HomeMy WebLinkAbout2014-351 1 RESOLUTION NO. 2014-351
2 RESOLUTION OF THE MAYOR AND COMMON COUNCIL OF THE
CITY OF SAN BERNARDINO ACTING AS THE SUCCESSOR AGENCY
3 TO THE SAN BERNARDINO REDEVELOPMENT AGENCY APPROVING
4 THE RECOGNIZED OBLIGATION PAYMENT SCHEDULE 14-15A FOR
THE PERIOD OF JULY THROUGH DECEMBER 2014 AND APPROVING
5 CERTAIN RELATED ACTIONS (#3506)
6 WHEREAS, pursuant to Health and Safety Code ("HSC") § 34172 (a)(1), the
7 Redevelopment Agency of the City of San Bernardino was dissolved on February 1, 2012; and
8 WHEREAS, consistent with the provisions of the HSC, the Mayor and Common Council
9 of the City of San Bernardino previously elected to serve in the capacity of the Successor Agency to
10 the Redevelopment Agency of the City of San Bernardino (the "Successor Agency"); and
11 WHEREAS, the Oversight Board for the Successor Agency ("Oversight Board") has been
12 established pursuant to HSC § 34179 to assist in the wind-down of the dissolved redevelopment
13 agency; and
14 WHEREAS, per HSC § 34177 (1)(1), the Successor Agency is required to prepare a
15 Recognized Obligation Payment Schedule ("ROPS") before each six-month fiscal period, which
16 corresponds to equal halves of a fiscal year (i.e., July through December and January through June);
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18 WHEREAS, a ROPS is the basis for the Successor Agency's authority to make payments
19 due for enforceable obligations ("EOs"); and
20 WHEREAS, each ROPS must also be approved by the Oversight Board and is reviewable
21 by the County Auditor-Controller, the County Administrative Officer, the California Department of
22 Finance ("DOF") and the California State Controller's Office; and
23 WHEREAS, on March 12, 2014, the Oversight Board adopted Resolution SBOB/2014-05,
24 approving ROPS 14-15A; and
25 WHEREAS, the ROPS 14-15A, which is appended to this Resolution as Exhibit "A";
26 included $28,221,443-worth of EOs, of which $821,984 represented the administrative allowance,
27 and $2,309,001 of non-RPTTF; and
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I WHEREAS, over an eight (8) week period following the filing of ROPS 14-15A,
2 Successor Agency representatives responded to DOF staff inquiries, provided them with supporting
3 and amending information (some of which was developed by third parties, e.g., US Bank, the
4 Successor Agency's bond trustee), participated in several conference call meetings, attended a meet
5 and confer meeting with DOF staff in Sacramento; and
6 WHEREAS, on May 16, 2014, the DOF issued their final determination letter, which is
7 appended to this Resolution as Exhibit`B"; and
8 WHEREAS, the DOF's May 16, 2014 letter: i) denied seven (7) EOs worth $11,282,792
9 (i.e., EO Nos. 82, 85, 87, 95, 102, 113 and 114), ii) denied $344,523 of the requested administrative
10 allowance; iii) modified or reclassified a portion of seven (7) EOs (i.e., EO Nos. 7, 10, 12, 13, 99,
11 100 and 105) in the amount of$201,294; iv) retroactively denied $5,858,914-worth of RPTTF of
12 which the Successor Agency actually spent $5,815,258 during prior ROPS periods as a "Prior
13 Period Adjustment"; and v) authorized the distribution of$10,533,920 of RPTTF to the Successor
14 Agency, of which $477,461 represents the administrative allowance; and
15 WHEREAS, on May 29, 2014, the County Auditor-Controller forwarded the Successor
16 Agency a check in the amount of$10,533,920, which is the RPTTF authorized by DOF for ROPS
17 14-15A; and
18 WHEREAS, in addition to available RPTTF, the Successor Agency is also able to apply
19 $5,068,569 of other funding, which consists of: i) funds for debt service that are either from
20 contributions from third parties or from Federal Direct Payments; and ii) fund balance and scheduled rent
21 receipts from active use properties that are to be used for property maintenance purposes; and
22 WHEREAS, therefore, the sum of RPTTF and other funds available for use during ROPS 14-15A
23 equals $15,602,489, which is $11,618,954 less than the Successor Agency requires to meet its
24 enforceable obligations during ROPS 14-15A; and
25 WHEREAS, due to the shortfall in RPTTF, by necessity the Successor Agency must
26 allocate the use of its available funds in a responsible way consistent with HSC § 34183 (a)(2),
27 ensuring that current debt service obligations are the highest priority for payment; and
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I WHEREAS, consistent with the immediately foregoing recital, staff has prepared a plan
2 for the Successor Agency's use of RPTTF and non-RPTTF for ROPS 14-15A, as depicted in
3 Exhibit "C"to this Resolution; and
4 WHEREAS, this Resolution has been reviewed with respect to applicability of the
5 California Environmental Quality Act ("CEQA"), the State CEQA Guidelines (California Code of
6 Regulations, Title 14, §§ 15000 et seq., hereafter the "Guidelines"), and the City's environmental
7 guidelines; and
8 WHEREAS, this Resolution is not a "project" for purposes of CEQA, as that term is
9 defined by Guidelines § 15378, because this Resolution is an organizational or administrative
10 activity that will not result in a direct or indirect physical change in the environment, per §
11 15378(b)(5) of the Guidelines; and
12 WHEREAS, all of the prerequisites with respect to the approval of this Resolution have
13 been met.
