BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                    AB 2818


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          Date of Hearing:  May 9, 2016


                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION


                           Sebastian Ridley-Thomas, Chair





          AB 2818  
          (Chiu) - As Amended May 2, 2016


          Majority vote.  Tax levy.  Fiscal committee.  


          SUBJECT:  Property taxation:  community land trust


          SUMMARY:  Presumes that the assessed value of specified  
          dwellings or units and the land on which they are situated is  
          the purchase price of only the dwelling or unit, and that the  
          property tax welfare exemption may apply to property on which  
          specified residences will be constructed, but construction has  
          not yet commenced.  Specifically, this bill:  


          1)Presumes, for lien dates occurring on and after January 1,  
            2017, that the assessed value of an owner-occupied  
            single-family dwelling or owner-occupied unit in a multifamily  
            dwelling, and the land on which the dwelling or unit is  
            situated for its convenient occupation and use by low or  
            moderate income (LMI) households, is the purchase price of the  
            dwelling or unit.










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          2)Presumes, for lien dates occurring on and after January 1,  
            2017, that the assessed value of a dwelling or unit owned by a  
            limited equity housing cooperative (LEHC) or a member-occupant  
            or resident shareholder of the LEHC, and the land on which the  
            dwelling or unit is situated for its convenient occupation and  
            use by LMI households, is the purchase price of the share  
            conveying an exclusive right to occupancy and possession of  
            the dwelling or unit.


          3)Provides, for lien dates occurring on and after January 1,  
            2017, that a property is within the welfare exemption provided  
            by Sections 4 and 5 of Article XIII of the California  
            Constitution if the property is owned and operated by a  
            nonprofit corporation otherwise qualifying for the exemption  
            under Revenue and Taxation Code (R&TC) Section 214, that has  
            as one of its primary purposes the creation and maintenance of  
            permanently affordable single-family or multifamily residences  
            to which both of the following conditions apply:


             a)   All residences on the land are intended for ownership by  
               a qualified owner to be occupied by LMI households as their  
               primary residence, and the land on which the residence is  
               situated is leased by the nonprofit corporation to the  
               qualified owner for the convenient occupation and use of  
               that residence for a renewable term of 99 years; and,


             b)   The residence is subject to affordability restrictions.


          4)Provides, in the case of property not previously designated as  
            open space, that the exemption may not be denied to a property  
            on the basis that the property does not currently include a  
            permanently affordable single-family or multifamily residence  
            in existence or in the course of construction.










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          5)Provides that the exemption is only applicable to a property  
            for no more than five years from the date any affordability  
            restriction is recorded against the property. 


          6)Provides that "affordability restrictions" include, but are  
            not limited to, all of the following:


             a)   A dwelling, unit, or residence that can only be rented,  
               sold, or resold to LMI households for purposes of their  
               principal place of residence;


             b)   The sale or resale price of the dwelling, unit, or  
               residence is determined by a formula that ensures it has a  
               purchase price affordable to LMI households;


             c)   The rent collected from the dwelling, unit, or residence  
               does not exceed the maximum rent allowable to be collected  
               from LMI households;


             d)   There is a purchase option for the dwelling, unit, or  
               residence in favor of the community land trust (CLT)  
               intended to preserve the dwelling or unit as affordable to  
               LMI households;


             e)   Any restriction that ensures the dwelling, unit, or  
               residence is to remain affordable to LMI households by  
               recorded deed, deed restriction, ground lease, covenant,  
               memorandum, or other recorded instrument; or,


             f)   Any restriction in a recorded instrument from which a  
               public agency or official has made a finding that the  
               restriction serves the public interest to create and  








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               preserve the affordability of residential housing for LMI  
               households.  The public agency or official must be one of  
               the following:


                i)     The director of the local housing authority or  
                 equivalent agency;


                ii)    The county counsel;


                iii)   The director of a county housing department;


                iv)    The city attorney; or,


                v)     The director of a city housing department.


          7)Defines "community land trust" as a nonprofit corporation  
            otherwise qualifying for an exemption under R&TC Section 214,  
            that has as one of its primary purposes the creation and  
            maintenance of permanently affordable single-family or  
            multifamily residences to which both of the following  
            conditions apply:


             a)   All residences on the land are sold to a qualified owner  
               to be occupied by LMI households as their primary  
               residence, and the land on which the dwelling or unit is  
               situated is leased by the nonprofit corporation to the  
               qualified owner for the convenient occupation and use of  
               that dwelling or unit for a renewable term of 99 years;  
               and,


             b)   The dwelling or unit is subject to affordability  








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               restrictions.


