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HomeMy WebLinkAboutAppropriation and allocation of $4,669,451 of General Funds , Dept. ID ED 13-33 Page 1 of 3 Meeting Date: 10/7/2013 CITY OF HUNTINGTON BEACH REQUEST FOR CITY COUNCIL ACTION MEETING DATE: 10/7/2013 SUBMITTED TO: Honorable Mayor and City Council Members SUBMITTED BY: Fred A. Wilson, City Manager PREPARED BY: Fred A. Wilson, City Manager Lori Ann Farrell, Director of Finance SUBJECT: Approve appropriation and allocation of$4,669,451 of General Funds to Successor Agency to pay Department of Finance's Demand Letter regarding former Redevelopment Agency's Assets Statement of Issue: On February 1, 2012, all former redevelopment agencies were dissolved statewide. In June 2012, Assembly Bill 1484 (AB 1484) was approved which set forth new requirements for the Successor Agency to the former Redevelopment Agency. AB 1484 required Due Diligence Reviews (DDR) of both Housing and Non-Housing Fund balances available for distribution to other taxing entities. On September 20, 2013, the City received the final determination and demand letter from the Department of Finance (DOF)for the Non-Housing DDR. The Demand is for a total of $11,071,092, which includes $4,669,451 in disallowed transfers from the former Redevelopment Agency to the City's General Fund. Due to this final determination, the City Council is requested to appropriate $4,669,451 from the General Fund and to transfer it to the Successor Agency. Financial Impact: The appropriation, transfer and subsequent remittance of$4,669,451 from the City's General Fund, to the Successor Agency, as per the State Department of Finance's demand notice, will be funded from a combination of sources. The primary source of funding is the City's General Fund Reserves, namely, the entire Budget Stabilization Fund of$3,100,000 will be expended to make this payment. As this amount only partially finances the full payment, it is anticipated the balance of the payment, or$1,569,851, will be funded from FY 2012/13 General Fund revenues projected to be available and unencumbered at year-end. As per the most recent budget projections, the City is projecting $1,900,000 in General Fund year-end balances may be available. This amount can be used, if available, to fund the remainder of this mandatory payment, barring adverse effects. If year-end balances are not available and instead must be used to help offset actual General Fund expenditures by year-end, other General Fund reserves, such as the Economic Uncertainties Reserve, will be utilized to finance the remaining portion. Recommended Action: A) Approve an appropriation $4,669,451 in the FY 2012/13 Non-Departmental General Fund Budget Account - 10040999.88210.350; and B) Approve the transfer of$4,669,451 from the General Fund FY 2012/13 Non-Departmental Budget to the FY 2012/13 Successor Agency Budget Account- 35000350.49101.100. Item 10. - 1 HB -388- Dept.ID ED 13-33 Page 2 of 3 Meeting Date: 10/7/2013 Alternative Action(s): Do not approve the payment to the Successor Agency and provide alternative direction. Analysis: On June 27, 2012, the Governor signed AB 1484 modifying provisions of the Dissolution Act and imposing new requirements on Successor Agencies. Section 34177(d) of the Health and Safety Code requires Successor Agencies to remit unobligated balances of redevelopment agency funds to the County Auditor-Controller for distribution to the taxing entities. Section 34179.5 of the Health and Safety Code requires Successor Agencies to hire a licensed accountant, approved by the County Auditor-Controller and with experience and expertise in local government accounting to conduct two due diligence reviews as noted below to determine the unobligated balances available for transfer to taxing entities. Two due diligence reviews are required to be performed: one for the Housing Funds; and one for Non-Housing funds. The report for the Non-Housing Funds review was completed and submitted to the County and State and was reviewed and approved by the Oversight Board as required by State law. The City/Successor Agency retained the accounting firm Vavrinek, Trine, Day& Co., LLP (VTD) and the firm was approved by the County of Orange to perform the required due diligence reviews. The Independent Accountant's Report on Applying the Agreed-Upon Procedures on the Successor Agency to the dissolved Huntington Beach Redevelopment Agency made the determination that there was no balance to be disbursed for Huntington Beach, due to Agency commitments. As required by Section 34179.6 of the Health and Safety Code, staff submitted the due diligence review for the Non-Housing Funds to the Oversight Board, the State Controller, the Department of Finance, and the County Auditor-Controller, by January 15, 2013. On April 1, 2013, our DDR was determined to be invalid, due to the City/Successor