NCTC LACAHSA SRA Exhibit C — Lancaster City Council, December 9, 2025

Transitional Program
Guidelines

LACAHSA
The Affordable Solutions Agency
September 2025

LACAHSA Transitional Program Guidelines | September 2025

i
Table of Contents

1. Program Overview ................................ ................................ ................................ ............................. 1 a. Purpose of the Guidelines ................................................................................................ 1 b. Roles and Responsibilities ................................................................................................ 2 c. Transitional Guidelines ..................................................................................................... 3

2. Funding Process Overview ................................ ................................ ................................ ............... 4 a. Annual Expenditure Plan .................................................................................................. 4 b. Funding to Eligible Jurisdictions ....................................................................................... 4 c. At-Large Funding Allocations ............................................................................................ 8

3. Determination of Eligible Uses of Funding ................................ ................................ .................... 8 a. Pre-Approved Eligible Use ................................................................................................ 8 b. Board-Approved Speciﬁc Eligible Use .............................................................................. 9

4. Production, Preservation, and Ownership (PPO) ................................ ................................ ......... 9 a. Overview ............................................................................................................................. 9 b. Program Requirements ..................................................................................................... 9 b. Approved Eligible Uses of Funding – PPO Products ..................................................... 17 c. Annual Budget ................................................................................................................. 23 d. Documentation Standards .............................................................................................. 24

5. Renter Protection & Homelessness Prevention (RPHP) ................................ ........................... 31 a. Overview ........................................................................................................................... 31 b. Program Requirements ................................................................................................... 33 c. Approved Eligible Uses of Funding ................................................................................ 39 b. Documentation Standards and Guidance ..................................................................... 50

6. Technical Assistance (TA) ................................ ................................ ................................ ............... 52 a. Overview ........................................................................................................................... 52 b. Approved Eligible Uses of Funding ................................................................................ 52

LACAHSA Transitional Program Guidelines | September 2025

ii
c. Documentation Standards .............................................................................................. 54

7. Funding Administration and Management ................................ ................................ ................ 55 a. Annual Budget ................................................................................................................. 55 b. Activity Delivery and Program Administration Costs .................................................... 56 c. Funding Obligation and Expenditure Timeline ............................................................. 59 d. Subrecipient Agreements ............................................................................................... 61 e. Contractor Procurement and Agreements .................................................................... 61 f. Disbursement Process and Requirements .................................................................... 61 g. Program Income .............................................................................................................. 63 h. Reporting .......................................................................................................................... 63 i. Monitoring ........................................................................................................................ 64 j. Audit and Record Retention ........................................................................................... 67 k. Remedies for Non-Performance .................................................................................... 68 l. Nondiscrimination ........................................................................................................... 68 m. Procurement .................................................................................................................... 69 n. Preventing Fraud, Waste, and Abuse ............................................................................. 69 o. Anti-Lobbying ................................................................................................................... 69 p. Conﬂict of Interest ........................................................................................................... 69

LACAHSA Transitional Program Guidelines | September 2025

1 1. Program Overview
In 2022, the California Legislature passed Senate Bill 679, the Los Angeles County Regional Housing Finance Act (“SB 679” or “the Act”), which created the Los Angeles County Affordable Housing Solutions Agency (“LACAHSA” or “the Agency”). The Agency’s purpose is to increase the supply of affordable housing in Los Angeles County by providing for significantly enhanced funding and technical assistance at a regional level for renter protections, affordable housing preservation, and new affordable housing production.

In 2024 , Los Angeles County voters approved Measure A, a half -cent sales tax to fund homeless services and affordable housing development throughout the County. The tax replaces Measure H, a quarter -cent sales tax for homeless services approved by voters in 2017. The goal of Measure A is to significantly reduce and prevent homelessness in Los Angeles County. Measure A is expected to generate over $1 billion in revenue annually.

Just over one third (35.75 percent) of revenues generated by Measure A will be directed to LACAHSA for affordable housing production and preservation, renter protection and homelessness prevention, and technical assistance. LACAHSA, in turn, must pass through 70 percent of this funding to Eligible Jurisdictions.

Eligible Jurisdictions are the County of Los Angeles, the City of Los Angeles, the City of Long Beach, the City of Glendale, the City of Santa Clarita, the Burbank -Glendale-Pasadena Regional Housing Trust, and the Councils of Government (COGs) in Los Angeles County. The Cities of Palmdale and Lancaster elected to receive their funding through the North Los Angeles County Transportation Coalition JPA (NCTC). COGs may pass through funding to their member cities, except to cities that are Eligible Jurisdictions that receive allocations directly from LACAHSA. COGs may also allocate funding to regional housing trusts as approved by the LACAHSA Board of Directors (“Board”). LACAHSA is required to spend its 30 percent allocation in Eligible Jurisdictions and may pass all or some of those funds through directly to Eligible Jurisdictions to administer or may administer programs itself. Finally, Eligible Jurisdictions may opt for LACAHSA to administer their funding allocation in whole or in part, as outlined in these Program Guidelines (“Guidelines”). a. Purpose of the Guidelines
The purpose of these Guidelines is to describe the programmatic and administrative requirements of LACAHSA’s funding program and to enable LACAHSA and the Eligible Jurisdictions to expend revenues as provided for in the approved Annual Expenditure Plan.

Within each programmatic category, LACAHSA and the Eligible Jurisdictions are required to only expend funds on the Eligible Uses described in the Act and Measure A . Furthermore,

LACAHSA Transitional Program Guidelines | September 2025

2 the Act charges the LACAHSA Board with approval of all allocations of revenues to projects and programs. To meet these requirements, these Guidelines set forth certain speciﬁc Eligible Uses within each category that the Board has pre -approved, but they also establish a mechanism for Eligible Jurisdictions to request the Board’s approval of other uses that meet the goals of the Act. This dual approach is intended to enable the quick deployment of funding, while not stiﬂing the creativity and innovation needed to address the homelessness crisis in Los Angeles County.

These Guidelines are meant to implement the goals and requirements contained in SB 679, Measure A, LACAHSA’s Annual Expenditure Plan, and other documents adopted by the LACAHSA Board. Eligible Jurisdictions may develop additional guidelines and standards consistent with the purposes of this funding.

Unless explicitly noted within these Guidelines, LACAHSA must follow the same requirements as established for Eligible Jurisdictions.

In instances where these Guidelines or additional guidance provided by LACAHSA conﬂicts with SB 679 or Measure A, the requirements in SB 679 and Measure A shall prevail. b. Roles and Responsibilities
i. LACAHSA
The Los Angeles County Affordable Housing Solutions Agency (“LACAHSA”) was created by the California State Legislature in 2022 through the Los Angeles County Regional Housing Finance Act (“SB 679” or “the Act”). LACAHSA is responsible for, among other duties:
• Providing a portion of Measure A funds to Eligible Jurisdictions; • Allocating a portion of Measure A funds directly to eligible programs and projects (through “At-Large Funding Allocations”);
• Adopting an Annual Expenditure Plan to set forth the share of revenue and estimated funding amount to be spent on each funding category included in SB 679; • Establishing and tracking performance metrics; and
• Approving the use of funds.
ii. Eligible Jurisdictions
Eligible Jurisdictions are public entities that are eligible to receive an allocation of Measure A funding directly from LACAHSA. Under SB 679, Eligible Jurisdictions are described as the County of Los Angeles on behalf of Unincorporated Communities , the City of Los Angeles, the City of Long Beach, the City of Glendale, the City of Santa Clarita, and the Councils of Government (COGs) in Los Angeles County. COGs may also choose to allocate all or some of their funding to regional housing trusts as approved by the LACAHSA Board of Directors.

LACAHSA Transitional Program Guidelines | September 2025

3 Eligible Jurisdictions are responsible for administering and expending Measure A funds in a manner consistent with the requirements included in Measure A, SB 679, the LACAHSA Annual Expenditure Plan, and these Program Guidelines.

Subrecipients
Subrecipients are public agencies and private nonprofit agencies that receive funding from LACAHSA and/or Eligible Jurisdictions to administer and implement programs. Subrecipients can include cities that receive funding from COGs , as well as nonprofits that receive funds from LACAHSA and Eligible Jurisdictions. Subrecipients must comply with the same program requirements as LACAHSA and the Eligible Jurisdictions.

Eligible Jurisdictions are responsible for ensuring that all subrecipients have the capacity and ability to manage and carry out the activities awarded to them.

Eligible Jurisdictions may elect to enter into agreements with subrecipients to directly administer all or a portion of their allocation on their behalf. The Eligible Jurisdiction must establish this relationship in accordance with their own processes and requirements.

Contractors
Contractors are for -profit, nonprofit, or public entities that are paid by LACAHSA, Eligible Jurisdictions, or Subrecipients in return for specific goods and services, where payment is made as compensation for such goods and services.
c. Transitional Guidelines
LACAHSA is committed to a strategic, collaborative approach to expanding these critical services throughout Los Angeles County. To promote innovation and ongoing program and policy development, LACAHSA will adopt these Guidelines for its initial year of operations .

This will allow time to reﬁne program design in collaboration with Eligible Jurisdictions and community partners. The Board may elect to amend these Guidelines throughout the year and prior to the next ﬁscal year.

LACAHSA will use this transitional phase to:
• Test and reﬁne program components;
• Collect feedback from community stakeholders;
• Develop shared tools to support standardized implementation of programs across the county in alignment with these Program Guidelines; and • Engage with Eligible Jurisdictions and community-based organizations to inform ﬁnal Program Guidelines for Fiscal Year 2026-27 and beyond.

LACAHSA Transitional Program Guidelines | September 2025

4 2. Funding Process Overview
a. Annual Expenditure Plan
The LACAHSA Board is required to adopt an Annual Expenditure Plan by July 1 of each year.

The Annual Expenditure Plan sets forth the share of revenue and estimated funding amounts to be spent on each funding category included in SB 679, indicates the household income levels to be served within each category of expenditures, and estimates the number of affordable housing units to be built or preserved and the number of tenants to be protected.

The Annual Expenditure Plan may also include a description of any specific project or program proposed to receive funding, including the location, amount of funding, and anticipated outcomes. The LACAHSA Board may revise and update the Annual Expenditure Plan throughout the fiscal year.

When taken together, SB 679 and Measure A require the following distribution of funding by programmatic use:
• 60 percent for Production, Preservation, & Ownership (“PPO”), of which 77.25 percent is set aside for new construction
o 80 percent of housing units produced during the time period in which funding is required to be expended must be subject to the Project Labor Agreement Requirements described in Section 4 of these guidelines • 30 percent for Renter Protection and Homelessness Prevention (“RPHP”) • 5 percent for Technical Assistance (“TA”)
• 5 percent for LACAHSA’s internal administration and operations SB 679 and Measure A also dictate how LACAHSA funds are distributed between LACAHSA and the Eligible Jurisdictions:
• 15 percent of programmatic funds are allocated annually at the discretion of the LACAHSA Board
• Of the remaining programmatic funds:
o 30 percent of programmatic funds are allocated to LACAHSA o 70 percent of programmatic funds are allocated to the Eligible Jurisdictions b. Funding to Eligible Jurisdictions
i. Allocation Notice
The Annual Expenditure Plan includes the allocations for each Eligible Jurisdiction and establishes an estimate of funds that LACAHSA will receive throughout the year. LACAHSA will make funds available to Eligible Jurisdictions in accordance with the actual revenues

LACAHSA Transitional Program Guidelines | September 2025

5 received. Once the County A uditor-Controller notifies LACAHSA that revenues have been placed in LACAHSA’s account, LACAHSA will then determine the amount of funds that are available for each Eligible Jurisdiction. LACAHSA will then issue a n Allocation Notice to each Eligible Jurisdiction.
ii. Memorandum of Understanding
Prior to receiving any portion of a funding allocation, each Eligible Jurisdiction will be required to execute a Memorandum of Understanding (MOU) with LACAHSA using the form at provided by LACAHSA. Each MOU will be a binding commitment from the Eligible Jurisdiction to comply with all requirements of the Act and Measure A in the use of the funding and to comply with these Program Guidelines and all other policies and guidelines of the LACAHSA Board. The term of the MOU is a period of one year and will be the administering agreement for all funds allocated during the program year.

As a condition of receiving funds, the Eligible Jurisdiction will affirm through execution of the MOU that it agrees to its proportional allocation and will not challenge the allocation amount. iii. Funding Requests
Once an Eligible Jurisdiction has executed an MOU with LACAHSA, it may make two types of funding requests: requests for Annual Allocations and requests to fund specific projects or programs. All funding requests are submitted to LACAHSA using the prescribed forms and processes as required by LACAHSA.

Funding can be provided as an advance, subject to funding availability , or as a reimbursement, based on the preference of the Eligible Jurisdiction. More information regarding the disbursement process and requirements for advanced funds and reimbursements is included below in the s ection titled “ Disbursement Process and Requirements.”
Annual Allocation
An Annual Allocation is a request to disburse funding directly to the Eligible Jurisdiction for the Eligible Jurisdiction to determine how to expend the funds within eligible uses. The requirements for Annual Allocations will vary based on the category of funds. An Annual Allocation may be for all or a portion of an Eligible Jurisdiction’s allocation of funds. In order to receive a n Annual Allocation of funds, the Eligible Jurisdiction must meet the following conditions speciﬁed in SB 679:
• Condition 1: The Eligible Jurisdiction agrees to adopt and adhere to these Guidelines and any other policies adopted by LACAHSA for the use of funds;

LACAHSA Transitional Program Guidelines | September 2025

6 • Condition 2: All funded projects comply with LACAHSA’s eligible uses and affordability requirements;
• Condition 3: The Eligible Jurisdiction will provide documentation of the legislative action approving the Eligible Jurisdiction’s annual budget and committing the funds for proposed activities. To meet this condition, the Eligible Jurisdiction must have no further legislative action to allocate the funds to the proposed activity, but the statute recognizes that the projects themselves may require additional legislative actions prior to completion, such as entitlements or contracts (See Section 64830.5(a)(2)(A)(iv)(II), which provides for a ﬁve-year period to expend the funds and allows for an extension of time if 75 percent of entitlements have been obtained) .

Meeting this condition also does not prevent a re -allocation to other proposed activities, provided that the Eligible Jurisdiction ﬁrst updates its budget (See Section

4.d. of these Guidelines regarding updates to the Annual Budget). Subsequent to local legislative body approval of the annual budget, t he Eligible Jurisdiction agrees to obligate its funding within 12 months of receipt through administrative processes without being subject to additional legislative actions for the obligation of said funds (to “obligate” funds means to commit funds to a project/activity; an obligation of funds is a legal liability to disburse funds immediately or at a later date. Once obligated, funds are then available to be spent on the project/activity); and • Condition 4: The Eligible Jurisdiction will provide documentation that the activity is in alignment with its Housing Element and the corresponding sections in which the Eligible Jurisdiction indicates how it will aﬃrmatively further fair housing. For COGs receiving an Annual Allocation of funds from LACAHSA, the COG must aﬃrm that it will verify this compliance with each jurisdiction at the point of award and maintain this documentation in the grants management system prior to an activity taking place. For purposes of this condition, an Eligible Jurisdiction will be deemed in compliance with Aﬃrmatively Furthering Fair Housing in California guidelines if the County or city has adopted a housing element that complies with the aﬃrmatively furthering fa ir housing requirements of the Housing Element law. If the Eligible Jurisdiction does not have a Housing Element that the Department of Housing and Community Development (“HCD”) has determined to be in compliance with the Housing Element Law, then i t will need to document one of the following as applicable: (i) it has adopted a Housing Element that aﬃrmatively furthers fair housing and is waiting for approval from HCD, (ii) it has received comments from HCD that do not modify the aﬃrmatively furthering fair housing provisions; (iii) it has received comments from HCD addressing its aﬃrmatively furthering fair housing provisions and is implementing such comments, (iv) it continues to aﬃrmatively

LACAHSA Transitional Program Guidelines | September 2025

7 further fair housing under an existing housing element while pursuing a housing element update, or (v) that it can otherwise document that it aﬃrmatively furthers fair housing under State law.