14 NOW, THEREFORE, by be it resolved by the Successor Agency to the Redevelopment
15 Agency of the City of San Bernardino, as follows:
16 Section 1. The foregoing recitals are true and correct and are a substantive part of this
17 Resolution.
18 Section 2. The Successor Agency's ROPS 14-15A for the period of July through
19 December 2014, which is attached hereto as Exhibit"A", is approved.
20 Section 3. The Successor Agency's plan for use of RPTTF and non-RPTTF for ROPS
21 14-15A, which is attached hereto as Exhibit"C", is approved.
22 Section 4. The City Manager, as Executive Director of the Successor Agency, or
23 designee, is hereby authorized and directed to: i) implement ROPS 14-15A on behalf of the
24 Successor Agency; ii) implement the Successor Agency's plan for use of RPTTF and non-RPTTF
25 for ROPS 14-15A; and iii) take such necessary actions and execute such documents as are necessary
26 to effectuate the intent of this Resolution, inclusive of authorizing ministerial revisions to the
27 Successor Agency's plan for use of RPTTF and non-RPTTF for ROPS 14-15A.
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1 Section 5. This Resolution is not a "project" for purposes of CEQA, as that term is
2 defined by Guidelines § 15378, because this Resolution is an organizational or administrative
3 activity that will not result in a direct or indirect physical change in the environment, per §
4 15378(b)(5) of the Guidelines.
5 Section 6. This Resolution shall take effect upon its adoption and execution in the
6 manner as required by the City Charter.
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1 RESOLUTION OF THE MAYOR AND COMMON COUNCIL OF THE CITY
OF SAN BERNARDINO ACTING AS THE SUCCESSOR AGENCY TO THE
2 SAN BERNARDINO REDEVELOPMENT AGENCY APPROVING THE
3 RECOGNIZED OBLIGATION PAYMENT SCHEDULE 14-15A FOR THE
PERIOD OF JULY THROUGH DECEMBER 2014 AND APPROVING
4 CERTAIN RELATED ACTIONS (#3506)
5 I HEREBY CERTIFY that the foregoing Resolution was duly adopted by the Mayor and Common
6 Council acting as the Successor Agency to the San Bernardino Redevelopment Agency, at a joint
7 adjourned regular meeting thereof, held on the 29th day of September, 2014, by the following
8 vote, to wit:
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Council Members Ayes Nays Abstain Absent
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MARQUEZ X
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BARRIOS X
12 VALDIVIA X
13 SHORETT X
14 NICKEL X
15 JOHNSON X
16 MULVIHILL X
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Georgearadlanna, Cit Clerk
19 '�
The foregoing Resolution is hereby approved this.�� day of September, 2014.
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Carey Davi , Chairman
23 Successor Agency to the
Redevelopment Agency of the
24 City of San Bernardino
Approved as to Form:
25 City Attorney
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G Saenz, General
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1 EXHIBIT "A"
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SUCCESSOR AGENCY TO THE
3 REDEVELOPMENT AGENCY OF THE CITY OF SAN BERNARDINO
4 RECOGNIZED OBLIGATION PAYMENT SCHEDULE 14-15A
(July through December 2014)
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(See Attachment)
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2014-351
Successor Agency Plan for Use of RPTTF and Non-RPTTF During ROPS 14-15A EXHIBIT"C"
Showing RPTTF Obligations(Requests,Approvals,Use Plan)and Use of Other Funds
Funding RPTTF RPTTF RPTTF Use of
EO# Obligation Priority ROPS Reauest DOF Approved Pr000sed Use Plan Other Funds
3 1998A TABS 1 $ 207,144 $ 207,144 $ 207,144 $
4 19988 TABS 1 125,588 125,588 125,588 -
6 2002A TABS 1 172,975 172,975 172,975 -
7 2002 TABS 1 631,688 593,888 593,888 -
8 2005A TABS 1 4,023,753 4,023,753 666,148 3,357,605
9 20058 TABS 1 1,540,393 1,540,393 1,540,393 -
10 2010A BABs 1 258,875 150,768 150,768 108,107 (see Note 2)
11 2010B TABS 1 86,800 86,800 86,800
12 1995H Bonds 1 41,938 40,486 40,486 1,452 (see Note 2)
13 199SR Bonds 1 38,194 7,024 7,024 31,170 (see Note 2)
14 EB-5 Notes($15M) 1 393,750 393,750 393,750 -
15 EB-5 Notes($10M) 1 262,500 262,500 262,500