Agency fiscal year being October 1 to September 30 and the State requirement that the DDR be based on the State Fiscal Year July 1 to June 30. On June 3, 2013, the City/Successor Agency resubmitted the DDR based on the revised fiscal year and still determined that there was no cash available for transfer to the County. On August 15, 2013, the City/Successor Agency received the DOF Letter stating that the City/Agency was required to remit $13,231,359. On September 4, 2013, the City and DOF held a Meet and Confer regarding the DDR Determination Response in Sacramento, CA. Transfers in the amount of $5,078,824 to the City of Huntington Beach (City) were disallowed. However, the Redevelopment Agency legally made loan repayments to the City between the period of January 1, 2011, to September 30, 2011. The loan payments were considered enforceable obligations at the time they were made. All of the transfers questioned by DOF took place before February 1, 2012. Until .tune 28, 2011, the Redevelopment Agency's actions were governed by Community Redevelopment Law in effect at the time, which plainly authorized the Redevelopment Agency to enter into the Agreements with the City, HSC 33220. However, AB 1484, which was adopted in June 2012, modified the law retroactive to January 1, 2011, and rendered all transfers of cash and/or assets between Agencies and Cities as disallowable transfers. The City did successfully argue that the transfer made on January 1, 2011, in the amount of$409,483 was enforceable and legal. As such, the disallowed amount of the former redevelopment agency's transfer to the General Fund was reduced from $5,078,824 to the required $4,669,451. The Successor Agency does not intend to waive any constitutional, statutory, legal, or equitable rights and expressly reserves any and all rights, privileges and defenses available under law and equity. Prior to and during the Meet and Confer, the Successor Agency provided the Department with ample documentation to demonstrate that (i) the payments from the former Redevelopment HB -389- Item 10. - 2 Dept. ID ED 13-33 Page 3 of 3 Meeting Date: 10/7/2013 Agency to the City were made pursuant to obligations that were enforceable at the time the payments were made and (ii) the amount of projected revenues to the Successor Agency would be insufficient to pay scheduled enforceable obligations. Environmental Status: Not Applicable Strategic Plan Goal: Improve long-term financial sustainability Attachment(s): 1) Department of Finance September 20, 2013, Letter 2) Department of Finance August 15, 2013, Letter Item 10. - 3 HB -390- AT TACH ANT 1 m IIII n DEPARTMEN■TT OF EDMUND G. BROWN JR. a GOVERNOR c4�rFDaa`� @ 91 5 L STREET ■ SACRAMENTO CA ■ 95S 1 4-3706 W WWW.DDF.GA.GG7V September 20, 2013 Ms. Kellee Fritzal, Deputy Director City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648-2702 Dear Ms. Fritzal: Subject: Other Funds and Accounts Due Diligence Review This letter supersedes the California Department of Finance's (Finance) original Other Funds and Accounts (OFA) Due Diligence Review (DDR) determination letter dated August 15, 2013. Pursuant to Health and Safety Code (HSC) section 34179.6 (c), the City of Huntington Beach Successor Agency (Agency) submitted an oversight board approved OFA DDR to Finance on June 3, 2013. The purpose of the review was to determine the amount of cash and cash equivalents available for distribution to the affected taxing entities. Since the Agency did not meet the January 15, 2013 submittal deadline pursuant to HSC section 34179.6 (c), Finance was not bound to completing its review and making a determination by the April 1, 2013 deadline pursuant to HSC section 34179.6 (d). Finance issued an OFA DDR determination letter on August 15, 2013. Subsequently, the Agency requested a Meet and Confer session on one or more items adjusted by Finance. The Meet and Confer session was held on September 4, 2013. Based on a review of additional information and documentation provided to Finance during the Meet and Confer process, Finance has completed its review of those specific items being disputed. Specifically, the following adjustments were made: • Transfers in the amount of$5,078,834 to the City of Huntington Beach (City)were not allowed. The former redevelopment agency (RDA) transferred a total of$5,485,765 in cash to the City during the period January 1, 2011 to September 30, 2011. Of the total cash transferred, $406,931 was supported by an enforceable obligation for payments for the 2010 Series A Lease Revenue Refunding Bond. Based on further review during the Meet and Confer process, the Agency provided supporting documents showing that an additional transfer of$409,483 occurred on January 1, 2011, which is outside of the period for disallowed transfers per HSC section 34179.5 (c) (2). The remaining transfers represent payments to