[bouldercouncilhotline] Hotline: Fwd: Follow-up from CHFA

[cmosupport at bouldercolorado.gov]

Sender: Young, Mary

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Please see email exchange below.

Mary Dolores Young
Boulder City Council
303-501-2439

Begin forwarded message:

From: "Jaime Gomez" <jgomez at chfainfo.com<mailto:jgomez at chfainfo.com>>
To: "Young,  Mary" <YoungM at bouldercolorado.gov<mailto:YoungM at bouldercolorado.gov>>, "Morzel, Lisa" <MorzelL at bouldercolorado.gov<mailto:MorzelL at bouldercolorado.gov>>
Cc: "Cris White" <cwhite at chfainfo.com<mailto:cwhite at chfainfo.com>>, "Cec Ortiz" <cec.ortiz at comcast.net<mailto:cec.ortiz at comcast.net>>, "Jaime Gomez" <jgomez at chfainfo.com<mailto:jgomez at chfainfo.com>>
Subject: Follow-up

With respect to your question from earlier todaycCHFA does not have a threshold requirement for the number of units or density of a project, either for 9% or 4% deals.  The average 9% tax credit development has around 50-55 units and the 4% tax credit projects are typically larger/have more units, but we do not have threshold requirements.  I will say that below a certain number of units these project become very difficult to make the financing structure work using 9% tax credits, but we do not have thresholds.

Also, I wanted to thank you and Lisa for keeping us in the loop with respect to what is happening with the Attention Homes project.  There seems to be a lot of activity going on with the upcoming hearing so I wanted to send you a note to provide some of the follow-up to the information we talked about at our meeting, and to comment or clarify a few items that were included in your summary blogpost of our meeting.  In addition, I am sending you a copy of information we received from the developer of the Attention Homes project, which highlights the neighborhood outreach they undertook as part of the project (see attachment above).  With respect to our prior meeting:

1.           In the blogpost, item #2 under the LIHTC section, the last sentence states that gThere was consensus that community support prior to funding was critical.h  I want to make sure we all understand that critical is an interpretive word in that it implies, to some, that community support is required for funding, when in fact it is not required.  I am careful to point this out because regulations issued by the United States Department of Housing and Urban Development (HUD) prohibit discrimination in housing related activities and transactions on such basiscsupport or rejection of a particular project at the community level is not required for CHFA to approve or reject an application for credits.  We would hope that projects submitted for LIHTC would have broad community support, but the tax code does not require it. So the clarification is that such support is ideal (as we discussed in our meeting), but not required.

2.           Also in the blogpost, #3 under the LIHTC section, there is a similar reference that notes stronger community support would give a project a better chance of receiving an award.  That was said following our discussion of a project having to turn back credit and whether they could apply again.  It is true that the same project with more community support would be ideal, but as stated above such support is not required. The Code requires that each local jurisdiction have a greasonable opportunityh to comment on any proposal to allocate LIHTC to projects within their jurisdiction.  It does not authorize CHFA to abandon its responsibility to exercise judgement and does not require or encourage us to bestow veto power over LIHTC projects, either on local communities or public officials.  While local support or opposition is considered, it is not required to approve or disapprove a project. Also, as we talked about in our meeting, a project that is delayed faces much greater risks both in competing and financial structuring due to increasing development costs, increasing construction costs, carrying costs, gap financing going away, etc. so those factors would harm the projects ability to compete effectively.

3.           During the meeting we stated that we would get you more information about how we go about notifying local jurisdictions about tax credit projects prior to the developer receiving an award.  The IRS tax code, which establishes guidelines for the program, requires the allocating agency (CHFA) to notify the chief executive officer (or the equivalent) of the local jurisdiction within which a project is located, and we do that when a project has submitted an application for tax credits.  We send a notification letter asking the recipient to provide any input from the local jurisdictions perspective.  Based on our recent experiences in Boulder, Littleton, and Colorado Springs, we plan to expand the distribution of our notification letter to include the Mayor and/or City Manager, the City Council person who is over that particular district in the municipality, and the head of the local housing authority (as applicable) of the communities in which projects are located and where we have received tax credit applications.  We also plan to encourage those we notify to inform others they deem necessary so that as many people as necessary are involved up front.   Attached above is a copy of our current letter we are using.

Let me know if there is any additional information I can provide.

Kind regards,

Jaime

Jaime G. Gomez

Deputy Executive Director and Chief Operating Officer

Colorado Housing and Finance Authority

CHFAfs Denver office has temporarily relocated. Please update your records. Visit www.chfainfo.com/tempmove<https://protect-us.mimecast.com/s/kJ0pBbT7dgrSX?domain=chfainfo.com> to learn more.

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