          8)Defines "limited equity housing cooperative" as having the  
            same meaning as the term in Civil Code Section 817.


          9)Defines "persons and families of low or moderate income" as  
            having the same meaning as the term in Health and Safety Code  
            (H&SC) Section 50093. 


          10)Defines "qualified owner" as either a LEHC or persons and  
            families of LMI.


          11)Defines "purchase price" as the price that does not exceed  
            the sale or resale formula that ensures the dwelling or unit  
            has a purchase price that is affordable to LMI households.


          12)Imposes a state-mandated local program and provides that, if  
            the Commission on State Mandates determines that the bill  
            contains costs mandated by the state, reimbursement for those  
            costs shall be made pursuant to these statutory provisions. 


          13)Provides that no appropriation is made and the state will not  
            reimburse local agencies for property tax revenues lost by  
            them pursuant to this bill.


          14)Takes effect immediately as a tax levy.


          EXISTING LAW:  


          1)Limits the maximum amount of any ad valorem tax on real  








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            property at 1% of full cash value.


          2)Requires property to be reassessed to current fair market  
            value whenever it is purchased, newly constructed, or when  
            ownership changes, with specified exceptions, and provides a  
            rebuttable presumption that the fair market value is the  
            purchase price.


          3)Defines "purchase price" as the total consideration provided  
            by the purchaser or on the purchaser's behalf, valued in  
            money, whether paid in money or otherwise.


          4)Requires county assessors, when determining assessed  
            valuation, to consider the effect on property of the value of  
            any enforceable restrictions against the use of the land,  
            including but not limited to:  


             a)   Zoning restrictions;


             b)   Development controls in accordance with local coastal or  
               protection programs;


             c)   Statutory environmental constraints;


             d)   Hazardous waste land-use restrictions;


             e)   Recorded conservation, trail, or scenic easements;


             f)   Solar-use easements; or, 









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             g)   Recorded contracts with a non-profit corporation granted  
               a welfare exemption for properties intended to be sold to  
               low-income families who participate in a special  
               no-interest loan program.  The contract must restrict use  
               of the land for owner-occupied affordable housing for at 30  
               years, include a deed of trust in favor of the nonprofit  
               corporation to ensure compliance, and be provided to the  
               assessor.  The local housing authority or equivalent agency  
               must also make a finding that the long-term deed  
               restrictions serve a public purpose.  (R&TC Section 402.1)


          5)Authorizes the Legislature to exempt from taxation property  
            used exclusively for religious, hospital, or charitable  
            purposes, as specified.  (California Constitution Article  
            XIII, Section 4(b).)  The Legislature has implemented this  
            "welfare exemption" in R&TC Section 214.  


          6)Grants the welfare exemption to property used exclusively for  
            rental housing and related facilities for lower income  
            households, as defined in H&SC Section 50053, operated by  
            non-profit organizations, as specified.  

          7)Imposes a "certification requirement" for low-income housing  
            owners seeking the welfare exemption.  Specifically, the law  
            requires a project's owner to "[c]ertify that the funds that  
            would have been necessary to pay property taxes are used to  
            maintain the affordability of, or reduce rents otherwise  
            necessary for, the units occupied by lower income households."  
                


          8)Authorizes nonprofit corporations organized and operated for  
            the specific and primary purpose of building and  
            rehabilitating single or multi-family residences to qualify  
            for the welfare exemption when property is acquired rather  
            than when construction commences.  (R&TC Section 214.15.)   








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            Generally, unimproved land is not exempt from when the  
            property is initially acquired through when onsite activity  
            commences, despite plans by the owning entity to build exempt  
            property on vacant land in the future.  


          FISCAL EFFECT:  Unknown.  The State Board of Equalization (BOE)  
          analysis of this bill is pending.


