BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                        AB 185


                                                                       Page  1





       Date of Hearing:  April 29, 2015


          ASSEMBLY COMMITTEE ON JOBS, ECONOMIC DEVELOPMENT, AND THE ECONOMY


                                Eduardo Garcia, Chair


       AB 185  
       (Eduardo Garcia) - As Introduced January 26, 2015


       SUBJECT:  Income taxation:  insurance taxation:  credits:  California  
       New Markets Tax Credit


       SUMMARY:  Establishes a five-year $200 million tax credit program to  
       attract new private capital to very low-income neighborhoods in  
       California.  In general, the new state credit parallels the federal  
       New Market Tax Credit (F-NMTC) Program.   Specifically, this bill:   





       1)Establishes the California New Markets Tax Credit (C-NMTC) Program,  
         administered through the Governor's Office of Business and Economic  
         Development (GO-Biz), for the purpose of stimulating private sector  
         investment in lower income communities, as specified.  The bill  
         authorizes GO-Biz to adopt guidelines for implementing the program  
         and provides that these guidelines are exempt from the  
         Administrative Procedures Act. 

       2)Directs the California Alternative Energy and Advanced  
         Transportation Authority to calculate the value of any unused  
         portion of the $100 million in State Sales and Use Tax Exclusion  
         (SUTE) program authority.  









                                                                        AB 185


                                                                       Page  2









       3)Authorizes GO-Biz to award authority to designate qualified equity  
         investments to qualified community development entities (CDEs).  In  
         order to finalize the designation of the qualified equity  
         investment, the qualified CDE obtains cash from a taxpayer in the  
         form of a qualified equity investment.  Once the investment moneys  
         are raised, the CDE submits documentation to GO-Biz verifying that  
         the funds have been obtained.  This process is technically referred  
         to the issuance of the qualified equity investment by the CDE.   
         Following the issuance, the qualified equity investment is available  
         to be deployed in qualified low-income communities in qualified  
         low-income community investments.     



       4)Authorizes GO-Biz, beginning in 2016 and concluding in 2020, to  
         award authority to designate qualified equity investments up to an  
         amount that the resulting tax credits do not exceed $40 million or  
         the unused SUTE authority, whichever is less.  The aggregate amount  
         of qualified equity investments that may be awarded over the  
         five-years of the C-NMTC Program cannot exceed the tax credit value  
         of $200 million.  The value of any undesignated qualified equity  
         investments and recaptured credits may be reissued without affecting  
         these limits, as specified.



       5)Authorizes a 39% tax credit earned over the mandatory seven years  
         that the taxpayer's investment remains under the control of the CDE.  
          The credit may be applied against the taxpayer's personal,  
         corporate, or gross premium insurance tax liability.  No credits may  
         be applied in the first two tax years of the investment.  In tax  
         year three a 7% credit may be applied and in years four through  
         seven an 8% credit may be applied.  [This differs from the F-NMTC,  
         as the bill allows for insurance companies to earn credits for  
         qualified investments made in qualified CDEs and provides for a  








                                                                        AB 185


                                                                       Page  3





         different credit application schedule.  The federal credit allows  
         taxpayers to apply the credit in the first year, as follows:  5% in  
         the first three years and 6% in the final four years.]



       6)Requires that each qualified low-income community investment have a  
         positive revenue impact on the state over a 10-year period relative  
         to the aggregate tax credit utilization over the same 10-year  
         period.   On a case-by-case basis, GO-Biz is authorized to waive  
         this requirement.  The bill also requires GO-Biz to approve one or  
         more nationally recognized revenue impact assessment models for this  
         purpose.
       7)Requires Go-Biz to begin accepting applications on or before May 1,  
         2016, to the extent tax incentive authority is available.  In the  
         first year of the program all allocations shall be awarded in the  
         order that they are received, with all applications received on the  
         same day being considered as having been received simultaneously. If  
         the amount requested exceeds the available authority to designate  
         qualified equity investments, GO-Biz is directed to make awards on a  
         pro-rata basis, as specified.





         In the second to fifth years of the C-NMTC Program, to the extent  
         tax incentive authority is available, at least 60% of the allocation  
         is to be awarded in the order that the applications are received and  
         up to 40% of the allocation may be awarded on a competitive basis.





