50 21,712.50 08/07/2026 Coupon 63743HFX5 1,000,000.00 NATIONAL RURAL UTILITIES COOPERATIVE FINANCE CORP 4.95 02/07/2030 24,750.00 24,750.00
08/12/2026 Coupon 92826CAZ5 590,000.00 VISA INC 4.1 02/12/2031 12,095.00 12,095.00 08/17/2026 Coupon 02079KBK2 1,000,000.00 ALPHABET INC 4.1 02/15/2031 20,727.78 20,727.78 08/17/2026 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 08/17/2026 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 08/17/2026 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 08/17/2026 Coupon 161571HT4 965,000.00 CHAIT 2023-1 A 5.16 09/15/2028 4,149.50 4,149.50 08/17/2026 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 08/17/2026 Coupon 171239AL0 505,000.00 CHUBB INA HOLDINGS LLC 4.65 08/15/2029 11,741.25 11,741.25 08/17/2026 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 1,409.76 1,409.76 08/17/2026 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 17,794.42 17,794.42 08/17/2026 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 08/17/2026 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 2,070.00 2,070.00 08/17/2026 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 08/17/2026 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 1,542.07 1,542.07 08/17/2026 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 20,836.82 20,836.82 08/17/2026 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,621.50 1,621.50 08/17/2026 Coupon 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 555.43 555.43 08/17/2026 Principal Paydown 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 23,580.68 23,580.68 08/17/2026 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 2,170.92 2,170.92 08/17/2026 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 19,057.34 19,057.34 08/17/2026 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 2,184.67 2,184.67 08/17/2026 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 7,511.33 7,511.33 08/17/2026 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 08/18/2026 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 825.85 825.85 08/18/2026 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 14,918.67 14,918.67 08/20/2026 Coupon 36269WAD1 2,821.80 GMALT 2024-2 A3 5.39 07/20/2027 12.67 12.67 08/20/2026 Effective Maturity 36269WAD1 2,821.80 GMALT 2024-2 A3 5.39 07/20/2027 2,821.80 2,821.80 08/20/2026 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 1,679.33 1,679.33 ATTACHMENT A Page 38 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 08/21/2026 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,742.44 1,742.44 08/21/2026 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 31,958.05 31,958.05 08/25/2026 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 1,132.61 1,132.61 08/25/2026 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 18,720.97 18,720.97 08/25/2026 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 2,686.67 2,686.67 08/25/2026 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 08/25/2026 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,900.00 3,900.00 08/25/2026 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 08/25/2026 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 08/25/2026 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 08/25/2026 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 08/25/2026 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 08/31/2026 Coupon 91282CGP0 2,500,000.00 UNITED STATES TREASURY 4.0 02/29/2028 50,000.00 50,000.00 08/31/2026 Coupon 91282CGQ8 1,000,000.00 UNITED STATES TREASURY 4.0 02/28/2030 20,000.00 20,000.00 08/31/2026 Coupon 91282CLK5 2,000,000.00 UNITED STATES TREASURY 3.625 08/31/2029 36,250.00 36,250.00 08/31/2026 Coupon 91282CNX5 2,250,000.00 UNITED STATES TREASURY 3.625 08/31/2030 40,781.25 40,781.25 08/31/2026 Coupon 91282CQD6 2,000,000.00 UNITED STATES TREASURY 3.5 02/28/2031 35,000.00 35,000.00 August 2026 Total 157,200.07 337,249.87 494,449.93
SEPTEMBER 2026
09/15/2026 Coupon 00287YDZ9 1,000,000.00 ABBVIE INC 4.875 03/15/2030 24,375.00 24,375.00 09/15/2026 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 09/15/2026 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 09/15/2026 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 09/15/2026 Coupon 084664CZ2 1,080,000.00 BERKSHIRE HATHAWAY FINANCE CORP 2.3 03/15/2027 12,420.00 12,420.00
09/15/2026 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 6,828.27 6,828.27 09/15/2026 Coupon 161571HT4 965,000.00 CHAIT 2023-1 A 5.16 09/15/2028 4,149.50 4,149.50 09/15/2026 Effective Maturity 161571HT4 965,000.00 CHAIT 2023-1 A 5.16 09/15/2028 965,000.00 965,000.00 09/15/2026 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 09/15/2026 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 09/15/2026 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 2,070.00 2,070.00 09/15/2026 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 ATTACHMENT A Page 39 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 09/15/2026 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 1,451.78 1,451.78 09/15/2026 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 23,033.12 23,033.12 09/15/2026 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,621.50 1,621.50 09/15/2026 Coupon 571748CA8 1,000,000.00 MARSH & MCLENNAN COMPANIES INC 4.65 03/15/2030 23,250.00 23,250.00
