BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1979
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          CONCURRENCE IN SENATE AMENDMENTS
          AB 1979 (Nazarian)
          As Amended  August 5, 2014
          Majority vote
           
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          |ASSEMBLY:  |73-0 |(May 8, 2014)   |SENATE: |35-0 |(August 18,    |
          |           |     |                |        |     |2014)          |
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           Original Committee Reference:    ED.

          SUMMARY  :  Expands the definition of "project" under the  
          California School Finance Authority (CSFA) Act (Act) to include  
          the reimbursement for the costs of acquisition, construction,  
          expansion, remodeling, renovation, improvement, furnishing, or  
          equipping of an educational facility to be financed or  
          refinanced; expands the authority to use the intercept repayment  
          method to include other bond-related costs, and consolidates the  
          caps on the total amount of revenue bonds that may be issued and  
          outstanding at any time under the Act.  

           The Senate amendments  :

          1)Require the reimbursement from bond proceeds to comply with  
            federal tax law in accordance with an opinion of counsel that  
            supports special treatment under federal tax law for the bonds  
            issued for the applicable financing or refinancing.

          2)Add language modifying the provisions that outline conditions  
            to be met by a school district, charter school, county office  
            of education, or community college district electing to  
            guarantee or provide for payment of bonds and related  
            obligations through the intercept repayment mechanism under  
            the Act.  Specifically, this bill:

             a)   Expands the costs which may be covered via the intercept  
               repayment method to include payment on authority bonds,  
               payments under credit enhancement or liquidity support  
               agreements and amounts pledged or assigned under these  
               agreements, payments to fund reserves for these items, fees  
               and charges, and any other costs necessary or incidental to  
               financing or refinancing activity under the Act. 

             b)   Modifies the process to be followed by a borrower in  








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               order to initiate the intercept repayment method to reflect  
               current practice. 

             c)   Establishes the rules by which the State Controller  
               (Controller) shall conduct the intercept and provides that  
               the Controller may rely on the requests for intercept made  
               by investors, bondholders, trustees, borrowers, and credit  
               providers without liability if these requests are made in  
               compliance with the bill's provisions.  

             d)   Establishes the following new authorities for the CSFA:

               i)     Authorizes the CSFA to require participation in the  
                 intercept repayment under the terms of  
                 financing/refinancing under the Act.

               ii)    Authorizes the CSFA to impose limits on new  
                 participation in the intercept repayment process.
               iii)   Authorizes the CSFA to require school districts,  
                 county offices of education, charter schools, and  
                 community college districts to apply to CSFA in order to  
                 participate in the intercept repayment process.

             e)   Declares that these provisions do not obligate the State  
               of California to provide additional appropriations to fund  
               debt service obligations beyond those specifically  
               designated for apportionment to the participating school  
               district, charter school, county office of education, or  
               community college district. 

          3)Add language eliminating the distinction in the cap between  
            revenue bonds issued and outstanding under the Act and the cap  
            on the total amount outstanding for purposes of the intercept  
            repayment mechanism, and consolidates these caps into a single  
            total amount of revenue bonds that may be issued and  
            outstanding at any time under the Act.  Specifically, this  
            bill:

             a)   Eliminates the $4 billion cap on the amount of bonds  
               outstanding for purpose of the intercept repayment  
               mechanism. 

             b)   Eliminates the $400 million cap on the total amount of  
               revenue bonds that may be issued and outstanding at any  
               time for any purpose under the Act.  








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             c)   Caps the total amount of revenue bonds that may be  
               issued and outstanding under the Act at $4.4 billion.

          4)Add double jointing language to avoid chaptering out  
            provisions contained in SB 971 (Huff) of the current  
            legislative session.  

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, pursuant to Senate Rule 28.8, negligible state costs.  
           