the City in relation to multiple cooperative agreements between the City and the former RDA entered into between 1983 through 2003 and amended annually from 2004 through 2011. However, per HSC section 34179.5 (c) (2), the dollar value of assets and cash transferred by the former RDA or successor agency to the city, county, or city and county that created the former RDA after January 1, 2011 through June 30, 2012, must be evidenced by documentation of the enforceable obligation that required the transfer. HSC section 34179.5 states HB -391- Item 10. - 4 Ms. Fritzal September 20, 2013 Page 2 enforceable obligation includes any of the items listed in subdivision (d) of section 34171, contracts detailing specific work that were entered into by the former RDA prior to June 28, 2011, with a third party other than the city, county, or city and county that created the former RDA. HSC section 34171 (d) (2) states enforceable obligation does not include any agreements, contracts, or arrangements between the city that created the RDA and the former RDA. Therefore, the transfers were not made pursuant to an enforceable obligation and are not permitted. The OFA balance available will be increased by $4,669,451 ($5,485,765 - $406,931 - $409,383). The repayment of these loans may become enforceable obligations after the Agency receives a Finding of Completion from Finance. If the oversight board makes a finding that the loans were for legitimate redevelopment purposes, these loans should be placed on future Recognized Obligation Payment Schedules (ROPS)for repayment. Refer to HSC section 34191.4 (b) for more guidance. • The request to retain balances totaling $12,241,970 to satisfy future enforceable obligations was originally decreased by$8,813,384. Based on further review during the Meet and Confer process, the Agency may retain a total of$5,179,470 for enforceable obligations, as further discussed below. Accordingly, the OFA balance available for distribution will be increased by $7,062,500 ($12,241,970 - $5,179,470). For the July through December 2012 ROPS (ROPS 11) period, Finance approved $5,747,947 to be distributed from the Redevelopment Property Tax Trust Fund (RPTTF). The County Auditor Controller only distributed $3,428,586 from the RPTTF. On the Estimated Obligations vs. Actual Payments tab of the July through December 2013 ROPS (ROPS 13-14A)form, the Agency reported $5,513,899 in expenditures for the ROPS II period, which consisted of$3,428,586 paid from the RPTTF and $2,085,313 paid from Reserves. However, based on the expenditure report provided for the period July 1 through December 31, 2012, only$5,179,470 in approved expenditures was supported. Therefore, the Agency may retain $5,179,470 ($3,428,586 in RPTTF + $1,750,884 in Reserves) for ROPS II approved enforceable obligations. Finance notes that HSC section 34177 (a) (3) states that only those payments listed in the approved BOPS may be made from the funding source specified in the ROPS. However, HSC section 34177 (a) (4) goes on to state that with prior approval from the oversight board, the successor agency can make payments for enforceable obligations from sources other than those listed in the ROPS. In the future, the Agency should obtain prior oversight board approval when making payments for enforceable obligations from a funding source other than those approved by Finance. For both the January through June 2013 (BOPS 111) and ROPS 13-14A periods, the Agency received the full amount approved from the RPTTF. Therefore, the Agency is not allowed to retain any additional funds for the ROPS ill and ROPS 13-14A periods. Although the Agency contends it will experience a shortfall of RPTTF for the ROPS 13- 14A and subsequent periods, the cash flow analysis provided does not adequately incorporate all the requirements detailed in HSC section 34179.5 (c) (5) (D). HSC section 34179.5 (c) (5) (D) requires an extensive analysis before retention of current unencumbered balances can be contemplated. This includes, but is not limited to, providing a detail of the projected property tax revenues and other general purpose revenues to be received by the Agency, together with both the amount and timing of the bond debt service payments, for the period in which the oversight board anticipates the Item 10. - 5 HB -392- Ms. Fritzal September 20, 2013 Page 3 Agency will have insufficient property tax revenue to pay the specified obligations. The cash flow analysis provided only identified one period (July through December 2014) in which there may be insufficient funding from the RPTTF; however, the period prior to this estimates excess funding from the RPTTF would be available to cover this shortfall, should it be needed to cover bond debt service. As such, it is not evident that future property tax revenue will be insufficient or that there is an immediate need to