Meeting Annual Allocation Conditions for PPO Activities Eligible Jurisdictions must also meet the statutory conditions to receive Annual Allocations for PPO funds as follows:
• Condition 1: The Eligible Jurisdiction will meet this condition by approving and executing the MOU.
• Condition 2: The Eligible Jurisdiction will have to show that its current project(s) are an approved eligible use, as documented in the Annual Expenditure Pla n, via submission of an annual budget in accordance with the schedule set forth by LACAHSA.
• Condition 3: The Eligible Jurisdiction will provide documentation of the legislative action approving the Eligible Jurisdiction’s annual budget and committing the funds for proposed activities. To meet this condition, the Eligible Jurisdiction must have no further legislative action to allocate the funds to the proposed activity, but the statute recognizes that the projects themselves may require additional legislative actions prior to completion, such as entitlements or contracts (See Section 64830.5(a)(2)(A)(iv)(II), which provides for a ﬁve-year period to expend the funds and allows for an extension of time if 75 percent of entitlements have been obtained) .

Meeting this condition also does not prevent a re -allocation to other proposed activities, provided that the Eligible Jurisdiction ﬁrst updates its budget (See Section

4.d. of these Guidelines regarding updates to the Annual Budget) • Condition 4: The Eligible Jurisdiction will provide documentation that the activity is in alignment with its Housing Element and the corresponding sections in which the Eligible Jurisdiction indicates how it will aﬃrmatively further fair housing. For COGs receiving an Annual Allocation of funds from LACAHSA, the COG must aﬃrm that it will verify this compliance with each jurisdiction at the point of award and maintain this documentation in the grants management system prior to an activity taking place. For purposes of this condition, an Eligible Jurisdiction will be deemed in compliance with Aﬃrmatively Furthering Fair Housing in California guidelines if the County or city has adopted a housing element that complies with the aﬃrmatively furthering fa ir housing requirements of the Housing Element law. If the Eligible Jurisdiction does not have a Housing Element that the Department of Housing and Community Development (“HCD”) has determined to be in compliance with the Housing Element Law, then i t will need to document one of the following as

LACAHSA Transitional Program Guidelines | September 2025

8 applicable: (i) it has adopted a Housing Element that aﬃrmatively furthers fair housing and is waiting for approval from HCD, (ii) it has received comments from HCD that do not modify the aﬃrmatively furthering fair housing provisions; (iii) it has received comments from HCD addressing its aﬃrmatively furthering fair housing provisions and is implementing such comments, (iv) it continues to aﬃrmatively further fair housing under an existing housing element while pursuing a housing element update, or (v) that it can otherwise document that it aﬃrmatively furthers fair housing under State law.

Program/Project-Speciﬁc Allocation Request
Program/Project-Specific requests are made to LACAHSA to carry out a program or project on behalf of an Eligible Jurisdiction. The requirement for a Program/Project-Specific request will be to show that the funds will be wholly used for an eligible use. c. At-Large Funding Allocations
At-Large Funding Allocations are made by LACAHSA using the portion of programmatic funds that are administered directly by LACAHSA. As revenues are received, LACAHSA will issue a Notice of Funding Availability (NOFA), or similar, to advertise the availability of funds.

The Act speciﬁes that LACAHSA must at a minimum consider the following factors when making At-Large Funding Allocations:
• Whether the allocation aﬃrmatively furthers fair housing; • The allocation’s eﬀect on displacement indicators;
• The allocation’s eﬀect on rent-burdened populations; and • Whether the allocation serves populations with disabilities.

Additional considerations for the allocation of Countywide funding will be established by the Investment Review Committee in collaboration with LACAHSA staﬀ.

3. Determination of Eligible Uses of Funding
LACAHSA funding may only be used for the eligible uses in the respective category of funding as set forth in Government Code section 64830 and Measure A. The LACAHSA Board will have sole authority to determine whether any particular use is an eligible use. There will be two mechanisms for the Board to do this.
a. Pre-Approved Eligible Use
The LACAHSA Board establishes, through adoption of the Annual Expenditure Plan and these Program Guidelines, the types of uses that are pre-approved as eligible uses.

LACAHSA Transitional Program Guidelines | September 2025

9 b. Board-Approved Specific Eligible Use
If an Eligible Jurisdiction wants to allocate LACAHSA funds to a use that has not been pre - approved in the Annual Expenditure Plan and Program Guidelines, the Eligible Jurisdiction may submit its proposed use to LACAHSA in a funding request. The funding request should include a summary of the proposed activity and how it aligns with Measure A and the Act.

The request will be submitted to the LACAHSA Board or its designated body for consideration and approval. The Board or its designee will determine whether the proposed use is eligible and whether it will require an amendment to the Annual Expenditure Plan.

Such requests will be reviewed and considered as they are received and prioritized for review by the Board or its designee during the next scheduled meeting or session.

4. Production, Preservation, and Ownership (PPO)
a. Overview
To increase the number of a ffordable housing units throughout Los Angeles County, Measure A and SB 679 provide for affordable housing production, preservation, and ownership by Eligible Jurisdictions subject to the program requirements detailed in the sections that follow. Eligible Jurisdictions may invest PPO funds to create new affordable housing units and/or maintain the existing stock of affordable units provided that the projects or programs comply with each of the applicable program requirements enumerated in Measure A and the Act.

Eligible Jurisdictions are provided with the flexibility to deploy the tools that best respond to unique market conditions, organizational capacity, and individual risk tolerance, without the burden of additional layers of regulation . Through Technical Assistance and other publications, LACAHSA will share the tools and strategies being deployed for projects receiving funds directly from LACAHSA. Eligible Jurisdictions may use these tools and strategies or other appropriate resources to guide the local investment of PPO resources. b. Program Requirements
i. Dedicated Share for New Construction
Measure A Section 29B mandates that 60 percent of funding is used for PPO. Of this amount,

77.25 percent is mandated for construction of new affordable housing (PPO -New Construction), which includes new construction of affordable housing units (inclusive of renter and owner housing), creation of new affordable housing units where there is no pre- existing residential us e (e.g., conversion of hotel/motel or adaptive reuse of commercial property), and rent or operating subsidies that support new construction. The remaining

LACAHSA Transitional Program Guidelines | September 2025

10 22.75 percent is a ﬂexible category (PPO-Flexible) that may be spent on any eligible PPO program including construction, preservation (expansion or deepening of a ﬀordability for an existing residential unit) , acquisition, rehabilitation, ownership, and rent and operating subsidies.
ii. Aﬀordability
Measure A and the Act define affordability requirements at the portfolio and project levels for each Eligible Jurisdiction, with separate project level requirements for new construction and preservation.

Portfolio Requirements
Pursuant to Government Code Section 64830(d)(1)(A)(ii)(I), each Eligible Jurisdiction’s portfolio of Measure A funded units shall meet or exceed the following requirements when measured in the aggregate over any two-year period:
• 25 percent of all funded and constructed units shall be reserved for extremely low- income households, as deﬁned in Health and Safety Code Section 50106 (extremely low-income households are deﬁned as households with incomes at or below 30 percent of the Area Median Income—AMI), and
• 25 percent of all funded and constructed units shall be reserved for very low-income households, as deﬁned in Health and Safety Code Section 50105 (very low-income households are deﬁned as households with incomes at or below 50 percent of AMI).

Compliance with this requirement will be monitored regularly by LACAHSA and the Citizen’s Oversight Committee in compliance with Government Code Section 64830 (d)(1)(A)(ii)(I).

During the time period required for the funding to be expended, 80 percent of all units produced must be subject to the Project Labor Agreement requirements described in more detail below.

Project Requirements – New Construction
Pursuant to Government Code Section 64830(d)(1)(A)(ii), new construction projects must meet one of the following requirements:

1. Be 100 percent aﬀordable, meaning all units are restricted to households that earn up to 80 percent of AMI, and, in addition:
a. 10 percent of units must be reserved for extremely low-income households. b. 10 percent of units must be reserved for very low-income households.

2. A project may also include a subset of at least 50 units, or 50 percent of the total units, whichever is greater, in a larger development that includes units targeted up to 120 percent of AMI. In these projects, the following requirements apply:

LACAHSA Transitional Program Guidelines | September 2025

11 a. 10 percent of units must be reserved for extremely low-income households. b. 10 percent of units must be reserved for very low-income households. c. Measure A funds may only pay for units that are designated for extremely low- and very low-income households, and shall not be used in connection with any unit that is income restricted solely due to development incentives, density bonuses, or similar programs.

3. In a project that is not 100 percent aﬀordable, an Eligible Jurisdiction may ﬁnance a share of aﬀordable units in said project. The project must reserve at least 10 percent of units for extremely low-income households and 10 percent of units for very low- income households. Measure A funds may not be used for units designated for households exceeding 80 percent of AMI.

Project Requirements – Preservation
Aﬀordable housing preservation programs may be used for four activities:
• Acquire existing housing units;
• Rehabilitate existing housing units;
• Place aﬀordability restrictions on existing units (through the provision of ﬁnancing); or
• Preserve existing aﬀordable housing units through the extension of aﬀordability restrictions.

Solely for projects in which the Eligible Jurisdiction (or a governmental entity) is acquiring existing subsidized aﬀordable housing or market -rate housing to convert to aﬀordable housing, Government Code Section 64830(d)(1)(B)(ii) requires that 100 percent occupancy by extremely low - or very low-income households shall be achieved over time through unit turnover. This allows for projects that are not currently subsidized to be converted to aﬀordable housing over time, working towards occupancy of 100 percent of the project units as aﬀordable to extremely low - and very low -income households. This provision of Government Code Section 64830(d)(1)(B)(ii) eﬀectively prohibits the use of Measure A funding for tenant evictions, even if the tenants are not income -qualiﬁed following the aﬀordability conversion.

If preserving aﬀordable housing through an action other than acquiring a housing unit(s) by an Eligible Jurisdiction (or government entity), the Measure A assistance must be limited to units designated for households at or below 120 percent of AMI, except that 10 percent of units must be reserved for extremely low-income households and 10 percent of units must be reserved for very low-income households.

LACAHSA Transitional Program Guidelines | September 2025

12 Achieving Occupancy Requirements for Preservation Projects LACAHSA recognizes that occupancy by extremely low- and very low -income households over time may not be ﬁnancially feasible if Government Code Section 64830(d)(1)(B)(ii) is narrowly interpreted to mean that each time a unit turns over, the unit must then immediately be occupied by an extremely low- or very low-income household.

Further, Measure A funds cannot permanently displace existing residents of buildings acquired, rehabilitated , or otherwise assisted for the purpose of aﬀordable housing preservation, even if the resident’s household income exceeds 120 percent of AMI.

As such, the following minimum standards are adopted as part of these Program Guidelines to facilitate a range of ﬁscally sustainable preservation projects:

Acquisition by Eligible Jurisdiction or Governmental Entity When a preservation project is acquired by an Eligible Jurisdiction or governmental entity, the following process must be used to achieve the occupancy requirements:

1. For an investment without must-pay debt service or debt service underwritten to accommodate extremely low- and very low-income households, a minimum 55-year restrictive covenant shall be recorded immediately upon execution of the written agreement providing Measure A funds for the preservation project.

The period of aﬀordability shall commence on the date of recordation in the Oﬃcial Records of the County of Los Angeles. Every time a unit turns over, the unit must be rented to an extremely low- or very low-income household.

2. For a ﬁnanced investment, a minimum 55-year restrictive covenant shall be recorded immediately upon execution of the written agreement providing Measure A funds for the preservation project. The 55-year period of aﬀordability shall commence on the date upon which at least 25 percent of the units are occupied by extremely low-income households and at least 25 percent of the units are occupied by extremely low-income households. The project owner may determine the pac e of conversion of units occupied by households earning more than 50 percent of AMI to units occupied by extremely low - or very low -income households over time through unit turnover, except that 30 years subsequent to the recordation of the restrictive covenant, 100 percent of the project units shall be occupied by extremely low- and very low-income households.

LACAHSA Transitional Program Guidelines | September 2025

13 Other Preservation Activities
When a preservation project is carried out for any other purpose, t he aﬀordability period shall commence on the date upon which at least 75 percent of the units are occupied by households earning at or below 120 percent of AMI. The project owner may determine the pace of conversion of units occupied by households earning more than 50 percent of AMI to units occupied by extremely low- and very low -income households over time through unit turnover . Full aﬀordability must be achieved 30 years subsequent to the recordation of the restrictive covenant, except that for Minor Rehabilitation projects (deﬁned as rehabilitation projects where the average amount of Measure A assistance per Measure A restricted unit in the project is $150,000 or less) full aﬀordability must be achieved prior to the midpoint of the term of the restrictive covenant.

Aﬀordable Rents
For PPO-New Construction and PPO-Flexible preservation projects, the restrictive covenant recorded in Oﬃcial Records of the County of Los Angeles shall describe the income targeting requirements in suﬃcient detail to demonstrate compliance with Government Code Section 64830(d)(1)(A)(ii). The restrictive covenant shal l also establish the aﬀordable rent levels selected by the developer and approved by the Eligible Jurisdiction, consistent with the following standards:
a. If the project is otherwise restricted by one other aﬀordable housing funding source’s published rent schedule, the restrictive covenant shall specify the use of the same rent schedule for Measure A units; or
b. If the project is otherwise restricted by more than one other aﬀordable housing funding source’s published rent schedule, the restrictive covenant shall specify the use of one of the other schedule(s) for Measure A units, to be selected by the developer and approved by the Eligible Jurisdiction; or c. If the project is not otherwise restricted by another aﬀordable housing funding source’s published rent schedule, the developer may select from any of the following, subject to approval by the Eligible Jurisdiction:
a. Multifamily Tax Subsidy Projects (MTSP) rents published by HUD; or b. Department of Housing and Community Development State Income Limits and Rents calculated pursuant to Health and Safety Code Sections 50052.5 and 50053.

LACAHSA Transitional Program Guidelines | September 2025

14 Rental Aﬀordability Restrictions and Period of Aﬀordability for New Construction and Preservation Projects
Pursuant to Section 6.6 of the Affordable Housing Production, Preservation, and Ownership; Technical Assistance, Research and Policy; and Renter Protection and Homelessness Prevention Funding Memorandum of Understanding entered into by LACAHSA and the Eligible Jurisdiction, Eligible Jurisdictions shall record a restrictive covenant on each project.

For rental new construction, acquisition, or rehabilitation projects, the minimum period of affordability shall be 55 years.

When issuing a NOFA or similar invitation for proposals, Eligible Jurisdictions must award bonus points for projects that extend affordability periods beyond 55 years . Maximum bonus points must be granted for any project that achieves permanent affordability.

For projects that do not achieve permanent affordability, LACAHSA encourages that the grant and loan agreements should require all best efforts by the owner to extend affordability permanently at the end of the 55 year covenant, including the tenant opportunity to purchase and community opportunity to purchase/right of first refusal.

When providing standalone rental assistance , operating subsidy, or master leasing assistance for existing properties, the Eligible Jurisdiction must deepen or establish an affordability period of at least 5 years after the conclusion of assistance.

Project Requirements – Homeownership
All homeownership assistance may only be provided to households who intend to purchase homes that will be used as their primary residence.

Pursuant to Government Code Section 64830(d)(1)(B), programs to enable 80 percent AMI or 120 percent AMI households to become or remain homeowners, including, but not limited to, below market rate ownership programs, down payment assistance programs, residential rehabilitation loan programs, and grants or loans to assist in the rehabilitation or replacement of existing mobile homes or manufactured home s are eligible uses of PPO - Flexible funds.

For programs that enable 80 percent AMI or 120 percent AMI households to become homeowners, Eligible Jurisdictions shall record a restrictive covenant on each homeownership unit. Either a resale or a recapture provision shall be used within the restrictive covenant to promote long -term aﬀordability. The Eligible Jurisdiction may use either a resale provision or a recapture provision, but not both. If an Eligible Jurisdiction uses an alternative approach to expand or deepen aﬀordability through homeownersh ip activities, they may submit a waiver request to LACAHSA to utilize that approach.

LACAHSA Transitional Program Guidelines | September 2025

15 When establishing a restrictive covenant, Eligible Jurisdictions are encouraged to explore existing models within the region that balance long- term aﬀordability with homeowner equity such as the CalHome program.

If the Eligible Jurisdiction uses resale restrictions, the resale requirements must ensure that during the aﬀordability period (a number of years determined by the Eligible Jurisdiction), the housing is subsequently purchased only by a buyer who earns les s than 120 percent of AMI, and who will use the property as their principal residence. The resale requirement must also ensure that the price at resale provides the original homebuyer a fair return on investment (including the homeowner's investment and any capital improvement) and ensures that the housing will remain aﬀordable to a reasonable range of buyers earning less than 120 percent of AMI.

