130 Newport Center Dr., Suite 230 Newport Beach, CA 92660 March 8, 2022
Oscar Orci
Community Development Director
Long Beach Development Services
411 W. Ocean Blvd., 3rd Floor
Long Beach, CA 90802
RE: COMMENTS TO PROPOSED HR&A “MIDDLE-INCOME” POLICY
Dear Mr. Orci:
On behalf of Waterford Property Company and the California Statewide Communities Development Authority (CSCDA), I would like to thank you for City Staff’s engagement on the proposed “middle- income” work-force housing program. Pursuant to the City’s request for Waterford and CSCDA’s comments to the proposed HR&A “middle-income” policy please find the following comments to HR&A’s Proposed Middle-Income Housing Bond Transactions Terms and Conditions:
1. Underwriting Standards:
a. City Property Tax: Agreed
b. Third Party Appraisal: Agreed; This is consistent with bond underwriting standard.
c. Maximum Rents: This is not consistent with underwriting standards and is not workable for a successful bond issuance.
d. Cumulative Rents: Agreed
e. Deed Restriction: This is something that we are open to discussing but this is not in the best interest of the City. It eliminates financial flexibility for future City Councils.
f. Cost and Rent Exceptions: This item is unclear. If this is referring to keeping all existing affordable units subjects to pre -existing regulatory agreements with lower rents in place, than this agreeable.
g. Unit Mix: This is only applicable for new construction projects. h. Capital Expenditure Reserve: Agreed
i. Minimum Debt Service Coverage Ratio: This is n ot consistent with the underwriting standards for these transactions.
j. Bond Principal Amortization: Agreed
k. Annual Rent Growth: Waterford recommends using the same language that is in the Regulatory Agreement for the Oceanaire transaction. The language caps rent growth at the lesser of “AMI growth or 4%”.
l. Operating Expense Growth: Agreed
m. Exit Scenario: Agreed
n. Construction Cost: Agreed
2. Transaction and Annual Fees:
a. Closing Fees: This is not consistent with the underwriting standards for these transactions.
Attachment B
2 b. Ongoing Fees to JPA and Project Administrator: Agreed c. Asset Management Reserves: Agreed
d. Accrual: This is not consistent with the underwriting standards for these transactions.
3. Property Transfer and Encumbrance:
a. Additional Debt: This is not consistent with the underwriting standards for these transactions.
b. Forced Sale: Agreed
c. Transfers: This is not consistent with the underwriting standards for these transactions.
4. Joint Powers Authority And Project Team Members Qualifications:
a. Joint Powers Authority And Other Sponsors: Agreed
b. Project Administrators or Asset Managers: Waterford meets these standards but disagrees with the criteria. This is an arbitrary requirement and discriminates based on age.
c. Property Managers: Agreed
d. Municipal Advisor: No. This is unnecessary and redundant. The City is not part of the issuance.
5. Tenant Protections and Occupancy Process:
a. Noticing: Agreed
b. Maximum Household Income: Agreed
c. Existing Tenants: Agreed
d. Affirmative Marketing: Agreed
e. Compliance with City Local Preference Policy: Agreed f. Section 8: Agreed if they income qualify
6. City Reporting Requirements:
a. Tenant Satisfaction Survey: This is not consistent with the underwriting standards for these transactions or traditional affordable housing projects. b. Market Rents and Property Discounts: This is not consistent with the underwriting standards for these transactions or traditional affordable housing projects.
c. Tenant Summary: Agreed
d. Property Financial Report: Agreed
e. Property Condition Report: The administrator will agreed to do Property Condition Assessments every five years but having the City do inspections creates liability for the City.
f. City Requests for Other Information: Agreed
g. Public Benefit Agreement: Agreed.
7. City Application and Annual Compliance Requirements:
a. City Application Fee: Agreed
b. Third Party Underwriting Costs: Agreed
c. Annual Monitoring Fee: Agreed
3 Appendix A Comments
This process seems acceptable for new development projects, but property acquisitions have a much different timeline.
In closing I would like to thank City Staff for its diligent work on the middle-income housing program. The middle-income program is an extremely innovative financing tool for cities to provide homes for the “missing-middle” demographic. The key take away is to point out that if the City adopts a Middle-Income Housing “MIH” Policy that allows for projects to be financed. If the City adopts the criteria as drafted MIH projects will not financially feasible in Long Beach. We look forward to working with you.