16 EB-5 Notes($8M) 1 210,000 210,000 210,000 -
17 Sec.108 Bonds(Cinema) 1 590,290 590,290 590,290 -
18 Sec.108 Bonds(A-G)) 4 -
19 Hillwood Tax Sharing Agr. 3 245,439 245,439 245,439 -
20 BP Cal Tax Sharing Agr. 3 95,127 95,127 95,127 -
24 Waterman Tax Sharing Agr. 3 11,052 11,052 11,052 -
28 2006 TABS(Housing) 1 571,559 571,559 571,559
30 PERS Unfunded Liability 4 - -
31 Retiree Health 3 14,850 14,850 14,850
32 SA Administration 2 821,984 477,461 477,461 -
33 Litigation(Placo) 3 283 283 283 -
34 Litigation(Peart) 3 9,085 9,085 9,085 -
36 Litigation(Glen Aire MHP) 3 23,357 23,357 12,410 10,947
38 Property Maintenance 2 1,385,200 1,385,200 - 1,385,200
41 Auto Mall Reader Board 4 - -
82 DSRF Replenishments 6 4,849,838 - -
84 Securities Servicing 1 71,089 71,089 71,089 - -
85 SBVMWD Pass Thru Pmt. 6 2,644,578 - -
87 Mall Property Taxes 6 869,691 - -
94 RUSD Past Pass-Thru Pmt. 3 42,742 42,742 42,742
95 SB City USD Pass Thru Pmt. 6 2,223,398 - - -
96 1999 COPS Reimbursement 3 1,139,588 1,139,588 965,500 174,088
97 1998A TABS PPA Correction 5 985,000 985,000 985,000 -
98 19988 TABS PPA Correction 5 420,000 420,000 420,000
99 1995H Bonds PPA Correction 5 59,274 58,307 58,307
100 1995R Bonds PPA Correction 5 35,406 15,691 15,691
101 2006 TABS PPA Correction 5 1,470,000 1,470,000 1,470,000
102 1997A TABS PPA Correction 5 21,156 - -
103 2005B TABS PPA Correction 5 219 219 (see Note 1)
104 CMB Export PPA Correction 5 900 900 (see Note 1)
105 Woolworth Bldg.PPA Corr. 5 10,416 8,333 (see Note 1) -
106 Litigation PPA Correction 5 67,119 67,119 (see Note 1)
107 LTPM PPA Correction 5 844,503 844,503 (see Note 1) -
108 Neighborhood Housing 3 17,238 17,238 17,238 -
109 2005A TABs PPA Correction 5 711 711 711 -
110 2005B TABS PPA Correction 5 1,721 1,721 1,721 -
111 1995R Bonds PPA Correction 5 1 1 1 -
112 CMB Export PPA Correction 3 900 900 900
113 SBCSS Pass Thru Pmt. 6 81,700 - -
114 SBCCD Pass Thru Pmt. 6 592,431 - -
115 Anticipated Litigation 3 10,000 10,000 -
TOTAL of EOs 28,221,443 16,392,834 10,533,920 5,068,569 Total
(140,729) 3P Payments
RPTTF Received for ROPS 14-15A 10,533,920 $ 4,927,840 "Other Funds"to
be provided from
Other Funds from Balances Retained Successor Agency
to be Applied in ROPS 14-15A 5,858,914 Retained Balance
NOTE 1: Payment of obligation was made during ROPS II period. Listing on ROPS 14-15A was for
purposes of obtaining DOF of the payment already made.Thus,no funds required in ROPS 14-15A.
.NOTE 2: "Other Funds"identified to be used in the payment of these ROPS items are payments
from third parties made directly to the bond trustee or bank,and are not funds of the Successor Agency.
Priorities
1= Debt Service or Debt Service Related
2=Administration
3=Enforceable Obligation
4=No Payment Due During ROPS 14-15A(See Notes)
5= Correction of Funding Deficiency During ROPS 13-148
6=Denied by DOF
EXHIBIT "A"
1 EXHIBIT "B"
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3 MAY 16, 2014 LETTER
FROM THE
4 CALIFORNIA DEPARTMENT OF FINANCE
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2014-351
ANT v,�
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DEPARTMENT OF EDMUND G. BROWN JR. - GOVERNOR
C'91lFpAN'F I N A N G 915 L STREET■ SACRAMENTO CA ■ 95814-3705 ■www.DOF.CA.GDV
May 16, 2014
Mr. Allen Parker, City Manager
City of San Bernardino
300 North D Street, 6th Floor
San Bernardino, CA 94218
Dear Mr. Parker:
Subject: Recognized Obligation Payment Schedule
This letter supersedes the California Department of Finance's (Finance) Recognized Obligation
Payment Schedule (ROPS) letter dated April 17, 2014. Pursuant to Health and Safety Code
(HSC) section 34177 (m), the City of San Bernardino Successor Agency(Agency)submitted a
Recognized Obligation Payment Schedule (ROPS 14-15A)to Finance on March 12, 2014,for
the period of July through December 2014. Finance issued a ROPS determination letter on
April 17, 2014. Subsequently, the Agency requested a Meet and Confer session on one or
more of the items denied by Finance. The Meet and Confer session was held on May 7, 2014.
Based on a review of additional information and documentation provided to Finance during the
Meet and Confer process, Finance has completed its review of the specific items being
disputed.