       8)Requires GO-Biz to develop an allocation process that, at a minimum,  
         includes or addresses the following:










                                                                        AB 185


                                                                       Page  4






          a)   To the extent reasonable and consistent in carrying out the  
            purposes of the C-NMTC, GO-Biz is required to consider timing the  
            state allocation rounds to correspond with the F-NMTC Program;



          b)   Within 20 calendar days of submitting an application for an  
            award to designate a qualified equity investment, GO-Biz is to  
            certify the application's completeness or to identify what  
            additional information is necessary.  The applicant is allowed  
            five days to furnish the missing information;



          c)   Within 20 calendar days of the application being certified as  
            complete, GO-Biz will approve or deny the application for an  
            award to designate the qualified equity investment allocation;



          d)   Within 60 calendar days of GO-Biz sending notice of an award  
            to designate a qualified equity investment, the qualified CDE is  
            required to raise the cash and issue the qualified equity  
            investment, as specified; 



          e)   At the close of the 60 calendar days, any amount less than the  
            total amount of the designated qualified equity investment  
            reverts to GO-Biz for reallocation, as specified;  



          f)   A qualified CDE may transfer all or a portion of its certified  
            qualified equity investment authority to its controlling entity  
            or any subsidiary qualified community development entity of the  
            controlling entity, as specified. The transferee shall be subject  
            to the same rules, requirements, and limitations applicable to  








                                                                        AB 185


                                                                       Page  5





            the transferor;



          g)   A qualified community development entity that issues qualified  
            equity investments must notify GO-Biz of the names of taxpayers  
            that are eligible to utilize tax credits pursuant to this section  
            and any transfer of a qualified equity investment;



          h)   The competitive application process is required to result in  
            an equitable distribution of projects within qualified low-income  
            communities so that low-income community populations across the  
            state are engaged and have an opportunity to benefit from the  
            program;  



          i)   The application for authority to designate qualified equity  
            investments is prohibited from requiring identification of the  
            specific qualified active community development business in which  
            invests will be made; 



          j)   Applicants will have the demonstrate they can meet  
            organizational capacity standards including business strategy,  
            targeted community outcomes, capitalization strategy, and  
            management capacity;  [These standards are consistent with the  
            F-NMTC allocation process]






       9)Requires that priority in the competitive allocation process be  
         given to applications that can demonstrate  that the resulting  








                                                                        AB 185


                                                                       Page  6





         investments will be in:



          a)   Historically underserved communities and result in the  
            greatest benefit to the hardest to serve and undercapitalized  
            lower income populations; or



          b)   Newly established businesses, or in activities that support  
            neighborhood revitalization strategies driven by local grassroots  
            stakeholders in multiple low-income communities across one or  
            more regions or the state for the purpose of scaling economic  
            development activities that compliment regional industry clusters  
            that result in the greatest benefit to the largest number of  
            lower income individuals.





       10)Requires a qualified CDE that issues qualified equity investments  
         to report to GO-Biz within the first five business days after the  
         first anniversary of the initial credit allowance date.  The report  
         shall include documentation that at least 85% of the purchase price  
         in qualified low-income community investments has been made in  
         qualified active low-income community businesses.  Specific  
         documentation will be determined by GO-Biz, but among other things,  
         the bill requires the documentation to include bank statements,  
         evidence that 15% of the investments were deployed in partnership or  
         in consultation with a California CDFI or nonprofit, as specified,  
         and that the investment was determined to have a positive revenue  
         impact on the state, as specified.



       11)Requires annual reporting in the second through seventh years  
         following the issuance of the qualified equity investment on the  








                                                                        AB 185


                                                                       Page  7





         following:



          a)   The social, environmental, and economic impact the qualified  
            equity investment on qualified low-income communities during the  
            report period and cumulatively;



          b)   The amount of money  invested in qualified active low-income  
            community businesses;



          c)   The number of employment positions created and retained and  
            the average annual salary of such positions;



          d)   The number of operating businesses assisted by industry and  
            number of employees;



          e)   Number of owner-occupied real estate projects;



          f)   Geographic location of the assisted businesses; and



          g)   Summary of the outcomes of each of the revenue impact  
            assessments undertaken during the report period.
       12)Defines a qualified community development entity as being certified  
         and remaining in good standing with the U.S. Treasury's Community  
         Development Financial Institution Fund (CDFI Fund), which includes  
         all of the following:








                                                                        AB 185


                                                                       Page  8








          a)   Being a domestic corporation or partnership that has as its  
            primary mission of serving or providing capital for low-income  
            communities or low-income persons;



          b)   Maintaining accountability to residents of low-income  
            communities, as specified; and



          c)   Has entered into an allocation agreement with the CDFI Fund on  
            or after January 1, 2012 that includes California within its  
            service area.