Sincerely,
Sean Rawson
Co-Founder
Waterford Property Company
Attachment C
City of Long Beach
Middle-Income Housing Program
The Program provides a framework for evaluating City participation in middle-income workforce housing proposals. The Program will accommodate transactions involving the conversion of existing developments as well as new construction projects. All proposals are subject to City Council review and approval.
POLICY ITEM NEW CONSTRUCTION ACQUISITION/CONVERSION DEVELOPER COMMENTS HR&A/STAFF RESPONSE Housing
Production/Preservation
and Affordability
50% of units restricted at
HCD moderate -income
rents for 55 years with
Regulatory Agreement
(must qualify for RHNA
credit at moderate -income
level).
Remainder of units at TCAC
moderate-income rents
based on 30 % of Income
calculation.
Modifications to these
production requirements
may be negotiated provided
that a project provides other
public benefits that qualify in
the Other Public Benefits
category below.
Must comply with the City’s
Inclusionary Housing, No -
Net-Loss requirements, and
any applicable entitlement
requirements.
A minimum 25 % of units are
restricted at 100 % AMI HCD
moderate-income rents for 55 years
with Regulatory Agreement. Units
must have been market-rate prior to
conversion and must realize a
minimum 10% reduction in average
monthly rents from previous 12
months.
Remainder of units at TCAC
moderate-income rents based on
30% of income calculation with 55 -
year Regulatory Agreement.
Modifications to t hese production
requirements may be negotiated
provided that a project provides
other public benefits that qualify in
the Other Public Benefits category
below.
The total number of units allowed to
be converted during the 2021
through 2029 Housing Element
planning period is 1,040 (25 % of
moderate-income RHNA allocation
of 4,158 per Assembly Bill 787).
Desires all units at higher
TCAC rents with 10 %
reduction in average
monthly rent from previous 6
months.
City’s goal is to receive
RHNA credit for both new
construction and conversion
units, which requires the use
of HCD rents as proposed.
In addition, this policy item
already allows for
modifications if other public
benefits are provided -
retain.
City Property Tax Revenues 100% of City property taxes
reimbursed through Host
Fee.
100% of City property taxes
reimbursed through Host Fee.
Other Public Benefits
Projects that provide unique
public benefits may obtain
modifications to the proposed
All units are able to be
counted toward RHNA
goals with some portion
Conversion of all units to Middle -
income units within 12 months of
conversion is encouraged as a goal.
This requirement is not
possible and will impact
financing.
Staff changed this to a goal
instead of a mandate.
Attachment C
Terms and Conditions
presented below.
counting toward moderate -
income production goals.
Generation of other new
City tax revenues and other
new local economic
benefits.
A minimum of 25% of units are able
to be counted toward RHNA goals.
Generation of other new City tax
revenues and other new local
economic benefits.
Preservation of properties that are
more than 10 years old.
This is not consistent with
state law and has no
bearing on the public benefit
of the project.
Receiving RHNA credit for
the units is critical to
compliance wi th the
Housing Element and the
meaningful affordability
provided by the lower rents
is a direct public benefit -
retain.
TERMS AND CONDITIONS NEW CONSTRUCTION ACQUISITION/CONVERSION DEVELOPER COMMENTS HR&A/STAFF RESPONSE Underwriting Standards
All applications must meet the
following basic prudent
underwriting standards:
a. City Property Tax: No project shall be considered that does not provide the City with a “host fee” in an amount equivalent to the City’s share of the otherwise exempted ad valorem
property tax.
b. Third Party Appraisal : The acquisition price for existing properties to be converted and/or land for a new construction project must be verified by a third -party appraisal from a City selected or mutually agreed upon licensed appraiser with the cost paid by the JPA or Project Administrator.
c. Maximum Rents: Tenant rents per the State Income Limits household income and gross rent schedules shall not exceed 30% of household income, net of a tenant -paid utility
allowance published by the Long Bea ch Housing Authority. 1 The maximum affordable rents shall be at least 10 % below current market rents for equivalent units at the time of initial rental and re-leasing of vacant units, subject to review by City staff. Use of the alternative CTCAC maximum gr oss rent schedule is allowed for some project units based on 30 % income calculation. TCAC rents based on 35 % income
calculation will be considered at the City’s discretion. d. Cumulative Rent Discounts: Over the term of the bonds the net present value of cumulative rent discount to market rate rents shall be approximately equal or greater than the net present value of cumulative foregone property tax revenue to all taxing entities.
e. Deed Restriction : The affordability restrictions will include a minimum 55 -year deed restriction, subject to review and approval by the City Attorney.
f. Cost and Rent Exceptions : The City may also consider alternative rental/housing cost standards, in its sole discretion.