Item No. 7—2002 Tax Allocation Bonds debt service payment in the amount of
$631,688. Finance approves this item for $593,888. The Agency requested $631,688
for interest due April 1, 2014. Our initial review indicated this amount was already
requested during the January through June 2014 (ROPS 13-14B) period. However,
according to the debt service schedule, $593,888 is due on October 1, 2014. During the
Meet and Confer, the Agency confirmed that this item should be $593,888. Therefore,
the requested Redevelopment Property Tax Trust Fund (RPTTF)funding has been
adjusted by$37,800 ($631,888—$593,888).
Item No. 10—2010A Recovery Zone debt service payment in the amount of$258,875.
Finance approves this item for$150,768 from the RPTTF and $108,107 from Other
Funds. The Agency receives a "Federal Direct Payment" subsidy as other revenue
pledged for debt service. Finance requested Trustee Bank statements for the Reserve
Fund account to support the amounts claimed. However, Finance initially denied this
item as the Agency was unable to provide documentation to support the amounts
claimed. During the Meet and Confer process, the Agency provided the methodology
used to estimate the subsidy to be received for the October 2014 payment. Based on
the calculation, $108,107 should be available towards the payment. Therefore, this item
is eligible for$150,768 from the RPTTF and $108,107 from Other Funds.
EXHIBIT "B"
2014-351
Mr. Allen Parker
May 16, 2014
Page 2
Item Nos. 12, 13, 99 and 100- 1995H Highland Lutheran SR Housing and 1995R Casa
Ramona SR Housing bonds debt service payments totaling $174,812. Finance
approves $40,486 from RPTTF and $1,452 from Other Funds for Item No. 12, $7,024
from RPTTF and $31,170 from Other Funds for Item No. 13, $58,307 from RPTTF for
Item No. 99, and $15,691 for Item No. 100.
Finance initially denied Item Nos. 12 and 13 because it was our understanding other
revenue is received monthly from third parties to cover the payments. During the Meet
and Confer process, the Agency provided the methodologies used to estimate the
revenues that would be applied to the payments. Although the Agency continues to
provide only a summary of account activity and still has not provided copies of the bond
fiscal statements to support the current balances, Finance will accept the Agency's
methodologies for estimating revenues for the ROPS 14-15A period. Therefore, Item
No. 12 is approved for$40,486 from RPTTF and $1,452 is reclassified to Other Funds
and Item No. 13 is approved for$7,024 from RPTTF and $31,170 is reclassified to Other
Funds.
Finance initially denied the amounts requested for Item Nos. 99 and 100 because the
Agency was unable to provide documentation to support the amount that was held in the
Revenue Fund and Trustee invoices supporting the credit of$2,902 and $59,953 applied
towards the items. During the Meet and Confer process for the ROPS 13-14B period,
the Agency contended that other revenues received are required to fund other
obligations related to the projects and are not available to fund debt service payments.
However, pursuant to the Bond Indenture, Section 5.02, on the 15th of each month, a
portion of gross revenues deposited in the Revenue Fund, in order of priority, should be
applied towards annual trustees fees, then applied to fund the taxes, assessments, and
insurance for the projects, then applied to fund interest and principal due on the next
succeeding due date. During the Meet and Confer process for ROPS 14-15A, the
Agency provided the invoices for the payments of these items for the ROPS 13-14B
period. Based on the invoices provided, the Agency's share of the payments is
$100,355 and $15,691, respectively. During the ROPS 13-14B review, Finance
approved and the Agency received $42,048 and $0, respectively, from the RPTTF.
Therefore, Finance approves $58,307 and $15,691, respectively, from the RPTTF on
ROPS 14-15A to cover the shortage in funds needed.
• Item No. 38- Long Term Property Maintenance costs in the amount of$11,500,000.
Finance no longer denies this item. Finance initially denied this item because the
Agency was unable to provide documentation to support the amounts claimed. During
the Meet and Confer process, the Agency provided a budget detailing the categories of
costs to be incurred by the various types of Agency-owned properties. Therefore,
Finance is approving this item for RPTTF funding; however, to the extent any revenues
generated on the properties are available for the estimated costs, those funds should be
used prior to using RPTTF. The Agency can obtain approval from the Oversight Board
to change the funding source for this item pursuant to HSC section 34177 (a)(4) if Other
Funds do become available.
When reporting the actual expenditures incurred on the ROPS 15-16A form, the Agency
should be able to identify how the costs incurred are associated with Agency-owned
properties, as well as supporting documents showing that the properties are currently
owned by the Agency. Without these supporting documents, any costs incurred may be
2014-351
Mr. Allen Parker
May 16, 2014
Page 3
disallowed and added to the prior period adjustment as funds available for expenditure
on a future ROPS.
Finance notes this item contains more than one contract and more than one payee. On
future ROPS, the Agency should list each contract as a separate obligation with its own
item number and list them in sequential order. Pursuant to HSC section 34177 (m)(1),
the Agency is required to complete the ROPS in a manner provided by Finance.
• Item No. 82- Debt Service Reserve Fund (DSRF) Replenishment in the amount of
$4,849,838. The Agency requests funds needed to replenish the DSRF to the required
balances for Item Nos. 3, 4, 6 through 11, and 28. Finance continues to reclassify the
funding source of this item to"Other Funds" as stated in the ROPS 13-14B Meet and
Confer determination letter dated December 17, 2013.
