BOULDER HOUSING PARTNERS REGULAR MEETING OF THE BOARD OF COMMISSIONERS MAY 9, 2016 2:30 PM 4800 BROADWAY, BOULDER COLORADO Our primary mission is to provide quality affordable housing that is developed and managed with respect for the dignity of all involved. We also seek to create a sense of community strength and spirit that supports resident efforts to realize success in their lives. AGENDA I. Call to order and Determination of a Quorum 2:30 II. Public Participation ** III. Meeting Opening and Approval of the Agenda and Consent Agenda 1. Minutes from April 4, 2016 Board of Commissioners meeting 2. Minutes from April 28, 2016 Special Meeting of the Board of Commissioners IV. Board Development: Project Based Vouchers in a LIHTC Project 2:45 V. Action/Discussion Agenda 3:15 1. Board Business a. Board Announcements b. Outreach Committee Report c. Matters from the Executive Director i. Proposal to Add an IT Manager Position ii. Conflict of Interest Policy Next Steps iii. Open Meetings Provisions iv. Sales Tax Exemption Clarification v. Successful NAHRO, MTW and Bringing School Home Meetings 2. Operations and Finance 3:45 a. Finance Committee Report b. Bringing School Home-cost to BHP c. MTW Funding for Development Projects i. Board Action: Approval of Resolution #7: Committing MTW Reserves d. March 2016 Financial Summary e. Preference for Homeless Transitional Housing Graduates 3. Development 4:00 a. Development Committee Report 4. Resident Services 4:15 a. RRC Report b. Resident Services Update 1
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BOULDER HOUSING PARTNERS REGULAR MEETING OF ...2016/05/09 · 1. Minutes from March 7, 2016 2. Resolution #5: Revised Housing Choice Administrative Plan Commissioner Klerman called
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BOULDER HOUSING PARTNERS
REGULAR MEETING OF THE BOARD OF COMMISSIONERS
MAY 9, 2016 2:30 PM
4800 BROADWAY, BOULDER COLORADO
Our primary mission is to provide quality affordable housing that is developed and managed with respect for
the dignity of all involved. We also seek to create a sense of community strength and spirit that supports
resident efforts to realize success in their lives.
AGENDA
I. Call to order and Determination of a Quorum 2:30
II. Public Participation **
III. Meeting Opening and Approval of the Agenda and Consent Agenda
1. Minutes from April 4, 2016 Board of Commissioners meeting
2. Minutes from April 28, 2016 Special Meeting of the Board of Commissioners
IV. Board Development: Project Based Vouchers in a LIHTC Project 2:45
V. Action/Discussion Agenda 3:15
1. Board Business
a. Board Announcements
b. Outreach Committee Report
c. Matters from the Executive Director
i. Proposal to Add an IT Manager Position
ii. Conflict of Interest Policy Next Steps
iii. Open Meetings Provisions
iv. Sales Tax Exemption Clarification
v. Successful NAHRO, MTW and Bringing School Home Meetings
2. Operations and Finance 3:45
a. Finance Committee Report
b. Bringing School Home-cost to BHP
c. MTW Funding for Development Projects
i. Board Action: Approval of Resolution #7: Committing MTW Reserves
d. March 2016 Financial Summary
e. Preference for Homeless Transitional Housing Graduates
3. Development 4:00
a. Development Committee Report
4. Resident Services 4:15
a. RRC Report
b. Resident Services Update
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VIII. Update and Information Items
1. Palo Park
2. Hayden Place
3. 3480 Hayden Place Request for Proposals
4. Mount Calvary Lutheran Church
5. State Tax Exemption
6. Project Renovate
7. City, State and Federal Issues Summary
X. Closing Matters and Wrap Up
XI. Adjourn 5:00
** Any member of the public is invited to address the Board on any topic that is on, or not on, the agenda during
Public Participation. Anyone wishing to speak will have the floor for a maximum of 3 minutes.