In the event there are other covenants on the property (e.g.,
Require 10% reduction in
rent at initial lease up and
remove re-leasing/City
review requirement.
This request is consistent
with AB 787 – policy to be
changed to remove re-
leasing/City review
requirement.
1 https://www.longbeach.gov/haclb/owners-and-agents/utility-allowance-schedule/ Attachment C
for new construction, any requirements to replace existing affordable units), the most restrictive rent standard shall apply. g. Unit Mix: The specific project unit mix by number of bedrooms, location within the project and allocation by middle -income household income category will be subject to City review and consideration.
h. Capital Expenditure Reserves: A minimum of $300 per unit per year escalating at no less than 3.0 % per year. The required level of annual reserves may increase based on the type and age of property at the sole discretion of the City. A JPA - or Project Administrator -provided, third -party physical needs assessment over the entire bond term summarized as a capital repairs program will be evaluated in determining these
requirements. Furthermor e, replacement reserves shall be part of Net Operating Income calculations and used in sizing the A Bond.
i. Minimum Debt Service Coverage Ratio : The A and B Bonds must have a minimum annual debt service coverage ratio of
1.0 beginning in year 1, defined as Net Operating Income plus the actual drawdown of interest and coverage reserves divided by the scheduled bond interest and/or principal payment for all A and B Bonds. One additional debt se rvice coverage ratio commonly used in such bond transactions, calculated by
dividing the Total Net Revenues plus any funds available in the Capitalized Interest Account and the Coverage Reserve Fund, for a particular period, by the Net Debt Service for the Outstanding Series A Bonds or Series of Bonds for the same period, should not be less than 1.20 beginning in year 1. j. Bond Principal Amortization: Projects in which bond principal is significantly reduced over the course of the bond term will be given more favorable consideration by the City.
k. Annual Rent Growth: Rents charged on all middle -income units shall not increase more than the lesser of: (1) the annual change in 100 % of AMI rents per the CTCAC rent schedule over the prior twelve months, or (2) at least a 10% discount to market rents for the same type of unit, and in no event exceed a maximum of 4.0 % per year. Rents charged on all existing market-rate units for tenants that do not income quality shall increase annually by the maximum amount allowed by the
This requirement is not
achievable.
Remove “(2) at least a 10%
discount to market rents for
the same type of unit.”
HR&A disagrees based on
how they define debt
service coverage ratio
(DSCR) as included in the
proposed policy – Retain.
This policy requirement is in
place in order to maintain
meaningful affordability for
these units -Retain.
Attachment C
Tenant Protection Act of 2019, 2 namely 5.0 % plus the
applicable Consumer Price Index (“CPI”) or 10%, whichever is lower to encourage conversion to moderate-income units. l. Operating Expense Growth: Annual operating expenses should be projected to grow at a minimum of 3.0 % per year.
Accumulated capital reserves should be used to conduct major renovation as scheduled in the capital repairs program. m. Exit Scenario: In estimating the City’s potential future financial benefit from the transaction, the income capitalization rate assumed by the JPA and Project Administrator at the end of the A Bond term must be at least 100 basis points greater than the capitalization rate for comparable housing development s at the time of project application review.
n. Construction Cost: For new construction projects, all workers must be paid applicable prevailing wages. The hard costs for new construction projects must be verified by a City approved, qualified and licensed general contractor with the estimate cost paid by the JPA or Project Administrator. The construction costs should include a contingency of at least 10%, depending on the level of design on which the estimate is based
This is not consistent with
affordable housing projects
and is not required by the
City when affordable
housing loans are provided,
and this was not required
for the Plenary project.
The Plenary project did
commit to the payment of
prevailing wages.
Not all affordable housing
projects are subject to
prevailing wages, but some
developers include them in
an abundance of caution.
Staff recommends that the
language be modified to
require a developer to
obtain a determination from
the State Department of
Industrial Relations, unless
the City Council wishes to
impose this as a
requirement.
Transaction and Annual
Fees
The JPA’s and Project
Administrator’s annual fees
must comply with the following
terms:
a. Closing Fees: Initial closing fees shall be evaluated to ensure that they meet market standards and are fully accounted for in the pro -forma provided by the JPA and Project
Administrator to the City. Closing fees include all bond origination (including without limitat ion issuer and legal fees and underwriter’s discount), Project Administrator and
ownership fees. Total fees should not exceed 2.0 % of either the total development cost for new construction or the
acquisition price for an existing building.
