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FROM: Derek Johnson, Community Development Director
Prepared By: Tyler Corey, Housing Programs Manager
SUBJECT: REQUEST FROM THE HOUSING AUTHORITY OF THE CITY OF SAN
LUIS OBISPO REGARDING A FORTY-ONE UNIT SENIOR RENTAL
HOUSING PROJECT LOCATED AT 2005 JOHNSON AVENUE KNOWN
AS THE DEL RIO TERRACE APARTMENTS
RECOMMENDATION
1. Conduct a public hearing under the Tax and Equity Fiscal Responsibility Act (TEFRA)
of 1982 and pursuant to the requirements of the Internal Revenue Code of 1986.
2. Adopt a resolution allowing the reissuance of a Loan by the Housing Authority of the
City of San Luis Obispo for the Del Rio Terrace Apartments located at 2005 Johnson
Avenue.
DISCUSSION
Background
The Housing Authority of the City of San Luis Obispo (the “Authority”) is requesting that the
Council hold a public hearing regarding the reissuance of a tax-exempt Loan that financed the
construction of the Del Rio Terrace Apartments located at 2005 Johnson Avenue. Although
there is no financial participation (or liability, direct or indirect) by the City in approving the
reissuance of this “conduit” financing, Council conduct of a public hearing and approval of the
reissuance is required under federal regulations for tax-exempt financing.
Project Summary
1. Del Rio Terrace Apartments is a 40 unit (plus one manager’s unit) affordable rental
apartment facility for seniors located at 2005 Johnson Avenue (the “Project”). The Project is
owned by Johnson DRT Associates, a California limited partnership (the “Borrower”), of
which the San Luis Obispo Non-Profit Housing Corporation (a nonprofit corporation
established by the Authority) is the general partner.
2. The construction of the Project was financed with the proceeds of a $4,000,000 Loan (the
“Loan”) made to the Authority on October 31, 2005, by First Bank of San Luis Obispo
(“FBSLO”). Through a series of bank mergers and acquisitions, the Loan is now owned by
Union Bank, N.A.
Meeting Date
Item Number 12-10-13
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Conduit Reissuance Request: Housing Authority of the City of San Luis Obispo Page 2
3. In order for the interest on the Loan to be tax-exempt, on May 6, 2003, the Council
conducted a public hearing regarding the financing by the Authority of the Project under the
Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”), and pursuant to the
requirements of the Internal Revenue Code of 1986, on that date the Council adopted
Resolution No. 9450 (2003 Series) approving the Loan by FBSLO to the Authority to finance
the Project (Attachment 1).
4. The expected April 30, 2005 completion of the Project was delayed due to circumstances
beyond the control of the Authority. As a consequence of the delay, FBSLO agreed to make
various modifications to the documents for the Loan, which modifications resulted in a
“reissuance” of the Loan for federal tax purposes. Applicable federal tax law required that
the Council approve the then reissuance of the Loan following the conduct of a TEFRA
hearing regarding the reissuance, in order to maintain the tax-exempt status of the interest on
the Loan.
5. On July 19, 2005, the Council held a TEFRA public hearing regarding the then reissuance of
the Loan and adopted Resolution No. 9709 (2005 Series) approving the reissuance by the
Authority of the Loan (Attachment 2).
6. Union Bank, N.A., the current owner of the Loan, has now agreed to lower the interest rate
on the Loan from 7.50% to 4.50%, which modification to the terms of the Loan will result in
another “reissuance” of the Loan for federal tax purposes. As with the reissuance of the
Loan in 2005, this new reissuance of the Loan once again requires that the Council hold a
TEFRA public hearing regarding the new reissuance and to adopt a resolution approving the
new reissuance by the Authority of the Loan, in order to maintain the tax-exempt status of
the interest on the Loan.
No City Liability for the Financing
There is no City liability in approving the reissuance of conduit financing. The Loan is payable
solely from the payments by the Borrower on a Loan made to it (the “Borrower Loan”) by the
Authority from the proceeds of the Loan. The rental payments by tenants in the Project are the
source of revenue used by the Borrower to repay the Borrower Loan. The City has no financial,
legal, or moral obligation, liability or responsibility for the Project or for the repayment of the
Loan or the repayment of the Borrower Loan. The documents for the Loan clearly provide that
the Loan is payable solely from payments on the Borrower Loan made by the Borrower. Outside
of holding this hearing and adopting the required resolution, no other participation or activity of
the City with respect to the Loan will be required.