           COMMENTS  :  The CSFA was established as a conduit to secure  
          financing for working capital and facilities projects for school  
          districts, charter schools and community college districts.  The  
          CSFA operates under the State Treasurer's Office, who is the  
          sponsor of this bill.  According to the Treasurer's Office,  
          because school districts and community colleges are able to  
          issue general obligation bonds on their own, the CSFA has  
          provided financing mostly to charter schools.  Over the last  
          four years, CSFA has issued $279.6 million bonds for 120 charter  
          school facilities.  Charter schools are the obligor and make  
          bond payments through an intercept process whereby the State  
          Controller intercepts or redirects state funds allocated to  
          charter schools to make bond payments.  According to the CSFA,  
          bonds are typically sold to large institutional investors, with  
          interest rates ranging between 4.19% to 7.58% over the last four  
          years.  

          Under the CSFA Act, "project" is defined as the acquisition,  
          construction, expansion, remodeling, renovation, improvement,  
          furnishing, or equipping of an educational facility to be  
          financed or refinanced.  According to the Treasurer's Office,  
          "when borrowers embark on a bond sale to fund a capital project,  
          the governing board of the entity adopts an inducement  
          resolution that starts the clock on the project.  The resolution  
          enables the entity to begin to incur project-related expense and  
          pay for these expenses out of existing operating or other  
          funding sources and reimburse itself with bond proceeds once the  
          bonds are sold.  Almost all financings issued through CSFA  
          utilize this resolution to begin work on projects in advance of  
          bonds closing with the expectation that costs will be reimbursed  
          once the sale of bonds takes place."  

          When bonds are issued, the Attorney General (AG), who serves as  








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          the legal counsel for the CSFA, provides an issuer's opinion to  
          protect the CSFA in the bond sale.  The AG's Office opined last  
          year that the CSFA Act authorizes the proceeds of bond funds to  
          be used for financing or refinancing of projects, but does not  
          expressly provide authority to reimburse borrowers for costs  
          incurred prior to issuance of the bond.  

          This bill expands the definition of "project" to include the  
          reimbursement for the costs of acquisition, construction,  
          expansion, remodeling, renovation, improvement, furnishing, or  
          equipping of an educational facility to be financed or  
          refinanced.  This language is consistent with the authority  
          provided to other boards, commissions and authorities under the  
          Treasurer's Office, such as the California Health Facilities  
          Financing Authority, the California Educational Facilities  
          Authority, and the California Pollution Control Authority.  

          In light of the AG's opinion, the AG's Office stopped providing  
          legal opinions on bonds, and the Treasurer's Office has retained  
          outside counsel.  This has resulted in higher costs to the  
          borrowers due to much higher fees charged by outside counsel  
          (e.g., $170 per hour for the AG and $500/hour for outside  
          counsel).  The Treasurer's Office states that any savings  
          derived from this bill could be better used for classroom  
          purposes.    

          Amendments adopted in the Senate make changes to the intercept  
          process.  According to the sponsor, the AG has interpreted  
          current law as authorizing the intercept process to be used only  
          to service debt payments and not for other bond-related costs.   
          This bill authorizes an optional intercept to be used for other  
          costs associated with bond financing such as bond counsel and  
          underwriting costs, making this financing more attractive to  
          borrowers and investors. 

          Amendments adopted in the Senate also consolidate the caps on  
          the amount of debt authorized to be issued.  Current law divides  
          CSFA's maximum bond authority into two categories:  $400 million  
          for debt that is not intercepted and $4 billion for debt that is  
          intercepted.  According to the Treasurer's Office, CSFA has  
          issued approximately $295 million in charter school debt over  
          the last three years, of which, only one financing for $7  
          million did not use the intercept method.  In addition, the  
          Treasurer's Office reports that the intercept repayment option  
          is typically preferred, if not required, by potential investors.  








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           This bill combines both categories of debt under a single cap,  
          authorizing a total of $4.4 billion in bonds, regardless of the  
          repayment method, in recognition of the current environment at  
          CSFA with respect to charter school financings.  


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



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