         Consistent with federal law, this bill also recognizes community  
         development financial institutions (CDFIs) and specialized small  
         business investment companies (SBICs) as meeting the requirements of  
         a qualified CDE, if they have also entered into an allocation  
         agreement with the CDFI Fund on or after January 1, 2012 that  
         includes California within its service area.   





       13)Requires at least 15% of qualified equity investments be invested  
         in partnership or in consultation with a CDFI, as defined, or a  
         nonprofit certified by GO-Biz.  Failing to meet this requirement  
         results in 100% recapture of the credits.



       14)Defines a qualified low-income community investment to mean the  








                                                                        AB 185


                                                                       Page  9





         same as the F-NMTC: 



          a)   Any capital or equity investment in, or loan to a qualified  
            low-income business, as defined; 



          b)   Any capital or equity investment in, or a loan to, a real  
            estate project in a low-income community; 



          c)   The purchase of a loan from another CDE that meets the other  
            requirements for a low-income community investment; 



          d)   Financial counseling and other services in support of business  
            activities to businesses and residents of a low-income community;  
            or 



          e)   Any equity investment in, or a loan to, a CDE. 



       15)Defines an equity investment as any stock, other than nonqualified  
         preferred stock, in a corporation or any capital interest in any  
         partnership. 
       16)Defines a qualified active low-income community business as meeting  
         the requirements of federal law with several modifications.  The  
         qualified low-income community business shall:












                                                                        AB 185


                                                                       Page  10






          a)   Have less than 250 employees. [There are no size limitations  
            in F-NMTC]



          b)   Derive less than 15% of its annual revenue from rental or sale  
            of real estate, as specified.  [There are no similar limitations  
            in F-NMTC]



          c)   Be authorized to provide services outside the low-income  
            community, as specified.  [The F-NMTC limits qualifying firms to  
            only those that substantially perform services within a  
            low-income community]



          d)   Be physically located in a census tract that has a poverty  
            rate above 30%, a median income less than 60% of California  
            median income, or an unemployment rate 1.5 times the national  
            average.  [This is the federal definition for severely distressed  
            and is more stringent than the general eligibility of the F-NMTC,  
            which is 20% poverty and 80% median income]



       17)Excludes financial assistance through the C-NMTC to a project that  
         has received funding through the Low-Income Housing Tax Credit.



       18)Excludes any business that operates or derives revenues from the  
         operation of a charter school, country club, or golf course from  
         C-NMTC funding.  The bill also excludes gaming establishments,  
         massage parlors, liquor stores, and sexually oriented business, as  
         defined, from qualifying as an active low-income community business.  
          [There are no similar exclusions in the F-NMTC.  There are,  








                                                                        AB 185


                                                                       Page  11





         however, other state tax credits which have similar limitations  
         including the California Competes Tax Credit.]



       19)Prohibits a taxpayer from taking another state tax credit for the  
         same investment.  
       20)Requires GO-Biz to work with Insurance Commissioner and the  
         Franchise Tax Board on establishing a process for recapturing the  
         credits.  Enforcement of the recapture provisions are subject to a  
         six-month cure period.  In addition to the recapture provisions in  
         federal law, the measure requires 100% recapture of the value of the  
         credit under the following conditions:





          a)   Less than 15% of the issued qualified equity investment is  
            invested in a qualified active low-income community business in  
            consultation or in partnership with a CDFI, as defined, or a  
            nonprofit certified by GO-Biz, as defined; and



          b)   The qualified CDE makes an investment without performing a  
            revenue impact assessment, as specified.