During the July through December 2013 period (ROPS 13-14A) Finance approved
$6,408,144 in RPTTF funding for this item. Finance authorized $17,569,239 in RPTTF
funds for ROPS 13-14A enforceable obligations, and applied a ROPS II Prior Period
Adjustment(PPA) in the amount of$5,876,914, resulting in $11,692,325 in RPTTF funds
approved for distribution, which was fully distributed by the San Bernardino County
Auditor Controller. The Agency also received $510,467 in RPTTF funds for
administrative costs. Consequently, sufficient RPTTF funding was available for the
Agency to replenish the required reserves for the ROPS 13-14A period, including the
funding that is available from the PPA of$5,876,914.
Through an email dated April 4, 2014, the Agency contends that the ROPS I I PPA was
spent on other obligations; therefore, it is impossible to fund the DSRF with a funds that
do not exist because the Agency has cash-flow problems.
The items on which the funds were spent were not approved by Finance; therefore, the
funds should be available for expenditure. HSC section 34177 (a)(3) states that only
those payments listed on the approved ROPS may be made from the funding source
specified in the ROPS. Also, HSC section 34183 (a)(2) explicitly requires debt service
payments to be made first, followed by revenue bonds (to the extent revenues are
insufficient to cover the payments due), and all other obligations, if sufficient RPTTF
funding remains. Additionally, HSC section 34171 (d)(1)(A) permits reserves to be held
only when required by the bond indenture, or when the next property tax allocation will
be insufficient to pay the next bond payment due in the following half of the fiscal year.
Therefore, to the extent the Agency has not been funding approved enforceable
obligations in this order; the Agency is in direct violation of the law. As such, the Agency
should reverse those non-debt service transactions that were either not approved by
Finance or subordinated to the Agency's debt service payments. Once corrected, the
Agency should return the funding to each DSRF.
During the Meet and Confer process, the Agency continued to object to Finance's
determination; however, no additional information or documents were provided.
Therefore, this item is not eligible for RPTTF funding; the funding source is being
reclassified to "Other Funds
• Item No. 85- Unfunded Prior-Year Pass-Through Payment Obligations in the amount of
$2,644,578. Finance continues to deny additional funding for this item. The Agency
requested funding for unfunded prior year pass-through payment obligations payable to
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May 16, 2014
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the San Bernardino Municipal Water District(SBVMWD). For ROPS 13-146, Finance
approved $12,164,545 in enforceable obligations to be funded from the RPTTF and the
San Bernardino County Auditor-Controller distributed $11,202,042 from the RPTTF with
$962,503 in a prior period adjustment; therefore, the Agency received all funds approved
on ROPS 13-14B. Furthermore, Finance approved $2,644,578 in RPTTF funding for
this item in ROPS 13-1413; therefore, funds should be available to make the payment.
The Agency contends that the item was unfunded because the funds allocated for the
obligation were used to pay for the principal reduction portion of the 1998A, 19986, and
2006 TABs that was inadvertently not requested on the ROPS 13-14B submitted to
Finance. The funds were also used to pay for the debt service shortfall for the 1995H
and 1995R Bonds. The Agency's unfunded amounts for these bonds have been
included on ROPS 14-15A under Item Nos. 97 through 101. Finance has approved the
shortfall for debt service for Item Nos. 97 through 101; therefore, the Agency cannot also
request to fund the unfunded pass-through payments. Therefore, this item is not eligible
for additional RPTTF funding.
• Item No. 87--Carousel Mall Past Due Property Tax in the amount of$869,691. Finance
continues to deny this item. The amount consists of past due property taxes for nine
parcels for tax years 2009, 2010, and 2012. The Agency acquired the property through
a Purchase Money Note dated May 3, 2010, when the former owner defaulted.
Based on review of the County of San Bernardino Treasurer-Tax Collector's website
during the ROPS 13-14B Meet and Confer process, it was determined that the current
owner for all nine parcels is the Carousel Mall LLC, not the Agency. All of these
properties were inappropriately transferred to the San Bernardino Economic
Development Corporation (SBEDC) in March 2011, who then transferred the properties
back to Carousel Mall LLC in December 2011. As of April 14, 2014, according to the
Tax Collector's website, these properties are still in the name of Carousel Mall.
Additionally, it appears the first payment for tax year 2009 was paid, and a refund issued
to SBEDC for the second installment.
Finance approved OB Resolution No. SBOB/2013-04 approving the acceptance by the
Agency of the transfer of the assets from SBEDC back to the Agency through a
determination letter dated March 13, 2014. At this point, it is not clear whether or not
SBEDC holds title to the properties to affect a transfer back to the Agency, nor is it clear
what amount, if any, is due for past due property taxes.
During the Meet and Confer process, the Agency continued to object to Finance's
determination; however, no additional information or documents were provided.
Therefore, this item is not an enforceable obligation and is not eligible for RPTTF
funding.
