HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 06/06/2000 - RESOLUTION 2000-79 AUTHORIZING THE EXECUTION OF AN AGENDA ITEM SUMMARY ITEM NUMBER: 21
FORT COLLINS CITY COUNCIL DATE: 3une 6,2000
STAFF: Alan Krcmarik
;SUBJECT:
Resolution 2000-79 Authorizing the Execution of an Assignment Agreement with the City of
Loveland and Acceptance of an Assignment of Allocation.
RECOMMENDATION:
Staff recommends adoption of the Resolution.
FINANCIAL IMPACT:
Private activity bonds are paid with revenues generated by the project. The City may not pledge
or use its resources for such projects. The total expected cost of the project is approximately
$4.5 million. The total amount of tax exempt private activity bonds is about $3.6 million. The
Project proponents will finance the remainder of the project with private taxable financing.
EXECUTIVE SUMMARY:
This Resolution allows the City of Fort Collins to receive an assignment of private activity bond
allocation from the City of Loveland. Fort Collins would use the $1,178,750 of allocation from
Loveland to supplement the private activity bond allocation received from Latimer County and
the State of Colorado. The combination of the allocations from Loveland, Larimer County, and
the State would provide a total of$3.6 million of allocation. The proponents of the Residence at
Oakridge Project would finance the remainder of the project through private taxable financing.
The Resolution also authorizes the City to enter into an agreement with Loveland regarding the
assignment and states the intent of the City to provide an assignment of Fort Collins' future
private activity bond allocation.
BACKGROUND
On February 15, 2000, the City Council induced the Residence at Oakridge Assisted Living
Project. The Project is an assisted-living rental housing complex to be located along McMurray
Drive in Oakridge Business Park. The total amount of the project is anticipated to be about
$4.4 million. The Project will contain 44 units (58 beds). Of the total units, 50% will be
reserved for persons whose incomes do not exceed 60% of the Area Median Income. The
Project will qualify as a low-income rental housing project. The remaining units in the Project
will be leased at market rates.
DATE: June 6, 2000 1 2 ITEM NUMBER: 21
The total cost of the project is estimated to be $4.5 million. The City secured the Larimer
County 2000 private activity bond allocation of$1,579,750. The Project applied for additional
allocation from the State of Colorado. The State Allocation Board ranked the project very high
and recommended that the Project receive an allocation. Due to some uncertainty about the
financing structure, the amount allocated, $800,000, was less than the amount that is needed for
the Project to complete the financing. With the County and State allocation, the Project now has
$2,379,750 available.
The support staff for the State Allocation Board suggested that the City request to use the City of
Loveland's 2000 allocation of$1,179,750. Loveland is receptive to this proposal, but would like
Fort Collins to assign an equal amount from its 2001 allocation, since the City of Loveland
Housing Authority expects that it will have a project in 2001.
For additional background, staff has included the agenda item from February 15, 2000.
RESOLUTION 2000-79
OF THE COUNCIL OF THE CITY OF FORT COLLINS, COLORADO
AUTHORIZING THE EXECUTION OF AN ASSIGNMENT AGREEMENT WITH
THE CITY OF LOVELAND AND ACCEPTANCE OF
AN ASSIGNMENT OF ALLOCATION
WHEREAS,representatives of National Healthcare Associates,Inc. (the"Company")have
met with officials of the City of Fort Collins, Colorado (the "City"), and have advised the City of
the Company's interest in acquiring, constructing, and equipping a multifamily housing assisted
living project (the "Project") to be located on approximately 3.02 acres of land east of Wheaton
Drive and south of the Comfort Suites in the Oakridge Business Park in Fort Collins, Colorado,
subject to the City's financing of the Project by the issuance of multifamily housing revenue bonds,
pursuant to the Colorado County and Municipality Development Revenue Bond Act, constituting
Article 3, Title 29, Colorado Revised Statutes, as amended(the "Act"); and
WHEREAS,the Council on February 15,2000, adopted Resolution 2000-32, Setting Forth