City’s Conduit Financing Policy
While the Council is not obligated to approve this request, it would be consistent with past City
actions regarding the Project.
Under the City’s debt financing and management policies, consideration of a request for conduit
financing is generally a two-step process:
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Conduit Reissuance Request: Housing Authority of the City of San Luis Obispo Page 3
1. First asking the Council if they are interested in considering the request and establishing
the ground rules for evaluating it.
2. And then returning with the results of this evaluation and recommending approval of
appropriate financing documents if warranted.
This two-step approach was completed in 2003 when the Council conducted the original TEFRA
hearing for the Loan and adopted Resolution No. 9450 (2003 Series) approving the Loan by
FBSLO to the Authority to finance the Project (Attachment 1).
City’s Past Experience with Conduit Housing Bonds
The City has approved seven “conduit” housing bond issues in the past as reflected in the
following summary. There have been no financial difficulties with any of these bond issues.
1. 1985. 168-unit apartment development on Southwood Drive (refinanced in 1993).
2. 1998. 30-unit development (all “affordable” for seniors and persons with disabilities) on
Brizzolara Street.
3. 1999. 122-unit apartment development by the De Vaul Ranch Company, of which 26 units
will be affordable—24 for “very-low” and 2 for “moderate” income households.
4. 2002. 19-unit seniors apartment development at 433 Pacific Street (Pacific and Carmel).
5. 2005. 40 affordable one-bedroom units for seniors as well as one manager’s unit in an
existing historic single-family residence at 2005 Johnson Avenue (“Del Rio Terrace”).
6. 2009 and 2011. 8-unit housing project at 1468 East Foothill Boulevard for the University
Board of the Santa Barbara Presbytery.
7. 2012. 120-unit apartment project affordable to low and very-low income households located
at 1550 Madonna Road.
Next Steps
After the TEFRA public hearing and adoption of the Resolution of the Council approving the
reissuance of the Loan, the Authority, the Borrower and Union Bank, N.A. will enter into
documents reducing the interest rate on the Bonds from 7.50% to 4.50%. There will be no further
actions required by the City.
FISCAL IMPACT
There are no fiscal impacts to the City associated with this matter. As noted above, the City has
no liability, directly or indirectly, for the financing.
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Conduit Reissuance Request: Housing Authority of the City of San Luis Obispo Page 4
ALTERNATIVES
1. Do not approve the reissuance of bonds by the Authority. Given the approvals that the
Project has already received from the City and the lack of any liability for repayment of the
Loan by the City, this option is not recommended.
2. Defer consideration of the request. Due to the savings in interest costs resulting from the
reissuance of the Loan, this option is not recommended.
ATTACHMENT
1. Council Resolution No. 9450 (2003 Series)
2. Council Resolution No. 9709 (2005 Series)
3. Draft Council Resolution approving the reissuance of the Loan by the Authority
T:\Council Agenda Reports\2013\2013-12-10\TEFRA Hearing for Del rio (Johnson-Corey)\PH1 - TEFRA Hearing for Del Rio Terrace
Apartments.docx
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Attachment 1
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Attachment 1
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RESOLUTION NO. 9709 (2005 SERIES )
A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISP O
APPROVING THE REISSUANCE OF A LOAN OF THE HOUSIN G
AUTHORITY OF THE CITY OF SAN LUIS OBISPO FOR THE PURPOSE O F
PROVIDING FINANCING FOR A RESIDENTIAL RENTAL HOUSIN G
FACILITY SPONSORED BY THE SAN LUIS OBISPO NON-PROFIT HOUSIN G
CORPORATION-DEL RIO TERRACE APARTMENT S
WHEREAS,the Housing Authority of the City of San Luis Obispo (the "Authority") i s
authorized by Chapter 1 of Part 2 of Division 24 of the Health and Safety Code of the State o f
California, as amended (the "Law"), to make bonds to finance housing developments as specified
in the Law ; and
WHEREAS,the Authority has entered into a Loan Agreement, dated as of October 1 ,