09/15/2026 Coupon 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 450.89 450.89 09/15/2026 Principal Paydown 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 25,275.69 25,275.69 09/15/2026 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 2,095.00 2,095.00 09/15/2026 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 26,741.53 26,741.53 09/15/2026 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 2,155.62 2,155.62 09/15/2026 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 32,456.95 32,456.95 09/15/2026 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 09/16/2026 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 1,341.25 1,341.25 09/16/2026 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 19,906.51 19,906.51 09/18/2026 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 760.33 760.33 09/18/2026 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 14,614.94 14,614.94 09/21/2026 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 1,679.33 1,679.33 09/21/2026 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,620.73 1,620.73 09/21/2026 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 31,276.85 31,276.85 09/24/2026 Coupon 46647PBJ4 1,000,000.00 JPMORGAN CHASE & CO 4.493 03/24/2031 22,465.00 22,465.00 09/25/2026 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 1,051.80 1,051.80 09/25/2026 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 18,385.43 18,385.43 09/25/2026 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 2,686.67 2,686.67 09/25/2026 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 09/25/2026 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,900.00 3,900.00 09/25/2026 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 177.01 177.01 09/25/2026 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 09/25/2026 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 09/25/2026 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 09/25/2026 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 09/25/2026 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 09/28/2026 Coupon 69371RT48 600,000.00 PACCAR FINANCIAL CORP 4.0 09/26/2029 12,000.00 12,000.00 ATTACHMENT A Page 40 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 09/28/2026 Coupon 743315AW3 1,000,000.00 PROGRESSIVE CORP 3.2 03/26/2030 16,000.00 16,000.00 09/30/2026 Coupon 91282CCZ2 1,150,000.00 UNITED STATES TREASURY 0.875 09/30/2026 5,031.25 5,031.25 09/30/2026 Final Maturity 91282CCZ2 1,150,000.00 UNITED STATES TREASURY 0.875 09/30/2026 1,150,000.00 1,150,000.00 09/30/2026 Coupon 91282CGS4 1,500,000.00 UNITED STATES TREASURY 3.625 03/31/2030 27,187.50 27,187.50 09/30/2026 Coupon 91282CKG5 2,300,000.00 UNITED STATES TREASURY 4.125 03/31/2029 47,437.50 47,437.50 09/30/2026 Coupon 91282CLN9 1,000,000.00 UNITED STATES TREASURY 3.5 09/30/2029 17,500.00 17,500.00 09/30/2026 Coupon 91282CQG9 1,000,000.00 UNITED STATES TREASURY 3.875 03/31/2031 19,375.00 19,375.00 September 2026
Total 2,306,868.05 297,412.60 2,604,280.64
OCTOBER 2026
10/15/2026 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 10/15/2026 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 10/15/2026 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 10/15/2026 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 10/15/2026 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 10/15/2026 Coupon 24422EYF0 1,000,000.00 JOHN DEERE CAPITAL CORP 4.375 10/15/2030 21,875.00 21,875.00 10/15/2026 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 10/15/2026 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 2,070.00 2,070.00 10/15/2026 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 10/15/2026 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 1,351.97 1,351.97 10/15/2026 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 21,851.89 21,851.89 10/15/2026 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,621.50 1,621.50 10/15/2026 Coupon 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 338.83 338.83 10/15/2026 Principal Paydown 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 26,384.03 26,384.03 10/15/2026 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,988.48 1,988.48 10/15/2026 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 25,607.54 25,607.54 10/15/2026 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 2,030.12 2,030.12 10/15/2026 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 31,077.88 31,077.88 10/15/2026 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 10/16/2026 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 1,264.61 1,264.61 10/16/2026 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 19,086.72 19,086.72 10/19/2026 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 696.14 696.14 ATTACHMENT A Page 41 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 10/19/2026 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 14,101.82 14,101.82 10/19/2026 Coupon 61748UAK8 695,000.00 MORGAN STANLEY 4.133 10/18/2029 14,362.18 14,362.18 10/20/2026 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 1,679.33 1,679.33 10/20/2026 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 40,433.42 40,433.42 10/21/2026 Coupon 38141GD27 735,000.00 GOLDMAN SACHS GROUP INC 4.153 10/21/2029 15,262.28 15,262.28
10/21/2026 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,501.62 1,501.62 10/21/2026 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 30,091.97 30,091.97 10/26/2026 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 972.44 972.44 10/26/2026 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 16,830.02 16,830.02 10/26/2026 Coupon 3133EPGW9 950,000.00 FEDERAL FARM CREDIT BANKS FUNDING CORP