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Please note, the numbering of the following items corresponds to the Board meeting
agenda
III. CONSENT ITEMS
1. Minutes from the Board of Commissioners Meeting, 4-9-2016
2. Ratification of the Special Meeting of the Board, 4-28-2016
Attachments:
Minutes from 4-4-2016
Minutes from 4-28-2016
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BOULDER HOUSING PARTNERS
REGULAR MEETING OF THE BOARD OF COMMISSIONERS
APRIL 4, 2016 2:30 PM
BHP OFFICE, 4800 N. BROADWAY, BOULDER COLORADO
Commissioner Klerman Betsey Martens Public:
Commissioner McCord
Commissioner Ruzzin
Commissioner Soraci
Commissioner Hagerty
Commissioner Harris
Commissioner Griffin
Commissioner Levy
Commissioner Shoemaker-absent)
Penny Hannegan
Rene Brodeur
Jim Koczela
Jeremy Durham
Sue Bohline
I. Call to order and Determination of a Quorum
Commissioner Klerman called the regular meeting of the Board of Commissioners to order at
2:30 pm. A quorum was declared.
II. Oath of Office
Commissioner Klerman administered the Oath of Office for Claire Levy and Nikki McCord as
new mayoral appointees to the Board of Commissioners. Both Ms. Levy and Ms. McCord have
been appointed for a five year term. The Board welcomed them both to the Board of
Commissioners.
III. Public Participation
There was no public participation.
IV. Approval of the Meeting Agenda and Consent Agenda
Consent agenda items approved:
1. Minutes from March 7, 2016
2. Resolution #5: Revised Housing Choice Administrative Plan
Commissioner Klerman called for an Executive Session at the end of the meeting per Colorado
Statues CRS-24-402 (4)(a) and (4)(f)to discuss Real Estate and Personnel Matters.
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COMMISSIONER MCCORD MADE A MOTION TO RECESS INTO EXECUTIVE
SESSION AT THE END OF THE MEETING PER COLORADO STATUTE C.R.S. 24-6-
402 (4)(a) and 4(F)TO DISCUSS REAL ESTATE AND PERSONNEL MATTERS.
COMMISSIONER GRIFFIN SECONDED THE MOTION. The motion passed
unanimously.
COMMISSIONER HARRIS MOVED TO APPROVE THE MEETING AND CONSENT
AGENDA INCLUDING RESOLUTION #5: THE REVISED HOUSING CHOICE
ADMINISTRATIVE PLAN. COMMISSIONER RUZZIN SECONDED THE MOTION.
The motion passed unanimously.
V. Board Development: Low Income Tax Credit’s 101
Jim gave an introduction to Low Income Housing Tax Credit (LIHTC) financing tool for
construction of new affordable housing units.
VI. Action and Discussion Agenda
1. Board Business
Board Announcements
The Conflict of Interest update discussion is scheduled for April 27 from 3:00-5:00pm.
The annual Board Tour of Properties is scheduled for Monday, May 9 from 12:00-2:30. The
focus of the tour will be the Project Renovate properties.
Outreach Committee Report
Commissioner Ruzzin reporting for the Outreach Committee stated that the Outreach Committee
had not met prior to the Board meeting but would be meeting on April 5 and report their activity
and progress at the May Board meeting.
Matters from the Executive Director
Betsey clarified the four work plan items that staff proposed be amended in the 2016 Work Plan.
The Board discussed the possible methods for notifying the public about upcoming
Commissioner Meetings. They confirmed the following:
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1. Adding a recording to the BHP phone line with a list of meeting dates and times
2. Posting the monthly meeting agenda on the News page of the website
3. Continuing to post the agenda in the BHP office lobby
4. Continuing to post the meeting packet on the website
5. Targeted advertisement in the Daily Camera for Public Hearings
6. Holding Public Hearings at 5:00 PM
COMMISSIONER HAGERTY MOVED TO APPROVE THE REVISED MEETING
NOTIFICATION PROCEEDURES. COMMISSIONER GRIFFIN SECONDED THE
MOTION. The motion passed unanimously.