          COMMENTS:  


           1)Author's Statement  :  The author has provided the following  
            statement in support of this bill:


               Non-profits throughout the state have experienced an  
               inconsistent methodology for assessing property taxes for  
               CLT units.  In some cases the units are assessed at the  
               "fair market value" which does not take into consideration  
               the underlying land lease and its restrictions on the  
               resale price.  In other cases homes are assessed somewhere  
               in between market and the actual restricted value with  
               varying explanations for the inconsistency.  The ongoing  
               affordability of CLT homes critically relies on the  
               accurate and fair assessment of the home.  In some cases,  
               the property taxes are nearly double what they should be,  
               particularly when assessed at the market value.  Even 10 to  
               20 percent higher taxes can make these homes no longer  
               affordable, putting the homeowner in jeopardy of  
               foreclosure or unable to properly maintain the physical  
               property.  AB 2818 would create a uniform standard so that  
               CLTs can receive a property tax exemption.  Non-profits  
               purchase existing multi-family structures and land to  
               convert or develop into a CLT.  During the time the  
               non-profit is developing the CLT and obtaining financing,  
               the property can be assessed at the market value.  This can  
               be prohibitive for a non-profit.  AB 2818 would exempt CLTs  








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               from assessment at the full market value during the  
               development process.  Under existing law, CLTs can obtain a  
               welfare exemption after occupancy of a rental property but  
               not before the property is developed.


           2)Arguments in Support  :  Proponents of this bill state:


               California is deep within the throes of an affordability  
               crisis with diminishing opportunities for families of  
               modest means to purchase their own homes.  AB 2818  
               affirmatively responds to our state's shortfall of  
               affordable homeownership opportunities for low-income  
               families, and affords community land trusts the same  
               equitable treatment under California law already extended  
               to more common forms of affordable housing provision.


           3)Community Land Trusts  :  CLTs provide an affordable housing  
            model to help LMI households that may not otherwise be able to  
            purchase a home.  The CLT acquires and develops properties for  
            sale to LMI households, but retains ownership of the  
            underlying land and leases the land to the homeowner for a  
            nominal fee through a long-term ground lease (usually a  
            99-year term).  The home is therefore more affordable because  
            the homeowner is only buying the building and not the land  
            underneath.  If the homeowner decides to sell the property,  
            the home must be resold to another LMI household, and the  
            original owner will only be eligible for a smaller share of  
            its appreciated value.  Since the CLT is the owner of the  
            land, it will be a party to all future sales and enforce  
            resale restrictions.  According to the California Community  
            Land Trust Network, it appears that many CLTs in California  
            also have robust rental portfolios restricted for LMI  
            households.


            A CLT is generally formed as a membership-based, non-profit  








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            organization with a professional staff, led by a  
            member-elected board of directors and funded by land rent  
            fees.  Members include CLT homeowners, neighbors, and other  
            local residents, providing community buy-in over local  
            development.  Many CLTs also provide homeowners with homebuyer  
            education and financial literacy courses.  While a subsidy is  
            often needed to start a CLT, outside funding is no longer  
            necessary once homes are occupied, which provides steady fee  
            revenues, and are resold, which recycles the original subsidy  
            thereby allowing homes to remain permanently affordable.  


            According to the National Community Land Trust Network,  
            virtually all CLT leases pass along the cost of property taxes  
            to the homeowner.  The homeowner is either directly assigned  
            to pay property taxes associated with both the home and  
            underlying land, or is directly assigned to pay property taxes  
            associated with the home and then pays any property taxes  
            associated with the underlying land via its lease fee to the  
            CLT.


           4)Limited-Equity Housing Cooperatives :  Housing co-ops are  
            democratically controlled corporations in which each household  
            owns a share, entitling the member to occupy a unit of  
            housing.  The co-op is usually financed through one mortgage  
            that covers the entire property, with members paying monthly  
            carrying charges to cover mortgage payments and operating  
            expenses, including property taxes.  The co-op model can be  
            used for virtually any type of housing construction covering  
            high-end, mid-range, and affordable developments, but LEHCs  
            are specifically developed to offer permanently affordable  
            homeownership opportunities for LMI households.  Share prices  
            in these co-ops are usually low, member households are limited  
            to owning only one share, and price restrictions are put on  
            the sale of shares to prevent speculative resale and preserve  
            affordability.  










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            Given the similar participatory community-based models of CLTs  
            and LEHCs to provide access to affordable housing for LMI  
            households, it is not uncommon to have LEHC-owned homes  
            situated on CLT-leased land.  Although California law  
            specifies that increases in LEHC share prices cannot exceed  
            10% annually and any profits from the sale of the co-op as a  
            whole must be dedicated to public or charitable entities,  
            existing law does not specify that ownership is limited to LMI  
            individuals.  If this broad scope is inconsistent with the  
            author's intent, amendments should be considered to harmonize  
            the definition of "qualified owner" utilized in this bill. 