3.875 04/25/2028 18,406.25 18,406.25
10/26/2026 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 2,686.67 2,686.67 10/26/2026 Principal Paydown 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 10,457.92 10,457.92 10/26/2026 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 10/26/2026 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,899.42 3,899.42 10/26/2026 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,801.99 1,801.99 10/26/2026 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 10/26/2026 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 10/26/2026 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 10/26/2026 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 10/26/2026 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 10/26/2026 Coupon 857477DB6 1,000,000.00 STATE STREET CORP 4.834 04/24/2030 24,170.00 24,170.00 October 2026 Total 237,725.23 156,157.52 393,882.75
NOVEMBER 2026
11/02/2026 Coupon 91282CKP5 2,150,000.00 UNITED STATES TREASURY 4.625 04/30/2029 49,718.75 49,718.75 11/16/2026 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 11/16/2026 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 11/16/2026 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 11/16/2026 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 11/16/2026 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 11/16/2026 Coupon 30303MAB8 750,000.00 META PLATFORMS INC 4.2 11/15/2030 15,750.00 15,750.00 ATTACHMENT A Page 42 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 11/16/2026 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 1,191.12 1,191.12 11/16/2026 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 18,680.34 18,680.34 11/16/2026 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 11/16/2026 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 2,070.00 2,070.00 11/16/2026 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 28,392.04 28,392.04 11/16/2026 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 11/16/2026 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 1,257.28 1,257.28 11/16/2026 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 25,904.24 25,904.24 11/16/2026 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,621.50 1,621.50 11/16/2026 Coupon 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 221.86 221.86 11/16/2026 Principal Paydown 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 20,381.74 20,381.74 11/16/2026 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,886.48 1,886.48 11/16/2026 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 25,118.12 25,118.12 11/16/2026 Coupon 717081FD0 900,000.00 PFIZER INC 4.2 11/15/2030 18,900.00 18,900.00 11/16/2026 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,909.95 1,909.95 11/16/2026 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 30,382.53 30,382.53 11/16/2026 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 11/18/2026 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 634.21 634.21 11/18/2026 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 13,792.03 13,792.03 11/19/2026 Coupon 665859AY0 850,000.00 NORTHERN TRUST CORP 4.15 11/19/2030 17,637.50 17,637.50 11/20/2026 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 1,525.01 1,525.01 11/20/2026 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 48,065.59 48,065.59 11/20/2026 Coupon 532457DL9 310,000.00 ELI LILLY AND CO 4.375 05/20/2031 6,781.25 6,781.25 11/23/2026 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,387.02 1,387.02 11/23/2026 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 29,362.62 29,362.62 11/25/2026 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 899.79 899.79 11/25/2026 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 16,505.21 16,505.21 11/25/2026 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 2,658.57 2,658.57 11/25/2026 Principal Paydown 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 156,258.11 156,258.11 11/25/2026 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 11/25/2026 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,893.57 3,893.57 11/25/2026 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,674.64 1,674.64 ATTACHMENT A Page 43 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 11/25/2026 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 11/25/2026 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 11/25/2026 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 11/25/2026 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 11/25/2026 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 11/30/2026 Coupon 91282CHE4 2,425,000.00 UNITED STATES TREASURY 3.625 05/31/2028 43,953.13 43,953.13 11/30/2026 Coupon 91282CJN2 625,000.00 UNITED STATES TREASURY 4.375 11/30/2028 13,671.88 13,671.88 11/30/2026 Coupon 91282CPN5 2,500,000.00 UNITED STATES TREASURY 3.5 11/30/2030 43,750.00 43,750.00 November 2026
Total 414,517.22 271,299.55 685,816.77
DECEMBER 2026
12/15/2026 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 12/15/2026 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 12/15/2026 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 12/15/2026 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 12/15/2026 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 12/15/2026 Coupon 341081GT8 1,000,000.00 FLORIDA POWER & LIGHT CO 5.15 06/15/2029 25,750.00 25,750.00 12/15/2026 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 12/15/2026 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,967.79 1,967.79 12/15/2026 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 32,179.78 32,179.78 12/15/2026 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 12/15/2026 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 1,145.02 1,145.02 12/15/2026 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 17,125.01 17,125.01 12/15/2026 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,621.50 1,621.50 12/15/2026 Coupon 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 131.50 131.50 12/15/2026 Principal Paydown 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 21,967.39 21,967.39 12/15/2026 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,786.43 1,786.43 12/15/2026 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 23,689.81 23,689.81 12/15/2026 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,792.48 1,792.48 12/15/2026 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 28,543.49 28,543.49 12/15/2026 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 12/16/2026 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 1,119.20 1,119.20 ATTACHMENT A Page 44 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 12/16/2026 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 17,645.93 17,645.93 12/18/2026 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 573.64 573.64 12/18/2026 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 11,190.51 11,190.51 12/21/2026 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 1,341.56 1,341.56 12/21/2026 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 61,049.80 61,049.80 12/21/2026 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,275.19 1,275.19 12/21/2026 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 28,001.64 28,001.64 12/25/2026 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 828.54 828.54 12/25/2026 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 15,751.44 15,751.44 12/25/2026 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 2,238.76 2,238.76 12/25/2026 Principal Paydown 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 152,841.29 152,841.29 12/25/2026 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 12/25/2026 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,888.13 3,888.13 12/25/2026 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,811.71 1,811.71 12/25/2026 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 12/25/2026 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 12/25/2026 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 12/25/2026 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 12/25/2026 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 12/31/2026 Coupon 91282CEW7 2,250,000.00 UNITED STATES TREASURY 3.25 06/30/2027 36,562.50 36,562.50 12/31/2026 Coupon 91282CGC9 300,000.00 UNITED STATES TREASURY 3.875 12/31/2027 5,812.50 5,812.50 12/31/2026 Coupon 91282CJR3 2,100,000.00 UNITED STATES TREASURY 3.75 12/31/2028 39,375.00 39,375.00 12/31/2026 Coupon 91282CKX8 1,000,000.00 UNITED STATES TREASURY 4.25 06/30/2029 21,250.00 21,250.00 12/31/2026 Coupon 91282CNK3 1,200,000.00 UNITED STATES TREASURY 3.875 06/30/2030 23,250.00 23,250.00 December 2026