If the Eligible Jurisdiction uses recapture restrictions, the recapture requirements must ensure that the Eligible Jurisdiction recoups all or a portion of the Measure A assistance to the homebuyers if the housing is sold during the aﬀordability period (a number of years determined by the Eligible Jurisdiction). The recapture requirement is triggered by the sale (voluntary or involuntary) of the housing unit. The amount recaptured by the Eligible Jurisdiction cannot exceed the net proceeds from the sale, if any. The net proceeds are the sales price minus superior loan repayment (other than Measure A funds) and any closing costs. Recapture provisions may permit the subsequent homebuyer to assume Measure A assistance (subject to the recapture requirements) if the subsequent homebuyer earns less than 120 percent of AMI. Eligible Jurisdictions are encouraged to structure recapture provisions based on their own program design and local market conditions. Some common options include:

1. Recapturing the entire amount of direct Measure A assistance to the original homebuyer, with or without interest.

2. Reducing the amount of direct Measure A assistance to the original homebuyer that will be recaptured on a pro-rata basis for the time the original homebuyer has owned and occupied the housing measured against the duration of the Eligible Jurisdiction’s aﬀordability period.

3. Sharing the net proceeds after the homeowner recovers their downpayment and any capital improvement investments made since the purchase. Such provisions must clearly specify the methodology used to calculate the equity sharing formula. The net proceeds are the sales price minus loan repayment (other than Measure A funds) and closing costs.

LACAHSA Transitional Program Guidelines | September 2025

16 iii. Prevailing Wage and Project Labor Agreements
To encourage the development of local job opportunities and career pathways into the building and construction trades, including but not limited to apprenticeship and pre - apprenticeship programs, and consistent with Measure A Section 28B and SB 679 Section 64720.5(a), PPO projects involving construction or rehabilitation constitute a public work for which prevailing wages shall be paid for purposes of Chapter 1 (commencing with section 1720) of Part 7 of Division 2 of the Labor Code. Construction or rehabilitation contracts and subcontracts must include provisions requiring the payment of prevailing wages. As established by the enabling legislation, prevailing wage applies to all PPO activities involving construction or rehabilitation including homeownership activities. If a project does not involve construction or rehabilitation, but only involves an activi ty such as downpayment assistance or rent/operating subsidy, prevailing wage does not apply.

Additionally, Measure A Section 28C and SB 679 Section 64720.5(b) require projects in buildings with 40 units or more to comply with the City of Los Angeles Department of Public Works Project Labor Agreement 2020-2030 if the project is within the City of Los Angeles, or the Countywide Community Workforce Agreement executed by the Chief Executive Officer on June 7, 2023 or any successor to either agreement. Construction or rehabilitation contracts for projects with 40 units or more must include provisions requiring compliance with the applicable Project Labor Agreement based on the location of the project.

At a minimum, 80 percent of all units produced by an Eligible Jurisdiction must meet the applicable Project Labor Agreement requirements, consistent with the time period required for the funding to be expended.
iv. Relocation and Unit Replacement
If demolition or rehabilitation of housing units is required as part of any PPO investment , relocation and unit replacement requirements apply.

Relocation
If existing residents are required to be relocated due to demolition or rehabilitation needs, the developer is required to provide relocation benefits to the occupants of those housing rental units subject to Government Code Chapter 16 (commencing with Section 7260) of Division 7 of Title 1. The developer shall comply with State and local government requirements for relocation assistance to displaced households.

If existing occupants who are lower income households are required to vacate their units due to demolition or rehabilitation needs, the developer shall provide a right of first refusal for a comparable unit available in the new or rehabilitated housing dev elopment that is affordable to the household at an affordable rent, as defined in Health and Safety Code

LACAHSA Transitional Program Guidelines | September 2025

17 Section 50053, or an affordable housing cost, as defined in Health and Safety Code Section 50052.5.

Unit Replacement
Any funded development or affordable housing grant on any property that includes a parcel or parcels that currently have residential uses, or within the five years preceding the grant have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low - or very low-income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low- or very low- income households, shall be subject to a policy requiring the replacement of all those units to be made available at affordable rent or affordable housing cost to, and occupied by, persons and families in the same or lower income category as those households in occupancy.

Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Government Code Section 65915, provided that any dwelling unit that is or was, within the five-year period preceding the grant, subject to a form of rent or price control through a local government’s valid exercise of its police power and that is or was occupied by persons or families above lower income shall be replaced with units made available at affordable rent or affordable housing cost to, and occu pied by, low -income persons or families.
b. Approved Eligible Uses of Funding – PPO Products
i. Direct Project Investments
LACAHSA and Eligible Jurisdictions may use direct project investments to address financing gaps for affordable new construction and preservation projects. Examples of direct project investments include grants, loans, equity, interest rate subsidies, or other appropriate financing tools . Eligible Jurisdictions may determine the appropriate amount of project subsidy and the most advantageous financing tool based on the unique needs of the project.

Eligible Jurisdictions are encouraged to use this dedicated funding with streamlined processes to move the backlog of entitled affordable housing deals in need of gap financing to the closing table, and to implement additional projects to realize production goals quickly.

LACAHSA expects that Eligible Jurisdictions will make best eﬀorts to align NOFA timelines, underwriting guidelines, award processes, and construction closing with other primary sources of funding (County, State, Federal) to promote eﬃciency and timeliness.

LACAHSA Transitional Program Guidelines | September 2025

18 Direct project inves tments may include the rehabilitation of existing units or the development of Accessory Dwelling Units or similar developments to existing housing units under the PPO-Flex category.
ii. Rent & Operating Subsidies
To encourage deep aﬀordability targeting and creation of permanent supportive housing units, among other purposes, operating subsidies are an eligible use of PPO funds to provide ongoing, annual payments to address expenses such as utilities, maintenance, taxes, management, as well as debt service payments.

Assisted units receiving an operating subsidy or Capital Operating Subsidy Reserve may only be occupied by households at or below 80 percent of AMI. Assisted units in a master leasing program OR receiving rental assistance through a shallow subsidy or project- based rental assistance program may only be occupied by extremely low-income households.

As part of a rent subsidy program, the Eligible Jurisdiction may request a waiver from LACAHSA to authorize the provision of LACAHSA funded reasonable housing stabilization services for any extremely low -income household for the duration of LACAHSA -funded assistance.

If through the course of time a household’s income exceeds 30 percent for rent subsidy or 80 percent for operating subsidy, the household can no longer be assisted with rent or operating subsidy respectively. However, in accordance with the enabling legislation the household cannot be evicted. Eligible Jurisdictions may structure rent or operating subsidy activities to allow for assistance to ﬂoat to another unit if a unit is no longer income qualiﬁed.

New Construction
Rent and operating subsidies can be provided to a new construction property for up to 20 years, with renewable terms allowed so long as that property has established aﬀordability covenants as deﬁned in Section 4.b.ii of these Guidelines and the property passes annual habitability inspections.

Existing Properties
Rent or operating subsidies can be provided to existing properties for up to 20 years under PPO-Flexible based on the existing or new aﬀordability covenants placed on the property.

Such projects must receive LACAHSA technical assistance and approval prior to obligation.

Types of rental and operating subsidies include the following eligible activities described below.

LACAHSA Transitional Program Guidelines | September 2025

19 Rental Assistance & Operating Subsidy
Eligible Jurisdictions may utilize funding fr om the Flexible Production, Preservation and Ownership (PPO-Flexible) pool to provide rental assistance to extremely low -income households. Rental assistance may be used in conjunction with additional activities funded with Measure A resources or as a stand-alone activity. Operating subsidy or Capital Operating Subsidy Reserve activities may assist units occupied by households at or below 80 percent AMI.

Master Leasing
Master leasing is a housing strategy where an organization (such as a nonproﬁt or government agency) becomes the primary tenant by leasing homes within a building or an entire building from the owner. The master lessor then subleases these spaces to individuals who might otherwise face barriers to housing. Master leasing is eligible within the Flexible category of PPO activities as long as it is tied to the extension or deepening of aﬀordability in the master leased units.

Any master lease agreement must contain an option for purchase by the Eligible Jurisdiction or LACAHSA unless otherwise waived by LACAHSA.

Standalone rental assistance, operating subsidy, or Master Leasing assistance must be tied to the extension or deepening of aﬀordability in the assisted units. This may include an extended aﬀordability period for assisted units at the conclusion of the rent or operating subsidy. At a minimum, the aﬀordability period must be extended by at least 5 years. iii. LACAHSA Mortgage
The LACAHSA Mortgage is intended to reduce costs and development ﬁnance timelines, develop an avenue to ﬁnance aﬀordable housing without tax credits, and deploy Measure A revenue quickly. Eligible Jurisdictions are encouraged to engage LACAHSA technical assistance early in the process if use of the LACAHSA Mortgage tool, or partnership with LACAHSA on the use of the tool, is contemplated for a project.

LACAHSA has the ability to i ncur debt and issue bonds and otherwise incur liabilities or obligations in accordance with Government Code 64720(d). The LACAHSA Mortgage is a ﬁnancing tool to raise lower -cost capital through the bond market and provide tax -exempt debt ﬁnancing for 100 percent aﬀordable and mixed- income projects. There are two complementary ﬁnancing tools that could be utilized to create this product, though these tools may also be used individually or in combination with other ﬁnancing tools: A-Notes and B-Notes with Guarantee.

LACAHSA Transitional Program Guidelines | September 2025

20 A-Notes constitute senior, construction to permanent debt with mandatory ﬁxed monthly payments (hard-pay). The A -Note conforms to typical ﬁrst mortgages for construction or permanent loans in structure with higher leverage and lower -cost due to its tax -exempt status.

B-Notes with Guarantee are subordinate, typically second position, construction to permanent residual receipts loans with a guarantee from LACAHSA for payment of the interest that increases the ability to sell the bond to third -party investors at a low interest rate. The guarantee is a commitment that the lender will cover the diﬀerence between the payments made by the project and the coupon of the B -Note. It can take many for ms such as an operating deﬁcit reserve or a contingent loan.

In either case, Eligible Jurisdictions must work with bond counsel to ensure that projects qualify for tax- exempt bond ﬁnancing and determine if the tax -exempt bond ﬁnancing is exempt from the California volume cap for private -activity bonds. LACAHSA Mortgage funding may be awarded to developers throughout the county.

The creation and implementation of a LACAHSA mortgage progra m or a similar eligible activity may be carried out by LACAHSA directly or by an Eligible Jurisdiction.

Prior to utilization, the LACAHSA Mortgage will be reviewed and approved by the Investment Review Committee.
iv. Impact Fund
Impact funds oﬀer below-market ﬁnancial terms and greater ﬂexibility than typical ﬁnancing, by raising impact-driven investments that serve as ﬁrst- loss capital. A public entity seeds a new impact fund by attracting mission -driven capital sources including philanthropy (such as through program -related investments, impact investors, and Community Reinvestment Act motivated funding). T h e f u n d m a y b e h e l d b y a q u a l i ﬁ e d Community Development Financial Institution, jurisdiction or municipality, or other ﬁnancial institution pursuant to an agreement between the Eligible Jurisdiction specifying the parameters for investment and use of the fund . The focus of the impact fund will be on preserving existing subsidized aﬀordable housing, acquiring and preserving Naturally Occurring Aﬀordable Housing , and increasing homeownership opportunities. Eligible Jurisdictions may elect to participate in the impact fund through investment of ﬁrst- loss capital or provision of predevelopment loans, residual receipts loans , or short -term ﬁnancing to bridge the gap in time between a construction loan and a permanent loan for awarded projects.

LACAHSA Transitional Program Guidelines | September 2025

21 v. Community Land Trusts
Grants, loans , or other ﬁnancing provided to Community Land Trusts (CLT) and other similarly structured nonproﬁt entities to acquire, rehabilitate, and preserve existing housing units are an eligible use of PPO funds not otherwise reserved for construction of new aﬀordable housing. Investment of Measure A PPO- Flexible funds in projects owned by Community Land Trusts that permanently own the land insulates those housing units from economic pressures of market appreciation by separating land ownership from home ownership and eﬀectively reducing the initial purchase price of homes within the Community Land Trust. Long term renewable ground leases and legally binding resale restrictions capping the resale price of the home ensure that Community Land Trust units remain aﬀordable for future homebuyers.

Community Land Trusts oﬀer a pathway to homeownership and wealth building for low- and moderate-income families, reducing the risks of foreclosure and providing greater housing stability compared to the private market. By preserving aﬀordable housing opt ions and preventing displacement in neighborhoods experiencing rising property values and gentriﬁcation pressures, Community Land Trusts contribute to more diverse and inclusive communities.

Eligible Jurisdictions can facilitate the mission of Community Land Trusts by providing funds for land acquisition, rehabilitation, and new construction, and oﬀering technical assistance to support Community Land Trust formation and expansion. Eligible Jurisdictions should work closely with the Community Land Trust to ensure it has adequate capacity to manage and operate the program.
vi. Social Housing
Social housing initiatives may be implemented by nonproﬁts , Community Land Trusts, or public agencies, ensuring a mission -driven approach to development and property management. A key component of social housing initiatives is the meaningful participation of residents in decision-making and governance, fostering a sense of agency and community.

Where feasible and desirable, opportunities for resident ownership are also encouraged to further empower tenants. Social housing initiatives can either be new cons truction or preservation activities.

Projects that include units serving homeowner households earning up to 120 percent of AMI are encouraged as part of social housing activities. Social housing rental activities are limited to serving units designated up to 80 percent of AMI that are not already income restricted due to development incentives, density bonuses, or similar programs.

LACAHSA Transitional Program Guidelines | September 2025

22 A wide range of approaches to the social housing concept are possible, including but not limited to new construction, preservation, and the preservation of small Naturally Occurring Aﬀordable Housing (NOAH). Social housing initiatives oﬀer ﬂexibility to address diverse community needs. For example, an organization implementing Social Housing and N OAH could implement an a cquisition and rehabilitation program to take units from the pr ivate market, impose an aﬀordability covenant, and thereby increase the amount of income - restricted aﬀordable housing, especially in neighborhoods with a high risk of gentriﬁcation or displacement. Project types could range from existing multi-family buildings of 2-20 units, inclusive of any units to be added such as Accessory Dwelling Units (ADU), or mobile home parks of any size. Upon completion, all units would be covered under a restrictive covenant as aﬀordable, with no existing residents being displaced.

Entities engaging in NOAH could include public entities, housing authorities, C ommunity Land Trusts, Limited Equity Housing Cooperatives , and nonproﬁt housing entities. NOAH programs may be supported through technical assistance for site identiﬁcation, including establishing and maintaining a centralized, real-time database of at-risk properties.

Beyond increasing the number of income-restricted aﬀordable housing units, social housing concepts and NOAH provide pathways for resident -run housing, including conversion to ownership structures such as co operatives, Limited Equity Housing Cooperatives, redevelopment of public housing sites, and tenancy in common, helping families remain in their communities and helping seniors age in place where they have roots. vii. Ownership Products
Programs to enable low - or moderate -income households to become or remain homeowners, including, but not limited to, below market rate ownership programs, down payment assistance programs, residential rehabilitation loan programs, and grants or loans to assist in the acquisition, rehabilitation, or replacement of existing mobile homes located in a mobile home or manufactured home park, are eligible uses of PPO funds not otherwise reserved for construction of new aﬀordable housing. Ownership products include a variety of ﬁnancing structures to improve the aﬀordability of existing ownership opportunities or to increase the production or preservation of aﬀordable homeownership opportunities.

There are a variety of ways Eligible Jurisdictions may oﬀer ﬁnancing to improve the aﬀordability of existing ownership opportunities or to increase the production or preservation of aﬀordable ownership opportunities. Some of these include:
• Community Land Trust Investment: Community Land Trust or a designated public entity retains ownership of the underlying land and allow owners to enter into leasehold mortgages whereby the owner only purchase s the home. Investments in

LACAHSA Transitional Program Guidelines | September 2025

23 Community Land Trusts may include, but are not limited to, loan products for households to purchase homes through a C ommunity Land Trust, interest rate subsidies, or direct investments into the Community Land Trust organization. • Soft Second Mortgages: Capital to reduce the upfront cost of homeownership through a permanent loan, forgivable over a speciﬁc period of time, for income - qualiﬁed households to cover a portion of the down payment and/or closing costs for a home.
• Interest Rate Subsidy: Capital to reduce the upfront cost of homeownership through a one-time payment to buy down the interest for the entire term of the mortgage. • New Aﬀordable Homeownership Products: Loans for the construction or preservation of existing aﬀordable accessory dwelling units (ADUs), mobile homes or manufactured homes, or other aﬀordable homeownership products. • Foreclosure Prevention Assistance: Programs, services, or resources designed to help homeowners who are at risk of losing their homes due to missed mortgage payments. Foreclosure assistance may include, but is not limited to, loan modiﬁcation, emergency ﬁnancial aid, or temporary mortgage assistance. • Limited or Shared Equity Cooperatives Investment: Limited Equity Cooperatives (LECs) and Shared Equity Cooperatives (SECs) provide opportunities for households to purchase a share of a development as opposed to an individual home. Price growth is restricted based on a formula for equity growth, and shares in the building can be resold at prices that ensure continued aﬀordability and modest equity growth.