the Intention of the City to Issue Multi-Family Housing Revenue Bonds for the National Healthcare
Associates Residence at Oakridge Assisted Living Project and Authorizing the Execution of an
Assignment Agreement and a Delegation Agreement with Larimer County; and
WHEREAS, in accordance therewith, the County has assigned to the City its allocation of
the private activity bond volume cap for the State and its issuing authorities pursuant to the Colorado
Private Activity Bond Ceiling Allocation Act,constituting Part 17 of Article 32 of Title 24,Colorado
Revised Statutes, as amended (the "Allocation Act"); and
WHEREAS,the Project has also received an allocation of$800,000 from the Colorado 2000
state-wide balance of private activity bond allocation; and
WHEREAS, the City of Loveland ("Loveland") is authorized under the Act to finance
projects as defined in the Act,including housing facilities for low-and middle-income persons and
families; and
WHEREAS, Loveland has been awarded an allocation for the year 2000 of the private
activity bond volume cap for the State and its issuing authorities pursuant to the Allocation Act and
is willing to assign a portion of that allocation, in the amount of $1,178,750, (the "Assigned
Allocation")to the City in order to assist with the financing of the Project,provided that Fort Collins
assigns a like portion of its allocation to Loveland for its use in 2001; and
WHEREAS,the Council believes that this reciprocal assignment of allocations is in the best
interests of the City; and
WHEREAS, it is necessary to evidence such assignments by the execution and delivery of
Assignment Agreements by and between the City and Loveland in substantially the form attached
hereto as Exhibits "A" and "B" and incorporated herein by this reference (the "Assignment
Agreements"); and
WHEREAS, the City is authorized to enter into intergovernmental agreements to provide
any function,service or facility,such as a grant agreement,under Article II,Section 16 of the Charter
of the City of Fort Collins and Section 29-1-203, C.R.S.
NOW,THEREFORE,BE IT RESOLVED BY THE COUNCIL OF THE CITY OF FORT
COLLINS, COLORADO that, for the purpose of financing the Project, the Mayor is hereby
authorized to execute the above-referenced Assignment Agreements,in the forms shown on Exhibits
"A" and "B", subject to such modifications thereto in form or substance as the City Manager, in
consultation with the City Attorney,may deem necessary to effectuate the purposes set forth herein.
Passed and adopted at a regular meeting of the City Council held this 6th day of June, A.D.
2000.
Mayor
ATTEST:
City Clerk
• EXHIBIT "A"
ASSIGNMENT AGREEMENT
This ASSIGNMENT AGREEMENT (the "Assignment") dated the day of June,
2000,is by and between the CITY OF LOVELAND,COLORADO,a body corporate and politic(the
"Assignor") and the CITY OF FORT COLLINS, COLORADO, a body corporate and politic (the
"Assignee");
RECITALS:
WHEREAS, the Assignor and the Assignee are authorized and empowered under the laws
of the State of Colorado (the "State") to issue revenue bonds for the purpose of financing multi-
family rental housing projects for low- and moderate-income persons and families; and
WHEREAS, the Internal Revenue Code of 1986, as amended (the "Code"), restricts the
amount of tax-exempt bonds('Private Activity Bonds")which maybe issued in the State to finance
such rental housing projects and for certain other purposes (the "State Ceiling"); and
WHEREAS, pursuant to the Code, the Colorado legislature adopted the Colorado Private
Activity Bond Ceiling Allocation Act,Part 17 of Article 32 of Title 24, Colorado Revised Statutes
. (the "Allocation Act"), providing for the allocation of the State Ceiling among the Assignee and
other governmental units in the State, and further providing for the assignment of allocations from
such other governmental units to the Assignee; and
WHEREAS,pursuant to an allocation under Section 24-32-1706 of the Allocation Act, the
Assignor has available for assignment to Assignee a portion its allocation of the 2000 State Ceiling
for the issuance of a specified principal amount of Private Activity Bonds prior to September 15,
2000, in the amount of$1,178,750 (the "Loveland Allocation"); and
WHEREAS, the Assignor has determined that, in order to increase the availability of