2. Management and Finance
Finance Committee Report
Commissioner Klerman reporting for the Finance Committee stated that the Committee had met
and discussed year to date financials through February.
February 2016 Financial Summary
Jim gave an overview of the February 2016 financial statements.
GASB 67 & 68
Jim explained the new GASB accounting rules pertaining to BHP’s PERA contributions.
3. Development
Development Committee Report
Jeremy gave an update from the Development Committee meeting. The meeting focused on four
main real estate topics. The two new ad-hoc members, Phil Lawrence and Bob Yates were in
attendance and brought important perspectives.
Palo Park: Resolution #6: Bond Inducement for Issuing Private Activity Bonds
Jeremy and Lauren reported they had submitted the Palo Park Community project for site review
and hope to have the project presented at the Planning Board meeting at the end of May.
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Lauren explained the Bond Inducement Resolution and the use of up to $9 million of BHP’s $39
million bond allocation for the Palo Park Community project.
COMMISSIONER HARRIS MOVED TO APPROVE RESOLUTION #6: ALLOWING
FOR THE ISSUANCE OF PRIVATE ACTIVITY BONDS TO BE USED TO FINANCE
THE PALO PARK PROJECT. COMMISSIONER GRIFFIN SECONDED THE
MOTION. The motion passed unanimously.
Sales Tax Update
Jeremy gave an update about progress at the state legislature for the Sales Tax Exemption
Bill.
4. Resident Services
Resident Representative Committee Report
Commissioner Griffin reporting for the RRC stated that the RRC had donated $1,000 to the Oak
“I Have a Dream” class. The RRC has elected Robin Chavez as treasurer. Mary Green, BHP’s
AmeriCorps Vista will also be helping with the accounting. The RRC has been discussing
Community garden space at BHP sites with particular interest at Red Oak Park. Commissioner
Griffin indicated that a volunteer, Barbara Habor is continuing to work on creating a Little Free
Library for the Red Oak Park community.
VII. Executive Session per Colorado Statute C.R.S. 24-6-402(4)(a)(f) to discuss Real
Estate and Personnel matters.
COMMISSIONER MCCORD MOVED TO RECESS INTO EXECUTIVE SESSION PER
COLORADO STATUTE C.R.S. 24-6-402(4)(a)(f) TO DISCUSS REAL ESTATE AND
PERSONNEL MATTERS. COMMISSIONER SORACI SECONDED THE MOTION.
The motion passed unanimously.
The Board recessed at 4:40 pm into Executive Session as per Colorado Statue C.R.S. 26-6-
402(4)(a)(f) to discuss Real Estate and Personnel Matters.
The Board met in executive session for about one hour at which time the only matters discussed
were those related to real estate and personnel matters.
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COMMISSIONER HARRIS MADE A MOTION TO ADJOURN THE EXECUTIVE
SESSION OF THE BOARD OF COMMISSIONERS. COMMISSIONER GRIFFIN
SECONDED THE MOTION. The motion passed unanimously.
The Board returned to regular session at 5:35 pm
VIII. Closing Matters
Executive Director Performance Review
Based on an additional independent market analysis conducted to review ED salaries at other
housing authorities similar in terms of mission, size, complexity and talent, the Personnel
Committee recommended an adjustment to the current Executive Director’s salary range.
COMMISSIONER HARRIS MADE A MOTION TO ADJUST THE EXECUTIVE
DIRECTOR’S SALARY RANGE TO BETTER REFLECT MARKET CONDITIONS
AND ADJUST THE EXECUTIVE DIRECTOR’S SALARY PER BHP COMPENSATION
POLICY. COMMISSIONER GRIFFIN SECONDED THE MOTION. The motion passed
unanimously.
In the future, the Personnel Committee will review Betsey’s contract by December 31 and will
complete her performance review in January with the annual board evaluation completed at the
February Board meeting.
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VIII. Adjourn
COMMISSIONER HAGERTY MADE A MOTION TO ADJOURN THE REGULAR
MEETING OF THE BOARD OF COMMISSIONERS. COMMISSIONER SORACI
SECONDED THE MOTION. The motion passed unanimously.