       21)Provides that recaptured credits revert to GO-Biz for reallocation.  
          The reallocation of these credits does not count toward the annual  
         or cumulative allocation limit.  Reallocation of recaptured credit  
         is first awarded to applications that received a pro-rate share of  
         their requested designation amount due to limitations on award  
         authority.  Thereafter, the reallocation process is defined by  
         GO-Biz.










                                                                        AB 185


                                                                       Page  12






       22)Authorizes GO-Biz to set fees to cover the costs for administering  
         the program. All fees are to be deposited in the California New  
         Markets Tax Credit Fund, which is established by this bill. 



       23)Specifies that GO-Biz shall only make a qualified equity investment  
         award to a CDE in a calendar year in which the Legislature  
         appropriates funds in the California New Markets Tax Credit Fund to  
         pay for the cost of administering the program. 



       24)Authorizes a six-year carryforward of any unused tax credits.



       25)) Authorize the Insurance Commissioner and the Franchise Tax Board  
         to prescribe any rules or regulations that may be necessary or  
         appropriate to implement the C-NMTC Program. The bill provides the  
         Insurance Commissioner and the Franchise Tax Board with access to  
         any documentation held by GO-Biz relative to the application and  
         reporting of the qualified CDEs.
       26)Contains a sunset of December 1, 2028.





       27)Contains a severability clause.



       28)Takes immediate effect as a tax levy. 



       EXISTING LAW establishes the CDFI Tax Credit, operated through the  








                                                                        AB 185


                                                                       Page  13





       California Investment Opportunity Network Program, which authorizes a  
       taxpayer to claim a state credit equal to 20% of qualified investments  
       in community development financial institutions. The credit may be  
       used against the taxpayers' personal income tax, corporation tax, and  
       insurance premiums tax for non-interest bearing investments of at  
       least $50,000, which are held for a minimum of 60 months. Total  
       qualified investment for all tax payers are capped at $50 million per  
       year ($10 million in credits).


       EXISTING FEDERAL LAW authorizes a taxpayer to claim a federal tax  
       credit for qualified investments made to qualified CDEs, as specified.  
       The value of the federal NMTC is 39% of the qualified equity  
       investment. The credit is applied by the taxpayer over a seven-year  
       period.


       FISCAL EFFECT:  Unknown


       POLICY ISSUE FRAME:


       Although California demonstrates policy leadership regarding the  
       future of its economy in areas that emphasize our state's role as a  
       technology giant, a leader in environmental sustainability, a  
       significant participant in global supply chains and as a driver for  
       middle-skill workforce development, California remains short on one  
       crucial piece. Equity remains unaddressed. Addressing inequity rooted  
       in race and geography requires public policy solutions that bring  
       market opportunity to the level of the neighborhood and integrate  
       low-income neighborhoods with their regional economies. Markets must  
       be engaged on matters of economic and place-based inequity if the  
       state wishes to achieve a truly prosperous future. These issues will  
       hold back that future if they remain ignored or inadequately  
       addressed.











                                                                        AB 185


                                                                       Page  14







       This measure proposes a program for delivering private capital to very  
       low-income neighborhoods in a manner that incentivizes investors and  
       empowers these communities in an innovative way.





       The Comment section of this analysis includes a discussion of how the  
       NMTC may address the state's increasing income disparities, challenges  
       businesses face in accessing capital, background on the F-NMTC  
       Program, reports and assessments of the federal program, and examples  
       of NMTC programs in other states.  Comment 7 includes a discussion of  
       the opposition's concerns relative to the F-NMTC Program and other  
       state credits.





       COMMENTS:  


       1)Economic Justice: Research shows that the inequality between the  
         residents in low-income communities and those that reside in  
         California's most affluent communities has dramatically increased in  
         the past several decades. For example, the average  
         inflation-adjusted income of the top 1% of California's taxpayers  
         increased by 50.2% between 1987 and 2009 - from $778,000 to $1.2  
         million. In contrast, the average income of taxpayers in each of the  
         bottom four-fifths of the income distribution lost purchasing power.  
         This economic disparity has significant social and economic  
         ramifications for everyone in the state and directly challenges the  
         state's global competitiveness and long-term economic success.