adequate affordable housing by low- and moderate-income persons and families in the local area,
it is necessary or desirable to provide for the utilization of all or a portion of the Loveland Allocation
as set forth herein; and
WHEREAS,the Assignor has determined that the Loveland Allocation can be utilized most
efficiently by assigning it to the Assignee to issue Private Activity Bonds for the purpose of
financing one or more multi-family housing projects for low- and moderate-income persons and
families, and the Assignee has expressed its willingness to attempt to issue such Private Activity
Bonds with respect to the Loveland Allocation; and
WHEREAS, subject to the terms and conditions set forth herein, the Assignor desires to
assign and transfer to the Assignee, and the Assignee desires to accept, the assignment of the
• Loveland Allocation in an amount equal to $1,178,750,which the Assignor and Assignee agree to
commit and reserve for the issuance of such private activity bonds; and
WHEREAS,the private activity bonds will be issued by the Assignee pursuant to the County
and Municipality Development Revenue Bond Act, constituting Article 3 of Title 29, Colorado
Revised Statutes,as amended(the"Act"),and such bonds will be used for a purpose which qualifies
as a"project" as described in the Act;
NOW,THEREFORE,in exchange for the agreements set forth herein and other good and
valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties
hereto agree as follows:
1. In accordance with action taken by the governing body of the Assignor on June 6,
2000, the Assignor hereby assigns and transfers to the Assignee, a portion of the Assignor's 2000
Allocation from the State Ceiling for private activity bonds in an amount equal to $1,178,750 (the
"Assigned Allocation"). In addition,the Assignor hereby consents to the election by the Assignee,
if the Assignee in its discretion so decides, to treat the Assigned Allocation as an allocation for a
project with a carryforward purpose and/or to make a mortgage credit certification election, thus
avoiding reversion of the Assigned Allocation to the statewide balance under the Allocation Act.
2. The Assignor represents that it has received no monetary consideration for the
assignment set forth above.
3. The Assignee hereby:
(a) Accepts the assignment of the Assigned Allocation from the State Ceiling
described above;
(b) Agrees to use reasonable efforts to use the Assigned Allocation to finance the
multifamily assisted living project to be located east of Wheaton Drive and south of the Comfort
Suites in the Oakridge Business Park in Fort Collins, Colorado, and to be known as The
Residence at Oakridge(the"Project"),subject to the terms and conditions set forth herein. In the
event Assignee is unable to finance the Project on or prior to September 15, 2000, Assignee
agrees to use its best efforts to use an amount equal to the 2000 Allocation hereby assigned in
connection with the issuance ofPrivate Activity Bonds to finance one or more other multi-family
housing projects located within Assignee's boundaries; and
(c) Agrees to abide by each of the terms and conditions of this Assignment in
connection with the use of the Assigned Allocation.
4. The parties acknowledge that nothing contained in this Assignment shall obligate the
Assignee to finance the Project or to use the Assigned Amount to finance any other multi-family
housing project located in the City of Fort Collins, and that the issuance of Private Activity Bonds
for the benefit of the Project is subject to due compliance with all requirements of law, and
contingent upon the determination by the State that a portion of the Statewide Balance of the State
Ceiling shall be used to issue such bonds, and a determination by the Assignee that the allocation
of authority available for the issuance of such bonds is sufficient, and further contingent upon the
authorization of the issuance of suchbonds and execution of such documents and agreements as may
2
be necessary to accomplish the same, by ordinance of the Assignee's City Council, in its sole
discretion.
5. This Assignment is effective upon execution and is irrevocable.
IN WITNESS WHEREOF,the Assignor and the Assignee have caused this instrument to be
executed to be effective as of the date and year first written above.