2 California Civil Code Section 1947.12 (a) (1).
Attachment C
b. Ongoing Fees to JPA and Project Administrator: The annual fees paid to all entities potentially including the JPA, Project Administrator, and Property Manager shall be evaluated to ensure they meet market standards.
c. Asset Management Reserves: For existing buildings,
reserves for asset management fees, which contribute to a project’s overall debt load, shall be initially funded at three years’ worth of payments, and not replenished.
d. Accrual: No capitalization of accrued interest for a B Bond is allowed.
Property Transfer and
Encumbrance
The City reserves, at
minimum, the following rights
related to the transfer or
additional encumbrance of the
property. Disclosures shall be
made by the JPA within three
business days of incurring any
additional debt and other
reportable events as defined
by the Securities and
Exchange Commission (SEC)
Section 15c2-12 disclosure
rules.
a. Additional Debt: After the initial bond issuances, the City shall have the right to approve the amount and terms of any
additional subordinate debt exceeding $50,000 in aggregate. b. Forced Sale: The City shall have the ability to force a sale or exercise a purchase option, as applicable, at any point after year 15 of the A Bond term.
c. Transfers: City shall have sole and absolute discretion to approve or reject any changes to the: a) ownership of the project, including changes that are made in whole or in part; b) Asset Manager/Project Administrator; and c) Property Manager. Any request to change the Asset Manager/Project Administrator or Property Manager (including any proposed transfers of controlling interests therein) shall be presented to the City for approval. Further, the City may request a transfer or replacement of a Property Manager for a ny failure to maintain the project or comply with the terms of the Property Management Agreement.
City cannot withhold
approval rights for a
refinance.
The bond investors should
have control over this, not
the City.
This policy item des not
relate to a refinance, rather
it provides the City with
approval rights over the
developer incurring
additional debt on the
property – Retain.
This is standard language
used in all affordable
housing Regulatory
Agreements and allows the
City to ensure strong and
successful property
management and operation
of the property – Retain.
Joint Powers Authority and
Project Team Member
Qualifications
The City requires the following
professional experience
parameters for the JPA
Project Team members:
a. Joint Powers Authority and Other Sponsors: The JPA and its consultants, shall demonstrate to the City’s reasonable satisfaction that it operates with responsible leadership and financing practices and has appropriate housing bond-issuing authority and experience, as evidenced by information on current performance on other Middle -Income Housing
transactions.
b. Project Administrators or Asset Managers: Project
Administrator or Asset Management companies will evidence no less than 10 years of extensive experience of key principal staff in the following areas:
i. Identifying real estate properties for acquisition, negotiating terms, conducting due diligence, documenting, and closing acquisitions;
Attachment C
ii. Borrowing or underwriting debt and/or equity invest ments in multifamily transactions;
iii. Developing properties from the ground up (new construction only);
iv. Overseeing substantial rehabilitation of multifamily projects of at least 100 units (acquisition/rehabilitation only; and v. Performing high-quality full a sset management of properties under control, including hiring, and overseeing reputable property management companies experienced with
affordable housing compliance and operations, as well as financial workouts and restructuring.
c. Property Managers : The Pr operty Manager shall have successful experience managing at least five large scale affordable housing apartment developments in Los Angeles County as well as extensive experience managing apartment buildings with deed-restricted affordable units and associated compliance administration. Property Management companies should have experience working diligently and cooperatively with local governments to resolve apartment building
condition and safety problems.
d. Affirmative Marketing: The Property Manager shall include contact information on the City’s Affordable Housing Development List. The Project Administrator or Property Manager will maintain a waiting list and follow the affirmative marketing procedures in compliance with the California
Department of Hou sing and Community Development’s
Affirmative Furthering Fair Housing.
e. Compliance with City’s Local Preference Policy: The Property Manager shall coordinate with City staff to implement the City’s Local Housing Preference Policy and Priority System Guidelines, to the extent possible.
f. Section 8: In accordance with California Government Code Sections 12927 and 12955, as amended, the Property
Manager shall not discriminate in renting units to Housing Choice or VASH (for veterans) voucher holders including those receiving rental assistance from any local, federal, state, or non-profit agency
Tenant Protections and
Occupancy Process
For acquisition of existing
projects, the City required that
the JPA Project Team adhere
to the following measures to
a. a. Noticing: Each tenant shall
be provided with a written
notice advising them of their
rights under the terms of the
City-approved transaction,
Regulatory Agreement, and
Attachment C
avoid involuntary
displacement of existing
tenants within the 12 months
following a property’s
acquisition.