retain these balances. Should a deficit occur in the future, HSC provides successor agencies with various methods to address short term cash flow issues. These may include requesting a loan from the city pursuant to HSC section 34173 (h), requesting the accumulation of reserves on the ROPS when a future balloon or uneven payment is expected pursuant to HSC section 34177 (d) (1) (A), or subordinating pass-through payments pursuant to HSC section 34183 (b). The Agency should seek counsel from their oversight board to determine the solution most appropriate for their situation if a deficiency were to occur. Since the Agency has not met the requirements detailed in HSC section 34179.5 (c)(5) (D)and possesses alternatives to address any short-term cash flow shortages, Finance deems it is not necessary for the Agency to retain any additional OFA unencumbered balances. The Agency's OFA balance available for distribution to the affected taxing entities is $11,071,092 (see table below). OFA Balances Available For Distribution To Taxing Entities Available Balance per DDR. $ (660,859) Finance Adjustments Add: Disallowed transfers $ 4,669,451 Requested retained balance not supported 7,062,500 Total OFAavailable to be distributed: $ 11,071,092 This is Finance's final determination of the OFA balances available for distribution to the taxing entities. HSC section 34179.6 (f) requires successor agencies to transmit to the county auditor- controller the amount of funds identified in the above table within five working days, plus any interest those sums accumulated while in the possession of the recipient. Upon submission of payment, it is requested you provide proof of payment to Finance within five business days. If funds identified for transmission are in the possession of the successor agency, and if the successor agency is operated by the city or county that created the former redevelopment agency, then failure to transmit the identified funds may result in offsets to the city's or the county's sales and use tax allocation, as well as its property tax allocation. If funds identified for transmission are in the possession of another taxing entity, the successor agency is required to take diligent efforts to recover such funds. A failure to recover and remit those funds may result in offsets to the other taxing entity's sales and use tax allocation or to its property tax allocation. If funds identified for transmission are in the possession of a private entity, HSC section 34179.6 (h) (1) (B) states that any remittance related to unallowable transfers to a private party may also be subject to a 10 percent penalty if not remitted within 60 days. HB -393 Item 10. - 6 Ms. Fritzel September 20, 2013 Page 4 Failure to transmit the identified,funds will also prevent the Agency from.being able to receive a finding of completion from Finance. Without a finding of completion, the Agency will be unable to take advantage of the provisions detailed in HSC section 34191.4. Specifically, these provisions allow certain loan agreements between the former redevelopment agency(RDA) and the city, county, or city and county that created the RDA to be considered enforceable obligations. These provisions also allow certain bond proceeds to be,used,for the purposes in which they were sold and allows for the transfer of real property and interests into the Community Redevelopment Property Trust Fund once Finance approves the:Agency's long-range property management plan. In addition to the consequences above, willful failure to return assets that were deemed an unallowable transfer or failure to remit the funds identified above could expose certain individuals to criminal penalties under existing law. Pursuant to HSC sections 34167.5 and 34178.8,the California State Controller's Office (Controller) has the authority to claw back assets thatwere inappropriately transferred to the city; county, or any other public agency. Determinations outlined in this letter do not in any way eliminate the Controller's authority. Please direct inquiries to Evelyn Suess, Dispute Resolution Supervisor, or Mary Haiterman Analyst, at (916)445-1546. Sincerely, STEVE SZALAY Local Government Consultant. cc: its. Lori Ann Farrell, Director of Finance, City of Huntington Beach' Mr. Frank Davies, Property Tax Manager, Grange County Mr. Steven Mar, Bureau Chief, Local Government Audit Bureau, California State Controller's Office Item 10. - 7 HB -394- ATT' ACHMENT #2 � IIII q Q � ;c DEPARTMENT OF EomUNO G. 13RaWN JR. m GMVERNOR oAkI OW4'' 'F 1 A t® A N�y! C 915 L STRrMT 0 SACRAMEKTo GA ]1 958 1 4-3 706 O WWW.DOF.CA.G[]V August 15, 2013 Ms. Kellee Fritzal, Deputy Director City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648-2702 Dear Ms. Fritzal: Subject: Other Funds and Accounts Due Diligence Review The City of Huntington Beach Successor Agency(Agency) submitted an