           5)Assessment of Restricted Homes  :  Existing law requires every  
            assessor to assess property subject to tax at its full value.   
            In the assessment of land, the assessor must consider the  
            effect of any enforceable restrictions to which the use of  
            land may be subject, such as zoning, easements, environmental  
            restrictions, and recorded contracts with governmental  
            agencies including those outlining affordable housing  
            restrictions.  However, "[a]s a general rule, private parties  
            cannot reduce the taxable value of their property by imposing  
            private encumbrances upon it; only enforceable government  
            restrictions under [R&TC] Section 402.1 are recognized as  
            limiting the full fee simple interest."  (Assessor's Handbook  
            Section 502, ADVANCED APPRAISAL December 1998, Reprinted  
            January 2015, pg. 6).  The inability of private parties to  
            reduce the taxable value of their property through  
            self-imposed private encumbrances has long been recognized by  
            the courts.  (Carlson v. Assessment Appeals Board (1985) 167  
            Cal. App. 3d 1004).


            Last year, AB 668 (Gomez) Chapter 698, Statutes of 2015,  
            provided that specified self-imposed private encumbrances  
            could result in assessments of reduced property taxes if the  
            applicable contract is recorded and provided to the assessor.   
            Authorized contracts are limited to those by a non-profit  
            corporation granted a welfare exemption to sell low-income  








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            families participating in a special no-interest loan program  
            affordable housing, similar to the model utilized by Habitat  
            for Humanity.  As a result, assessors must now consider the  
            non-profit's organization-imposed restrictions when  
            determining a property's assessed valuation.  


           6)How Are CLTs Assessed  ?  According to the author, CLTs in  
            California experience an inconsistent methodology for  
            assessing property taxes.  In some cases, the units are  
            assessed at "fair market value," which does not take into  
            consideration the underlying land lease and restrictions on  
            home resale price.  In other cases, the units are assessed in  
            between the market and restricted value with varying  
            explanations for the inconsistency.  For example, the Oakland  
            CLT (OakCLT) states that while it technically owns the land,  
            "there is no value to the land that it can realize apart from  
            the nominal below-market monthly lease fee ($50/month)  
            collected?the value of the land under an OakCLT home is fully  
            included in the restricted sales price (i.e., $150,000)."  As  
            such, OakCLT believes that the total assessed value  
            (improvements and land) of a CLT property should be based upon  
            the restricted sales price of the home.


           7)Purpose of This Bill - Consistent Assessments  :  This bill does  
            not prescribe the assessment methodology that should be used  
            in valuing a dwelling or unit and the CLT-leased land on which  
            it is situated, but establishes a presumption that the value  
            of the dwelling or unit and the land is the purchase price of  
            the dwelling or unit only, and not the CLT-leased land on  
            which it is situated (or in the case of a dwelling or unit  
            owned by a LEHC, the purchase price of the share conveying  
            exclusive right to occupancy).  However, under existing law,  
            there is already a rebuttable presumption that assessment of  
            fair market value is the property's purchase price.  The  
            reason why the property may be assessed higher than the  
            purchase price is that current law does not allow the assessor  
            to consider the impact of private party enforceable  








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            restrictions.  As such, the Committee may wish to consider the  
            extent to which the standard established by this bill  
            contrasts with existing precedent that requires assessors to  
            consider the effect of restrictions on a property's use, in  
            lieu of specifying what purchase price should be used for  
            assessment purposes, and may not achieve its desired intent.  


            This bill suggests but does not explicitly provide that the  
            specified purchase price presumption is limited to CLTs  
            subject to affordability restrictions via ground leases.   
            Additionally, this bill outlines a number of factors that may  
            constitute applicable affordability restrictions, but does not  
            distinguish between factors that influence purchase or rental  
            price unique to CLTs and factors that establish restrictions  
            with a governmental agency.  For example, the affordability  
            restrictions include either a rule providing that only LMI  
            households can occupy the home or a recorded instrument  
            ensuring LMI affordability, potentially allowing other  
            non-profit housing models aside from CLTs to qualify for the  
            assessment considerations proposed by this bill.  If this is  
            broad scope is inconsistent with the author's intent,  
            amendments should be considered to better identify what  
            non-profit housing models qualify for the welfare exemption  
            proposed by this bill and require certain restrictions to be  
            executed in combination with one another.
                                                                     