The regular session of the Board of Commissioners adjourned at 5:40pm
Commissioner Klerman called the special meeting of the Board of Commissioners to order at
8:30 am. A quorum was declared.
II. Public Participation
There was no public participation.
III. Approval of the Meeting Agenda and Consent Agenda
1. Motion to adjourn into Executive Session per Colorado Statue CRS-24-402 (4)(a) to
discuss Real Estate matters.
COMMISSIONER LEVY MOVED TO RECESS INTO EXECUTIVE SESSION PER
COLORADO STATUTE C.R.S. 24-6-402(4)(a) TO DISCUSS REAL ESTATE MATTERS.
COMMISSIONER HARRIS SECONDED THE MOTION. The motion passed
unanimously.
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The Board recessed at 8:40 am into Executive Session as per Colorado Statue C.R.S. 26-6-
402(4)(a) to discuss Real Estate Matters.
The Board met in executive session for about twenty minutes at which time the only matters
discussed were those related to real estate matters.
COMMISSIONER KLERMAN MADE A MOTION TO ADJOURN THE EXECUTIVE
SESSION OF THE BOARD OF COMMISSIONERS. COMMISSIONER HARRIS
SECONDED THE MOTION. The motion passed unanimously.
The Board returned to regular session at 8:50 am
VIII. Closing Matters
COMMISSIONER HARRIS MADE A MOTION TO AUTHORIZE BETSEY TO SIGN A
LETTER OF INTENT AS DISCUSSED IN EXECUTIVE SESSION ON APRIL 28, 2016.
COMMISSIONER LEVY SECONDED THE MOTION. The motion passed unanimously.
IX. Adjourn
COMMISSIONER KLERMAN MADE A MOTION TO ADJOURN THE SPECIAL
MEETING OF THE BOARD OF COMMISSIONERS. COMMISSIONER HARRIS
SECONDED THE MOTION. The motion passed unanimously.
The special session of the Board of Commissioners adjourned at 9:00 am
Seal
DATE: 4/28/16
KAREN KLERMAN, CHAIR
Boulder Housing Partners
BETSEY MARTENS
Executive Director
Penny Hannegan
Recording Secretary
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V. ACTION/DISCUSSION AGENDA
1. ACTION/DISCUSSION AGENDA: BOARD BUSINESS
a. Board Announcements
b. Outreach Committee Report
c. Board Development
As our Board Development topic this month, Jim will be continuing last month’s
presentation about the Low Income Housing Tax Credit (LIHTC) and this month
demonstrating how, and why, we pair the tax credit with a Project Based Voucher. Project
Renovate will be the example. He’ll also review the differences between RAD vs Section
18 vouchers.
d. Matters from the Executive Director
1. Proposal to Add an IT Manager Position
Two key employees who manage BHP’s office systems have recently announced plans to
leave the organization. Our Office Manager is retiring at the end of 2016 and our Software
Application Specialist (SAS) is pursuing a new opportunity. We are taking this opportunity
to reevaluate our overall approach to IT. As we analyzed the projects that were most
difficult in 2016, all of them had a diagnosis related to the absence of integrated technology
management. We are asking the Board to consider the addition of an Information
Technology Manager which would be the addition of an FTE in the 2016 budget. Below
you will find additional background and a more detailed rationale for this addition.
Background
The office manager is currently responsible for all hardware including servers, desktop
computers, laptops, office and cell phones, tablets and networks, desktop software, remote
office setup and maintenance, printers and Wi-Fi. Much of the technical aspects of this
work, including managing the network setup, server maintenance, backup and system
security are outsourced to a contractor, Klein Design. The office manager manages the IT
contract. In addition to the work by Klein, one Administrative Assistant is dedicated to IT
support. The office manager reports to Penny.