oversight board approved Other Funds and Accounts (OFA) Due Diligence Review (DDR)to the California Department of Finance (Finance) on June 3, 2013. The purpose of the review was to determine the amount of cash and cash equivalents available for distribution to the affected taxing entities. Since the Agency did not meet the January 15, 2013 submittal deadline pursuant to HSC section 34179.6 (c), Finance is not bound to completing its review and making a determination by the April 1, 2013 deadline pursuant to HSC section 34179.6 (d). However, Finance has completed its review of your DDR, which may have included obtaining clarification for various items. HSC section 34179.6 (d) authorizes Finance to adjust the DDR's stated balance of OFA available for distribution to the taxing entities. Based on our review of your DDR, the following adjustments were made: • Transfers in the amount of$5,078,834 to the City of Huntington Beach (City) are not allowed. The former redevelopment agency (RDA)transferred a total of$5,485,765 in cash to the City during the period January 1, 2011 to September 30, 2011. Of the total cash transferred, only$406,931 was supported by an enforceable obligation, payments for the 2010 Series A Lease Revenue Refunding Bond. Therefore, $5,078,834 ($5,485,765- $406,931) is not an allowable transfer. ® The request to retain balances totaling $12,241,970 to satisfy future enforceable obligations has been adjusted by$8,813,384. The Agency is allowed to retain $3,428,586 that was distributed for the July through December 2012 Recognized Obligation Payment Schedule period. However, the Agency's request to retain current unencumbered OFA balances of$8,813,384 ($12,241,970--- $3,428,586) to cover future obligations is not allowed. The cash flow analysis provided does not adequately incorporate all the requirements detailed in HSC section 34179.5 (c) (5) (D). HSC section 34179.5 (c) (5) (D) requires an extensive analysis before retention of current unencumbered balances can be contemplated. This includes but is not limited to, providing a detail of the projected property tax revenues and other general purpose revenues to be received by the Agency, together with both the amount and timing of the HB -395- Item 10. - 8 Ms. Kellee Fritzal August 15, 2013 Page 2 bond debt service payments, for the period in which the oversight board anticipates the Agency will have insufficient property tax revenue to'pay the specified obligations. As such, it is not evident that future property tax revenue will be insufficient or that there is an immediate need to retain these balances. Should a deficit occur in the future, HSC provides successor agencies with various methods tee-address short term cash flow issues. These may include requesting a loan from the city pursuant to HSC section 34173 (h), or subordinating pass-through payments pursuant to HSC section .34183 (b). The Agency should seek counsel from their oversight board todetermine.the solution most appropriate for their situation if a deficiency were to occur. Since the Agency has not met the requirements detailed in HSC section 34179.5 (c) (5) (D) and possesses alternatives to address short term cash flow shortages, Finance deems it is not necessary for Agency to retain $8,813,384 in OFA unencumbered balances. If you disagree-with Finance's adjusted amount of OFA balances available for distribution to the taxing entities, you may request a Meet and Confer within five business days of the date of this letter. The Meet and Confer proce'ss,and guidelines are available at Finance's website below: http://www.dof.ca.gov/redevelopment/meet and,confer/ The Agency's OFA balance available for distribution to the affected taxing entities is $13,231,359 (see table below). OFA Balances Available For Distribution To Taxing Entities Available Balance per DDR: $ (660,859) Finance Adjustments Add: Disallowed transfers $ 5,078,834 Requested retained balance not supported 8,813,384 Total OFA available to be distributed: $ 13,231,359 Absent a Meet and. Confer request, HSC section 34179.6 (f) requires successor agencies to transmit to the county auditor-controller the amount of funds identified in the above table within five working days, plus any interest rest those sums accumulated while in the possession of the recipient. Upon submission of payment, please provide proof of payment to Finance within five business days, If funds identified for transmission are in the possession of the successor agency, and if the successor agency is operated by the city or county that created the former redevelopment, agency, then failure to transmit the identified funds may result in offsets to the city's or the county's sales and use tax allocation, as well as its property tax allocation. If funds identified for transmission are in the possession of another taxing entity, the successor,agency is