Total 411,797.80 211,690.43 623,488.22
JANUARY 2027
01/04/2027 Coupon 74456QCX2 750,000.00 PUBLIC SERVICE ELECTRIC AND GAS CO 4.2 01/01/2031 15,750.00 15,750.00
01/08/2027 Coupon 14913UBH2 880,000.00 CATERPILLAR FINANCIAL SERVICES CORP 4.15 01/08/2031 18,260.00 18,260.00
01/11/2027 Coupon 023135EC6 1,010,000.00 AMAZON.COM INC 4.8 07/09/2031 24,240.00 24,240.00 ATTACHMENT A Page 45 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 01/11/2027 Coupon 89236TPH2 475,000.00 TOYOTA MOTOR CREDIT CORP 4.2 01/10/2031 9,975.00 9,975.00 01/15/2027 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 01/15/2027 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 01/15/2027 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 01/15/2027 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 01/15/2027 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 01/15/2027 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 01/15/2027 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,851.94 1,851.94 01/15/2027 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 31,482.06 31,482.06 01/15/2027 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 01/15/2027 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 1,070.81 1,070.81 01/15/2027 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 24,537.21 24,537.21 01/15/2027 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,621.50 1,621.50 01/15/2027 Principal Paydown 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 487.01 487.01 01/15/2027 Coupon 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 34.11 34.11 01/15/2027 Effective Maturity 58770JAD6 138,775.82 MBALT 2024-A A3 5.32 01/18/2028 7,694.90 7,694.90 01/15/2027 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,692.06 1,692.06 01/15/2027 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 23,304.77 23,304.77 01/15/2027 Coupon 756109AX2 1,000,000.00 REALTY INCOME CORP 3.25 01/15/2031 16,250.00 16,250.00 01/15/2027 Coupon 828807DK0 1,000,000.00 SIMON PROPERTY GROUP LP 2.65 07/15/2030 13,250.00 13,250.00 01/15/2027 Coupon 87612EBM7 535,000.00 TARGET CORP 1.95 01/15/2027 5,216.25 5,216.25 01/15/2027 Final Maturity 87612EBM7 535,000.00 TARGET CORP 1.95 01/15/2027 535,000.00 535,000.00 01/15/2027 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,682.11 1,682.11 01/15/2027 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 26,799.46 26,799.46 01/15/2027 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 01/18/2027 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 1,051.27 1,051.27 01/18/2027 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 17,342.49 17,342.49 01/18/2027 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 524.50 524.50 01/18/2027 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 10,979.96 10,979.96 01/19/2027 Coupon 713448FX1 830,000.00 PEPSICO INC 4.5 07/17/2029 18,675.00 18,675.00 01/20/2027 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 1,108.56 1,108.56 01/20/2027 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 62,549.40 62,549.40 ATTACHMENT A Page 46 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 01/21/2027 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,168.56 1,168.56 01/21/2027 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 27,415.44 27,415.44 01/25/2027 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 760.54 760.54 01/25/2027 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 15,490.37 15,490.37 01/25/2027 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 1,828.12 1,828.12 01/25/2027 Principal Paydown 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 255,543.76 255,543.76 01/25/2027 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 01/25/2027 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,882.24 3,882.24 01/25/2027 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,685.08 1,685.08 01/25/2027 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 01/25/2027 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 01/25/2027 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 01/25/2027 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 01/25/2027 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 01/25/2027 Coupon 95000U4D2 580,000.00 WELLS FARGO & CO 4.182 01/23/2030 12,127.80 12,127.80 January 2027 Total 1,040,311.93 192,001.06 1,232,312.99 FEBRUARY 2027
02/01/2027 Coupon 13063EGT7 965,000.00 CALIFORNIA STATE 4.5 08/01/2029 21,712.50 21,712.50 02/01/2027 Coupon 91282CFB2 600,000.00 UNITED STATES TREASURY 2.75 07/31/2027 8,250.00 8,250.00 02/01/2027 Coupon 91282CGH8 2,500,000.00 UNITED STATES TREASURY 3.5 01/31/2028 43,750.00 43,750.00 02/01/2027 Coupon 91282CJW2 1,500,000.00 UNITED STATES TREASURY 4.0 01/31/2029 30,000.00 30,000.00 02/08/2027 Coupon 63743HFX5 1,000,000.00 NATIONAL RURAL UTILITIES COOPERATIVE FINANCE CORP 4.95 02/07/2030 24,750.00 24,750.00
02/12/2027 Coupon 92826CAZ5 590,000.00 VISA INC 4.1 02/12/2031 12,095.00 12,095.00 02/15/2027 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 02/15/2027 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 1,037.50 1,037.50 02/15/2027 Principal Paydown 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 17,921.67 17,921.67 02/15/2027 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,738.61 1,738.61 02/15/2027 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 31,161.62 31,161.62 02/15/2027 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 02/15/2027 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 964.49 964.49 02/15/2027 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 22,236.10 22,236.10 ATTACHMENT A Page 47 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 02/15/2027 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,619.78 1,619.78 02/15/2027 Principal Paydown 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 31,718.38 31,718.38 02/15/2027 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,599.23 1,599.23 02/15/2027 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 23,103.58 23,103.58 02/15/2027 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,578.48 1,578.48 02/15/2027 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 26,513.82 26,513.82 02/16/2027 Coupon 02079KBK2 1,000,000.00 ALPHABET INC 4.1 02/15/2031 20,500.00 20,500.00 02/16/2027 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 02/16/2027 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 02/16/2027 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 02/16/2027 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 02/16/2027 Coupon 171239AL0 505,000.00 CHUBB INA HOLDINGS LLC 4.65 08/15/2029 11,741.25 11,741.25 02/16/2027 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 984.50 984.50 02/16/2027 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 16,328.91 16,328.91 02/16/2027 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 02/18/2027 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 476.28 476.28 02/18/2027 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 10,823.96 10,823.96 02/22/2027 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 869.83 869.83 02/22/2027 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 50,626.40 50,626.40 02/22/2027 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 1,064.15 1,064.15 02/22/2027 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 26,943.53 26,943.53 02/25/2027 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 693.68 693.68 02/25/2027 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 15,309.07 15,309.07 02/25/2027 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 1,141.56 1,141.56 02/25/2027 Principal Paydown 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 279,790.28 279,790.28 02/25/2027 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 02/25/2027 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,876.76 3,876.76 02/25/2027 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,690.07 1,690.07 02/25/2027 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 02/25/2027 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 02/25/2027 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 02/25/2027 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 ATTACHMENT A Page 48 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 02/25/2027 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 February 2027