Our enterprise software system, Yardi is managed by a software application specialist
(SAS) who supervises the Assistant SAS. This work includes system administration, user
management, evaluation of business requirements for new modules and custom
development. More recently, this position has taken on the evaluation of any new
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operational software products considered by BHP to determine upfront what interface with
Yardi might be necessary if it is even possible. The SAS position reports to Jim.
Proposal
Our proposal is to combine the IT function which is currently spread between the Admin
and Finance departments into one team that would include the SAS, the Assistant SAS, the
IT Administrative Assistant and a new FTE position of Information Technology Manager.
We can no longer continue to have this responsibility within the Office Manager position as
it has grown too demanding, and requires the technical expertise, analysis and strategic
planning outside of this position’s purview. In addition to centralizing decision-making,
and supervision of our technology, the IT Manager position will bring several strategic
benefits:
Coordinate and plan our growth of community centers and property-based offices;
Allow for better coordination of our long term IT strategy and future growth;
Assure that our staff are working without system disruption, particularly in the
remote offices;
Assure that our staff are maximizing their use of current technology and analyze
and advocate for new and emerging technologies;
Provide some cross training for other IT staff in order to reduce our exposure to the
departure of one critical person.
Allow for the development of consistent management practices for resolving issues.
Allow for integrated approach between system hardware requirements, Yardi
interfaces and business needs when reviewing new software products
Budget Impact
While a position with the necessary technical expertise would likely require a salary in the
$80-90K range there may be some potential savings in the contract with our third party
contractor if we could bring some of that expertise in-house. We currently pay Klein
Design approximately $28,000 per year. There would also be potential savings in the
salary required for the office manager position. Jim has confirmed that BHP will have
additional revenue to offset the additional cost of this position in 2016.
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2. Conflict of Interest Policy Next Steps
We were not able to generate threshold attendance at the proposed special meeting to
discuss the conflict of interest policy revisions. Instead, we will schedule a full Board
discussion at the June meeting. We’re attaching a copy of the draft proposal. Please review
it prior to the June meeting and send Betsey your questions so that we can be prepared to 1)
answer them fully, and 2) organize the discussion around your primary questions.
Attachments:
Draft Ethical Standard of Conduct Policy
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Page 1 of 9
BOULDER HOUSING PARTNERS
ETHICAL STANDARDS OF CONDUCT POLICY
I. STATEMENT OF PURPOSE AND APPLICATION
The purpose of this Ethical Standards of Conduct Policy (“Policy”) is to A) establish
ethical requirements and standards of conduct for current and former Boulder Housing
Partners (BHP) employees and Board Members; B) to encourage BHP Board Members
and employees to maintain the highest standard of conduct to justify the public trust that
they enjoy; and C) foster public trust by defining standards of honest government and
prohibiting the use of their position with BHP for private gain.
This policy shall be applied so as to avoid the appearance, or actual occurrence of,
any favoritism or special treatment toward any Board Member, employee, applicant,
resident, or vendor, having business, or dealings of any kind, with Boulder Housing
Partners.
BHP is a housing authority established and governed by the Colorado State housing
law, Colorado Revised Statutes (CRS) Title 29, Article 4, including Section CRS 29-4-
207 -- Interested commissioners or employees. Furthermore, as a housing authority
created under State law, BHP is also governed by CRS 24-18-101 -- Code of Ethics, in
general and as it relates to BHP Board Members specifically under CRS 24-18-108.5 --
Rules of Conduct for members of boards and commissions. Such statutory requirements
are made a part of this Policy.
Furthermore, BHP from time-to-time enters into contracts and agreements with the
U.S. Department of Housing and Urban Development to develop, acquire, and manage
certain housing. When such contracts are Annual Contribution Contracts, they contain
specific conflict of interest requirements (See Appendix A, entitled Section 19 - Conflict
of Interest, HUD Annual Contributions Contract, Form HUD-53012A). These
requirements also are made part of this Policy and they shall apply when the nature of the
activity, action, interests, or decision-making of a BHP Board Member or employee
involves properties and/or activities covered by such Annual Contribution Contracts.