         Programs like the NMTC program proposed in this measure are based on  
         the economic principle that targeting significant incentives to  








                                                                        AB 185


                                                                       Page  15





         lower income communities allows these communities to more  
         effectively compete for new businesses and retain existing  
         businesses, which results in increased tax revenues, less reliance  
         on social services, and lower public safety costs. Residents and  
         businesses also directly benefit from these more sustainable  
         economic conditions through improved neighborhoods, business  
         expansion, and job creation.

       2)Challenges to Accessing Capital: Access to debt and equity financing  
         is critical for promoting the efficient operation and expansion of  
         small businesses. Small businesses rely on adequate short-term  
         (working capital) and long-term debt as well as equity financing to  
         purchase new equipment, replenish inventories, fund ongoing  
         operations, and market their services long before those activities  
         generate revenue. While financial institutions routinely extend  
         working capital and long-term debt products to established, larger  
         businesses, smaller businesses are often bypassed because they lack  
         the collateral and threshold operating and revenue generating  
         history of larger businesses.

         The same dynamic occurs when small businesses attempt to access  
         equity financing, with investment funds often bypassing smaller  
         businesses because they lack the operating history and revenue  
         generating track record of larger businesses. The situation often  
         results in a "chicken or the egg" scenario whereby businesses are  
         told they need to grow in order to access financing, while at the  
         same time being denied access to the financing they need to grow.    
         AB 185 would support the development of new capital resources for  
         businesses in low-income neighborhoods.

       3)Federal New Market Tax Credit Program: Congress enacted the NMTC  
         with the Community Renewal Tax Relief Act of 2000 for the purpose of  
         stimulating equity investments in low-income communities. Under the  
         program, CDE's and CDFIs apply to the U.S. Treasury's CDFI Fund, for  
         an allocation of federal tax credits, which the CDE can then offer  
         to individual and corporate investors in exchange for making an  
                                                                                  equity investment in the CDE or its subsidiary.

         In this way, the CDE serves as a community and financial  








                                                                        AB 185


                                                                       Page  16





         intermediary between sources of private capital and low-income  
         communities. The value of the federal credit to the investor is 39%  
         of the original investment amount, claimed over a period of seven  
         years (5% for each of the first three years, and 6% for each of the  
         remaining four years). The investment in the CDE cannot be redeemed  
         before the end of the seven-year period.

         The CDFI Fund received $19.9 billion in applications for the $5  
         billion available in 2014 credit allocation round.  Over 260  
         applications were submitted from CDEs, CDFIs, and SBICs,  
         headquartered in 44 states, the District of Columbia, Guam, and  
         Puerto Rico.  Since its inception, The CDFI Fund has made 836 awards  
         allocating a total of $40 billion in NMTC authority to CDEs through  
         its competitive application process. This $40 billion includes $3  
         billion in Recovery Act Awards and $1 billion of special allocation  
         authority to be used for the recovery and redevelopment of the Gulf  
         Opportunity Zone.

         The Obama Administration is proposing to permanently reauthorize the  
         F-NMTC program in 2016 with a $5 billion allocation authority per  
         year.  Several Members of Congress have introduced legislation to  
         also permanently extend the NMTC Program, which expired December 31,  
         2014.  In its analysis of AB 185, the Franchise Tax Board states  
         that an extension of the F-NMTC Program is generally expected.

         Supporters of the bill have expressed concern that California has  
         not received its fair share of federal NMTC allocations. States that  
         regularly receive larger shares have parallel state tax credit  
         programs or other resources that encourage community development  
         within lower income communities. In 2012, 29 California CDEs  
         received federal NMTC allocations totaling $17 million. Individual  
         allocations range from $1.4 million for the Northern California  
         Community Loan Fund to $100,000 to the Women's Economic Ventures of  
         Santa Barbara. 

         Since the program's inception, California-based CDEs, CDFIs, and  
         SBICs have received 85 F-NMTC awards for a total of $3.5 billion.   
         While that may seem like a considerable amount of money, it  
         represents less than 10% of funds.  As California represents over  








                                                                        AB 185


                                                                       Page  17





         12% of the population, it has 16% of individuals living under the  
         federal poverty line, and 24.4% of individuals living below the  
         supplemental poverty rate that includes, among other things, the  
         cost of shelter.  In 2014, California-based CDFIs or CDEs received 8  
         awards for a total of $293 million (5.8%).  