Total 554,167.39 229,386.78 783,554.17
MARCH 2027
03/01/2027 Coupon 91282CGP0 2,500,000.00 UNITED STATES TREASURY 4.0 02/29/2028 50,000.00 50,000.00 03/01/2027 Coupon 91282CGQ8 1,000,000.00 UNITED STATES TREASURY 4.0 02/28/2030 20,000.00 20,000.00 03/01/2027 Coupon 91282CLK5 2,000,000.00 UNITED STATES TREASURY 3.625 08/31/2029 36,250.00 36,250.00 03/01/2027 Coupon 91282CNX5 2,250,000.00 UNITED STATES TREASURY 3.625 08/31/2030 40,781.25 40,781.25 03/01/2027 Coupon 91282CQD6 2,000,000.00 UNITED STATES TREASURY 3.5 02/28/2031 35,000.00 35,000.00 03/15/2027 Coupon 00287YDZ9 1,000,000.00 ABBVIE INC 4.875 03/15/2030 24,375.00 24,375.00 03/15/2027 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 03/15/2027 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 03/15/2027 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 03/15/2027 Coupon 084664CZ2 1,080,000.00 BERKSHIRE HATHAWAY FINANCE CORP 2.3 03/15/2027 12,420.00 12,420.00
03/15/2027 Final Maturity 084664CZ2 1,080,000.00 BERKSHIRE HATHAWAY FINANCE CORP 2.3 03/15/2027 1,080,000.00 1,080,000.00
03/15/2027 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 03/15/2027 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 03/15/2027 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 975.52 975.52 03/15/2027 Principal Paydown 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 17,561.75 17,561.75 03/15/2027 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,626.42 1,626.42 03/15/2027 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 30,230.91 30,230.91 03/15/2027 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 03/15/2027 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 868.13 868.13 03/15/2027 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 21,926.01 21,926.01 03/15/2027 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,507.98 1,507.98 03/15/2027 Principal Paydown 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 23,086.37 23,086.37 03/15/2027 Coupon 571748CA8 1,000,000.00 MARSH & MCLENNAN COMPANIES INC 4.65 03/15/2030 23,250.00 23,250.00
03/15/2027 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,507.20 1,507.20 03/15/2027 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 22,432.68 22,432.68 ATTACHMENT A Page 49 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 03/15/2027 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,475.96 1,475.96 03/15/2027 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 25,734.56 25,734.56 03/15/2027 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 03/16/2027 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 921.63 921.63 03/16/2027 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 15,762.15 15,762.15 03/18/2027 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 428.74 428.74 03/18/2027 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 10,521.88 10,521.88 03/22/2027 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 676.60 676.60 03/22/2027 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 44,989.59 44,989.59 03/22/2027 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 961.54 961.54 03/22/2027 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 26,164.46 26,164.46 03/24/2027 Coupon 46647PBJ4 1,000,000.00 JPMORGAN CHASE & CO 4.493 03/24/2031 22,465.00 22,465.00 03/25/2027 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 627.59 627.59 03/25/2027 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 13,518.98 13,518.98 03/25/2027 Coupon 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 389.86 389.86 03/25/2027 Final Maturity 3137BXQY1 1,000,000.00 FHMS K-064 A2 3.224 03/25/2027 145,108.64 145,108.64 03/25/2027 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 03/25/2027 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,871.27 3,871.27 03/25/2027 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 2,088.24 2,088.24 03/25/2027 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 03/25/2027 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 03/25/2027 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 03/25/2027 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 03/25/2027 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 03/26/2027 Coupon 69371RT48 600,000.00 PACCAR FINANCIAL CORP 4.0 09/26/2029 12,000.00 12,000.00 03/26/2027 Coupon 743315AW3 1,000,000.00 PROGRESSIVE CORP 3.2 03/26/2030 16,000.00 16,000.00 03/31/2027 Coupon 91282CGS4 1,500,000.00 UNITED STATES TREASURY 3.625 03/31/2030 27,187.50 27,187.50 03/31/2027 Coupon 91282CKG5 2,300,000.00 UNITED STATES TREASURY 4.125 03/31/2029 47,437.50 47,437.50 03/31/2027 Coupon 91282CLN9 1,000,000.00 UNITED STATES TREASURY 3.5 09/30/2029 17,500.00 17,500.00 03/31/2027 Coupon 91282CQG9 1,000,000.00 UNITED STATES TREASURY 3.875 03/31/2031 19,375.00 19,375.00 March 2027 Total 1,479,126.22 458,822.89 1,937,949.11
APRIL 2027
ATTACHMENT A Page 50 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 04/15/2027 Coupon 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 3,138.00 3,138.00 04/15/2027 Effective Maturity 02582JKH2 720,000.00 AMXCA 2024-1 A 5.23 04/16/2029 720,000.00 720,000.00 04/15/2027 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 04/15/2027 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 04/15/2027 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 04/15/2027 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 04/15/2027 Coupon 24422EYF0 1,000,000.00 JOHN DEERE CAPITAL CORP 4.375 10/15/2030 21,875.00 21,875.00 04/15/2027 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 914.79 914.79 04/15/2027 Principal Paydown 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 18,175.47 18,175.47 04/15/2027 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,517.59 1,517.59 04/15/2027 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 31,552.54 31,552.54 04/15/2027 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 04/15/2027 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 773.12 773.12 04/15/2027 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 23,188.20 23,188.20 04/15/2027 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,426.60 1,426.60 04/15/2027 Principal Paydown 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 27,663.17 27,663.17 04/15/2027 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,417.85 1,417.85 04/15/2027 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 23,493.73 23,493.73 04/15/2027 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,376.46 1,376.46 04/15/2027 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 26,773.88 26,773.88 04/15/2027 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 04/16/2027 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 860.95 860.95 04/16/2027 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 16,493.01 16,493.01 04/19/2027 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 382.53 382.53 04/19/2027 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 10,747.85 10,747.85 04/19/2027 Coupon 61748UAK8 695,000.00 MORGAN STANLEY 4.133 10/18/2029 14,362.18 14,362.18 04/20/2027 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 504.89 504.89 04/20/2027 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 43,996.66 43,996.66 04/21/2027 Coupon 38141GD27 735,000.00 GOLDMAN SACHS GROUP INC 4.153 10/21/2029 15,262.28 15,262.28
04/21/2027 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 861.89 861.89 04/21/2027 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 20,689.89 20,689.89 ATTACHMENT A Page 51 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 04/26/2027 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 569.24 569.24 04/26/2027 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 13,786.45 13,786.45 04/26/2027 Coupon 3133EPGW9 950,000.00 FEDERAL FARM CREDIT BANKS FUNDING CORP

