BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2560
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          Date of Hearing:   April 21, 2010

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                   AB 2560 (Brownley) - As Amended:  April 14, 2010
           
          SUBJECT  :   Federal tax credit bond volume cap

           SUMMARY  :   Authorizes the California Department of Education  
          (CDE) and the California School Financing Authority (CSFA) to  
          assign and distribute the state's 2010 federal tax credit bond  
          volume cap for qualified school construction bonds (QSCB).   
          Specifically,  this bill  :  

          1)Makes findings and declarations as follows:

             a)   The United States Department of the Treasury released  
               the second allocation authority of $11 billion in federal  
               tax credit volume cap for QSCBs that can be used to lower  
               the cost of financing the construction, rehabilitation or  
               repair of a public school facility or for the acquisition  
               of land where a school will be built;

             b)   California has received $720 million of federal tax  
               credit bond volume cap for QSCBs designated to the state by  
               the federal American Recovery and Reinvestment Act (ARRA)  
               of 2009; and,

             c)   The federal tax credit bond volume cap for QSCBs  
               designated for the state does not constitute federal  
               moneys, federal funds, or funds of any kind.

          2)Authorizes the CDE to assign and distribute the state's 2010  
            federal tax credit bond volume cap for QSCBs to or for the  
            benefit of school districts and county offices of education.

          3)Authorizes the CSFA to assign and distribute the state's 2010  
            federal tax credit bond volume cap for QSCBs to or for the  
            benefit of charter schools, or to be further assigned and  
            distributed to one or more issuers in the state for the  
            benefit of charter schools, as determined by CSFA.

           EXISTING FEDERAL LAW  establishes the ARRA in order to provide  
          funding and other economic stimulus to foster economic recovery  
          among the states.








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           FISCAL EFFECT  :  According to the Assembly and Senate  
          Appropriations Committees of a similar bill, there is no General  
          Fund impact.  

           COMMENTS  :  In February 2009, the federal government passed ARRA,  
          which allocated approximately $100 billion nationwide for  
          education programs with the purpose of stimulating the economy,  
          including $22 billion in tax credits over two years under the  
          QSCB program.  The QSCB program provides savings for school  
          districts issuing local bonds for the construction and  
          renovation of school facilities by lowering or eliminating  
          interest payments.  The federal government will provide federal  
          tax credits for bondholders in lieu of interest normally paid by  
          issuers.  According to the CDE, interest payments typically  
          equal about 50% of the cost of a bond.  The maximum term of a  
          bond using QSCB tax credits is determined by the United States  
          Treasury Department - currently at approximately 15 years.   

          ARRA provides for an allocation to each state based on the  
          state's Title 1 (poor, needy pupils) allocation, 40% of which  
          are allocated directly by the federal government to large school  
          districts and the remaining to be allocated to local educational  
          agencies (LEAs) by the state.  California received a total of  
          $1.3 billion for 2009 and received another $1.3 billion for  
          2010.  Of the amount for 2009 and 2010, $582 million and $547  
          million, respectively, were allocated directly to 11 large  
          school districts and $773.5 and $720 million, respectively, were  
          reserved for school districts, COEs, and charter schools.  

          For the 2009 allocations, $73.5 million of the state's $773.5  
          million allocation was reserved for charter school facilities  
          and administered by the CSFA.  This amount was determined based  
          on charter schools receiving approximately 10% of new  
          construction funding in the last two statewide education school  
          facility bonds.  CDE developed an administrative process for  
          implementing this program, including parameters for  
          participation.  There is not a minimum bond authorization amount  
          in order for LEAs to participate in this program.  LEAs,  
          however, were limited to $25 million in tax credits per  
          authorization cycle.  With requests from 231 school districts  
          applications totaling $3.6 billion in requests for $700 million,  
          the CDE conducted a lottery and allocated tax credits to 43  
          school districts.  The CDE reports that thus far, one district  
          has issued a bond using the QSCB tax credits.  








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          CSFA was granted authority to administer the QSCB program for  
          charter schools due to its existing expertise in administering  
          federal and state funds for charter school facilities.  Similar  
          to CDE, CSFA developed parameters and procedures for this  
          program; the eligibility criteria are similar to criteria used  
          for the Charter School Facility Program.  CSFA received an  
          initial 28 applications from charter schools.  The CSFA  
          guidelines prioritize charters that are deemed "credit worthy"  
          and that are "shovel ready" and awarded $29.2 million in tax  
          credits to six charter schools.  The 22 remaining applicants are  
          being further evaluated by CSFA.  Because charter schools do not  
          have authority to issue bonds, the CSFA will sell the bonds and  
          provide low- or no-interest loans to charter schools. 

          The problem that arose that prompted the introduction of a bill  
          came when school districts, in attempting to sell the bonds,  
          were informed by bond counsels that the federal law contained  
          ambiguity that requires statutory clarification by the state.   
          Specifically, the ARRA authorized "the state" to make federal  
          tax credit allocations, but did not specify which entity in the  
          state is the responsible entity.  As a result, bond counsels  
          refused to issue bond opinions for school districts to sell  
          bonds fearing that a challenge can be made that a school  
          district did not receive the tax credits from a  
          legally-authorized entity.  

          SB 205 (Hancock), Chapter 11, Statutes of 2010, provided the  
          authorization for CDE and CSFA to assign and distribute the 2009  
          tax credits.  This bill provides statutory authority for the CDE  
          and CSFA to administer the QSCB program and assign and  
          distribute 2010 program tax credits.    

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Coalition for Adequate School Housing
          State Superintendent of Public Instruction, Jack O'Connell
          State Treasurer's Office

           Opposition 
           
          None on file
           








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          Analysis Prepared by  :    Sophia Kwong Kim / ED. / (916) 319-2087