BHP may from time-to-time also enter into other contracts and agreements that
impose other statutory or contractual standards of conduct. When such provisions apply
to a BHP Board Member or employee, they too shall be adhered to.
BHP in establishing its Ethical Standards of Conduct Policy has also considered and
attempted to reflect, where it has determined appropriate, the local standards of the City
of Boulder.
When there is a conflict between these various applicable requirements (including
those stated below) the most stringent and strict requirements shall apply.
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Page 2 of 9
II. SERVING BHP INTERESTS
The purpose of BHP is to serve the interests of BHP and the general population that it
serves and not the personal interests of Board Members, employees or the individual
interests of elected or appointed officials. All Board Members and employees have a
fiduciary responsibility to take actions and do what is in the best interest of BHP.
III. DEFINITIONS
Immediate Family Member shall mean a spouse, domestic partner, partner in a
civil union, child, and whether related directly or through adoption or marriage, a child,
parent, brother or sister.
Interest shall mean a benefit or anything of value accruing directly or indirectly to a
Board Member or employee. A Board Member or employee is deemed to have an
Interest if any of the following have an Interest:
(1) An Immediate Family Member;
(2) Any person or business entity with whom a contractual relationship exists with
the Board Member or employee;
(3) Any business entity in which the Board Member or employee is an officer or
director; or
(4) Any business entity in which the Board Member or employee has a stock, legal
ownership, or beneficial ownership of at least five percent of the total stock or
total legal and beneficial ownership, or which is controlled or owned directly or
indirectly by the Board Member or employee.
A benefit or interest shall not include any situation in which the Board Member,
employee, or family member has only a Remote Interest. A benefit does not include
things that affect the entire membership of a significant class or a significant
segment of the community in a similar manner as the affected Board Member or
employee.
Not Participating in a decision, selection, award or administration of a contract
shall mean not discussing the matter in or outside meetings, not being physically present
for any discussions and neither voting on nor being present for a vote. Furthermore, it
means not using a BHP position to influence in any way a decision in which the Board
Member or employee has a personal interest.
Remote Interest shall mean any interest which is incidental to a contract or
transaction and shall include:
(1) A position as a non-salaried director, officer or employee of a non-profit
corporation or organization;
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(2) Less than five percent of the total stock or total legal and beneficial ownership in
a business entity;
(3) A position of employment held by a Board Member, employee or a family
member which is not a director, officer, manager or supervisor in a business
entity;
(4) A position of employment held by a Board Member, employee or a family
member which does not directly exercise decision making authority affecting a
contract or transaction; or
(5) A position in a representative capacity such as a receiver, trustee or
administrator.
IV. WAIVERS
The Policy is intended to apply in all cases. However, in rare and unique
circumstances, and only in those cases where it is expressly authorized in this Policy, a
special waiver of particular requirement can be considered and approved by the BHP
Board. In the case of this particular Policy, this waiver may occur only if (1) Board
Members with personal direct or indirect interests abstain from and are not present for
both the Board’s deliberations and decision, (2) full and complete public disclosure of a
waiver request occurs before, during, and after a vote, (3) a two-thirds (2/3) favorable
vote of all Board Members appointed is obtained and (4) the waived Policy provision is
not required by federal, state, or local law. Some waivers will require concurrence and
approval by HUD. If the Board is unsure as to which provisions are required by federal,
state or local law, they shall consult with legal counsel.
V. REQUIREMENTS
A. PROHIBITED ACTS.
1. No Board Member or employee shall solicit, receive or accept anything of value
in exchange for performing or refraining from performing any act associated with the
Board Member’s or employee's position with BHP. See also, Section VI “Gifts and
Donations,” below.
2. No Board Member or employee shall use his or her position with BHP for
financial gain. For employees, financial gain does not include regular salary and benefits.
3. No Board Member or employee shall use or disclose confidential information
obtained as a result of holding his or her position. See also, Section VII “Confidentiality
and Privileged Information,” below.