         Compounding the impact of less than equitable F-NMTC allocations, is  
         that not every California-based CDE, CDFI, or SBIC uses the money  
         raised through the federal credit in the state where they are  
         headquartered.  In fact, there are over 100 CDEs that have national  
         service areas.  New Markets Tax Credits are designed to attract  
         private capital to very low-income neighborhoods including money  
         from national investment pools.  The federal General Accounting  
         Office reports that the presence of the federal credit attracts  
         capital for projects that may otherwise be overlooked.

         In its August 2014 report, the U.S. Treasury reports that there is  
         over $4 billion in capital raised through federal New Markets Tax  
         Credits that has not been deployed.  Of those CDEs with nationwide  
         service areas, the report shows that over $2.4 billion of these  
         funds are with community development entities (CDEs) with national  
         service areas.  These national CDEs prefer making investments in low  
         income neighborhoods located in states with their own NMTC Program.

       4)Other State New Market Tax Credits: Since the inception of federal  
         NMTC, 14 other states have enacted matching programs to help  
         leverage more federal dollars in NMTC investments including: Ohio,  
         Florida, Missouri, Louisiana, Mississippi, Kentucky, Illinois,  
         Oklahoma, and Connecticut. According to information provided by the  
         author's office, several of these states have experienced a return  
         on investment of 13 to 1. In addition, the author states:

          a)   In Missouri, in the first two years the state New Markets Tax  
            Credit paid for itself, bringing in more in additional investment  
            dollars than was allocated in state funds for the entire  
            seven-year period.

          b)   In Illinois, federal allocations of NMTC funds more than  
            doubled after the Legislature implemented a matching state  








                                                                        AB 185


                                                                       Page  18





            program in 2008. In the first year of implementation, allocations  
            jumped to $875 million. Prior to the 2008 law, federal  
            allocations never exceeded $400 million.

          c)   Most recently, the Georgia General Assembly passed a New  
            Markets Tax Credit bill in March 2015, which is currently in the  
            process of being reconciled before being sent to Georgia Governor  
            for signature.   The latest version of the bill calls for a 55%  
            state credit with a $4 million per-development cap and a $100  
            million statewide cap. It does not state a sunset date.  Similar  
            to AB 185, investments in qualified active low-income community  
            businesses are limited to businesses having fewer than 250  
            employees and the businesses cannot make more than 15% of their  
            income from real estate, whether in rents or sales.

       5)NMTC Research Findings: Over the years the F-NMTC Program has been  
         reviewed and evaluated by a number of sources including the  
         Government Accountability Office (GAO), Pacific Community Ventures;  
         and the Urban Institute.   
         In 2010, the GAO released one of several statutorily mandated  
         reports on the New Market Tax Credit program that found:

          a)   Since 2003, NMTC investments totaling $26 billion have been  
            made in all 50 states, the District of Columbia and Puerto Rico.

          b)   NMTCs are often used as "gap financing," accounting for a  
            portion of total project costs. 

          c)   NMTC investments in low-income community businesses generally  
            use leveraged structures, where equity is left in the businesses,  
            or subsidized loan structures, where below market interest rate  
            loans are offered.



         According to a January 2011 case study prepared by Pacific Community  
         Ventures on the NMTC program, Impact Investing: A Framework for  
         Policy Design and Analysis:









                                                                        AB 185


                                                                       Page  19





         "Through 2009, CDEs made more than $16 billion in NMTC investments  
         in low income communities. Approximately 95% of NMTC funds are  
         invested in designated areas of distress. For every dollar of  
         forgone tax revenue, NMTC leverages $12-$14 of private investment."