2003 (the "Loan Agreement") with the First Bank of San Luis Obispo (the "Bank"), pursuant t o
which the Bank agreed to make a loan to the Authority (the "Loan") in an amount of up t o
$4,000,000, and on October 31, 2003 (the "Date of Issuance") the Bank made the first advance o f
$54,000 of the principal of the Loan to the Authority ; and
WHEREAS,the Authority has entered into a Loan Agreement, dated as of October, 1 ,
2003, with Johnson DRT Associates, a California limited partnership (the "Borrower") of whic h
the San Luis Obispo Non-Profit Housing Corporation, a California nonprofit public benefi t
corporation is the sole general partner, whereby the Authority has agreed to loan the proceeds o f
the Loan to the Borrower to enable the Borrower to finance the acquisition and construction of a
41 unit residential rental housing facility for seniors to be located at 2005 Johnson Avenue in th e
City of San Luis Obispo (the "Project"); and
WHEREAS,the Loan is considered to be a "qualified exempt facility bond" unde r
Section 142(a) of the Internal Revenue Code of 1986, as amended (the "Code"), and Sectio n
147(f) of the Code requires that the "applicable elected representative" with respect to th e
Authority approve the incurrence of the Loan by the Authority following the holding of a publi c
hearing with respect thereto ; and
WHEREAS,the Authority determined that the Council of the City was the "applicabl e
elected representative" to approve the incurrence of the Loan by the Authority and on May 6 ,
2003, the Council held a public hearing regarding the Loan and adopted a Resolution approvin g
the incurrence of the Loan by the Authority for the purpose of providing financing to th e
Borrower for the Project ; and
WHEREAS,the City is not a part to any of the agreements or other documents relatin g
to the financing of the Project, and neither the financing of the Project nor the Loan will impos e
any legal, financial or moral obligation upon the City with respect to the financing of the Project ;
and
WHEREAS,the Loan Agreement contemplated that the Project would be full y
constructed by April 30, 2005, and, due to construction delays it now appears that th e
construction of the Project will not be completed until December 31, 2005 ; and
R9709
Attachment 2
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Resolution No . 9709 (2005 Series )
Page 2
WHEREAS,the Bank has agreed to allow modifications to be made to the Loan
Agreement to extend the construction period of the Loan, and the maturity date of the Loan t o
accommodate the additional time necessary to construct the Project, but such modifications will ,
under the Code, cause a "reissuance" of the Loan ; and
WHEREAS,in order to maintain the tax-exempt status of the interest on the Loan pai d
by the Authority to the Bank, prior to the modification of the Loan Agreement, the Authorit y
needs the Council to approve the reissuance of the Loan following a public hearing on the matter ;
and
WHEREAS,notice of said public hearing has been duly given as required by the Code ,
and the Council has heretofore held such public hearing at which all interested persons wer e
given an opportunity to be heard on all matters relative to the financing of the Project and th e
Authority's reissuance of the Loan and the Authority's loan of the proceeds thereof to th e
Borrower ; an d
WHEREAS,it is consistent with the General Plan, in the public interest and for th e
public benefit that the Council approve the reissuance of the Loan for the aforesaid purposes .
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Lui s
Obispo, as follows :
Section 1 .The Council of the City of San Luis Obispo hereby approves the reissuance o f
the Loan by the Authority under the Code in the amount of up to four million dollar s
($4,000,000), and the use of the proceeds of the reissued Loan to make a loan to the Borrower t o
enable the Borrower to finance the acquisition and construction of the Project .
Section 2. This Resolution shall take effect immediately upon its adoption .
On motion of Vice Mayor Ewan, seconded by Council Member Brown ,
and on the following roll call vote :
AYES :
Council Members Brown and Mulholland, Vice Mayor Ewan and Mayo r
Romero
NOES :
Non e
ABSENT :
Council Member Settle
The foregoing resolution was adopted this 19 th day of July 2005 .