Investments in LECs and SECs may include, but are not limited to, construction subsidies or low -interest ﬁnancing through the provision of loan products for residents to own shares in a cooperative housing corporation. c. Annual Budget
Eligible Jurisdictions must create an annual allocation budget for their PPO funding to be approved by the Eligible Jurisdiction’s governing body by November 1, 2025, for the FY25-26 time period. For subsequent ﬁscal years, an annual budget for PPO will be expected to be in place by May 1 of the preceding ﬁscal year or 60 days after the release of the expected annual budget, whichever is later. This budget will be a component of the ﬁrst quarter report.

If the Eligible Jurisdiction is requesting PPO funds to be advanced to them, funds shall be disbursed monthly, subject to availability.

During the course of the ﬁscal year, Eligible Jurisdictions may amend the annual budget based on changing needs and conditions. The revised budget shall be submitted to LACAHSA as amended.

LACAHSA Transitional Program Guidelines | September 2025

24 d. Documentation Standards
Eligible Jurisdictions should maintain appropriate documentation evidencing compliance with SB 679, Measure A, the MOU, and the requirements contained in these Guidelines. The guidance below represents the minimum documentation standards. Depending on the Eligible Jurisdiction’s unique project characteristics or program design, other documents not speciﬁed in this guidance may be appropriate; therefore, Eligible Jurisdictions are encouraged to retain all documentation related to Production, Preservation, and Ownership projects to support the reasonableness and eligibility of expenditures during LACAHSA monitoring and audit reviews.
i. PPO New Construction
Requirement Guidance Eligible Jurisdiction File
Use of PPO Funds Eligible Jurisdictions must maintain
accounting records demonstrating that
at least 77.25% of Measure A PPO Funds
are used for construction of new
aﬀordable housing.

Documentation Required
• Accounting records

Applications for
funding
The Eligible Jurisdiction’s application
documents (as may vary from
jurisdiction to jurisdiction).

Documentation Required
• Eligible Jurisdiction
application documents (at a
minimum the schedule of
performance)

• Development sources and
uses

• Cash ﬂow projections
Eligible
Jurisdiction’s
Project
Underwriting
The Eligible Jurisdiction’s project
underwriting documents
Documentation Required
• Underwriting guidelines /
lending standards

• Appraisals
• Construction cost estimates
• Subsidy layering review (as
applicable)

• Cost allocation for mixed
income projects

• Validation of other funding
source ﬁrm commitments

• Evaluation of developer
capacity

LACAHSA Transitional Program Guidelines | September 2025

25 Requirement Guidance Eligible Jurisdiction File
Written
Agreement
Written agreement containing
appropriate grant or loan documents
identifying the eligible project, passing
down the SB 679 and Measure A
requirements, and specifying the use of
funds within the project budget.

Documentation Required
• Copy of written agreement
and grant/loan documents
Aﬀordability
Restriction

Restrictive covenant for at least 55 years
containing at least the minimum unit
mix and income targeting required
pursuant to Government Code Section
64830(d)(1)(A)(ii).

Documentation Required
• Copy of recorded restrictive
covenant
Compliance with
Prevailing Wage
and Project Labor
Agreement
Requirements
A written certiﬁcation of compliance
with the Project Labor Agreement
requirements of Measure A Section 28C
and SB 679 Section 64720.5(b), which
require projects with 40 units or more
to comply with the City of Los Angeles
Department of Public Works Project
Labor Agreement 2020-2030 if the
project is within the City of Los Angeles,
or the Countywide Community
Workforce Agreement executed by the
Chief Executive Oﬃcer on June 7, 2023 if
the project is elsewhere, or any
successor to either agreement.

Construction or rehabilitation contracts
for projects with 40 units or more must
include provisions requiring compliance
with the applicable Project Labor
Agreement based on the location of the
project.
• Developer’s certiﬁcation of
compliance with PLA
requirements.

LACAHSA Transitional Program Guidelines | September 2025

26 Requirement Guidance Eligible Jurisdiction File
Aﬀordability
Requirements
Documentation of compliance with
portfolio and project aﬀordability
requirements pursuant to
64830(d)(1)(A)(ii).

Documentation Required
• Copy of recorded restrictive
covenants
• To demonstrate compliance
with the portfolio rule, a
table or inventory of
restricted units including
restricted unit mix by
income level that
corresponds with recorded
restrictive covenants
• To demonstrate compliance
with the project rule, a copy
of the full unit mix showing
all units and their
respective AMI restrictions
• Cost allocation
documentation for projects
that include units targeted
up to 120 percent of AMI
Relocation
Documents
If demolition or rehabilitation of
housing units is required as part of any
PPO investment, relocation and unit
replacement requirements apply. For
projects that require residents to be
relocated due to demolition or
rehabilitation needs, the developer is
required to provide relocation beneﬁts.

Documentation Required
• Evidence of relocation
pursuant to Gov. Code
7260-7277
• Calculation of relocation
assistance and justiﬁcation
for assistance amount

LACAHSA Transitional Program Guidelines | September 2025

27 Requirement Guidance Eligible Jurisdiction File
Unit Replacement Parcels with current residential uses or those with residential uses within ﬁve
years preceding the project that have
been vacated or demolished, or that
were subject to a recorded covenant,
ordinance, or law that restricts rents to
aﬀordable levels to levels aﬀordable to
persons and families of low- or very
low-income, subject to any other form
of rent or price control through a public
entity’s valid exercise of its police
power, or occupied by low- or very low-
income households, shall be subject to
a policy requiring the replacement of all
those units to be made available at
aﬀordable rent or aﬀordable housing
cost to, and occupied by, persons and
families in the same or lower income
category as those households in
occupancy.

Documentation Required
• Documentation of prior use
of parcels (e.g., were there
any residential uses
requiring replacement?)
• Evidence of unit
replacement pursuant to
Gov. Code 65915(c)(3)
Long-Term
Compliance
For projects leased up and in their
aﬀordability period, documentation of
compliance with unit mix and rent
requirements speciﬁed in the restrictive
covenant.

Documentation Required
• A copy of the full unit mix
showing all units and their
respective AMI restrictions
• A copy of the rent roll
• Tenant Income
Certiﬁcations
• Copies of residential leases

LACAHSA Transitional Program Guidelines | September 2025

28 ii. PPO Preservation
Requirement Guidance Eligible Jurisdiction File
Applications for
funding
The Eligible Jurisdiction’s application
documents (as may vary from
jurisdiction to jurisdiction).

Documentation Required
• Eligible Jurisdiction
application documents
(at a minimum the
schedule of
performance)
• Development sources
and uses

• Cash ﬂow statements
• Cash ﬂow projections
Eligible Jurisdiction’s
Project Underwriting
The Eligible Jurisdiction’s project
underwriting documents
Documentation Required
• Underwriting guidelines
/ lending standards

• Construction cost
estimates

• Subsidy layering review
(as applicable)

• Cost allocation for mixed
income projects

• Validation of other
funding source ﬁrm
commitments

• Evaluation of developer
capacity
Written Agreement Written agreement containing
appropriate grant or loan documents
identifying the eligible project, passing
down the SB 679 and Measure A
requirements, and specifying the use
of funds within the project budget.

Documentation Required
• Copy of written
agreement and
grant/loan documents

Aﬀordability
Restriction

Restrictive covenant for at least 55
years containing at least the minimum
unit mix and income targeting
required pursuant to Government
Code Section 64830(d)(1)(A)(ii).

Documentation Required
• Copy of recorded
restrictive covenant

LACAHSA Transitional Program Guidelines | September 2025

29 Requirement Guidance Eligible Jurisdiction File
Aﬀordability
Requirements
Documentation of compliance with
portfolio and project aﬀordability
requirements pursuant to
64830(d)(1)(A)(ii).

• Cost allocation
documentation for
projects that have units
targeted up to 120
percent of AMI
Relocation
Documents
If demolition or rehabilitation of
housing units is required as part of any
PPO investment, relocation and unit
replacement requirements apply. For
projects that require residents to be
relocated due to demolition or
rehabilitation needs, the developer is
required to provide relocation
beneﬁts.

Documentation Required
• Evidence of relocation
pursuant to Gov. Code
7260-7277
• Calculation of relocation
assistance and
justiﬁcation for
assistance amount

LACAHSA Transitional Program Guidelines | September 2025

30 Requirement Guidance Eligible Jurisdiction File
Unit Replacement Parcels with current residential uses or those with residential uses within ﬁve
years preceding the project have had
residential uses that have been
vacated or demolished, or that were
subject to a recorded covenant,
ordinance, or law that restricts rents to
aﬀordable levels to levels aﬀordable to
persons and families of low- or very
low-income, subject to any other form
of rent or price control through a
public entity’s valid exercise of its
police power, or occupied by low- or
very low-income households, shall be
subject to a policy requiring the
replacement of all those units to be
made available at aﬀordable rent or
aﬀordable housing cost to, and
occupied by, persons and families in
the same or lower income category as
those households in occupancy.

Documentation Required
• Documentation of prior
use of parcels (e.g., were
there any residential
uses requiring
replacement?)
• Evidence of unit
replacement pursuant to
Gov. Code 65915(c)(3)
Long-Term
Compliance
For projects leased up and in their
aﬀordability period, documentation of
compliance with unit mix and rent
requirements speciﬁed in the
restrictive covenant.

Documentation Required
• A copy of the full unit
mix showing all units
and their respective AMI
restrictions
• A copy of the rent roll
• Tenant Income
Certiﬁcations
• Copies of residential
leases

iii. PPO Ownership
Requirement Guidance Eligible Jurisdiction File
Ownership Program
Guidelines
The Eligible Jurisdiction’s program
guidelines to provide assistance
enabling low- or moderate-income
households to become or remain
homeowners.

Documentation Required
• Program Guidelines
• Underwriting /
assistance calculation
methodology

LACAHSA Transitional Program Guidelines | September 2025

31 Requirement Guidance Eligible Jurisdiction File
Written Agreement Written agreement containing
appropriate grant or loan documents
identifying the eligible project, passing
down the SB 679 and Measure A
requirements, and specifying the use
of funds.

Documentation Required
• Copy of written
agreement and
grant/loan documents

Eligible Jurisdiction’s
Application
The Eligible Jurisdiction’s application
documents (as may vary from
jurisdiction to jurisdiction).

Documentation Required
• Application documents
• Income determination
Aﬀordability
Restriction
Restrictive covenant as established by
Eligible Jurisdiction
Documentation Required
• Copy of recorded
restrictive covenant
Long-Term
Compliance
Veriﬁcation of compliance with
restrictive covenant.

Documentation Required
• Annual veriﬁcation of
ownership

5. Renter Protection & Homelessness Prevention (RPHP)
a. Overview
LACAHSA’s Renter Protection and Homelessness Prevention (RPHP) activities aim to address housing instability, reduce evictions and displacement, and prevent people from falling into homelessness. In accordance with SB679, LACAHSA is required to use a minim um of 30 percent of annual funding for RPHP.

RPHP achieves this by providing a comprehensive combination of renter protection and homelessness prevention services within an integrated, accessible, countywide approach.

Eligible uses of RPHP funds include:
• Marketing, Assessment, Eligibility, and Referral;
• Legal Services and Renter Education;
• Emergency Rental and Flexible Financial Assistance;
• Temporary Rental Assistance; and
• Short-Term Income Support.

RPHP assistance is intended to be temporary, short- term, and delivered to individuals and families who are currently housed in order to prevent the loss of housing or to resolve a housing cris is in a timely manner. RPHP funds are not intended to provide supports or

LACAHSA Transitional Program Guidelines | September 2025

32 services to people experiencing homelessness, nor to provide permanent housing assistance (longer than six months) . Other Measure A funds are available to Eligible Jurisdictions to support homeless services and permanent aﬀordable housing solutions, including funds administered by Los Angeles County Department of Homeless Services and Housing, Local Solutions Funds, and LACAHSA PPO Flex funds.
i. LACAHSA’s Integrated RPHP Service Model
An integrated approach for Los Angeles County is essential for maximizing the impact of resources, creating equitable access to services, ensuring eﬀective outcomes in reducing homelessness, and to:
• Make access and services consistent for households across the region; • Facilitate more eﬃcient referrals and resource coordination; • Target resources to households most likely to become homeless or experience housing instability without assistance;
• Promote regional alignment and reduce duplication; and • Enable consistent data collection to support program evaluation and equity analyses.

To support this approach across the region, LACAHSA will develop an RPHP Integrated Service Model, which will build on and enhance coordination between existing RPHP programs to deliver comprehensive RPHP services throughout Los Angeles County.

During FY 2025 -26, LACAHSA will lead a community wide planning process to design the Integrated Service Model in collaboration with Eligible Jurisdictions, community members, and stakeholders. Concurrent with the planning process, LACAHSA will also conduct pilots to test approaches to the Integrated Service Model. The model will be ﬁnalized in Spring 2026 and the Integrated Service Model will go into eﬀect in July 2026.

To support the participation of Eligible Jurisdictions in the planning process, during FY 2025- 26, LACAHSA will provide supplemental funds of up to 5 percent of an Eligible Jurisdiction’s RPHP allocation to an Eligible Jurisdiction that participates in the planning process. To receive these funds, Eligible Jurisdictions must commit to active involvement in planning sessions and to conduct outreach and engagement with community members and stakeholders in their jurisdication to ensure broad awareness of and participation in the process.

Eligible Jurisdictions may use their Technical Assistance funds to support participation in planning activities. Additionally, a portion of LACAHSA Technical Assistance funds will be dedicated to support the development of the Integrated Service Model , including providing funding for planning, collaboration, evaluation, and infrastructure to enable integration and eﬀective service delivery.

LACAHSA Transitional Program Guidelines | September 2025

33 b. Program Requirements
i. Implementation
Eligible Jurisdictions have two choices for administering the RPHP funds allocated to them under LACAHSA’s Annual Expenditure Plan:

LACAHSA-Administered
Eligible Jurisdictions may elect to have LACAHSA administer all or a portion of their RPHP allocation in partnership with that Eligible Jurisdiction. LACAHSA will use those funds to ensure that eligible services are provided in the Eligible Jurisdiction’s area, utilizing LACAHSA’s Integrated Service Model when it is developed and implemented.

The details regarding LACAHSA’s administration of an Eligible Jurisdiction’s RPHP allocation will be determined case by case through a collaborative decision -making process between LACAHSA and the Eligible Jurisdiction.

Self-Administration
Eligible Jurisdictions may administer all or a portion of their funding themselves, to directly carry out RPHP programs. This may include passing through their allocation to another Eligible Jurisdiction to administer on their behalf, subject to the applicable terms of the MOU.

Whether Eligible Jurisdictions choose LACAHSA -administration, self -administration, or a combination, LACAHSA program staﬀ are available to all Eligible Jurisdictions for consultation and planning regarding the use of LACAHSA funds, development of budgets and spending plans, programmatic technical assistance, and to foster cross-jurisdictional partnerships.

All programs funded with RPHP resources administered by the Eligible Jurisdiction must meet all the requirements contained in Measure A, SB 679, and these Program Guidelines.

This may include the required use of any future data systems, shared tools, or processes developed for the Integrated Service Model and determined by LACAHSA to promote an accessible and equitable RPHP countywide approach and accountability. ii. Annual Budget
Eligible Jurisdictions must create an annual budget for their RPHP funding to be approved by the Eligible Jurisdiction’s governing body by November 1, 2025, for the FY 2025 -26 time period. For subsequent ﬁscal years, an annual budget for RPHP will be expe cted to be in place by May 1 of the preceding ﬁscal year or 60 days after the release of the expected annual budget, whichever is later. This budget will be a component of the ﬁrst quarter report.

If the Eligible Jurisdiction is requesting RPHP funds to be advanced to them, funds shall be disbursed monthly, subject to availability.

LACAHSA Transitional Program Guidelines | September 2025

34 During the course of the ﬁscal year, Eligible Jurisdictions may amend the annual budget based on changing needs and conditions. The revised budget shall be submitted to LACAHSA as amended.