3.875 04/25/2028 18,406.25 18,406.25
04/26/2027 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 04/26/2027 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,864.48 3,864.48 04/26/2027 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,701.60 1,701.60 04/26/2027 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 04/26/2027 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 04/26/2027 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 04/26/2027 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 04/26/2027 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 04/26/2027 Coupon 857477DB6 1,000,000.00 STATE STREET CORP 4.834 04/24/2030 24,170.00 24,170.00 04/30/2027 Coupon 91282CKP5 2,150,000.00 UNITED STATES TREASURY 4.625 04/30/2029 49,718.75 49,718.75 April 2027 Total 978,262.46 197,208.02 1,175,470.48
MAY 2027
05/17/2027 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 05/17/2027 Coupon 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 1,889.83 1,889.83 05/17/2027 Effective Maturity 05522RDJ4 460,000.00 BACCT 2024-1 A 4.93 05/15/2029 460,000.00 460,000.00 05/17/2027 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 05/17/2027 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 05/17/2027 Coupon 30303MAB8 750,000.00 META PLATFORMS INC 4.2 11/15/2030 15,750.00 15,750.00 05/17/2027 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 797.45 797.45 05/17/2027 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 15,842.33 15,842.33 05/17/2027 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 851.93 851.93 05/17/2027 Principal Paydown 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 17,460.04 17,460.04 05/17/2027 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,404.00 1,404.00 05/17/2027 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 30,298.41 30,298.41 05/17/2027 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 05/17/2027 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 672.64 672.64 05/17/2027 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 20,426.61 20,426.61 05/17/2027 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,329.08 1,329.08 ATTACHMENT A Page 52 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 05/17/2027 Principal Paydown 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 28,940.72 28,940.72 05/17/2027 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,324.26 1,324.26 05/17/2027 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 22,573.77 22,573.77 05/17/2027 Coupon 717081FD0 900,000.00 PFIZER INC 4.2 11/15/2030 18,900.00 18,900.00 05/17/2027 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,272.93 1,272.93 05/17/2027 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 25,731.67 25,731.67 05/17/2027 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 05/18/2027 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 335.33 335.33 05/18/2027 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 10,365.90 10,365.90 05/19/2027 Coupon 665859AY0 850,000.00 NORTHERN TRUST CORP 4.15 11/19/2030 17,637.50 17,637.50 05/20/2027 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 336.97 336.97 05/20/2027 Principal Paydown 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 43,890.62 43,890.62 05/20/2027 Coupon 532457DL9 310,000.00 ELI LILLY AND CO 4.375 05/20/2031 6,781.25 6,781.25 05/21/2027 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 783.10 783.10 05/21/2027 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 19,902.14 19,902.14 05/25/2027 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 509.72 509.72 05/25/2027 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 13,306.05 13,306.05 05/25/2027 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 05/25/2027 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,858.95 3,858.95 05/25/2027 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,836.93 1,836.93 05/25/2027 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 05/25/2027 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 05/25/2027 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 05/25/2027 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 05/25/2027 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 May 2027 Total 710,575.19 108,350.31 818,925.50
JUNE 2027
06/01/2027 Coupon 91282CHE4 2,425,000.00 UNITED STATES TREASURY 3.625 05/31/2028 43,953.13 43,953.13 06/01/2027 Coupon 91282CJN2 625,000.00 UNITED STATES TREASURY 4.375 11/30/2028 13,671.88 13,671.88 06/01/2027 Coupon 91282CPN5 2,500,000.00 UNITED STATES TREASURY 3.5 11/30/2030 43,750.00 43,750.00 06/15/2027 Coupon 02582JKP4 790,000.00 AMXCA 2025-2 A 4.28 04/15/2030 2,817.67 2,817.67 06/15/2027 Coupon 14041NGJ4 930,000.00 COMET 2026-1 A 4.48 07/16/2029 3,472.00 3,472.00 ATTACHMENT A Page 53 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 06/15/2027 Coupon 161571JA3 700,000.00 CHAIT 2026-1 A 4.4 05/15/2029 2,566.67 2,566.67 06/15/2027 Coupon 341081GT8 1,000,000.00 FLORIDA POWER & LIGHT CO 5.15 06/15/2029 25,750.00 25,750.00 06/15/2027 Coupon 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 791.55 791.55 06/15/2027 Principal Paydown 437921AD1 300,000.00 HAROT 252 A3 4.15 10/15/2029 17,148.48 17,148.48 06/15/2027 Coupon 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 1,294.93 1,294.93 06/15/2027 Principal Paydown 44935CAD3 575,000.00 HART 2025-A A3 4.32 10/15/2029 29,827.57 29,827.57 06/15/2027 Coupon 44935KAD5 510,000.00 HART 26B A3 4.51 02/18/2031 1,916.75 1,916.75 06/15/2027 Coupon 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 584.12 584.12 06/15/2027 Principal Paydown 47786WAD2 358,475.92 JDOT 2024-B A3 5.2 03/15/2029 11,453.05 11,453.05 06/15/2027 Coupon 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 1,227.07 1,227.07 06/15/2027 Principal Paydown 47800DAD6 460,000.00 JDOT 2025 A3 4.23 09/17/2029 26,410.62 26,410.62 06/15/2027 Coupon 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 1,234.34 1,234.34 06/15/2027 Principal Paydown 58773DAD6 545,000.00 MBART 2025-1 A3 4.78 12/17/2029 22,254.03 22,254.03 06/15/2027 Coupon 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 1,173.43 1,173.43 06/15/2027 Principal Paydown 89240JAD3 565,000.00 TAOT 2025-A A3 4.64 08/15/2029 25,321.37 25,321.37 06/15/2027 Coupon 92970QAE5 515,000.00 WFCIT 2024-2 A 4.29 10/15/2029 1,841.13 1,841.13 06/16/2027 Coupon 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 736.46 736.46 06/16/2027 Principal Paydown 362955AD8 363,113.26 GMCAR 2025-1 A3 4.62 12/17/2029 15,610.98 15,610.98 06/18/2027 Coupon 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 289.81 289.81 06/18/2027 Principal Paydown 437930AC4 176,330.45 HAROT 2024-2 A3 5.27 11/20/2028 10,166.39 10,166.39 06/21/2027 Coupon 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 169.45 169.45 06/21/2027 Effective Maturity 362962AD4 440,000.00 GMALT 2025-2 A3 4.58 05/22/2028 44,398.51 44,398.51 06/21/2027 Coupon 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 707.31 707.31 06/21/2027 Principal Paydown 43813YAC6 413,756.15 HAROT 2024-3 A3 4.57 03/21/2029 19,504.26 19,504.26 06/25/2027 Coupon 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 452.29 452.29 06/25/2027 Principal Paydown 096919AD7 233,296.82 BMWOT 2024-A A3 5.18 02/26/2029 13,095.21 13,095.21 06/25/2027 Coupon 3137F83Q4 2,000,000.00 FHMS K-121 A2 1.547 10/25/2030 2,578.33 2,578.33 06/25/2027 Coupon 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 3,852.98 3,852.98 06/25/2027 Principal Paydown 3137FEZU7 1,200,000.00 FHMS K-076 A2 3.9 04/25/2028 1,712.15 1,712.15 06/25/2027 Coupon 3137FLMV3 1,000,000.00 FHMS K-090 A2 3.422 02/25/2029 2,851.67 2,851.67 06/25/2027 Coupon 3137FRUT6 1,000,000.00 FHMS K-106 A2 2.069 01/25/2030 1,724.17 1,724.17 06/25/2027 Coupon 3137FXZ35 1,000,000.00 FHMS K-127 A2 2.108 01/25/2031 1,756.67 1,756.67 ATTACHMENT A Page 54 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