CITY OF LOVELAND, COLORADO
[SEAL]
By
Mayor
ATTEST:
By
City Clerk
APPROVED AS TO FORM:
By
City Attorney
CITY OF FORT COLLINS, COLORADO
[SEAL]
By
Mayor
ATTEST:
By
City Clerk
APPROVED AS TO FORM:
By
Assistant City Attorney
3
• EXHIBIT "B"
ASSIGNMENT AGREEMENT
This ASSIGNMENT AGREEMENT(the"Assignment')dated the day of_,
is by and between the CITY OF FORT COLLINS,COLORADO, a body corporate and politic (the
"Assignor") and the CITY OF LOVELAND, COLORADO, a body corporate and politic (the
"Assignee");
RECITALS:
WHEREAS, the Assignor and the Assignee are authorized and empowered under the laws
of the State of Colorado (the "State") to issue revenue bonds for the purpose of financing multi-
family rental housing projects for low- and moderate-income persons and families; and
WHEREAS, the Internal Revenue Code of 1986, as amended (the "Code"), restricts the
amount of tax-exempt bonds("Private Activity Bonds")which may be issued in the State to finance
such rental housing projects and for certain other purposes (the "State Ceiling"); and
WHEREAS, pursuant to the Code, the Colorado legislature adopted the Colorado Private
Activity Bond Ceiling Allocation Act,Part 17 of Article 32 of Title 24, Colorado Revised Statutes
• (the "Allocation Act"), providing for the allocation of the State Ceiling among the Assignee and
other governmental units in the State, and further providing for the assignment of allocations from
such other governmental units to the Assignee; and
WHEREAS,pursuant to an allocation under Section 24-32-1706 of the Allocation Act,the
Assignor has available for assignment to Assignee a portion its allocation of the 2001 State Ceiling
for the issuance of a specified principal amount of Private Activity Bonds prior to September 15,
2001, in the amount of$1,178,750 (the "Fort Collins Allocation"); and
WHEREAS, the Assignor has determined that, in order to increase the availability of
adequate affordable housing by low- and moderate-income persons and families in the local area,
it is necessary or desirable to provide for the utilization of all or a portion of the Fort Collins
Allocation as set forth herein; and
WHEREAS, the Assignor has determined that the Fort Collins Allocation can be utilized
most efficiently by assigning it to the Assignee to issue Private Activity Bonds for the purpose of
financing one or more multi-family housing projects for low- and moderate-income persons and
families, and the Assignee has expressed its willingness to attempt to issue such Private Activity
Bonds with respect to the Fort Collins Allocation; and
WHEREAS, subject to the terms and conditions set forth herein, the Assignor desires to
assign and transfer to the Assignee, and the Assignee desires to accept, the assignment of the Fort
Collins Allocation in an amount equal to $1,178,750, which the Assignor and Assignee agree to
commit and reserve for the issuance of such private activity bonds; and
WHEREAS,the private activity bonds will be issued by the Assignee pursuant to the County
and Municipality Development Revenue Bond Act, constituting Article 3 of Title 29, Colorado
Revised Statutes,as amended(the"Act"),and such bonds will be used for a purpose which qualifies
as a"project"as described in the Act;
NOW,THEREFORE,in exchange for the agreements set forth herein and other good and
valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties
hereto agree as follows:
1. In accordance with action taken by the governing body of the Assignor on, June 6,
2000, the Assignor hereby assigns and transfers to the Assignee, a portion of the Assignor's 2001
Allocation from the State Ceiling for private activity bonds in an amount equal to $1,178,750 (the
"Assigned Allocation"). In addition,the Assignor hereby consents to the election by the Assignee,
if the Assignee in its discretion so decides, to treat the Assigned Allocation as an allocation for a
project with a carryforward purpose and/or to make a mortgage credit certification election, thus
avoiding reversion of the Assigned Allocation to the statewide balance under the Allocation Act.
2. The Assignor represents that it has received no monetary consideration for the
assignment set forth above.
3. The Assignee hereby:
(a) Accepts the assignment of the Assigned Allocation from the State Ceiling
described above;
(b) Agrees to use reasonable efforts to use the Assigned Allocation to finance a
project to be sponsored by the Loveland Housing Authority(the"Project"), subject to the terms
and conditions set forth herein. In the event Assignee is unable to finance the Project on or prior
to September 15,2001,Assignee agrees to use its best efforts to use an amount equal to the 2001
Allocation hereby assigned in connection with the issuance of Private Activity Bonds to finance
one or more other multi-family housing projects located within Assignee's boundaries; and
(c) Agrees to abide by each of the terms and conditions of this Assignment in
connection with the use of the Assigned Allocation.
4. The parties acknowledge that nothing contained in this Assignment shall obligate the
Assignee to finance the Project or to use the Assigned Amount to finance any other multi-family
housing project located in the City of Loveland, and that the issuance of Private Activity Bonds for
the benefit of the Project is subject to due compliance with all requirements of law, and contingent
upon the determination by the State that a portion of the Statewide Balance of the State Ceiling shall
be used to issue such bonds, and a determination by the Assignee that the allocation of authority
available for the issuance of such bonds is sufficient, and further contingent upon the authorization
of the issuance of such bonds and execution of such documents and agreements as maybe necessary
to accomplish the same,by ordinance of the Assignee's City Council, in its sole discretion.