LACAHSA program staﬀ are available to all Eligible Jurisdictions for consultation and planning regarding the development of budgets and spending plans. Eligible Jurisdictions are encouraged to contact LACAHSA staﬀ as needed to support preparation of budget submissions.
iii. Deﬁnition of Eligible Renter and Prohibited Uses
RPHP provides renter protection and homelessness prevention services. A ssistance is intended to be temporary, short- term, and delivered to individuals and families who are currently housed in order to prevent the loss of housing or to resolve temporary housing crises in a timely manner.

For the purposes of RPHP funding, an eligible renter household includes any household that is lower income
1 and currently resides in rental housing, whether with a written lease, verbal agreement, or other informal arrangement conferring rights of tenancy. It also includes households temporarily staying in another housing setting who do not have suﬃcient resources or support networks to maintain stable housing or to prevent housing loss and/or homelessness.

RPHP funds are not intended to provide support and services to people experiencing homelessness or to households that own a home or have a mortgage. Homeless services not eligible for RPHP funding are as follows: coordinated entry and access point services, outreach, intake, case management, housing navigation, safe parking, emergency shelter, congregate shelter, interim housing, transitional housing, rental subsidies greater than six months, or income support programs (e.g., Universal Basic Income (UBI) or Guaranteed Basic Income (GBI)) , or other homeless -targeted programs serving an individual or family who lacks a ﬁxed, regular, and adequate nighttime residence. iv. Overarching Requirements
RPHP provides funding for ﬁve primary eligible uses, as deﬁned in the LACAHSA Annual Expenditure Plan. Eligible Jurisdictions are encouraged to oﬀer an integrated and comprehensive combination of eligible activities:

1. Marketing, Assessment, Eligibility, and Referral

2. Legal Services and Renter Education

1 Per Section 50079.5 of the California Health and Safety Code.

LACAHSA Transitional Program Guidelines | September 2025

35 3. Emergency Rental and Flexible Financial Assistance

4. Temporary Rental Assistance

5. Short-Term Income Support
Households may receive either Emergency Rental and Flexible Financial Assistance OR Temporary Rental Assistance, but cannot receive both during the same 24-month period of assistance. Households receiving Emergency Rental and Flexible Financial Assistance or Temporary Rental Assistance may also receive Short- Term Income Support, but assistance cannot be provided concurrently. Households may also receive Short-Term Income Support independently (i.e. without also having received Emergency Rental and Flexible Financial Assistance or Temporary Rental Assistance) based on the needs identiﬁed in the intake and assessment of the household.

All RPHP activities conducted by Eligible Jurisdictions must adhere to these Program Guidelines, including but not limited to:
• Utilization of required data systems, shared tools, or processes (once they are developed).
• Services must incorporate Marketing, Assessment, Eligibility, and Referral to ensure that all households are served consistently and equitably across the county. • Eligible Jurisdictions must spend at least 20 percent of their allocation on Legal Services and at least 40 percent of their allocation on Emergency Rental and Flexible Financial Assistance.
v. Limits on Financial Assistance
Households may receive up to $ 36,000 in combined ﬁnancial assistance within a 24-month period. After reaching either the assistance limit of $ 36,000 or time limit of 24 months, a household must wait at least 6 months before receiving additional assistance.

The period of assistance to a household begins on the ﬁrst day any RPHP assistance payment is made, whether directly to a household or to a property owner or third -party vendor on the household’s behalf. To ensure adequate and appropriate levels of assistance can be made available to as many households as possible, LACAHSA encourages Eligible Jurisdictions to customize the amount of assistance to households based on factors such as household size, income level, and ability to cover a portion of costs.

Expenditures of RPHP funds to provide housing-focused case management services or other staﬃng costs to provide ﬁnancial assistance do not count towards the $ 36,000 limit on combined ﬁnancial assistance.

LACAHSA Transitional Program Guidelines | September 2025

36 Financial assistance cannot be concurrently provided between two or more eligible activities at the same time. For example, a household receiving Emergency Rental and Flexible Financial Assistance from January to June (up to six months of rental assistance) cannot also be receiving Short- Term Income Support for the same period. If the Eligible Jurisdiction determines the household requires continued assistance in the form of Short-Term Income Support, that assistance could begin in July (when Emergency Rental and Flexible Financial Assistance concludes).

Eligible Jurisdictions are encouraged to work with households to determine the least amount of assistance necessary to resolve the housing crisis, allowing households to return for reassessment and/or additional assistance if the crisis is not resolved. vi. Tax Implications of Financial Assistance for Participants Eligible Jurisdictions operating ﬁnancial assistance programs must have a clear understanding of what the income/beneﬁts and tax implications are for their participants who receive ﬁnancial assistance, must oﬀer individual assessments for people regarding the potential impacts, and must make any potential consequences clear to participants prior to enrollment.

To support Eligible Jurisdictions in providing appropriate guidance, LACAHSA will use LACAHSA TA resources to provide a summary document highlighting potential tax and public beneﬁt implications for RPHP participants. LACAHSA will publish this document by the end of calendar year 2025.
vii. Minimum Expenditure Levels for Legal Services and Emergency Rental and Flexible Financial Assistance
Eligible Jurisdictions must spend at least 20 percent of their RPHP allocation on Legal Services (inclusive of eviction defense and other legal services) and at least 40 percent of their RPHP allocation on Emergency Rental and Flexible Financial Assistance (inclusive of ﬁnancial assistance to households and staﬀ costs to provide ﬁnancial assistance). If an Eligible Jurisdiction has made a documented, commensurate investment in legal services or ﬁnancial assistance, they may request a waiver from this requirement.

For example, if an Eligible Jurisdiction has an RPHP allocation of $1,000,000, the expenditure levels would be:

Category Amount
Legal Services $200,000 (Minimum 20%)

LACAHSA Transitional Program Guidelines | September 2025

37 This includes the jurisdiction’s allocation of
Activity Delivery Costs (up to 25% of total Legal
Services allocation)
Emergency Rental and Flexible Financial
Assistance
$400,000 (Minimum 40%)
This includes the jurisdiction’s allocation of
Activity Delivery Costs (up to 25% of total
Emergency Rental and Flexible Financial
Assistance allocation)
Jurisdictional Discretion (may consist of any
of the eligible categories)
$275,000

This includes the jurisdiction’s allocation of
Activity Delivery Costs (up to 25% of total funds
allocated to each eligible activity)
Administration (12.5%) $125,000
Jurisdiction Award $1,000,000

viii. Reporting Requirements
SB 679 and Measure A have requirements for data collection and reporting. Data must be collected related to risk of homelessness and reductions in homelessness, displacement and displacement risk, rents, and evictions in the region. Annual aggregate reporting on households served and expenditures will be required, including, but not limited to:
• Household composition and demographics
• Eligibility including income, housing status, and qualifying event(s)/crisis(es) • Prioritization factors
• Expenditure categories, payees, and amounts
• Time in program
• Destination at end of program
To ensure consistent tracking and oversight across the region, LACAHSA will identify or develop a database and/or shared data collection methods that all Eligible Jurisdictions will be required to use for collecting and reporting household -level program da ta once the database and/or shared data collection methods are available. LACAHSA will work to ensure that any database and/or shared data collection methods align and/or integrate with existing

LACAHSA Transitional Program Guidelines | September 2025

38 tools utilized by Eligible Jurisdictions and protect Personally Identiﬁable Information (PII) of all participants. If an Eligible Jurisdiction wishes to use an alternative database and/or data collection method, they must ﬁrst obtain prior approval from LACAHSA.

The database and/or shared data collection methods will also support a Duplication of Beneﬁts check, helping to ensure that households do not receive overlapping or redundant assistance. For purposes of Measure A funding, Duplication of Beneﬁts refers to any household that receives Measure A funding from multiple sources for the same time period OR receives Measure A funding from multiple sources that results in the household exceeding the time period and ﬁnancial limits set forth in these Guidelines.

Programmatic reporting for RPHP activities shall be submitted on a regular basis as part of the overall reporting requirement. To ensure that reporting is not duplicative of existing requirements, reporting to LACAHSA will be aligned, to the maximum extent feasible, with existing reporting requirements.
ix. Marketing, Assessment, Eligibility and Referral
Eligible Jurisdictions can choose to deliver any combination of eligible activities; however, all programs are expected to include Marketing, Assessment, Eligibility, and Referral services.

These required services should be accessible and low -barrier for h ouseholds seeking assistance and should connect households to the most eﬀective services for their needs in a timely manner.

Eligible Jurisdictions are encouraged to use a standard access, assessment, eligibility and referral method for all services (Legal Services, Emergency Rental and Flexible Financial Assistance, Temporary Rental Assistance , and Short- Term Income Support) in order to ensure that households are assessed and prioritized equitably, have access to any service or combination of services for which they qualify, and receive the appropriate services that oﬀer the most successful ho using stability outcome. Eligible J urisdictions are also encouraged to work with households to determine the least amount of assistance necessary to resolve the housing crisis, allowing households to return for reassessment and/or additional assistance if the crisis is not resolved.

Eligible Jurisdictions are required to assess household needs and target services to those most at risk of eviction or homelessness. Assessment and targeting tools and processes should consider populations who have higher risk factors, which may include fo rmerly homeless individuals, older adults, people with disabilities, families with minor children that are not yet school -age, families where the head of household is young, undocumented individuals, people living in impacted zip codes, and those on ﬁxed-incomes.

LACAHSA Transitional Program Guidelines | September 2025

39 Upon implementation of the Integrated Service Model, LACAHSA will provide standardized assessment and targeting tools and processes for use by all Eligible Jurisdictions. Use of alternative tools or processes prior to and following implementation of the In tegrated Service Model requires approval from LACAHSA.
x. Grievance and Appeals
Participating and eligible households have the right to grieve any service that they believe was not properly delivered and to appeal any decision resulting in a denial or limitation of service. Eligible Jurisdictions that do not participate in LACAHSA‘s I ntegrated Service Model when it is implemented will be required to develop their own process. Grievance and appeals processes should be as accessible and supportive as possible, which may include: accounting for the fear and barriers that households may ex perience when reporting harm or unfair treatment; making the process available in multiple languages; oﬀering the option to have an advocate present at any interview or hearing; and oﬀering the option to ﬁle anonymously, through an advocate, or via a third-party system.
c. Approved Eligible Uses of Funding
LACAHSA’s Annual Expenditure Plan identiﬁes Board-approved eligible uses for RPHP funds.

This section outlines the eligible uses and requirements regarding household eligibility criteria and the duration and amount of assistance.

Eligible Jurisdictions are encouraged to oﬀer a comprehensive combination of activities allowable within the eligible uses in order to oﬀer ﬂexibility and choice to households seeking assistance. Eligible Jurisdictions may choose to deliver any combination of eligible activities; however, all programs are expected to include Marketing, Assessment, Eligibility, and Referral services.

For each eligible activity, LACAHSA and Eligible Jurisdictions may provide services directly, through partnerships with contracted service providers, and in partnership with LACAHSA and other Eligible Jurisdictions on countywide or regional initiatives.

As needed, inquiries regarding additional eligible uses for RPHP funding may be raised to the LACAHSA’s Chief Programs Oﬃcer for assistance and consideration.

LACAHSA Transitional Program Guidelines | September 2025

40 The pathways of assistance are summarized in the chart below:

i. Marketing, Assessment, Eligibility, and Referral
Marketing, Assessment, Eligibility, and Referral identiﬁes households at risk of losing their housing, assesses their needs, determines their eligibility for assistance, and connects them directly with RPHP resources and support to avoid homelessness.

Eligible
Activities

Marketing – Marketing involves eﬀorts to ensure that the target population for services is aware of the services and able to apply for and access them at the appropriate time. Marketing may include outreach, advertising, attending community events, visiting sites where low-income households facing a housing crisis may be found, and other eﬀorts to ensure that the services are well publicized. LACAHSA encourages marketing eﬀorts to include aﬃrmative outreach strategies for speciﬁc vulnerable and historically excluded subpopulations including, but not limited to, transition- aged youth, families with young children, older adults, limited English proﬁciency populations, and people with disabilities.

Assessment – Assessment involves gathering applications from potential participants, assessing their likely eligibility, and prioritizing among applicants to determine the order and level at which eligible households are oﬀered assistance based on level of need or
vulnerability. Assessment
activities include establishing and operating application and assessment mechanisms, such as electronic portals for receiving and reviewing applications, assessment and prioritization tools, and providing assistance to p otentially eligible households to gather documents and apply for assistance.

LACAHSA Transitional Program Guidelines | September 2025

41 Eligibility – Eligibility determination is the process of reviewing an application and assessment, conﬁrming priority, establishing eligibility for support, and enrolling a household. Eligibility determination may include meeting with potential participants and/or r eviewing documents to verify eligibility for assistance, assisting households to gather additional needed documents to prove eligibility and document payment needs, and enrolling households in the program.

Referral – Referral is the process of connecting eligible households to RPHP resources and services for which they are eligible, and which will help them to maintain their housing and to avoid eviction or homelessness.

Activities related to ongoing housing- focused case management are included as eligible activities under the uses outlined below.

ii. Legal Services and Renter Education
Legal Services and Renter Education oﬀers legal representation, advocacy, outreach, and education to households at risk of losing their housing.

Eligible
Activities
Eligible Legal Services and Renter Education activities include, but are not limited to, the following:
• Renter outreach and education
• Evaluation of underlying issues aﬀecting the client’s legal situation • Holistic legal representation and advocacy for issues that directly impact a household’s ability to remain housed:
o Housing issues such as pre -leasing, obtaining vital
documents, reasonable accommodations, habitability, pre - eviction and eviction defense
o Clearing evictions, tickets, warrants, or criminal records o Application for or appealing the denial of public beneﬁts o Other housing-related legal issues such as domestic violence, consumer ﬁnance, immigration, and issues aﬀecting family composition (divorce, child support, restraining orders, health concerns)
• Mediation Services, including negotiating payment plans • Pre-eviction and eviction defense services
• Right-to-counsel legal services

LACAHSA Transitional Program Guidelines | September 2025

42 • Limited payments associated with court appearances (e.g. court ﬁling fees)
Emergency Rental and Flexible Financial Assistance, Temporary Rental Assistance, and Short-Term Income Support are not eligible expenses under Legal Services and Renter Education. Eligible Jurisdictions are strongly encouraged to pair rental and ﬁnancial assistance with Legal Services and Renter Education services.

Eligible Jurisdictions may also use Legal Services and Renter Education funds to provide housing- focused case management services to support housing stability for households receiving Legal Services and Renter Education. Eligible Jurisdictions that provide multiple types of assistance are encouraged to use the same case management staﬀ across all categories of assistance, rather than staﬀ case management separately for each type of assistance program. Eligible housing-
focused case management services
may include, but are not limited to, the following:
• Ongoing assessment and housing stability support
• Preparation of a housing stability plan
• Support with accessing legal services and/or ﬁnancial assistance, including completing assistance requests and following up on receipt of assistance and outcomes for households
• Providing information and referrals to community resources, and support with accessing County programs and other mainstream beneﬁts and services oﬀered by partner agencies
Household
Eligibility
Criteria
To be eligible to receive Legal Services and Renter Education assistance, a person/household must meet the following criteria:
• Live in Los Angeles County; and
• Have an annual income at or below 80 percent of AMI (Eligible Jurisdictions are encouraged to prioritize assistance to households at or below 50 percent of AMI; as described in Documentation Standards section, renter outreach and education does not require individual household income veriﬁcation);
• Be a renter (as deﬁned above in the section titled “Deﬁnition of Eligible Renter and Prohibited Uses”); and

LACAHSA Transitional Program Guidelines | September 2025

43 • Have experienced an emergency, crisis, or unexpected event within the previous 12 months that puts the household at risk of losing their housing, such as:
o Action of landlord or property management
o Unlawful detainer (eviction lawsuit)
o Threat of displacement or housing instability
o Loss of income
o Loss or delay of public income beneﬁts
o Medical emergency
o Change of household (birth, death, loss of income earner) o Natural disaster
o Sudden increase in critical expenses
o Other emergency that threatens housing stability
Duration
and
Amount of
Assistance
Not applicable

iii. Emergency Rental and Flexible Financial Assistance Emergency Rental and Flexible Financial Assistance provides ﬁnancial assistance for a variety of housing- related expenses to support the stabilization of households experiencing an immediate housing crisis and at risk of losing their housing.