CASH FLOW REPORT
Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 06/25/2027 Coupon 3137H5YC5 1,500,000.00 FHMS K-748 A2 2.26 01/25/2029 2,825.00 2,825.00 06/25/2027 Coupon 3137HBC51 2,323,557.00 FHMS K-754 A2 4.94 11/25/2030 9,565.31 9,565.31 06/30/2027 Coupon 91282CEW7 2,250,000.00 UNITED STATES TREASURY 3.25 06/30/2027 36,562.50 36,562.50 06/30/2027 Final Maturity 91282CEW7 2,250,000.00 UNITED STATES TREASURY 3.25 06/30/2027 2,250,000.00 2,250,000.00 06/30/2027 Coupon 91282CGC9 300,000.00 UNITED STATES TREASURY 3.875 12/31/2027 5,812.50 5,812.50 06/30/2027 Coupon 91282CJR3 2,100,000.00 UNITED STATES TREASURY 3.75 12/31/2028 39,375.00 39,375.00 06/30/2027 Coupon 91282CKX8 1,000,000.00 UNITED STATES TREASURY 4.25 06/30/2029 21,250.00 21,250.00 06/30/2027 Coupon 91282CNK3 1,200,000.00 UNITED STATES TREASURY 3.875 06/30/2030 23,250.00 23,250.00 June 2027 Total 2,486,902.60 299,804.09 2,786,706.70
Grand Total 393,724,477.37 10,777,454.16 2,759,383.10 13,536,837.26 ATTACHMENT A Page 55 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