2
5. This Assignment is effective upon execution and is irrevocable.
IN WITNESS WHEREOF,the Assignor and the Assignee have caused this instrument to be
executed to be effective as of the date and year first written above.
CITY OF FORT COLLINS, COLORADO
[SEAL]
BY
Mayor
ATTEST:
By
City Clerk
APPROVED AS TO FORM:
By
Assistant City Attorney
CITY OF LOVELAND, COLORADO
[SEAL]
By
Mayor
ATTEST:
By
City Clerk
APPROVED AS TO FORM:
By
City Attorney
3
AGENDA ITEM SUMMARY ITEM NUMBER: 22
DATE: February 15, 2000
FORT COLLINS CITY COUNCIL STAFF: Alan Krcmarik
SUBJECT:
Resolution 2000-32 Setting Forth the Intention of the City to Issue Multi-Family Housing Revenue
Bonds for the National Healthcare Associates Residence at Oakridge Assisted Living Project and
Authorizing the Execution of an Assignment Agreement and a Delegation Agreement with Larimer
County.
RECOMMENDATION:
Staff recommends adoption of the Resolution. The Affordable Housing Board's recommendation
will be forwarded to Council prior to the meeting on February 15.
FINANCIAL IMPACT:
The private activity bonds that would be issued by the City for this project cannot be obligations of
the City of Fort Collins. The City serves only as the sponsor and issuer of the bonds for the project.
The debt service on the bonds would be repaid from revenue generated by the project. The debt
service on the private activity bonds does not constitute a debt of the City. The City had an
allocation of$2,756,250 of private activity bonds for 2000 and used this allocation for the Fox
Meadows Apartments Project. Larimer County's allocation ($1,579,750) is available. If the City
induces the project,the proponents will apply for the County's allocation and for additional private
activity bond allocation from the Statewide Balance or the Colorado Housing Finance Authority
("CHFA").
EXECUTIVE SUMMARY:
In late December 1999,Mr. Robert Mattrazo,a representative of the National Healthcare Associates
Project(the"Project"),contacted staff members of the Advance Planning and Finance Departments.
The organization has requested the City consider issuing private activity bonds for the purpose of
acquiring property, constructing and equipping an assisted living multifamily housing project in
the southeast part Fort Collins. The Project would qualify as a low-income rental housing project.
The project is located along McMurray Drive in Oakridge Business Park. Forty-four units(58 beds)
will be included in the project. Of the total, 50% of the units (beds)will be affordable to persons
whose incomes do not exceed 60%of the Area Median Income. The remaining units will be leased
at market rental rates.
Passage of this Resolution will allow the City to issue up to $4.5 million in tax-exempt private
activity bonds for the purpose of constructing the project. The issuance is contingent on the Project
receiving an additional allocation from the Statewide Balance or the Colorado Housing Finance
Authority. The Resolution also authorizes the execution of an Assignment Agreement and a
Delegation Agreement with the County, which would carry out the proposed assignment of the
County's allocation to the City. The execution of those agreements is made contingent upon the
February 15, 2000 2 22
receipt of the necessary additional allocations for the Project. The proposal is consistent with the
City's adopted policies regarding the issuance of multi-family rental housing bonds.
Staff finds that the project is consistent with Council's goal of increasing the quality of affordable
housing in the City. The project also serves a special niche in the housing market, that of low-
income seniors that require some assistance in the course of their daily lives. The project proponent
has prepared and submitted an application to secure an the additional Private Activity Bond
Allocation from the Statewide Balance of private activity bonds. Based on Council's action on the
resolution,the City will support the project proponent in its application to Larimer County and the
competitive statewide balance. The deadline for applications for allocations is January 21, 2000.
BACKGROUND:
One of the Council's top priority work plan goals for since 1995 has been to increase the quality and
affordability of housing. In 1984 the City adopted policies for the issuance of tax exempt bonds
that would acquire, rehabilitate, or maintain the supply of low-income housing. Through the
adoption of Resolution 84-179,specific criteria were set to allow the City the opportunity to pursue
its commitment to affordable housing in accordance with State and Federal legislation and
regulations. Although the project proponent is seeking support for the Project from the State,
CBFA, and Larimer County, the City's support for the Project is crucial, since the Project would
be located in the City. As a general rule, the City, rather than the County, issues private activity
bonds for projects such as this one that will be located within the City. The Concorde Project has
been evaluated according to the criteria for issuance of multi-family revenue bonds set forth in
Resolution 84-179. Below, staff has provided a summary of the project and then the evaluation.