           8)Property Tax Welfare Exemption  :  The California Constitution  
            exempts from property taxes, in whole or in part, "property  
            used exclusively for religious, hospital, or charitable  
            purposes and owned or held in trust by corporations or other  
            entities (1) that are organized and operating for those  
            purposes, (2) that are nonprofit, and (3) no part of whose net  
            earnings inures to the benefit of any private shareholder or  
            individual."  With regards to housing owned and used by these  
            nonprofit entities, courts have ruled that this "welfare  
            exemption" applies to uses that are either primary to or  
            incidental to and reasonably necessary for the accomplishment  








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            of the exempt purposes of the organization.  For example, in  
            Cedars of Lebanon Hospital v. County of Los Angeles (1950) 35  
            Cal. 2d 729, the court exempted any housing facility for  
            interns, resident doctors, student nurses, and certain  
            hospital employees deemed essential to the operation of a  
            complete modern hospital on a 24-hour basis.  


            The California Constitution also provides that the welfare  
            exemption applies to "buildings under construction, land  
            required for their convenient use, and equipment in them if  
            the intended use would qualify the property for the  
            exemption."  Generally, a vacant property is not considered  
            being used for a charitable purpose by the non-profit that  
            otherwise qualifies for the welfare exemption, although the  
            exemption would become effective as soon as construction or  
            other activity begins onsite.  However, existing law does  
            provide that non-profits with an affordable housing model  
            similar to that utilized by Habitat for Humanity may qualify  
            for the welfare exemption as soon as the property is acquired  
            and prior to commencement of construction.  In providing  
            special treatment for this affordable housing model, the  
            Legislature issued findings proclaiming that its exempt  
            activities are distinct from other affordable housing  
            providers because its exempt purpose is not to own and operate  
            a housing project on an ongoing basis, but to make housing and  
            the land reasonably necessary for the use of that housing  
            available for prompt sale to low-income residents.  In other  
            words, the Legislature found that the holding of real property  
            for the future construction of housing on that property is  
            central to the affordable housing model's exempt purposes and  
            activities, and therefore constitutes "use."


            Existing law also provides that the welfare exemption also  
            applies to property owned and operated exclusively for rental  
            housing occupied by lower-income households, defined as 30-60%  
            of area median income (AMI).  A proportionate partial  
            exemption is granted if lower-income households occupy only a  








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            percentage of rental housing.  The property must be financed  
            with tax-exempt bonds or government grants with rents of the  
            lower-income households below deed restrictions set by the  
            terms of the financing, financed with low-income housing tax  
            credits (LIHTC), or comprised of at least 90% lower-income  
            households.   Owners must also certify that property tax  
            savings from the exemption are used to "maintain the  
            affordability of, or reduce rents otherwise necessary for, the  
            units occupied by lower income households."


           9)Do CLTs Qualify for the Welfare Exemption  ?  This bill defines  
            "community land trust" as a nonprofit corporation, otherwise  
            qualifying for the welfare exemption, that has as one of its  
            primary purposes creating and maintaining permanently  
            affordable housing.  However, it is not clear that CLTs always  
            qualify for the welfare exemption.  CLTs are a relatively new  
            affordable housing model and exist in a variety of  
            permutations.  Although a CLT will always be the ground lessor  
            of any housing development it manages, and it appears the  
            primary goal is to promote affordable homeownership, many CLTs  
            in California provide rental opportunities in addition to  
            ownership opportunities.  


            Homes owned by individuals or LEHCs on CLT land do not qualify  
            for the welfare exemption.  While LEHCs are nonprofit  
            corporations, they exist solely as a means to hold property  
            and do not serve a charitable purpose.  Generally,  
            facilitating housing for a finite number of people in their  
            own private homes, albeit for LMI households, also does not  
            constitute a charitable purpose.  Rental housing is more  
            complex.  Some CLTs rent units they own directly to tenants  
            while some lease their land to an affordable housing developer  
            that then rents units it owns to tenants.  Under either rental  
            model, the welfare exemption would apply if the property was  
            financed with deed-restricted tax-exempt bonds or government  
            grants or the LIHTC, or served the requisite threshold of  
            lower-income individuals.  Since CLTs also serve  








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            moderate-income households (income that does not exceed 120%  
            AMI), not every CLT rental property qualifies for the  
            exemption in whole or in part.  Accordingly, it is unclear how  
            many CLTs currently qualify for the welfare exemption and the  
            manner in which they may qualify.


           10)Purpose of This Bill - Special Exemption  :  This bill provides  
            that non-profits with affordable housing models similar to  
            CLTs qualify for the welfare exemption and prohibits the  
            exemption from being denied on the basis that the property  
            does not yet have a housing development in use onsite.  The  
            exemption would be effective for five years after  
            affordability restrictions are recorded against the property. 