Eligible
Activities
Eligible Emergency Rental and Flexible Financial Assistance expenses include the following:
• Security Deposits and Other Required Deposits
• Rental Assistance (up to 6 months)
• Rental Arrears (no time limit for how far back arrears can be paid) • Utility Deposits
• Utility Assistance
• Utility Arrears
• Move-in Expenses
• Essential Furniture and Cleaning
• Moving Expenses
• Relocation Expenses (to cover costs beyond what is legally required of property owners according to local or state law)

LACAHSA Transitional Program Guidelines | September 2025

44 • Housing Stability Expenses:
o Document Fees
o Employment-Related Expenses
o Transportation-Related Expenses, including vehicle repairs, public transportation costs, and rideshare service costs o Healthcare Costs, including medical bills
o Food
o Dependent Care
o Short-Term Vocational Training
Households currently enrolled or exiting a permanent or time limited subsidy program such as rapid rehousing, shallow subsidies, or other TLS, including Temporary Rental Assistance programs funded by RPHP, are not eligible for Emergency Rental and Flexible Financial Assistance.

The only exception to this requirement is if a household is enrolled in an income-based subsidy program (such as Housing Choice Voucher or Permanent Supportive Housing). These households may receive ﬁnancial assistance for rental arrears. Staﬀ supporting
households with
Emergency Rental and Flexible Financial Assistance should make every eﬀort to engage public housing authorities, landlords, property management, utility companies, and other venders to establish appropriate rent or payment adjustments and reasonable payment plans.

Eligible Jurisdictions may also use Emergency Rental and Flexible Financial Assistance funds to provide housing-focused case management services to support housing stability for households receiving Emergency Rental and Flexible Financial Assistance, for the full duration of their assistance period (i.e. up to 24 months from the ﬁrst ﬁnancial assistance payment).

Eligible Jurisdictions that provide multiple types of ﬁnancial assistance are encouraged to use the same case management staﬀ across all categories of assistance, rather than staﬀ case management separately for each type of assistance program. Eligible housing -focused case management services may include, but are not limited to, the following:
• Ongoing assessment and housing stability support
• Preparation of a housing stability plan

LACAHSA Transitional Program Guidelines | September 2025

45 • Support with accessing ﬁnancial assistance, including completing ﬁnancial assistance requests and following up on receipt of assistance and outcomes for households
• Providing information and referrals to community resources, and support with accessing County programs and other mainstream beneﬁts and services oﬀered by partner agencies
Household
Eligibility
Criteria
To be eligible to receive Emergency Rental and Flexible Financial Assistance, a person/household must meet the following criteria:
• Live in Los Angeles County; and
• Have an annual income at or below 80 percent of AMI (Eligible Jurisdictions are encouraged to prioritize assistance to households at or below 50 percent of AMI);
• Be a renter (as deﬁned above in the section titled “Deﬁnition of Eligible Renter and Prohibited Uses”); and
• Have experienced an emergency, crisis, or unexpected event within the previous 12 months that puts the household at risk of losing their housing, such as:
o Action of landlord or property management
o Unlawful detainer (eviction lawsuit)
o Threat of displacement or housing instability
o Loss of income
o Loss or delay of public income beneﬁts
o Medical emergency
o Change of household (birth, death, loss of income earner) o Natural disaster
o Sudden increase in critical expenses
o Other emergency that threatens housing stability

LACAHSA Transitional Program Guidelines | September 2025

46 Duration and
Amount of
Assistance

Households may receive up to 6 months of Emergency Rental and Flexible Financial Assistance. Total ﬁnancial assistance to a person/household must not exceed $ 36,000 from any combination of eligible ﬁnancial assistance activities within a 24- month period. After reaching either the assistance limit of $36,000 or time limit of 24 months, a household must wait at least 6 months before receiving additional assistance.

Households are not eligible for Emergency Rental and Flexible Financial Assistance if they are already receiving Temporary Rental Assistance.

Emergency Rental and Flexible Financial Assistance payments can only be authorized for one month at a time (excluding arrears payments) to ensure that households continue to reside in the assisted housing unit.

Prioritization To support the equitable and eﬀective provision of Emergency Rental and Flexible Financial Assistance, Eligible Jurisdictions are required to assess household needs and target assistance to those most at risk of eviction or homelessness.

iv. Temporary Rental Assistance
Temporary Rental Assistance provides rental assistance for households at risk of losing their housing OR who have a housing crisis which the household cannot resolve independently.

Eligible
Activities
Eligible Temporary Rental Assistance expenses include the following:
• Rental Assistance (up to 6 months)
• Utility Assistance (up to 6 months)
For households that require security deposit or move -in assistance, the program is encouraged to leverage other resources. such as the County HAP program.

Temporary Rental Assistance can be used to provide step -down assistance to households exiting time -limited or permanent subsidy programs.

Eligible Jurisdictions may also use Temporary Rental Assistance funds to provide housing-focused case management services to support housing stability for households receiving Temporary Rental Assistance, for the full duration of their assistance period (i.e. up to 24 months from the ﬁrst

LACAHSA Transitional Program Guidelines | September 2025

47 ﬁnancial assistance payment). Eligible Jurisdictions that provide multiple types of ﬁnancial assistance are encouraged to use the same case management staﬀ across all categories of assistance, rather than staﬀ case management separately for each type o f assistance program.

Eligible housing-focused case management services may include, but are not limited to, the following:
• Ongoing assessment and housing stability support
• Preparation of a housing stability plan
• Support with accessing ﬁnancial assistance, including completing ﬁnancial assistance requests and following up on receipt of assistance and outcomes for households
• Providing information and referrals to community resources, and support with accessing County programs and other mainstream beneﬁts and services oﬀered by partner agencies
Case management assistance cannot be used to provide housing navigation or housing search services.

Household
Eligibility
Criteria
To be eligible for Temporary Rental Assistance, a household must:
• Live in Los Angeles County; and
• Have an annual income at or below 80 percent of AMI (Eligible Jurisdictions are encouraged to prioritize assistance to households at or below 50 percent of AMI); and
• Be a renter (as deﬁned above in the section titled “Deﬁnition of Eligible Renter and Prohibited Uses”) or have a rental unit identiﬁed; and
• Have a documented housing crisis which the household cannot resolve without Temporary Rental Assistance.

Duration and
Amount of
Assistance
Households may receive up to 6 months of Temporary Rental Assistance.

Total ﬁnancial assistance to a person/household must not exceed $36,000 from any combination of eligible ﬁnancial assistance activities within an 24- month period. After reaching either the assistance limit of $36,000 or time limit of 24
months, a household must wait at least 6
months before receiving additional assistance.

Households are not eligible for Temporary Rental Assistance if they are already receiving Emergency Rental and Flexible Financial Assistance.

LACAHSA Transitional Program Guidelines | September 2025

48 Temporary Rental Assistance payments can only be authorized for one month at a time to ensure that households continue to reside in the assisted housing unit.

Prioritization To support the equitable and eﬀective provision of Temporary Rental Assistance, Eligible Jurisdictions are required to assess household needs and target assistance to those most at risk of eviction or homelessness.

v. Short-Term Income Support
Short-Term Income Support involves providing direct income assistance for households at risk of losing their housing.

Eligible
Activities
Short-Term Income Support payments are made directly to eligible households.

Short-Term Income Support provides ﬁnancial assistance to help eligible households meet their basic needs during temporary periods of ﬁnancial instability.

Eligible Jurisdictions may also use Short -Term Income Support funds to provide housing-focused case management services to support housing stability for households receiving Short-Term Income Support, for the full duration of their assistance period (i.e. up to 18 months from the ﬁrst ﬁnancial assistance payment). Eligible Jurisdictions that provide multiple types of ﬁnancial assistance are encouraged to use the same case management staﬀ across all categories of assistance, rather than staﬀ case manage
ment separately for each type of assistance program.

LACAHSA Transitional Program Guidelines | September 2025

49 Case management assistance cannot be used to provide housing navigation or housing search services.

Household
Eligibility
Criteria
To be eligible for Short-Term Income Support, a household must:
• Live in Los Angeles County; and
• Have an annual income at or below 80 percent of AMI (Eligible Jurisdictions are encouraged to prioritize assistance to households at or below 50 percent of AMI); and
• Be a renter (as deﬁned above in the section titled “Deﬁnition of Eligible Renter and Prohibited Uses”) or have a rental unit identiﬁed; and
• Have a documented housing crisis which the household cannot resolve without Short-Term Income Support.

Duration and
Amount of
Assistance
Households may receive up to 18 months of Short-Term Income Support.

Total ﬁnancial assistance to a person/household must not exceed $36,000 from any combination of eligible ﬁnancial assistance activities within a 24-month period. After reaching either the assistance limit of $36,000 or time limit of 24 months, a household must wait at least 6 months before receiving additional assistance.

Monthly Short- Term Income Assistance to a household cannot exceed $2,000 per month.

Short-Term Income Support programs may be structured for periods up to 18 months, but payments can only be authorized for one month at a time to ensure that households are still located in Los Angeles County and eligible for assistance.

Prioritization As the income support payments are intended to be short -term, Eligible Jurisdictions are encouraged to prioritize households who have or anticipate having income from employment/beneﬁts, are currently at or below 50 percent of AMI, and are currently working toward an increase in income through employment, education, or eligibility for beneﬁts.

LACAHSA Transitional Program Guidelines | September 2025

50 b. Documentation Standards and Guidance
Eligible Jurisdictions and Subrecipients must ensure that eligibility is determined for households assisted and that funds are spent in accordance with Measure A, SB679, and these Program Guidelines.

No RPHP program or activity may request or maintain documentation related to assisted household immigration status.

Eligible Jurisdictions and Subrecipients may utilize their own documentation requirements and review standards, provided they include policies and procedures covering all of the following elements:

1. Collect and review documentation to determine that households meet all eligibility criteria for assistance, including:

Legal Services and Renter Education and Emergency Rental and Flexible Financial Assistance2 a. Live in Los Angeles County; and
b. Have an annual income at or below 80 percent of AMI (Eligible Jurisdictions are encouraged to prioritize assistance to households at or below 50 percent of AMI); and
c. Be a renter (as deﬁned above in the section titled “Deﬁnition of Eligible Renter and Prohibited Uses”); and
d. Have experienced an emergency, crisis, or unexpected event within the previous 12 months that puts the household at risk of losing their housing, such as:
i. Action of landlord or property management
ii. Unlawful detainer (eviction lawsuit)
iii. Threat of displacement or housing instability
iv. Loss of income
v. Loss or delay of public beneﬁts
vi. Medical emergency
vii. Change of household (birth, death, loss of income earner) viii. Natural disaster
ix. Sudden increase of critical expenses

2 When conducting workshops or other educational activities under the Legal Services and Renter Education activity , Eligible Jurisdictions do not need to collect individual income or other eligibility documentation for all participants. Eligible Jurisdictions must maintain documentation to show how the activities were marketed in a fashion to encourage participation by eligible, low-income households.

LACAHSA Transitional Program Guidelines | September 2025

51 x. Other emergency that threatens housing stability
Temporary Rental Assistance and Short-Term Income Support a. Live in Los Angeles County; and
b. Have an annual income at or below 80 percent of AMI (Eligible Jurisdictions are encouraged to prioritize assistance to households at or below 50 percent of AMI); and
c. Be a renter (as deﬁned above in the section titled “Deﬁnition of Eligible Renter and Prohibited Uses”) OR have a rental unit identiﬁed; and d. Have a documented housing crisis which the household cannot resolve without Short-Term Income Support.

2. P o l i c i e s m u s t i n c l u d e t h e a b i l i t y f o r a h o u s e h o l d t o c o m p l e t e a n a ﬃ d a v i t o f z e r o income if the household has no income.

3. Verify and document amounts owed by the renter for all expenditures covering anticipated costs or previous costs incurred by the renter. (This means, for example, that for past rent due or utilities, there is a document that shows how much is owed, by whom it is owed, and to whom it is owed.)

4. Verify and ensure that payments of any type of ﬁnancial assistance are made to parties eligible to receive them and have measures in place to ensure that the party receiving the funds is the intended party and that funds are applied to the cost they are intended for. (This means, for example, in the case of rental assistance, that a property owner or property management agency is veriﬁed as the legal owner of the property or a representative of the owner, and that communication with the property owner or property manager makes it clear that the funds are to be applied to the speciﬁc eligible renter’s rent.)

5. Adopt and follow policies and practices in place to prevent and detect fraud, waste, and abuse and to avoid actual, or appearances of, conﬂicts of interest.

6. Conduct a Duplication of Beneﬁts check before providing ﬁnancial assistance to ensure that assistance does not duplicate beneﬁts available from other federal, state, or local sources.

Such policies shall not be used to refuse assistance to an otherwise eligible household. For example, if an eligible household is living with another household to whom they pay rent, but there is no lease between the parties, the program should document the relationship, the right to occupy of the second household, and a past pattern of payment in order to serve the household.

LACAHSA Transitional Program Guidelines | September 2025

52 Programs that do not have currently conforming policies must either update their policies or adopt documentation policies that cover the above conditions and needs. Examples of conforming policies already in use in Los Angeles County include:
• LAHSA Scope of Required Services (SRS) for Homeless Prevention Services • Pasadena Partnership Homeless Prevention

6. Technical Assistance (TA)
a. Overview
SB 679 requires LACAHSA to allocate funding for Technical Assistance (TA). LACAHSA directly administers a portion of the TA funding and allocates a portion to Eligible Jurisdictions.

LACAHSA’s Annual Expenditure Plan identiﬁes eligible program types for TA funds. For each program type, LACAHSA and Eligible Jurisdictions may provide services directly or through contracted service providers. SB 679 also requires that LACAHSA set aside programmatic funds speciﬁcally to provide TA to cities with a population under 50,000 and create a bench of consultants able to provide TA to those cities.

As needed, additional uses of TA funding may be raised to the LACAHSA’s Chief Engagement and Intergovernmental Oﬃcer for consideration and escalated to LACAHSA’s General Counsel or the LACAHSA Board if required.
b. Approved Eligible Uses of Funding
i. Local Agency TA Grants
Local Agency TA Grants - At Large
LACAHSA will administer a Local Agency TA Grant program that will allow Eligible Jurisdictions and their member jurisdictions to apply directly to LACAHSA for TA funds. TA grants may be used to supplement an Eligible Jurisdiction’s allocation of TA funds or provide direct funding to member cities and their Housing or Community Development Departments. TA funds may also be used to develop supporting materials and trainings for Eligible Jurisdictions.

Local Agency TA Grants - Small Cities
LACAHSA, in collaboration with the COGs, will administer a Small Cities TA Grant program for cities with populations under 50,000. Eligible cities will apply directly to LACAHSA and/or the COG for technical assistance funds. The TA grants will provide dire ct funding to member cities and their Housing or Community Development Departments.

LACAHSA Transitional Program Guidelines | September 2025

53 Application and Funding Process
Eligible Jurisdictions may apply for direct TA from LACAHSA at any point during the program year. Upon receipt of the application, LACAHSA will review the requested TA needs and meet with the Eligible Jurisdiction to determine if LACAHSA can provide the as sistance or identify an alternative approach to support the Eligible Jurisdiction.

Upon submission of an application, small cities that apply for a Small Cities TA Grant will be immediately provided with a limited amount of on-call TA from a TA provider contracted by LACAHSA and matched to the city based on the TA topic(s) identiﬁed in the city’s application. ii. Direct TA Programming
LACAHSA may provide direct TA to Eligible Jurisdictions and their member jurisdictions to engage in coordination and capacity building. Direct TA may be delivered through technical workshops, training sessions, education on best practices, and regulatory c ompliance support. LACAHSA may hire dedicated staﬀ to lead programming and coordination eﬀorts and/or engage with outside experts including academics, practitioners, and third -party consultants.

Speciﬁc eligible uses of LACAHSA’s Direct TA funding include but are not limited to:
• Full-time staﬀ dedicated to regional coordination, such as an Ombuds role; and • Training and capacity building workshops for Eligible Jurisdictions related to core program services including NOFA administration, loan underwriting, risk analysis, and asset management.

Needs Assessment
As part of LACAHSA’s Direct TA Programming, LACAHSA will assign a TA provider to conduct a needs assessment with each new funding recipient to review their proposed activities and structure. The assigned TA team will provide a written needs assessment to L ACAHSA identifying potential resources that could beneﬁt each recipient. The needs assessment will be conducted within the ﬁrst three months of the program year of the funding allocation. iii. Program Design, Administration, Monitoring, and Evaluation LACAHSA and Eligible Jurisdictions may use TA funds to develop internal staﬀ capacity and administrative infrastructure required to design, operate, monitor, and evaluate related programs. TA may be provided by agency staﬀ, third- party experts, and/or co nsultants.