The Project
The Residence at Oakridge Project is planned to be a44-unit assisted living multi-family project in
the southeast part of Fort Collins. The site is located along McMurray Drive in the Oakridge
Business Park ( see the attached map). The project will contain 44 unit, 58 beds. The project is
designed as one-story residential units.
Financing for the project also includes tax credits. The Project may apply for other affordable
housing programs offered by the City, thereby improving the overall financial viability of the
proj ect.
According to the information received from the Project proponents,the tenancy for at least 29(50%
of the Project) of the beds will be affordable for residents making no greater than 60%of the area
median income. The Project proponents have indicated that some of the units maybe reserved at
even lower income levels should the financing and cash flow allow.
Tenant eligibility and proof of meeting the targeted income clientele will be provided for in the and
be regulated by deed restrictions of the tax credit allocation.
February 15, 2000 3 22
Criterion#1
The City's policy requires a minimum of 20%of the units be rented to families at or below 70%of
median income. The state guidelines are more restrictive,requiring at least 40% of the units to be
rented to households at 60% of the area median income. The materials presented for the project
indicate that 50% of the units will be affordable to households at 60% of area median income or
lower. Therefore,the first policy criterion is met by the project.
Criterion#2
For restricted units, the rents must be set at 30% of 70% of median income. The rents for this
project will have 45% of the units' monthly rents set at or below 30% of 60% of area median
income.
The project meets this criterion.
RENT CALCULATIONS
The Residence at Oakridge Project Rent Calculations
The Residence at Oakridge is an assisted living project. Unit sizes and rents are not directly
comparable to typical multi-family apartment projects financed with private activity bonds. The
table below illustrates unit type, size and mix.
Type of Unit Unit Size Number and Type of Number of Set-Aside Market
(#Beds/#Bath) in sq. ft. Units Beds Set-Aside Rent Rent
Medicaid Shared 380 12 24 24 $309 n/a
Private(2/1)
Shared Private 380 2 4 0 n/a $365
(2/1)
Small Private 225 6 6 5 $433 $433
(1/1)
Large Private 330 24 24 0 n/a $605
Based on projected cash flows, staff and the Affordable Housing Board have requested that the
project proponents attempt to reserve a portion of the "set-aside" units for persons with income
lower than 60% of the Area Median Income.
Criterion#3
The City's policy is to request that the owner of the projects provide an additional rent subsidy for
the 20% restricted units. (The rent subsidy is provided in lieu of collection the City's normal
issuance fee.)
February 15, 2000 4 22
This project will have 50%of the beds reserved for persons at 60%of the area median income. In
addition, this project serves the frail elderly population. Because this is not a typical low to
moderate income project, it is difficult to apply the additional rent subsidy policy.
Criterion#4
This criterion requires the use of#2 and#3 to calculate the actual rents for the restricted units. The
proponent has agreed to do so.
Criterion#5
This criterion requires final approval for the project by the Planning and Zoning Board. Further,
any rights for appeal need to have expired. The underlying zoning for the subject property supports
the proposed land use.
Criterion#6
This criterion requires that amenities for the low-income units be the same as other units in the
project. The proponent states that access to complex amenities are open to all residents. All units
will have the same features and quality.
This criterion will be met.
Criterion#7
The owner of the project must meet all Federal and State requirements for the bonds. It is the
applicant's intention to meet all requirements. The bond documents for the project will comply with
the requirements.
This criterion will be met.
Criterion#8
Monitoring of the project management to meet the Federal and State requirements will be assigned
to the bond trustee. Bond documents will be drafted with this stipulation. The term of the rent
restrictions will be 25 years according to the requirements of the Colorado Housing Finance
Authority.
Criterion#9 and#10
These criteria allow the City to deny a project even if all criteria are met or to vary criteria #1
through#4.
Recommendation
Staff recommends adoption of the Resolution as it supports Council's goal of increasing the quality
and affordability of housing and is consistent with the adopted policies for multi-family housing
private activity bonds. The Affordable Housing Board had not completed its recommendation at
February 15, 2000 5 22
the time this packet went to print. Staff will provide the Board's recommendation as soon as it is
• available.
•