• Item Nos. 90 to 93-Discounted Settlement of Lawsuits to foreclosure mechanics liens
against former RDA properties totaling $2,309,000 funded by"Other"funds. Finance
continues to deny these items. During the California State Controller Office's
(Controller)Asset Transfer Review, the Controller ordered the return of several
properties formerly owned by the Agency. The Agency contends the Controller's return
order also includes any outstanding related liabilities related to those assets; therefore,
those liabilities are now obligations of the Agency. Finance denied these items as it was
our understanding that these liabilities were incurred or created during the time the
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May 16, 2014
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properties were owned and operated by the S.BEDC, and any contracts or agreements
signed were executed between the SBEDC and various third parties; the former RDA
was not a party to the contracts. Additionally, Finance denied the transfer of liabilities
related to these properties through a determination letter dated March 13, 2014 for OB
Resolution No. SBOB/2013-04.
During the Meet and Confer process, the Agency continued to object to Finance's
determination; however, no additional information or documents were provided.
Therefore, these items are not enforceable obligations and are not eligible for"Other
Funds."
• Item Nos. 94, 95, 113 and 114- Unfunded Prior-Year Pass-Through Obligations totaling
$2,940,241. Finance no longer denies Item No. 94; however, Finance continues to deny
Item Nos. 95, 113, and 114. During our initial review, the Agency provided demand
letters from Rialto Unified School District(RUSD), San Bernardino City Unified School
District, San Bernardino County Superintendent of Schools, and San Bernardino
Community College District that requested payments of underfunded pass-throughs for
fiscal years 2008-09 through 2010-11 based on a Los Angeles Unified School District
(LAUSD) court decision. However, Finance denied these items because the Agency is
not named as a party to the court decision and has not shown that the requested
payments are binding.
During the Meet and Confer process, RUSD contended that Item No. 94 is not related to
the calculations of the AB 1290 pass-throughs based on the LAUSD court decision.
RUSD clarified that this item is related to unpaid amounts and miscalculations in fiscal
years 2007-08 through 2010-11 under a contractual pass-through agreement between
the former RDA and RUSD dated July 25, 1990. Based on a review of the
1990 Agreement and other documents provided to support the calculations and
payments made, Finance approves this item for payment from RPTTF funding.
During the Meet and Confer process, the San Bernardino City Unified School District,
San Bernardino County Superintendent of Schools, and San Bernardino Community
College District contended that the demand letters for Item Nos. 95, 113, and 114 for
underfunded AB 1290 pass-throughs are enforceable obligations. However, as
previously stated, these demands are based on a LAUSD court decision and the Agency
was not a named party. Therefore, these items are not enforceable obligations and are
not eligible for RPTTF funding.
• Item Nos. 102 through 107-Various obligations to correct a Prior Period Adjustment
error totaling $944,503. Finance no longer denies Item Nos. 102 through 106; however,
Finance continues to deny Item No. 107 at this time. Finance initially denied the items
summarized below because the Agency did not provide documentation to support the
items claimed:
2014-351
Mr. Allen Parker
May 16, 2014
Page 6
ROPS 14-15A ROPS III PPA Description Authorized Actual Disallowed
Item No. Item No.
102 2 1997A Bond $22,500 $43,656 $21,156
103 9 2005B TAB 430,887 431,106 219
104 15 CMB-E $10,000,000 261,600 262,500 900
105 26 Woolworth Bldg 506,637 517,053 10,416
106 33 Litigation—Carousel 40,000 107,119 67,119
Mall(Placo)
107 38 Long Term Property 102,000 946,693 844,693
Maintenance
Total $1,363,624 $2,308,127 $944,503
During the Meet and Confer process the Agency provided invoices and checks showing
the actual payments made for the following items in the following amounts:
o Item No. 103-$431,106 was paid; therefore, the additional $219 is approved.
o Item No. 104-$262,500 was paid; therefore, the additional $900 is approved.
o Item No. 105-$514,970 was paid; therefore, an additional $8,333 is approved
and the remaining $2,083 continues to be denied.
o Item No. 106-$107,119 was paid; therefore, the additional $67,119 is approved.
For Item No. 102, the Agency stated that the prior period adjustment in the amount of
$21,156 is correct and no additional funds are needed.
For Item No. 107, the Agency provided a list of all Agency-owned properties and a
document detailing the various expenditures incurred during the ROPS III period that the
Agency classified as maintenance costs totaling $966,755. However, information was
not provided indicating how the detailed costs are associated with the Agency-owned
properties. The Agency indicated they are in the processing of completing a bridging
document linking the property maintenance expenditures to the specific properties.
Therefore, Finance will approve this item for funding and continue working the Agency
on the review of the specific expenditures incurred. However, any costs incurred, but
not associated with the maintenance of Agency-owned properties may be disallowed
and added to the prior period adjustment as funds available for expenditure on a future
ROPS.
• Claimed administrative costs exceed the allowance by$344,523. HSC section 34171 (b)
limits the fiscal year 2014-2015 administrative expenses to three percent of property tax
allocated to the Agency or $250,000, whichever is greater. Although $821,984 is
claimed for administrative cost, only$477,461 is available pursuant to the cap.
Therefore, $344,523 of excess administrative cost is not allowed.
• Pursuant to HSC section 34186 (a), successor agencies were required to report on the
ROPS 14-15A form the estimated obligations and actual payments (prior period
adjustments) associated with the July through December 2013 period. HSC section
34186 (a) also specifies prior period adjustments self-reported by successor agencies
are subject to audit by the county auditor-controller(CAC)and the Controller. The
amount of RPTTF approved in the table below includes the prior period adjustment
resulting from the CAC's audit of the Agency's self-reported prior period adjustment.