Eligible uses include but are not limited to:
• Dedicated staﬀ for policy analysis, program development and administration, monitoring, and/or evaluation;

LACAHSA Transitional Program Guidelines | September 2025

54 • IT infrastructure, data, and software subscriptions necessary for research, policy analysis, program administration, monitoring and evaluation; and • Staﬀ attendance at conferences, workshops, or education training programs focused on program-related technical skills.

Technical assistance resources may be used to also support capacity building related to program implementation and design at the activity level. For example, technical assistance resources may be used to support residents to establish and maintain decision- making authority within a social housing project.
iv. Professional Services Support
LACAHSA and Eligible Jurisdictions may use TA funds to contract additional professional services directly related to program implementation, monitoring, and evaluation. Eligible uses include but are not limited to:
• Program design and NOFA Administration;
• Real estate and land acquisition support;
• Underwriting, closing, and asset management support;
• Program monitoring, auditing, and evaluation;
• Legal counsel;
• Data and policy analysis;
• Public outreach and engagement; and
• Accounting and ﬁnancial management.

Professional services are not an eligible use to the extent that the services are rendered for the Eligible Jurisdictions general needs or otherwise not directly related to a LACAHSA program. TA funds cannot be treated as general fund revenues. For example , the TA funds cannot pay an Eligible Jurisdiction’s costs for general counsel to attend a board meeting, but TA funds may be used to pay legal counsel’s costs of preparing project loan transactional documents or drafting model ordinances to streamline housing production for member cities.
c. Documentation Standards
Eligible Jurisdictions must maintain adequate documentation to show that TA activities were used to support the implementation and eﬀectiveness of Measure A funded activities, and costs were incurred in accordance with the annual budget.

To document cost eligibility, the Eligible Jurisdiction should maintain documentation to show the associated costs can clearly be allocated to the delivery of TA. Documentation may include:

LACAHSA Transitional Program Guidelines | September 2025

55 • Invoices and Receipts: Documentation of payments for associated TA costs such as receipts for trainings or travel for participation in a capacity building activity. • Contracts and Agreements: Any service contracts or agreements related to TA support (e.g., accounting services, IT support).
• General Ledger Entries: Accounting entries reﬂecting expenses and corresponding allocations.
• Budget and Expense Reports: Reconciliations that link costs to the approved budget. • Supporting Correspondence: Emails or memos that justify expenditures or approvals.

For staﬀ costs, the Eligible Jurisdiction or subawardee must maintain adequate documentation showing that the staﬀ provided direct support to LACAHSA funded activities.

This can be achieved through timesheets or self-certiﬁcation reporting. • Timesheets or personnel activity reports showing hours worked on TA tasks, including the employee’s role and pay rates.
• Alternatively, Eligible Jurisdictions may report time spent supporting TA activities through self-certiﬁcation reporting. At a minimum, each employee's name, title, and wage rate should be included along with the total hours or % of time to be allocated for the period. The self-certiﬁcation must include certiﬁcation that the hours reported are true and accurate by the supporting employee and their supervisor. Self - certiﬁcation must be signed and dated by the employee and supervisor to be complete.

7. Funding Administration and Management
a. Annual Budget
To enable LACAHSA to plan for eﬀective cash management, timely disbursement of funding, and programmatic coordination with Eligible Jurisdictions, all Eligible Jurisdictions must maintain a current annual budget.

The budget must establish the proposed activities for the corresponding ﬁscal year. The budget shall be approved by the Eligible Jurisdiction’s governing body by November 1, 2025, for the FY25-26 time period. For subsequent ﬁscal years, an annual budget will be expected to be in place by May 1 of the preceding ﬁscal year or 60 days after the release of the expected annual budget, whichever is later . This budget will be a component of the ﬁrst quarter report. LACAHSA will conﬁrm the budget provides adequate detail and documentation within 15 business days of receipt.

If the Eligible Jurisdiction is requesting funds to be advanced to them, LACAHSA shall advance funds upon request once a budget has been submitted to LACAHSA.

LACAHSA Transitional Program Guidelines | September 2025

56 Annual budgets must provide adequate detail to demonstrate that the proposed uses meet an eligible activity and align with the enabling legislation and these guidelines. For example, the budget must identify the proposed activity, speciﬁc use of funds, and the anticipate d outcomes of the funding. At a minimum, advances must be reconciled as part of reporting.

If determined necessary, LACAHSA reserves the right to require more frequent reconciliation.

During the course of the ﬁscal year, Eligible Jurisdictions may amend the annual budget based on changing needs and conditions. The revised budget shall be submitted to LACAHSA as amended.
b. Activity Delivery and Program Administration Costs
To ensure sufficient resources are available for administration and program implementation and oversight activities, while also maximizing the amount of funds that go directly to program beneficiaries, the LACAHSA Board has established the following budget guidance for Activity Delivery Costs and Program Administration Costs. i. Activity Delivery Costs (ADCs)
RPHP
RPHP activities have a 25 percent cap on Activity Delivery Costs (ADCs), meaning Eligible Jurisdictions and Subrecipients can spend up to 25 percent of their RPHP program budgets on these costs.

One hundred percent of ADCs must be passed on to the subrecipient or the entity that is directly carrying out the activity.

Eligible Jurisdictions/Subrecipients can request a waiver of this cap based on unique program circumstances by submitting a request to LACAHSA. The decision whether or not to grant a waiver is at the discretion of LACAHSA.

ADCs include staﬀ and overhead costs incurred for administering and implementing a speciﬁc program or project. ADCs include the cost of staﬀ directly carrying out a program/project activity as well as equipment and supplies that are necessary for successful completion of the activity.

Activity delivery costs are direct expenses related to implementing the program's objectives and delivering services to households. These costs include determining eligibility, reviewing required documentation, communication with households, and providing direct ﬁnancial assistance or services to participants seeking assistance. Examples of ADCs include:
• Eﬀorts to market, assess, and enroll potential households into RPHP activities

LACAHSA Transitional Program Guidelines | September 2025

57 • Ongoing case management services
Budget allocations for ADCs must be held by the entity that is responsible for program or project delivery. This may be LACAHSA, an Eligible Jurisdiction, or a Subrecipient.

PPO and TA
There is not a definitive set aside for activity delivery costs for PPO or TA activities, but PPO funds can be used to fund necessary and associated soft costs with the proposed activity. ii. Program Administration Costs
Program Administration costs have a cap of 12.5 percent, meaning Eligible Jurisdictions can spend up to 12.5 percent of their total allocation on these costs. If LACAHSA or an Eligible Jurisdiction enters into an agreement with a S ubrecipient to administer any program, the Eligible Jurisdiction/LACAHSA must pass through at least 50 percent of their Program Administration cost allocation to their subrecipients or the entity that is directly carrying out the activity for the proportional budget awarded to the subrecipient.

Program Administration costs include costs for staff -time and overhead costs for planning, general management, oversight, coordination, and implementation of the program as a whole. These are costs that cannot be directly attributed to a single project or activity.

Program administration also includes coordination activities with other regional initiatives .

These costs may include but are not limited to:
a. Executive oversight staﬀ salaries and beneﬁts
b. Financial management, accounting, and audit preparation c. Grant reporting and documentation requirements
d. Information technology systems supporting program operations, data collection and reporting
e. General oﬃce expenses
If an activity is funded with multiple sources of funding, Program Administration costs may be used to support the implementation of the entire project but CANNOT be used to support speciﬁc activities such as reporting, reimbursement documentation, or monitoring activities associated with the other funding source(s) being used for the project. iii. Indirect Costs
Indirect costs as allocated by an indirect cost rate are not allowed. All such costs should be included in the Eligible Jurisdiction/Subrecipient’s ADCs and Program Administration costs.

LACAHSA Transitional Program Guidelines | September 2025

58 iv. Documentation Standards
Eligible Jurisdictions must maintain adequate documentation to show that ADC and Program Administration funds were used to support the implementation and eﬀectiveness of Measure A funded activities and costs were incurred in accordance with the annual budget.

Eligible Jurisdictions/Subrecipients of funds must maintain documentation standards for Activity Delivery Costs and Program Administration Costs to ensure transparency and accountability. Below are some examples of documentation; more detailed guidance will be provided to clarify speciﬁc requirements and best practices.

Documentation Standards for Program Administration Costs Program Administration costs refer to expenses necessary for the general management and administration of the funded project or program.

To support these costs, Eligible Jurisdictions and their subrecipients and contractors should maintain clear, detailed, and organized records that may include, but are not limited to:
• Invoices and Receipts: Documentation of payments for oﬃce supplies, utilities, rent, and other overhead costs.
• Contracts and Agreements: Any service contracts or agreements related to administrative support (e.g., accounting services, IT support). • General Ledger Entries: Accounting entries reﬂecting administrative expenses and corresponding allocations.
• Budget and Expense Reports: Reconciliations that link administrative costs to the approved budget.
• Supporting Correspondence: Emails or memos that justify administrative expenditures or approvals.
• Payroll Records:
o Timesheets or personnel activity reports showing hours worked on administrative tasks, including the employee’s role and pay rates. o Alternatively, Eligible Jurisdictions may report time spent supporting Program Administration through self -certiﬁcation reporting. At a minimum, each employee's name, title, and wage rate should be included along with the total hours or percentage of time to be allocated for the period. The self - certiﬁcation must include certiﬁcation that the hours reported are true and accurate by the supporting employee and their supervisor. Self -certiﬁcation must be signed and dated by the employee and supervisor to be complete.

These documents ensure that administrative costs are reasonable, allowable, and allocable to the project. Maintaining comprehensive records ensures compliance with funding

LACAHSA Transitional Program Guidelines | September 2025

59 requirements, facilitates audits, and enhances ﬁnancial accountability. Further detailed instructions and templates will be provided to guide recipients in maintaining appropriate documentation.

Documentation Standards for Activity Delivery Costs
Activity delivery costs are direct expenses related to implementing the program’s objectives and delivering services. Documentation should be robust to verify that funds were used appropriately for program activities. Typical required records include:
• Participant Records: Attendance sheets, case management notes, sign- in logs, or beneﬁciary tracking documents to verify who received services. • Invoices and Receipts: Proof of purchases for materials, supplies, equipment, or contracted services used directly to support or communicate with households. • Travel Documentation: Travel authorizations, itineraries, mileage logs, and expense receipts for travel related to program activities.
• Program Reports: Progress reports, deliverables, or outputs that demonstrate activity completion.
• Subrecipient Monitoring: Documentation of subrecipient agreements, invoices, and monitoring activities if funds are passed through to partners. • Payroll Records:
o Timesheets or personnel activity reports showing hours worked on program- related tasks, including the employee’s role and pay rates. o Alternatively, Eligible Jurisdictions may report time spent implementing program activities through self -certiﬁcation reporting. At a minimum, each employee's name, title, and wage rate should be included along with the total hours or percentage of time to be allocated for the period. The self - certiﬁcation must include certiﬁcation that the hours reported are true and accurate by the supporting employee and their supervisor. Self -certiﬁcation must be signed and dated by the employee and supervisor to be complete.

Both administrative and activity delivery costs require documentation that clearly supports the nature, amount, and purpose of expenditures. Maintaining comprehensive records ensures compliance with funding requirements, facilitates audits, and enhances ﬁnancial accountability. Further detailed instructions and templates will be provided to guide recipients in maintaining appropriate documentation.
c. Funding Obligation and Expenditure Timeline
Under SB 679, Eligible Jurisdictions must obligate funding within 12 months of receipt of funds from LACAHSA. Funding obligations must be made through administrative processes

LACAHSA Transitional Program Guidelines | September 2025

60 without being subject to additional legislative process es. Funding is considered to be “obligated” upon receipt and written approval of the Eligible Jurisdiction’s Annual Budget by LACAHSA staﬀ. This action starts the expenditure period (3 years for PPO, 12 months for RPHP and TA ). The expenditure period is restarted if the Eligible Jurisdiction provides a revised budget that is approved by LACAHSA staﬀ.
i. PPO Funds
Once funds are obligated to a speciﬁc PPO project, they must be expended within 3 years of the obligation date, unless an extension is authorized by LACAHSA. If PPO funds have not been expended within 3 years of the obligation date, the Eligible Jurisdiction must submit evidence to LACAHSA that it has made adequate progress towards completing the project. If LACAHSA determines that the Eligible Jurisdiction has made adequate progress, LACAHSA shall authorize up to an additional 24 months to grant entitlements to the remainder of the project.

If LACAHSA determines that the Eligible Jurisdiction has not made adequate progress, the funds shall be transferred back to LACAHSA and/or funding distributions to that Eligible Jurisdiction may be suspended . LACAHSA shall hold the funds until the Eligible Jurisdiction submits a satisfactory plan to LACAHSA to move forward with the project or allocate funds to another qualiﬁed project and/ or diﬀerent Eligible Jurisdiction. “Adequate progress” means the project has received the land use approvals or entitlements necessary for at least 75 percent of the project’s units.
ii. RPHP Funds
Once RPHP funds are obligated, they must be expended within 12 months of the obligation date. At the conclusion of the 12 -month period to expend funding, an Eligible Jurisdiction may request to re-allocate unexpended legal services funds within the RPHP category, even if the proposed re -allocation results in expenditures that are less than any mini mum expenditure levels. The request would be reviewed by LACAHSA staﬀ, pursuant to objective guidelines that will be included in the FY26-27 Program Guidelines. iii. TA Funds
Once TA funds are obligated, they must be expended within 12 months of the obligation date, unless an extension is authorized by LACAHSA. If TA funds have not been expended within 12 months of the obligation date, the Eligible Jurisdiction must submit evidence to LACAHSA that it has made adequate progress towards completing the project. If LACAHSA determines that the Eligible Jurisdiction ha s made adequate progress, LACAHSA shall authorize an additional 12 months to complete the project. Such extensions can be granted annually for a period of up to 5 years from the date of obligation.

LACAHSA Transitional Program Guidelines | September 2025

61 If LACAHSA determines that the Eligible Jurisdiction has not made adequate progress, the funds shall be transferred back to LACAHSA and/or funding distributions to that Eligible Jurisdiction may be suspended. LACAHSA shall hold the funds until the Eligible Jurisdiction submits a satisfactory plan to LACAHSA to move forward with expending funds. “Adequate progress” means the there is an established budget documenting the anticipated period of performance.
d. Subrecipient Agreements
LACAHSA and Eligible Jurisdictions are entitled to make use of S ubrecipients to administer and implement their programs. A Subrecipient is a public agency or a nonproﬁt organization receiving funds from LACAHSA or an Eligible Jurisdiction to carry out an activity on behalf of the recipient (e.g., a COG passing through funds to a city, or a city passing through funds to a nonproﬁt organization). Subrecipients must comply with the same program requirements as LACAHSA or the Eligible Jurisdiction . For each activity undertaken by a S ubrecipient, a Subrecipient Agreement must be executed between the Eligible Jurisdiction or LACAHSA and the Subrecipient that incorporates the program requirements contained in these Program Guidelines and in LACAHSA’s Annual Expenditure Plan.
e. Contractor Procurement and Agreements
LACAHSA, Eligible Jurisdictions, and Subrecipients are entitled to make use of Contractors to carry out program activities. Contractors are for- proﬁt or nonproﬁt entities that are paid in return for speciﬁc goods and services, where payment is made as compensation for such goods and services. When procuring Contractors, LACAHSA, Eligible Jurisdictions, and Subrecipients must follow their own established procurement policies and procedures.

Before disbursing funds to any Contractor procured to provide goods or services under this program, LACAHSA, Eligible Jurisdictions, and S ubrecipients must enter into a written agreement with the Contractor. The written agreement should include any requirements included in these Guidelines (for example, related to prevailing wages and project labor agreements for construction projects) as well as any relevant terms and conditions required by State and local laws.
f. Disbursement Process and Requirements
To ensure funds are dis bursed to Eligible Jurisdictions and Subrecipients in a way that facilitates the eﬃcient and eﬀective implementation of programs, LACAHSA will make advance payments and reimburse costs based on the requirements listed in this section.

Eligible Jurisdictions will be required to submit a Form W -9 to LACAHSA and be set up as a payee with LACAHSA prior to receipt of payments. Payee onboarding instructions will be

LACAHSA Transitional Program Guidelines | September 2025

62 provided to each Eligible Jurisdiction. All Eligible Jurisdictions must be in good standing and cannot be a debarred entity at the Federal, State or local level. i. Advance Payments
Eligible Jurisdictions and Subrecipients can receive a dvance payments for funds that are receipted by LACAHSA. Advance payments cannot be made until the Eligible Jurisdiction submits an Annual Budget.