required to take diligent efforts to recover such funds. A failure to recover and remit those funds may result in offsets to the other taxing entity's sales,and use tax allocation or to its property tax allocation. If funds identified for transmission are in the possession of a private entity, HSC 34179.6 (h)(1) (6) states that any remittance related to unallowable transfers to a private party may also be subject to a 10 percent penalty if not remitted within 60 days. Item 10. - 9 HB -396- Ms. Kellee Fritzal August 1.5, 201`3 Page.3 Failure to transmit the identified funds will also prevent the Agency from being able to receive a finding of completion from Finance. Without a finding of completion, the Agency will be unable to take advantage of the provisions detailed in HSC section 34191.4. Specifically, these provisions allow certain loan agreements between the former redevelopment agency (RDA) and the city, county, or city and county that created the RIBA to be considered enforceable obligations, These provisions also allow certain bond proceeds to be used for the purposes in which they were sold and allows for the transfer of real property and interests into the Community Redevelopment Property Trust Fund once Finance approves the Agency's long- range property management plan. In addition to the consequences: above, willful failure to return assets that were deemed an unallowable transfer or failure to remit the funds identified above could expose certain individuals to criminal penalties under existing law. Pursuant to HSC section 34167.5 and 34178.8, the California State Controller's Office (Controller) has the authority to claw back assets that were inappropriately transferred to the city, county, or any other public agency. Determinations outlined in this letter do not in any way eliminate the Controller's authority. Please direct inquiries to Nichelle Thomas, Supervisor or Alex Watt, Lead Analyst at. (91 6)445-1546'. Sincerely; STEVE SZALAY Local Government Consultant cc: Ms. Lori Ann Farrell, Director of Finance, City of Huntington.Beach Mr. Frank Davies., Property Tax Manager, Orange County California State Controller's:Office HB -397- Item 10. - 10 Huntington Beach Successor Agency Non Housing DDR Final �. Determination October 7. 2013 r r On June 27, 2012, the governor signed AB 1484 modifying provisions of the Dissolution Act and imposing new requirements on successor agencies. AB 1484 requires successor agencies to remit unobligated balances of redevelopment agency funds to the County Auditor-Controller for distribution to the taxing entities. Successor Agencies had to prepare two Due Diligence Reviews (DDR's) one of housing assets and one of all L er non-housing assets, including unencumbered h balances Will DDR Summary As required staff submitted the DDR for both the Non- Housing and Housing Funds On August 15, 2013 the City/Successor Agency received the DOF Letter stating that the City/Agency was required to submit$13,231,359 On September 4, 2013, the City and DOF held a Meet and Confer regarding the DDR Determination Response. The amount owed was reduced to $11,071,092 Disallowed Transfers—General Fund ➢ Transfers in the amount of$4,669,451 to the City of Huntington Beach were disallowed. ➢ The Redevelopment Agency legally made loan repayments to the City between the period of January 1, 2011 to September 30, 2011. > The loan payments were considered enforceable obligations at the time they were made pursuant to State Law. r All of the transfers questioned by DOF occurred before February 1, 2012, the formal date of dissolution. 2 Disallowed Transfers - General Fund ➢ However, AB1484 retroactively disallowed transfers from the redevelopment agency to the City ➢ As such, staff recommends the appropriation, transfer and subsequent remittance of$4,669,851 from the City's General Fund, to the Successor Agency ➢ Primary source of funding is the Budget Stabilization Fund of$3,100,000 ➢ The balance of the payment, or $1,569,851, will be funded from FY 2012/13 General Fund revenues projected to be available and unencumbered at year- end Retentionof Funds . Agency ➢ In addition, based upon the Meet and Confer of September 4, 2013 DOF reduced the demand from $8,813,384 to $7,062,500 ➢ After applying a small credit, the remaining $6,401,641 payment will be funded from the former redevelopment agency's fund balances ➢ The Successor agency will accept the General Fund transfer of$4,669,451 and approve a Budget appropriation to make the $11,071,092 payment for remittance to the County Auditor-Controller. 3 ➢ The City and Successor Agency will be making the payment under protest and will reserve the rights to future litigation This option is being recommended in order to avoid a claw back of the City's sales taxes and property taxes that fund most public services Huntington Beach Successor Agency QUESTIONS? 4