         In 2013, the Urban Institute released a report on the first four  
         years of the program (2002-2006).  This was the first independent  
         evaluation of the F-NMTC program requested by the CDFI Fund:

          a)   The vast majority of qualified active low-income community  
            businesses (93%) either could not otherwise have obtained  
            financing or, compared with other available financing, received  
            better rates and terms in conjunction with F-NMTCs.

          b)   77% of projects increased payroll, property, sales, corporate,  
            or other taxes to the benefit of the local community

          c)   60% of projects saw an increase in their employment levels of  
            more than 33% compared with pre-NMTC levels,

       1)July 2014 Report from the Government Accountability Office:  In the  
         summer of 2014, the GAO issued a special report at the request of  
         U.S. Senator Tom Coburn (R-OK) regarding the F-NMTC Program.  The  
         report was critical of the complexity of the projects and the lack  
         of consistent reporting.  More specifically, the report made the  
         following findings:

          a)   Investments have become more complex and less transparent over  
            time.  One reason is the practice of combining New Market Tax  
            Credits (NMTCs) with other government assistance.  While the GAO  
            agrees that this can help finance projects that would not  
            otherwise be economically viable, it raises questions about  
            whether some amount of these additional subsidies are  
            unnecessary.

          b)   The increasingly complex financial structures may also be  
            masking investors' actual rates of return.  The GAO is concerned  
            that the return on investment (ROI) may be above market and cite  
            a 24% ROI reported by one investor.  The GAO reports that the IRS  








                                                                        AB 185


                                                                       Page  20





            and U.S. Treasury have the authority, but have not updated  
            guidance to reflect the inclusion of other government resources.

          c)   GAO also recommends that the CDFI Fund collect additional data  
            on fees and other charges collected by the CDEs.  Finally, the  
            GAO report expresses concern over the lack and quality of data on  
            equity remaining with the business in low-income areas and  
            failure rates of NMTC projects.

         In conclusion, the GAO recommended the U.S. Treasury issue further  
         guidance to ensure:

          a)   Appropriate means for combining the F-NMTC with other  
            government programs;  

          b)   Adequate controls to limit the risks of unnecessary  
            duplication and above-market rates of return;

          c)   That more complete and accurate data are collected on fees and  
            costs, the equity remaining in the business after 7 years, and  
            loan performance; and 

          d)   That the CDFI Fund issues instructions to clarify the  
            reporting of loan performance and making the reporting of that  
            data mandatory.

         The U.S. Treasury agreed with GAO's recommendations to improve data  
         collection on loan performance and equity remaining with the  
         low-income business.  The GAO also established a working group in  
         response to the report to consider the other recommendations.  

       1)Opposition Position:  AB 185 is opposed by the California Tax Reform  
         Association based, in part, on the GAO report and Senator Coburn's  
         own report which expressed the concern that the F-NMTC Program  
         overly rewards investors and raises questions as to the ultimate  
         beneficiary of the program.  In two examples, the opposition letter  
         quotes the GAO report to say, "62% of NMTC projects received other  
         federal, state, or local government assistance from 2010 to 2012?and  
         found one investor apparently earning a 24% rate of return."








                                                                        AB 185


                                                                       Page  21






       2)Author Response to GAO Report:  The GAO report focuses on NMTC  
         investments between 2010 and 2012.  Although this would be the most  
         recent program data, it also represents the height of the global  
         recession.  With global capital markets frozen, public policy  
         makers, including the President and the U.S. Congress, were taking  
         drastic actions to substitute public moneys where previously there  
         would have been private funds.  Most notably, the federal government  
         passed the Stimulus Package (2009) and the Small Business Jobs Act  
         (2011).  The GAO report is absolutely silent on the potential  
         economic impact of the assessment period on either the complexity of  
         the financial structures or on the increase in the use of other  
         government programs.  The author also noted that AB 185 includes a  
         number of tighter controls on accountability, reporting, and  
         prohibits a taxpayer from claiming another state credit for the same  
         C-NMTC investment.

       3)Related Legislation:  Below is a list of bills from prior sessions.

          a)   AB 1399 (Medina and V. Manuel Pérez) State New Market Tax  
            Credit:   This bill authorizes  the creation of a New Markets Tax  
            Credit for qualified investments made in low income communities  
            beginning in the 2015 tax year.  The NMTC Program will be  
            administered through the Governor's Office of Business and  
            Economic Development.  The bill authorizes $40 million in tax  
            credits over a five-year period for a total program of $200  
            million in credits.  Total private investment raised is estimated  
            at $512 million.  Tax credit authority comes from the  
            reallocation of the unused portion of the State Sales and Use Tax  
            Exclusion Program.  Status:  Vetoed by the Governor.  In his veto  
            message the Governor states, "This bill creates a new market tax  
            credit that will cost - over time - $200 million.  I certainly  
            endorse programs that result in private investments to help low  
            income areas, but a bill to spend this much should be considered  
            with other priorities during the annual budget."