2014-351
Mr. Allen Parker
May 16, 2014
Page 7
During the Meet and Confer process, the Agency objected to the prior period adjustment
amount; however, no additional information or documents were provided. Therefore, no
change is being made to the prior period adjustment.
Except for the items denied in whole or in part as enforceable obligations or for the items that
have been reclassified, Finance is not objecting to the remaining items listed on your
ROPS 14-15A. The Agency's maximum approved RPTTF distribution for the reporting period is
$10,533,920 as summarized below:
Approved RPTTF Distribution
For the period of July through December 2014
Total requested or non-administrative obligations 27,399,459
Total RPTTF requested for administrative obligations 821,984
Total RPTTF requested for obligations $ 28,221,443
Total RPTTF requested for non-administrative obligations 27,399,459
Denied Item
Item No. 7 (37,800)
Item No. 85 (2,644,578)
Item No. 87 (869,691)
Item No. 95 (2,223,398)
Item No. 99 (967)
Item No. 100 (19,715)
Item No. 102 (21,156)
Item No. 105 (2,083)
Item No. 113 (81,700)
Item No. 114 (592,431)
(6,493,519
Reclassified Item
Item No. 82 (4,849,838)
Item No. 10 (108,107)
Item No. 12 (1,452)
Item No. 13 (31,170)
(4,990,567)
Total RPTTF authorized for non-administrative obligations $ 15,915,373
Total RPTTF requested for administrative obligations 821,984
Administrative costs in excess of the cap(see Admin Cost Cap table below) (344,523)
Total RPTTF authorized for administrative obligations $ 477,461
Total RPTTF authorized for obligations $ 16,392,834
RODS 13-14A prior period adjustment (5,858,914)
Total RPTTF approved for distribution $ 10,533,920
Administrative Cost Cap Calculation
Total RPTTF authorized for non-administrative obligations 15,915,373
Percent allowed pursuant to HSC section 34171 (b) 3%
Total RPTTF allowable for administrative obligations 477,461
Total RPTTF administrative obligations after Finance adjustments 821,984
Administrative costs in excess of the cap $ (344,523)
2014°351
Mr. Allen Parker
May 16, 2014
Page 8
Pursuant to HSC section 34177 (1)(1) (E), agencies are required to use all available funding
sources prior to RPTTF for payment of enforceable obligations. During the ROPS 14-15A
review, Finance requested financial records to support the fund balances reported by the
Agency; however, Finance was unable to reconcile the financial records to the amounts
reported. As a result, Finance will continue to work with the Agency after the ROPS 14-15A
review period to properly identify the Agency's fund balances. If it is determined the Agency
possesses fund balances that are available to pay approved obligations, the Agency should
request the use of these fund balances prior to requesting RPTTF in BOPS 14-15B.
Please refer to the ROPS 14-15A schedule that was used to calculate the approved RPTTF
amount:
http://www.dof.ca.gov/redevelooment/ROPS
This is Finance's final determination related to the enforceable obligations reported on your
ROPS for July 1 through December 31, 2014. This determination only applies to items where
funding was requested for the six-month period. Finance's determination is effective for this
time period only and should not be conclusively relied upon for future periods. All items listed
on a future ROPS are subject to a subsequent review and may be denied even if it was or was
not denied on this ROPS or a preceding ROPS. The only exception is for those items that have
received a Final and Conclusive determination from Finance pursuant to HSC section
34177.5(i). Finance's review of items that have received a Final and Conclusive determination
is limited to confirming the scheduled payments as required by the obligation.
The amount available from the RPTTF is the same as the amount of property tax increment that
was available prior to enactment of ABx1 26 and AB 1484. This amount is not and never was
an unlimited funding source. Therefore, as a practical matter, the ability to fund the items on the
ROPS with property tax is limited to the amount of funding available to the successor agency in
the RPTTF.
To the extent proceeds from bonds issued after December 31, 2010 exist and are not
encumbered by an enforceable obligation pursuant to HSC section 34171 (d),
HSC section 34191.4(c)(2)(B) requires these proceeds be used to defease the bonds or to
purchase those same outstanding bonds on the open market for cancellation.
Please direct inquiries to Evelyn Suess, Dispute Resolution Supervisor, or Mary Halterman,
Analyst, at(916)445-1546.