Attachment 2
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Resolution No. 9709 (2005 Series )
Page 3
Mayor David F . Romero
ATTEST :
APPROVED AS TO FORM :
Jon is . Lowell
City Attorney
Attachment 2
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Attachment 3
RESOLUTION NO. XXXX-13
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF SAN LUIS OBISPO APPROVING THE REISSUANCE
OF A MULTIFAMILY HOUSING REVENUE LOAN BY THE HOUSING
AUTHORITY OF THE CITY OF SAN LUIS OBISPO FOR THE DEL RIO
TERRACE APARTMENTS LOCATED AT 2005 JOHNSON AVENUE
WHEREAS, the Housing Authority of the City of San Luis Obispo (the “Authority”) is
authorized by Chapter 1 of Part 2 of Division 24 of the Health and Safety Code of the State of
California to issue bonds and borrow money to finance multifamily rental housing facilities
located within the area of operation of the Authority; and
WHEREAS, on October 31, 2003, the Authority borrowed $4,000,000 (the “Authority
Loan”) from First Bank of San Luis Obispo (the “Original Bank”) pursuant to a Loan
Agreement, dated as of October 1, 2003 (the “Authority Loan Agreement”), between the
Authority and the Original Bank; and
WHEREAS, the Authority loaned (the “Borrower Loan”) the proceeds of the Authority
Loan to Johnson DRT Associates, a California limited partnership (the “Borrower”) pursuant to a
Loan Agreement, dated as of October 1, 2003 (the “Borrower Loan Agreement”), between the
Authority and the Borrower; and
WHEREAS, the Borrower used the proceeds of the Borrower Loan to finance the
acquisition and construction of 41 units of multifamily rental housing for seniors known as Del
Rio Terrace Apartments (the “Project”), located at 2005 Johnson Avenue in the City of San Luis
Obispo (the “City”); and
WHEREAS, the Authority Loan is considered to be “a qualified exempt facility bond”
under Section 142(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and
Section 147(f) of the Code requires that the “applicable elected representative” with respect to
the Authority approve the incurrence by the Authority of the Authority Loan following the
holding of a public hearing with respect thereto; and
WHEREAS, the Authority determined that the Council of the City was the “applicable
elected representative” to approve the incurrence by the Authority of the Authority Loan and on
May 6, 2003, the Council held a public hearing regarding Authority Loan and adopted
Resolution No. 9450 (2003 Series) approving the incurrence by the Authority of the Authority
Loan for the purpose of providing financing to the Borrower for the Project; and
WHEREAS, in July of 2005, the Original Bank agreed with the Authority and the
Borrower to amend the Authority Loan Agreement, the Borrower Loan Agreement and related
documents to modify certain terms of the Authority Loan and the Borrower Loan; and
WHEREAS, the amendments resulted in a “reissuance” of the Authority Loan under
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Attachment 3
applicable provisions of the Code and in order to maintain the tax-exempt status of the interest
on the Authority Loan the Council held a public hearing on July 19, 2005 regarding the
reissuance of the Authority Loan and the ownership and operation of the Project, and on that date
the Council adopted Resolution No. 9709 (2005 Series) approving the reissuance by the
Authority of the Authority Loan; and
WHEREAS, Union Bank, N.A. (the “Bank”), has succeeded to the interests of the
Original Bank under the Authority Loan Agreement and is the current payee of the Authority
Loan; and
WHEREAS, the Bank has now agreed to allow modifications to be made to the Authority
Loan Agreement and the Borrower Loan Agreement to lower the interest rate on the Authority
Loan and on the Borrower Loan, but such modifications will, under the Code, cause another
“reissuance” of the Authority Loan; and
WHEREAS, in order to maintain the tax-exempt status of the interest on the Authority
Loan paid by the Authority to the Bank, prior to the modification of the Authority Loan
Agreement and the Borrower Loan Agreement, the Authority needs the Council to approve the
new reissuance of the Authority Loan following a public hearing on the matter; and
WHEREAS, notice of the required public hearing has been duly given as required by the
Code, and the Council has heretofore held the public hearing at which all interested persons were
given an opportunity to be heard on all matters relative to the reissuance of the Authority Loan
and the ownership and operation of the Project; and
WHEREAS, the City is not a party to any of the agreements or other documents relating
to the Authority Loan, the Borrower Loan or the financing of the Project, and none of the
financing of the Project, the Authority Loan or the Borrower Loan impose any legal, financial or
moral obligation upon the City with respect to the financing of the Project; and
WHEREAS, it is in the public interest and for the public benefit that the Council approve
the reissuance of the Authority Loan for the aforesaid purposes.
BE IT RESOLVED, by the City Council of the City of San Luis Obispo as follows:
Section 1. Action. The Council of the City of San Luis Obispo hereby approves the
reissuance of the Authority Loan by the Authority for purposes of the Code. This resolution shall
take effect immediately upon its adoption.
Upon motion of , seconded by , and on the
following vote:
AYES:
NOES:
ABSENT:
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Attachment 3
The foregoing resolution was passed and adopted this 10th day of December, 2013.
____________________________________
Mayor Jan Marx
ATTEST:
____________________________________
Anthony J. Mejia
City Clerk
APPROVED AS TO FORM:
_____________________________________
Christine Dietrick
City Attorney
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