          b)   AB 305 (V. Manuel Pérez) State New Market Tax Credit:   This  
            bill would have authorized the creation of a New Markets Tax  
            Credit for qualified investments made in low income communities  








                                                                        AB 185


                                                                       Page  22





            beginning in the 2013 tax year.  The NMTC Program would have been  
            administered through the California Tax Credit Allocation  
            Committee.  The bill authorized $30 million in tax credits over a  
            seven-year period for a total program of $200 million.  Tax  
            credit authority came through the elimination of the  
            underutilized Small Business New Hire Credit.  Status:  Held in  
            the Assembly Committee on Appropriations in 2013.

          c)   AB 2037 (Davis and V. Manuel Pérez) State New Market Tax  
            Credit:  This bill would have authorized the creation of a New  
            Markets Tax Credit for qualified investments made in low income  
            communities beginning in the 2011 tax year.   The NMTC Program  
            would have been administered through the California Tax Credit  
            Allocation Committee.  Tax credit authority came through the  
            elimination of the underutilized Small Business New Hire Credit.   
            Status:  Held in the Assembly Committee on Appropriations in  
            2011.

          d)   AB 643 (Davis and V. Manuel Pérez) State New Market Tax  
            Credit:  This bill would have created a New Markets Tax Credit  
            for qualified investments made in low income communities  
            beginning in the 2012 tax year.   The State Treasurer's Office  
            would administer the new credit program and allocate credits of  
            up to $50 million per year for a total amount equal to $300  
            million over six years.  Status:  Held in the Assembly Committee  
            on Appropriations in 2012.

          e)   SB 1316 (Romero) State New Market Tax Credit:  This bill would  
            have authorized the creation of a New Markets Tax Credit for  
            qualified investments made in low income communities beginning in  
            the 2011 calendar year.  The State Treasurer's Office would  
            administer the new credit program and allocate credits in an  
            amount equal to the estimated revenue gains resulting from the  
            temporary elimination of specified like-kind property exchanges.   
             Status:  Died on the Senate inactive file in 2010.

       1)Double Referral:  The Assembly Rules Committee has referred this  
         measure to the Assembly Committee on Jobs, Economic Development and  
         the Economy and to the Assembly Committee on Revenue and Taxation  








                                                                        AB 185


                                                                       Page  23





         (R&T).  Should this measure pass the committee, it will be referred  
         to R&T for further policy consideration.
       
       REGISTERED SUPPORT / OPPOSITION:


       Support


       Advantage Capital Partners 


       Bay Area Council 


       Business Council of San Joaquin County


       California Association for Local Economic Development 


       California Association for Micro Enterprise Opportunity 


       California Bankers Association


       California Communities United Institute 


       California Urban Partnership


       Capital Impact Partners 


       East Bay Leadership Council










                                                                        AB 185


                                                                       Page  24





       Enhanced Capital 


       Fresno Community Development Financial Institution 


       Fresno Economic Opportunities Commission 


       Genesis LA Economic Growth Corporation 


       Greater Fresno Area Chamber of Commerce


       Indian Wells, City of


       Inland Empire Economic Partnership


       Joint Venture


       League of California Cities 


       Long Beach Area Chamber of Commerce


       Los Angeles Area Chamber of Commerce


       Los Angeles County Economic Development Corporation 


       North Bay Leadership Council










                                                                        AB 185


                                                                       Page  25





       Northern California Community Loan Fund 


       Oakland Metropolitan Chamber of Commerce 


       Opportunity Fund 


       Orange County Business Council


       Sacramento Metro Chamber of Commerce


       San Diego Economic Development Corporation


       San Diego Regional Chamber of Commerce


       San Francisco Chamber of Commerce 


       San Gabriel Valley Economic Partnership 


       San Jose Silicon Valley Chamber of Commerce


       Silicon Valley Leadership Group


       Small Business California 


       TELACU










                                                                        AB 185


                                                                       Page  26








       Opposition


       California Tax Reform Association


       


       Analysis Prepared by:Toni Symonds / J., E.D., & E. / (916) 319-2090