IMPORTANT DISCLOSURES
Chandler Asset Management, Inc. (“Chandler”) is an SEC registered investment adviser. For additional information about our firm, please see our current disclosures (Form ADV).

To obtain a copy of our current disclosures, you may contact your client service representative by calling the number on the front of this statement or you may visit our website at www.chandlerasset.com.

Information contained in this monthly statement is confidential and is provided for informational purposes only and should not be construed as specific investment or legal advice. The information contained herein was obtained from sources believed to be reliable as of the date of this statement, but may become outdated or superseded at any time without notice.

Custody: Your qualified custodian bank maintains control of all assets reflected in this statement and we urge you to compare this statement to the one you receive from your qualified custodian. Chandler does not have any authority to withdraw or deposit funds from/to the custodian account.

Valuation: Prices are provided by IDC, an independent pricing source. In the event IDC does not provide a price or if the price provided is not reflective of fair market value, Chandler will obtain pricing from an alternative approved third party pricing source in accordance with our written valuation policy and procedures. Our valuation procedures are also disclosed in Item 5 of our Form ADV Part 2A.

Performance: Performance results are presented gross-of-advisory fees and represent the client’s Total Return. The deduction of advisory fees lowers performance results. These results include the reinvestment of dividends and other earnings. Past performance may not be indicative of future results. Therefore, clients should not assume that future performance of any specific investment or investment strategy will be profitable or equal to past performance levels. All investment strategies have the potential for profit or loss. Economic factors, market conditions or changes in investment strategies, contributions or withdrawals may materially alter the performance and results of your portfolio.

Source ICE Data Indices, LLC (“ICE”), used with permission. ICE PERMITS USE OF THE ICE INDICES AND RELATED DATA ON AN “AS IS” BASIS; ICE, ITS AFFILIATES AND

THEIR RESPECTIVE THIRD PARTY SUPPLIERS DISCLAIM ANY AND ALL WARRANTIES AND REPRESENTATIONS, EXPRESS AND/OR IMPLIED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE, INCLUDING THE INDICES, INDEX DATA AND ANY DATA INCLUDED IN, RELATED TO, OR DERIVED THEREFROM.

NEITHER ICE DATA, ITS AFFILIATES OR THEIR RESPECTIVE THIRD PARTY PROVIDERS GUARANTEE THE QUALITY, ADEQUACY, ACCURACY, TIMELINESS OR COMPLETENESS OF THE INDICES OR THE INDEX DATA OR ANY COMPONENT THEREOF, AND THE INDICES AND INDEX DATA AND ALL COMPONENTS THEREOF ARE PROVIDED ON AN “AS IS” BASIS AND LICENSEE’S USE IS AT LICENSEE’S OWN RISK. ICE DATA, ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY DO NOT SPONSOR, ENDORSE, OR RECOMMEND CHANDLER, OR ANY OF ITS PRODUCTS OR SERVICES.

Index returns assume reinvestment of all distributions. Historical performance results for investment indexes generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment management fee, the incurrence of which would have the effect of decreasing historical performance results. It is not possible to invest directly in an index.

Ratings: Ratings information have been provided by Moody’s, S&P and Fitch through data feeds we believe to be reliable as of the date of this statement, however we cannot guarantee its accuracy.

Security level ratings for U.S. Agency issued mortgage-backed securities (“MBS”) reflect the issuer rating because the securities themselves are not rated. The issuing U.S. Agency guarantees the full and timely payment of both principal and interest.

LGIP Yields: Reported yields for local government investment pools may be presented as either the 30-day yield or the monthly distribution yield, as applicable. For certain funds, the 30-day yield is calculated using reported daily yield data. Yield calculations are subject to change and may not be directly comparable across funds.

LAIF Yields: Additional Disclosure for CA Clients - As a result of a reporting lag from the Local Agency Investment Fund (LAIF), reported LAIF yields represent the most recently available Daily Effective Yield and may reflect data from approximately 7–10 days prior to month-end.

ATTACHMENT A Page 56 of 186
City of Brea | Account #120 | As of July 31, 2026
Execution Time: 08/05/2026 09:37:51 AM Chandler Asset Management | [email protected] | www.chandlerasset.com | 800.317.4747

BENCHMARK INDEX & DISCLOSURES
Benchmark Disclosure
ICE BofA 1-5 Yr US Treasury & Agency
Index
The ICE BofA 1-5 Year US Treasury & Agency Index tracks the performance of US dollar denominated US Treasury and nonsubordinated US agency debt issued in the US domestic market. Qualifying securities must have an investment grade rating (based on an average of Moody’s, S&P and Fitch). Qualifying securities must have at least one year remaining term to final maturity and less than five years remaining term to final maturity, at least 18 months to maturity at time of issuance, a fixed coupon schedule, and a minimum amount outstanding of $1 billion for sovereigns and $250 million for agencies.

ATTACHMENT A Page 57 of 186

CITY OF BREA
ATTN.: CITY MANAGER1 CIVIC CENTER CIRCLEBREA, CA 92821-5792 00184001 30- -01-B -62C-218-010102 -11-02877-01Questions?If you have any questions regarding your account or thisstatement, please contact your Account Manager.Account Manager:RODION BUTYRSKI18300 VON KARMANSUITE 500IRVINE CA 92612Phone: 949-224-7211E-mail: [email protected] Number: 6746050899PARS/CITY OF BREA 115P-PENSIONCONSOLIDATEDThis statement is for the period from July 1, 2026 to July 31, 2026 DATATFTTADFTTFATFFTFTATFTTFATTATDAFDTTDDDDFFTADDTDFTTTFAFFTFADTAT00000001840 000638224929864 P

ATTACHMENT A