Once an advance payment is disbursed to an Eligible Jurisdiction, the obligation period will begin for the Eligible Jurisdiction for those funds.

Advance Payment Request Process
LACAHSA may deny advance funding requests by Eligible Jurisdictions/Subrecipients who do not adhere to documentation requirements and/or are otherwise deemed at risk. If an advance payment request is denied, LACAHSA will provide their rationale and the steps the Eligible Jurisdiction/Subrecipient can take to address the reasons for denial.

Advance Payment Management and Reporting
Advance payment funds must be held by the Eligible Jurisdiction/Subrecipient in a separate interest-bearing account and all interest must be tracked and documented as Program Income until expenditure. Program Income can only be used to pay costs for approved eligible uses.

Eligible Jurisdictions/Subrecipients that receive advance payments are required to report to LACAHSA on the expenditure of advance funds and all interest earned , as part of the reporting described below . LACAHSA r eserves the right to request additional reports , increase the frequency of reporting, and/or terminate advance payments at any time for Eligible Jurisdictions/Subrecipients who do not adhere to documentation requirements and/or are otherwise deemed by LACAHSA to be at risk.

If advance payments to an Eligible Jurisdiction/Subrecipient are terminated by LACAHSA, LACAHSA will provide the rationale for the decision and the steps the Eligible Jurisdiction/Subrecipient can take to address the reasons for termination. In these cases, the Eligible Jurisdiction/Subrecipient may only receive funding via reimbursement until the issues leading to the termination have been addressed.
ii. Reimbursement Requests
In lieu of advance payments, Eligible Jurisdictions may request reimbursement for all eligible costs as costs are incurred or when the obligation requirements are met and there is a demonstrated commitment of when the funds will be expended.

LACAHSA Transitional Program Guidelines | September 2025

63 To request reimbursement, Eligible Jurisdictions must submit the following to LACAHSA:

1. A signed requisition by an authorized representative that itemizes eligible costs by program and activity and includes a description of each itemized cost and a reference to the corresponding supporting documentation. LACAHSA will provide a requisition template for submitting reimbursement requests.

2. Supporting documentation providing evidence that the cost was incurred, or there is a demonstrated commitment for expenditure.

Funds provided in advance of expenditure must be held by the Eligible Jurisdiction/Subrecipient in a separate interest -bearing account, and all interest must be tracked and documented as P rogram Income until expenditure. Program Income can only be used to pay costs for approved eligible uses.

Reimbursement requests should not include performance data, which are only to be submitted as part of the reports described below.

LACAHSA will review all reimbursement requests within 15 business days of receipt. If any revisions to the request and/or additional information or documentation are needed, LACAHSA will submit a request in writing to the Eligible Jurisdiction. LACAHSA will review additional information submitted by Eligible Jurisdiction within 5 business days of receipt.

Upon approval of a reimbursement request for payment, LACAHSA will inform the Eligible Jurisdiction/Subrecipient it was approved and process the payment. g. Program Income
Any revenue generated by program funding by LACAHSA, Eligible Jurisdictions , or Subrecipients (i.e. interest earned on construction loans, interest earned on advance payment deposits, etc.) qualiﬁes as Program Income. Program Income must be tracked until expenditure and can only be used to pay costs for eligible uses approved by LACAHSA Board.

Program Income generated by the Eligible Jurisdiction (either through interest earned from funds disbursed to the Eligible Jurisdiction OR through programmatic activity) shall remain with the Eligible Jurisdiction . Eligible Jurisdictions may elect to allow S ubrecipients to maintain and use P rogram Income for eligible activities OR return P rogram Income to the Eligible Jurisdiction as it is earned for allocation to eligible activities. h. Reporting
Eligible Jurisdictions are required to periodically submit ﬁnancial and programmatic reports to LACAHSA as outlined below. Eligible Jurisdictions are responsible for gathering all required information from their Subrecipients and Contractors and reporting it to LACAHSA as part of

LACAHSA Transitional Program Guidelines | September 2025

64 the web-based reporting process. When reporting to LACAHSA, Eligible Jurisdictions must use the most current reporting tools provided by LACAHSA.

Eligible Jurisdictions are required to report on performance and ﬁnancial data on a biannual basis. To reduce reporting burdens on Eligible Jurisdictions, LACAHSA has separated the timing of submission for programmatic or ﬁnancial reports according to the schedule below.

If the reporting deadline falls on a weekend or holiday, reports will be due on the following business day.

Report Reporting Period Report Type Due Date
First quarter report July 1 – September 30 Financial November 14 (45 days after quarter
end)
Second quarter
report
July 1 – December 31 Programmatic February 14
(45 days after quarter
end)
Third quarter report October 1 – March 31 Financial May 15 (45 days after quarter
end)
Fourth quarter
(Annual) report
January 1 – June 30 Programmatic July 30
(30 days after quarter
end)

The fourth quarter report will also serve as the Eligible Jurisdiction ’s annual report to LACAHSA, and as such will include a n annual summary of programmatic activities and accomplishments.

Annual ﬁnancial data will be gathered as a component of the annual audit conducted by LACAHSA.

Reports will require suﬃcient detail for LACAHSA to track and report on the performance metrics adopted by the LACAHSA Board, which are included in the Annual Expenditure Plan. i. Monitoring
LACAHSA is responsible for ensuring that funding recipients comply with all regulations and requirements governing the administrative, programmatic, and ﬁnancial management of LACAHSA funds. Monitoring is the primary tool that LACAHSA uses to ensure that programs and activities are being carried out in accordance with funding requirements. Monitoring is a review of program or project performance and compliance. There are several types of monitoring:

LACAHSA Transitional Program Guidelines | September 2025

65 • Administrative and Financial monitoring ensures that Eligible Jurisdictions and Subrecipients are administering a program properly (i.e., tracking funds, using proper methods of recordkeeping, and managing ﬁnances appropriately). • Program monitoring reviews the operations and management of Eligible Jurisdictions and Subrecipients for eﬃciency, eﬀectiveness, compliance, etc. This kind of monitoring focuses on overall program performance.
• Project monitoring ensures that projects are in compliance with all relevant standards and requirements. This kind of monitoring focuses on the compliance of an individual project, including compliance with labor standards when applicable. i. Year One and Every Five Years: Monitoring all Recipients During the ﬁrst year of program funding, LACAHSA will monitor all entities that receive funding from LACAHSA (this includes Eligible Jurisdictions and LACAHSA’s subrecipients; Eligible Jurisdictions will be responsible for monitoring their subrecipients). Subsequently, at least once every ﬁve years monitoring will include a review of revenues allocated to all recipients.
ii. Recipient Risk Assessment and Monitoring Plan
After Year One and outside the requirement to monitor all recipients at least once every ﬁve years, monitoring is dependent on the risk designation of each funding recipient. High risk recipients will be subject to monitoring by LACAHSA at least annually, and more frequently if determined by LACAHSA to be necessary.

Risk Assessment
LACAHSA will complete a risk assessment at the beginning of each program year to determine which r ecipients are considered low and high risk. The risk assessment will be developed utilizing any sources of information that assist in providing a clear and timely picture of each recipient’s progress and level of compliance with program requirements. This may include but is not limited to ﬁnancial and performance reports, annual audits, requests for funding, and program/project scopes of work and budgets.

The risk factors that will be assessed may include the following:

1. Project Complexity, including size of the budget, u se of funds, and if there will be program income.

2. Recipient Organization, including experience with similar programs and/or projects, and staﬀ experience and capacity.

3. Recipient Track Record, including monitoring record and / or complaints, timeliness and accuracy of reports, and whether they have met performance objectives.

LACAHSA Transitional Program Guidelines | September 2025

66 4. Financial, including audit ﬁndings.

As part of the risk assessment, LACAHSA will a ssess and record a risk score for each risk factor based on the information on hand; and will sum the risk scores for each factor to determine the Total Risk Score for each recipient.

Monitoring Plan
Recipients with the highest total risk scores will be subject to monitoring. Following the risk assessment, LACAHSA will develop a monitoring plan to deﬁne monitoring strategies and timelines for each high-risk recipient.
iii. Recipient Monitoring Process
The monitoring process will be determined by LACAHSA and will consist of the following steps:

1. Notice. LACAHSA will submit a written notice to the r ecipient/subrecipient of their intent to monitor. The letter will describe the scope of the monitoring and request documentation needed by LACAHSA to complete monitoring. The letter will be sent with suﬃcient notice for the recipient/subrecipient to prepare.

2. Monitoring. LACAHSA will review documentation provided by the recipient/subrecipient and will send questions and conduct interviews with recipient/subrecipient staﬀ as needed.

3. Preliminary Report. Based on the document review and interviews, LACAHSA will draft a preliminary monitoring report outlining the initial ﬁndings, including ﬁndings that will require additional consultation with recipient/subrecipient staﬀ.

4. Monitoring Conference. LACAHSA will meet with the r ecipient/subrecipient to discuss the preliminary ﬁndings and get clariﬁcation on ﬁndings that need additional information.

5. Final Monitoring Report. After the Monitoring Conference, LACAHSA will prepare a Monitoring Report that includes ﬁndings and concerns, and that identiﬁes the conditions contributing to the ﬁnding or concern, and the corrective actions to be undertaken by the recipient/subrecipient.

6. Corrective Actions and Clearance Letter. Recipients/subrecipients take corrective actions to resolve ﬁndings in the Monitoring Report. Upon completion of all corrective actions to the satisfaction of LACAHSA, LACAHSA issues a Monitoring Review Clearance Letter to formally close the monitoring.

LACAHSA Transitional Program Guidelines | September 2025

67 iv. Project Monitoring
LACAHSA is responsible for monitoring housing production and preservation projects that are directly funded by LACAHSA through the at-large funding allocation process. Monitoring will generally include the following:
• During the construction/rehabilitation phase, LACAHSA will monitor contractors for compliance with labor standards and other State and local requirements; review contractor invoices; and conduct progress and ﬁnal inspections of all construction/rehabilitation work.
• During the aﬀordability/compliance period, LACAHSA will conduct annual compliance monitoring to ensure projects continue to meet all program requirements, including occupancy and aﬀordability requirements.
v. LACAHSA Administration Monitoring
In addition to monitoring activities undertaken by r ecipients/subrecipients and projects on an annual basis, at least every three (3) years LACAHSA will monitor its own administration of the program to ensure compliance with program regulations. This monitoring includes reviewing LACAHSA’s policies and procedures covering program administration and project- speciﬁc requirements (such as labor standards), reviewing ﬁles to verify adequate implementation of the relevant policies and procedures, and identifyi ng and implementing changes to LACAHSA’s program administration as needed.
j. Audit and Record Retention
All records pertaining to LACAHSA funds must be retained for a minimum of ﬁve (5) years after all terms of an MOU, Subrecipient Agreement, or Contractor Agreement are fulﬁlled, unless a longer period of records retention is stipulated.

LACAHSA and Eligible Jurisdictions must provide citizens, public agencies, and other interested parties with reasonable access to records, consistent with applicable state and local laws regarding privacy and obligations of conﬁdentiality. LACAHSA or its designated representative will have the right during normal business hours to review and to copy any records and supporting documentation pertaining to LACAHSA funding and interview any employees who might reasonably have information related to such records.

LACAHSA will be subject to an annual audit and will conduct an audit annually of each Eligible Jurisdiction that receives funding . The audit will be completed within six months after the end of the ﬁscal year being audited and will comply with any standards adopted by the LACAHSA Board.

LACAHSA Transitional Program Guidelines | September 2025

68 k. Remedies for Non-Performance
It is the intent of LACAHSA to cultivate positive partnerships with high- performing Eligible Jurisdictions and Subrecipients. LACAHSA has a responsibility to address problems with Eligible Jurisdictions and Subrecipients directly and fairly. There are three (3) progressive approaches to addressing Eligible Jurisdictions and Subrecipients that are determined to be high risk, including early intervention, intervention for more serious or persistent problems, and ﬁnally, the imposition of sanctions.
• Early intervention involves any combination of the following measures:
o The development of strategies with the Eligible Jurisdiction/Subrecipient that include additional training and technical assistance; or o Requiring more frequent or more thorough reporting by the Eligible Jurisdiction/Subrecipient; or
o Conducting more frequent monitoring.
• Intervention for more serious or persistent problems may include, as appropriate:
o Placing restrictions on the Eligible Jurisdiction/Subrecipient’s payment requests; or
o Incorporating additional restrictions in the MOU/Subrecipient Agreement, such as requiring approval prior to purchasing goods or providing services to clients.
• Imposition of sanctions for non-compliant Eligible Jurisdiction/Subrecipients involves:
o Suspension of ongoing funding distributions;
o Disallowance of ineligible costs incurred; or
o Termination of MOU/Agreement.

Additionally, pursuant to Government Code 64830.5(a)(2)(A)(iii), if an E ligible Jurisdiction is found to be out of compliance with aﬀordability targets at the end of a two -year period, LACAHSA may take any of the following actions:
• Limit the funding for the Eligible Jurisdiction to extremely low- and very low-income housing units only until compliance is reestablished.
• Require the funding allocated to the Eligible Jurisdiction to be administered by LACAHSA instead of the Jurisdiction.
• Increase funding incentives as needed to meet project and programmatic targets. l. Nondiscrimination
Eligible Jurisdictions and Subrecipients must adopt and follow a nondiscrimination policy that complies with all relevant local, state, and federal laws, and which at minimum ensures that no person shall be excluded from participation in, denied the beneﬁt of, or be subject

LACAHSA Transitional Program Guidelines | September 2025

69 to discrimination under any program or activity funded in whole or in part with LACAHSA funds on the basis of their religion or religious aﬃliation, age, race, color, creed, gender, sexual orientation, marital status, familial status (children), physical or mental disability, national origin, ancestry, immigration status, or other arbitrary cause. m. Procurement
Eligible Jurisdictions must ensure their funds are used to procure contractors and vendors in accordance with their own established procurement policies and procedures. If an Eligible Jurisdiction does not have an established procurement policy, it must de velop said policy prior to awarding LACAHSA funds to subawardees.
n. Preventing Fraud, Waste, and Abuse
LACAHSA is committed to maintaining a culture of honesty and preventing fraud, ﬁnancial abuse and/or waste of public funds or assets. Eligible Jurisdictions and Subrecipients must adopt and follow policies and procedures to prevent and detect fraud, waste , and abuse, including but not limited to the following:
• Clearly deﬁning fraud, waste, and abuse in organizational policies. • Providing whistleblower information in easily accessible locations. • Training staﬀ to prevent, detect, and report fraud.
• Maintaining strong ﬁnancial management systems with robust internal controls. • Routinely monitoring, evaluating, and improving internal controls when necessary. o. Anti-Lobbying
Eligible Jurisdictions and Subrecipients must adopt and follow an anti -lobbying policy that prohibits the use of Measure A funds for payment to any person for inﬂuencing or attempting to inﬂuence an oﬃcer or employee of any agency, an elected representative or their employees, or an oﬃcer or employee of a legislative body, in connection with the awarding, extension, continuation, renewal, amendment, or modiﬁcation of any contract, grant, or loan involving Measure A funds.
p. Conflict of Interest
Eligible Jurisdictions and Subrecipients must maintain a written code of conduct governing the performance of their employees, agents, consultants, oﬃcers, or elected oﬃcials or appointed oﬃcials who exercise or have exercised any functions or respon sibilities related to Measure A-funded programs, or who are in a position to participate in a decision-making process or gain inside information with regard to these activities. Codes of conduct should be written so as to avoid actual, or appearances of, conﬂicts of interest. Such conﬂicts would arise when any of the following parties has a personal ﬁnancial interest in, or may personally

LACAHSA Transitional Program Guidelines | September 2025

70 ﬁnancially beneﬁt from a Measure A-assisted activity, or has a personal ﬁnancial interest in any contract, subcontract, or agreement with respect to the Measure A -assisted activity, or the proceeds from such activity:
• An employee, agent, consultant, oﬃcer, or elected oﬃcial or appointed oﬃcial of the Eligible Jurisdiction or Subrecipient;
• A person with whom they have business or immediate family ties (immediate family ties include, by blood, marriage or adoption: the spouse, parent/stepparent, child/stepchild, brother/stepbrother, sister/stepsister, grandparent, grandchild, and in-laws);
• An organization which employs, has recently employed, or is about to employ, any of the above.

Relationships among public agencies, or the oﬃcials or employees of public agencies, are not considered conﬂicts of interest. For example, a member of a COG’s board of directors who is also a city council member, does not have a conﬂict of interest under these guidelines.

Lancaster City CouncilDecember 9, 2025

Lancaster City Council
December 9, 2025