Community Development Agency
www.santa-ana.gov/cd
Item # 30
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
September 15, 2026
TOPIC: Tax Equity Fiscal Responsibility Act Hearing for Garden Court Apartments
AGENDA TITLE
Public Hearing - Tax Equity Fiscal Responsibility Act Hearing for Garden Court Apartments
Legal Notice published in the OC Reporter on August 28, 2026.
RECOMMENDED ACTION
1. Conduct a Tax Equity and Financial Responsibility Act Hearing in consideration of the issuance of tax-exempt bond financing by the California Municipal Finance Authority for Garden Court Santa Ana LP, to finance or refinance the acquisition, rehabilitation, improvement, and equipping of the multifamily rental housing project located at 300 East Santa Ana Boulevard, Santa Ana, California.
2. Adopt a resolution approving the issuance of revenue bonds by the California Municipal Finance Authority in an amount not to exceed $45,000,000 for financing the project.
RESOLUTION NO. 2026-XXX entitled A RESOLUTION OF THE CITY OF SANTA
ANA APPROVING THE ISSUANCE BY THE CALIFORNIA MUNICIPAL FINANCE
AUTHORITY OF EXEMPT FACILITY BONDS FOR GARDEN COURT
APARTMENTS
GOVERNMENT CODE §84308 APPLIES: Yes
DISCUSSION
Garden Court Santa Ana LP (GCSA) has requested that the City of Santa Ana conduct a Tax Equity and Fiscal Responsibility Act (TEFRA) hearing and provide the required local governmental approval. This approval enables GCSA to qualify for tax-exempt bond financing issued by the California Municipal Finance Authority (CMFA) for the Garden Court Apartments located at 300 East Santa Ana Boulevard. The purpose of the hearing is to provide the public an opportunity to comment on the project’s proposed tax-exempt bond financing and is required by federal tax law. As the host jurisdiction, the City Council is only being asked to hold the hearing and approve the proposed bond issuance by CMFA for federal tax purposes. This action does not obligate City funding or grant any land-use entitlements. CMFA will issue the bonds, and the borrower,
Tax Equity Fiscal Responsibility Act Hearing for Garden Court Apartments September 15, 2026
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GCSA, will be solely responsible for repayment. The City serves solely as the local approving body of the transaction for federal tax purposes and has received a $1,101 fee to conduct the TEFRA hearing.
Garden Court Apartments is an existing, occupied 84-unit multifamily property located at 300 East Santa Ana Boulevard. Under a 1995 agreement between the City, the former Community Redevelopment Agency, and Orange Housing Development Corporation (“OHDC”), 41 units were restricted to households earning no more than 40% of the Area Median Income (“AMI”) in perpetuity; the remaining units consisted of 42 market-rate units and one manager’s unit. In February 2024, OHDC and C&C Development Co., LLC (“C&C”) approached the City and proposed rehabilitating the property and converting the 42 market-rate units to affordable housing.
On July 16, 2024, the City Council and Housing Authority approved an Amended and Restated Regulatory Agreement, a tenant relocation plan, and the issuance of revenue bonds by the California Municipal Finance Authority in an amount not to exceed $55 million following a Tax Equity and Fiscal Responsibility Act (“TEFRA”) hearing (Exhibit 1). The Housing Authority also consented to termination of the 1995 agreement. The amended agreement established a new 55-year affordability term for 83 units, 41 units restricted at or below 60% of AMI and 42 units restricted at or below 80% of AMI, while retaining one unrestricted manager’s unit. The rehabilitation remained contingent upon C&C and OHDC securing the necessary tax-credit and bond financing to complete the project.
Following City Council’s approval in July 2024, C&C applied five (5) times for competitive Low-Income Housing Tax Credits before receiving a tax credit award in May 2026. Because the bonds were not issued within one year of the July 2024 TEFRA approval, a new hearing and resolution are required. The current action below would approve CMFA’s issuance of bonds in an amount not to exceed $45 million and would not create any financial or legal obligation for the City.
Upon completion of the rehabilitation, the existing residential building will feature various updated architectural design features. Abundant community and programming spaces will also undergo modernization to enhance the living experience for residents, bringing it on par with market-rate communities. Parking provisions will adhere to the State of California density bonus law, providing a ratio of 1:1 space for one-bedroom units and 2:1 spaces for two-bedroom units, totaling 104 parking spaces for family residents.
The rehabilitation plan also includes updates to green spaces, aiming to aesthetically enhance the street frontage on all four sides of the building. Additionally, a small dog run area will be incorporated on the ground floor, facing North Spurgeon Street. Access to the parking garage on the ground floor will be facilitated through two parking garage gates, located on French Street and North Spurgeon Street respectively. Tenants will access their assigned parking spaces from within the parking garage. For residents on the three floors of apartments above the parking garage, access to the garage will be provided via elevator or stairs.
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This financing initiative will contribute to the creation of 83 units of affordable housing for low-income households in the City of Santa Ana, ensuring their availability for the next 55 years.
Tax Equity Fiscal Responsibility Act (TEFRA)
To complete this rehabilitation, Garden Court Santa Ana LP (the “Borrower”) has requested that the CMFA adopt a financing plan to issue one or more series of revenue bonds, issued periodically, including bonds for refunding such revenue bonds, in an aggregate principal amount not exceeding $45,000,000 (the “Bonds”). These funds are intended to finance or refinance the acquisition, rehabilitation, improvement, and equipping of a multifamily rental housing project located at 300 East Santa Ana Boulevard.
However, for any portion of the Bonds to qualify as tax-exempt, the City of Santa Ana must conduct a public hearing (the “TEFRA Hearing”), allowing community members the opportunity to voice their opinions regarding the use of tax-exempt bonds for the Project's financing. After the TEFRA Hearing concludes, an “applicable elected representative” of the governmental unit hosting the Project, in this case, the City, must provide approval for the CMFA to issue the Bonds for the Project's financing (Exhibit 2). Pursuant to Section 147(f) of the Code, the issuance of the Bonds by the Authority must be approved by the City of Santa Ana because the Project is located within the territorial limits of the City.
The bonds to be issued by the CMFA are the sole responsibility of the borrower. The City bears no financial or legal liability for the project or bond repayment and incurs no indebtedness. The adoption of the Resolution shall not obligate the City or any department thereof to: (i) provide any financing with respect to the Project; (ii) approve any application or request for or take any other action in connection with any planning approval, permit, or other action necessary with respect to the Project; (iii) make any contribution or advance any funds whatsoever to the Authority; or (iv) take any further action with respect to the CMFA or its membership therein.
The Board of Directors of the California Foundation for Stronger Communities, a California non-profit public benefit corporation (the “Foundation”), serves as the Board of Directors for the CMFA. Through its conduit issuance activities, the CMFA shares a portion of its issuance fees with its member communities and allocates a portion of these fees to the Foundation to support local charities.
FISCAL IMPACT
Funds in the amount of $1,101 were deposited into the General Fund revenue account for the Miscellaneous Service Charge account (no. 01102002-53902).
EXHIBIT(S)
1. Staff Report from July 16, 2024
2. TEFRA Resolution
3. Proof of Publication
Tax Equity Fiscal Responsibility Act Hearing for Garden Court Apartments September 15, 2026
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Submitted By: Sylvia Vazquez, Deputy City Manager/Acting Executive Director of Community Development Agency
Approved By: Alvaro Nuñez, City Manager