            Although this bill is modeled on existing law that provided  
            specified affordable housing developments a property tax  
            exemption between the time vacant land is purchased and  
            construction begins, operational differences between the CLT  
            model and the Habitat for Humanity model result in a much  
            broader exemption being granted to CLTs.  In effect, this bill  
            would grant all CLTs a welfare exemption for five years upon  
            recordation of affordability restrictions, or until the unit  
            is sold to a new owner, even if the CLT would not otherwise  
            qualify for an exemption.  Habitat for Humanity is generally a  
            "short-term" holder of property - as soon as property  
            ownership is transferred from the organization to a low-income  
            household, the property is returned to the tax rolls.   
            However, some CLTs maintain ownership of the development and  
            rent units directly to tenants, which may include those of  
            moderate-income who would not ordinarily qualify under the  
            welfare exemption.  Since this bill would grant the welfare  
            exemption to nonprofits that have as one of their primary  
            purposes the creation and maintenance of permanently  
            affordable homes intended for ownership, rental housing  
            traditionally excluded from the exemption would now qualify  
            for it in limited instances.  Even if the unit is immediately  
            resold, the exemption would still have been granted to  








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            construct a unit restricted for purchase by a moderate-income  
            household, representing an expansion of the current exemption.  



            The Committee may wish to consider the precedent set by  
            extending the welfare exemption to more unimproved properties  
            and more households, and whether it may incentivize other  
            taxpayers to seek a similar exemption.  The Committee may also  
            wish to consider whether a five-year exemption is too long of  
            a "grace period" to begin construction, or whether CLTs that  
            do not begin construction after five years must owe deferred  
            property taxes to the county, since initial plans should at  
            least be underway if affordability restrictions must be in  
            place, prior to receiving the exemption.  Finally, as  
            referenced earlier, this bill suggests but does not explicitly  
            provide that the specified welfare exemption is limited to  
            CLTs subject to affordability restrictions via ground leases.   
            This bill also outlines a number of factors that may  
            constitute applicable affordability restrictions, but does not  
            distinguish between factors that influence purchase or rental  
            price unique to CLTs and factors that establish restrictions  
            with a governmental agency.  If this broad scope is  
            inconsistent with the author's intent, amendments should be  
            considered to require certain restrictions to be executed in  
            combination with one another to better identify what  
            non-profit housing models qualify for the welfare exemption  
            proposed by this bill.


           11)Technical Amendments  :  Committee staff suggests adoption of  
            the following amendments:


             a)   On Page 4, Line 29, strike "preserves" and insert  
               "preserve";


             b)   On Page 5, Line 1 and Page 5, Line 37, strike "creating  








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               and maintaining" and insert "creation and maintenance";  
               and,


             c)   On Page 6, Line 20, strike "required" and insert  
               "authorized".


           12)Related Legislation  :  AB 668 (Gomez) Chapter 698, Statutes of  
            2015, requires assessors to consider self-imposed private  
            encumbrances on the value of a property if the contract is  
            executed by a non-profit corporation granted a welfare  
            exemption to sell affordable housing to low-income families  
            participating in a special no-interest loan program and the  
            contract is recorded and provided to the assessor.


           13)Prior Legislation : AB 1559 (Wiggins) Chapter 927, Statutes of  
            1999 provides an extension of the welfare exemption to vacant  
            land in the case of a nonprofit corporation with a charitable  
            purpose to acquire and hold real property for the future  
            construction or rehabilitation of affordable housing for sale  
            at cost to low-income families.


          REGISTERED SUPPORT / OPPOSITION:




          Support


          AMCAL Multi-Housing, Inc.


          Bolinas Community Land Trust










                                                                    AB 2818


                                                                    Page  19





          California Association of Local Housing Finance Agencies


          California Housing Consortium


          Enterprise Community Partners


          Greenlining Institute


          Grounded Solutions Network


          Habitat for Humanity of Orange County


          Housing Land Trust of Sonoma County


          Irvine Community Land Trust


          Oakland Community Land Trust


          Policy Innovation + Justice Project, Dellums Institute for  
          Social Justice


          PolicyLink


          San Diego Community Land Trust


          San Diego Housing Federation









                                                                    AB 2818


                                                                    Page  20






          San Francisco Community Land Trust


          Urban Strategies Council





          Opposition


          None on file





          Analysis Prepared by:Irene Ho / REV. & TAX. / (916) 319-2098