Sincerely,
JUSTYN HOWARD
Assistant Program Budget Manager
cc: Ms. Lisa Connor, Project Manager, City of San Bernardino
Ms. Linda Santillano, Property Tax Manager, San Bernardino County
California State Controller's Office
1 EXHIBIT "C"
2
THE SUCCESSOR AGENCY'S PLAN
3 FOR USE OF RPTTF AND NON-RPTTF
4 FOR ROPS 14-15A
(JULY THROUGH DECEMBER 2014)
5
(See Attachment)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
8
2014-351
1 RESOLUTION NO. SBOB/2014-02
2
3 RESOLUTION OF THE OVERSIGHT BOARD FOR THE SUCCESSOR AGENCY TO
THE REDEVELOPMENT AGENCY OF THE CITY OF SAN BERNARDINO APPROVING
4 THE ESTABLISHMENT OF THE RECOGNIZED OBLIGATION PAYMENT SCHEDULE
14-15A FOR THE PERIOD OF JULY THROUGH DECEMBER 2014
5
6
7 WHEREAS, the Redevelopment Agency of the City of San Bernardino was dissolved
February 1,2012;and
8
WHEREAS, the Oversight Board for the Successor Agency to the Redevelopment Agency
9 of the City of San Bernardino ("Oversight Board") has been established pursuant to Health and
10 Safety Code ("HSC") § 34179 to assist in the wind-down of the dissolved redevelopment agency;
and
11 WHEREAS, Per Health and Safety Code § 34177 (1)(1), the Successor Agency to the
Redevelopment Agency of the City of San Bernardino ("Successor Agency") is required to prepare
12 a ROPS before each six-month fiscal period,which corresponds to equal halves of a fiscal year(i.e.,
July through December and July through December); and
13
14 WHEREAS, The ROPS is the basis for the Successor Agency's authority to make
payments due for enforceable obligations;and
15
WHEREAS, the ROPS 14-15A,which consists of several spreadsheets, is appended to this
16 Resolution as Exhibit"A"; and
17 WHEREAS, pursuant to Health and Safety Code § 34177 (m), an Oversight Board-
18 approved ROPS 14-15A must be submitted to the County Auditor-Controller, County
Administrative Officer, the State Controller and the State Department of Finance not later than
19 March 3, 2014; and
20 WHEREAS, pursuant to Health and Safety Code Section 34177, the Successor Agency is
21 legally required to continue to make payments due for enforceable obligations; and
22 WHEREAS, the Oversight Board's approval of the establishment of ROPS 14-15A will
ensure that the Successor Agency has the authority to continue to pay its enforceable obligations;
23 and
WHEREAS, all of the prerequisites with respect to the approval of this Resolution have
24 been met.
25 NOW, THEREFORE, BE IT RESOLVED by the Oversight Board for the Successor
26 Agency to the Redevelopment Agency of the City of San Bernardino, as follows:
27 Section 1. The foregoing recitals are true and correct and are a substantive part of this
Resolution.
28
1
PAAgendasSOversight8oud\ResolutionM808201 4.02ROPS14-15A.dm EXHIBIT "C"
2014-351
1 Section 2. The establishment of the Successor Agency's ROPS 14-15A for the period of July
through December 2014,which is attached hereto as Exhibit"A",is approved.
2
3 Section 3. The City Manager, or designee, is authorized to: i) post ROPS 1.4-15A on the City's
website, ii) transmit ROPS 14-15A to the County Auditor-Controller, the County
4 Administrative Officer, the State Controller and the State Department of Finance for
their review within the timeframe and in the manner prescribed by the Health and
5 Safety Code; and iii) make ministerial revisions to ROPS 14-15A, which may
include, but are not limited to restating the information included within ROPS 14-
6 15A in any format that may be requested by the State Department of Finance, take
7 such other actions and execute such other documents as are necessary to effectuate
the intent of this Resolution, and to implement BOPS 14-15A on behalf of the
8 Successor Agency,including authorizing and causing such payments.
9 Section 4. This Resolution shall take effect upon the date of its adoption
10 Ill
11
12
13
14
15 IIl
16 IIl
17 IIl
18
19
20
IlI
21
22 III
23 IlI
24
25
26 /lI
27
28
2
P:Wgendas%OversighI BouMesolU600SBOB 2014-02 BOPS 14-15A.doc
2014-251
1 RESOLUTION OF THE OVERSIGHT BOARD FOR THE SUCCESSOR AGENCY TO
THE REDEVELOPMENT AGENCY OF THE CITY OF SAN BERNARDINO APPROVING
2 THE ESTABLISHMENT OF THE RECOGNIZED OBLIGATION PAYMENT SCHEDULE
3 14-15A FOR THE PERIOD OF JULY THROUGH DECEMBER 2014
4
5 PASSED, APPROVED AND ADOPTED THIS 28th day of February, 2014, by
the following vote.
6
7 Board Members Ayes Nays Abstain Absent
8 HEADRICK X
9 HILL X
X
10 LONGVILLE
X
11 MACIAS-HARRISON
12
MORRIS X
13
O'TOOLE X SMITH X
14 ,
15 ,
16
17 The foregoing Resolution is hereby approved this 28th day of February, 2014.
18 _'_j`47�, F--
19 James P. Morri Chairman
Oversight Board for the City of San Bernardino
20 As Successor Agency to the Redevelopment
21 Agency of the City of San Bernardino
22
23
24
25
26
27
28
3
PA Agendasl0versight BoudNResolulioaMBOB 2014-02 AOPS 14.15-0 doe
2014-351
1
EXHIBIT "A"
2
3 SUCCESSOR AGENCY TO THE REDEVELOPMENT AGENCY
4 OF THE CITY OF SAN BERNARDINO
RECONGNIZED OBLIGATION PAYMENT SCHEDULE 14-15A
5 (July through December 2014)
6 (See Attachment)
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4
KkAgendas\O ersight BoudlLesolutioosMOB 2014-02 ROPS 14-15A.doc
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