deed restriction (as
applicable) and on -going
JPA project team
compliance procedures to
maintain their eligibility to
reside in any market-rate or
income and rent restricted
units by category, as
applicable. A copy of the
notice shall also be
provided to the City
Manager. The notice shall
include procedures for the
conversion of tenancies of
any market rate units to
price-restricted units in a
way that does not cause
involuntary displacement of
existing tenants during their
tenure.
b. Maximum Household
Income: Following
conversion to restricted
rents of all occupied
market-rate units at the
commencement of lease -
up, no units shall be rented
to tenants with incomes that
exceed 120% of AMI.
c. Existing Tenants: Existing
tenants who meet
household in come
requirements should be
transitioned first into more
deeply affordable units at
their option, prioritizing
those with the highest
proportion of income spent
on rent payments.
Affirmative Marketing: The
Property Manager shall
include contact information
on the City’s Affordable
Housing Development List.
The Project Administrator or
Attachment C
Property Manager will
maintain a waiting list and
follow the affirmative
marketing procedures in
compliance with the
California Department of
Housing and Community
Development’s Affirmative
Furthering Fair Housing.3
d. Compliance with City’s
Local Preference Policy:
The Property Manager shall
coordinate with City staff to
implement the City’s Local
Housing Preference Policy
and Priority System
Guidelines, to the extent
possible.
e. Section 8 : In accordance
with California Government
Code Sections 12927 and
12955, as amended, the
Property Manager shall not
discriminate in renting units
to Housing Choice or VASH
(for veterans) voucher
holders including those
receiving rental assistance
from any local, federal,
state, or non-profit agency.
City Reporting
Requirements
The City requires the following
annual reporting by the JPA
Project Team to the Director
of Development Services.
a. Market Rents & Property Discounts : The Project
Administrator will provide an annual report on submarket rents and discounts. The report will draw on comparable rent and market data that is mutually agreed upon by the City and the JPA Project Team. Rents for each type of unit in a project shall be set annually, or at the renewal of tenants' leases if less than 12 months.
b. Tenant Summary: The Property Manager will provide an annual summary of tenant attributes including household size, income and rent information on a form acceptable to the Director of Development Services.
3 https://www.hcd.ca.gov/community-development/affh/index.shtml Attachment C
c. Property Financial Report: The Project Administrator will provide an annual financial report that details operating expenses and debt metrics associated with the project.
d. Property Condition: The Property Manager shall continually maintain the units in a condition which, at a minimum,
satisfies the Uniform Physical Cond itions Standards
promulgated by the U.S. Department of Housing and Urban Development (24 CFR §5.705). The project shall also be
subject to the City’s rotation of property inspections set forth by the City’s Code Enforcement Division.
e. City Requests for Oth er Information: The JPA Project Team shall respond within 10 calendar days in writing to any reasonable written request from the City for other information about project’s maintenance conditions or leasing practices. f. Public Benefit Agreement Requirements: The above
reporting requirements must be included in the transaction’s Public Benefit Agreement or shall otherwise be enforceable by the City.
City Application and Annual
Compliance Requirements
The following costs shall be
paid by the JPA and/or Project
Administrator for the City’s
transaction application review
and annual transaction
compliance review.
a. City Application Fee. A City transaction application review fee to pay for City staff time to review and process the application.
b. Third Party Underwr iting Review Costs: The JPA or Project Administrator shall enter into a reimbursement agreement with the City to pay for the City’s reasonable cost to retain independent professionals to review each proposed Middle - Income Housing transaction application an d its degree of adherence to the above City terms and conditions. City will make a best effort and act in good faith to limit underwriting review costs.
c. Annual Monitoring Fee: All projects will be required to pay the City’s annual affordable housing monitoring fee (currently $170 per unit) as increased from time-to-time.
Cost shall not exceed
$40,000 and may adjust
with inflation.
Modify policy to indicate
that the City will make a
best effort and act in good
faith to limit underwriting
review costs.
Attachment C
Proposed Middle-Income Housing Transaction Application and Review Process
City staff will prepare an application form for City Council consideration of a proposed Middle-Income Housing transaction, which may be a conversion of an existing apartment building or a new construction project. Review of the application contents, including its degree of adherence to City terms and conditions for such transactions, and City Council decision making will include the following steps:
1. Initial Consultation Meeting . A Middle -Income Housing transaction Applicant must first conduct a meeting with City staff to introduce and discuss the proposed transaction, and the City’s application and review process.
2. Submittal of the Application . The applicant must complete the City application form and provide all the information listed below in the Middle-Income Housing Application Information Checklist.
3. Application Completeness Review . City staff, with advice from independent professional advisors, will review the transaction application and required information a nd make a “completeness” determination within 30 days.
Applicants will be notified if their application is complete, or if deemed incomplete, what additional information is required to deem the application complete.
4. Application Analysis Review. City staff and independent professional advisors will conduct analysis of the proposed transaction, including its degree of adherence to the City’s required terms and conditions and seek to clarify any questions or need for additional information from the Applicant to complete their analysis. The City staff’s independent professional advisors will prepare a memorandum for review by the Applicant summarizing its initial review of the proposed transaction and its adherence or lack of adherence to City terms and conditions. This process may take 60 days or more, depending on project specifics.
5. Meet and Confer Process. City staff, its independent professional advisors and the Applicant will meet and confer to attempt to resolve any areas in which the proposed transaction does not adhere to the City’s terms and conditions. The schedule required for such discussions will depend on project specifics.
6. Application Consideration by the City Council. When City staff determines that the foregoing meet and confer process has reache d a conclusion, and after consultation with the City Manager and Mayor, the matter will be scheduled for a City Council hearing in not less than 30 days, to allow for preparation and distribution of a City staff report (including a final memorandum by the independent professional advisors) and publication of a public notice about the hearing. Final approval to enter into the transaction and approve required documents, or to disapprove the application, or take other related action(s) will be by majority vote of the City Council.
Attachment C
Middle-Income Housing Application Information Checklist
The following information must be submitted to the satisfaction of City staff to deem a Middle-Income Housing transaction application complete for review and consideration by the City Council:
Requested Item Description
Long Beach Application To be determined
JPA Project Team
Narrative & Org Chart
Include a narrative description of the experience and roles of each of member of the JPA Project Team and other parties. Include information on current Middle-Income Housing bonds as well as real estate portfolio performance.
Property Information Detailed information about the location, age, size, and current uses of the property.
Regulatory Agreements Copies of any existing regulatory agreements covering the project site.
Property Tax History Copies of property tax bills for all project parcels from the last five years, if available
Full Project Financial Pro
Forma
Provide a “live” or dynamic Excel version of the financial pro forma with formulas reflecting current and projected income and expenses, reserves, bond payments, debt coverage ratio, proposed basis for annual rent increases and a schedule of all transaction fees for the project, and estimated sale disposition and net proceeds scenarios at year 15 and termination of the bond term, along with notes on all key assumptions. (Developer objected to “live” pro forma requirement and stated that it is not customary to provide for any affordable housing transaction. That is not true, a “live” pro forma is always provided for affordable housing projects in Long Beach – Retain.
Existing Rent Roll Trailing 12 month rent roll at the property, if applicable.
Historic Revenue and
Expenses
Full accounting of revenue and expenses of up to the last five years, if applicable.
Payroll and Staffing Plan Detailed payroll and staffing plan for the proposed project.
Capital Expenditure Plan Detailed capital expenditure plan with estimated financing levels over the entire bond term for the proposed project.
Purchase and Sale
Agreement
A copy of the draft purchase and sale agreement.
Draft Public Benefit
Agreement
A copy of the draft Public Benefit Agreement between the JPA and the City.
Copies of Draft
Agreements
Copies of the draft agreement between JPA and Project Administrator, and between the Project Administrator/JPA and the Property Manager.
Public Offering Statement A copy of the draft documents for the proposed bond transactions or a comparable recently closed transaction by the same Applicant.
Offering Memorandum Underwriter offering memorandum from a previously marketed transaction or similar marketing materials.
Property Conditions
Assessment
Property Condition Assessment report for the project, if available. For a conversion project, information about the scope and cost of any recent remodel or major capital improvements since initial stabilized operation. For both existing buildings and new construction projects, the assessment should evaluate future replacement requirements over the bond term.
Appraisal A copy of a draft or final appraisal or similar document justifying the proposed valuation of the building and property (for conversion projects) or land (for new construction projects).
Market Rent Study Study that supports the restricted rent discount to market rents proposed by the Applicant.
Executed Reimbursement
Agreement and Payment of
City Application Fee
A fully executed reimbursement agreement, payment of fees for the City’s independent professional advisors, and payment of the City application processing fee.