4. No Board Member or employee of BHP shall acquire any Interest in any project
or in any property included or planned to be included in any project, nor shall they have
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any Interest in any contract or proposed contract for materials or services to be furnished
or used in connection with any project. If any Board Member or employee of BHP owns
or controls an Interest in any property included or planned to be included in any project,
they shall immediately disclose the same in writing to BHP, and such disclosure shall be
entered upon the minutes of the BHP Board. Failure to so disclose such interest shall
constitute misconduct in office.
5. No Board Member or employee shall appoint, hire, or advocate for the
appointment or hiring by BHP any person who is his or her relative. In the event that an
employee is concerned that the employee's decision to appoint, hire or advocate for the
appointment or hiring by BHP a person who is the employee's relative may cause an
appearance of violating this Policy, the employee may request that the Executive Director
make such decision on the employee's behalf. Board Members may request the remaining
un-conflicted Board Members to make such an appointment or hiring decision on their
behalf.
B. CONFLICTS OF INTEREST ARISING BEFORE, DURING, AND
AFTER POSITION AT BHP.
The duties and responsibilities of Board Members and employees are to act in the
best interest of BHP. These duties are not to conflict with personal interests of Board
Members or employees nor shall there be the appearance of any such conflicts of interest.
1. Board Members. BHP Board Members are prohibited from entering into,
proposing or acquiring a contract, subcontract, or Interest, in any BHP project or activity.
Former Board Members are prohibited for a period of twelve (12) months after their
tenure on the Board from employment, acquiring a contract, or an Interest, in any BHP
project or activity. This requirement may be waived in rare and unique cases, but only
after compliance with the provisions of Section III hereof.
2. Employees. BHP employees are prohibited from entering into, proposing or
acquiring a contract, subcontract, or other Interest, in any BHP project or activity.
Employees who have such Interests prior to being hired must divest themselves of those
Interests in order to be hired, except in the case of an employee who has a Remote
Interest, a membership, or is a non-employee Board Member of a community based not-
for-profit entity.
Former employees are prohibited for a period of twelve (12) months after termination of
their employment from having a contract or Interest, in any BHP project or activity in
which the former employee either (A) had a substantial involvement in BHP procuring or
awarding that contract, project or activity or, (B) was a senior official of BHP
administering that contract, project or activity. This latter requirement may be waived by
the Executive Director in rare and unique circumstances but only after full and public
disclosure and a determination that this interest is not obtained because of non-public
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information obtained because of the prior employment.
3. Award and Administration of Contracts. No employee or Board Member shall
participate in a decision, selection, award, administration of a contract or a BHP
determination if in fact or by appearance the Board Member or employee, has a contract
or Interest, in that BHP project or activity. In addition, to other disclosure requirements
contained elsewhere in this Policy, Board Members, employees, and the BHP Board shall
strive to openly and publicly disclose these Interests whenever there is even merely a
question of a conflict of interest and no matter whether it is permitted, restricted or
prohibited.
4. Disclosure and Recusal Procedure. It is important in addressing all Board
Member and employee conflicts of interests for all BHP Board Members and employees
to disclose to the public, as well as to BHP, their Interest, in any BHP project or activity.
(a) An employee or Board Member with an Interest prohibited by this Policy shall
give written notice of such Interest to the BHP Board and Executive Director as soon
as reasonably possible after the Interest has arisen. However, no written notice is
required if such person discloses the conflict of interest on the record of a public
meeting of the BHP Board. The interested employee or Board Member shall
thereafter:
(1) Refrain from voting upon or otherwise acting in an official capacity in such
transaction;
(2) Physically absent himself or herself from the room in which a matter related
to such transaction is being considered; and
(3) Not discuss any matter related to such transaction with any other member of
the council, board, commission, task force or similar body of which the person is
a member.
(b) Recusal by the BHP Board: The BHP Board may order recusal of one of its
members if that member has an obligation to do so under this Policy and has failed to
do so. Such an order is valid if reached after majority vote of the members of the
Board, not including the member whose recusal is sought, based on competent
evidence.
5. Program Participants. Nothing in this Policy shall prohibit a BHP program
participant, who is a Board Member or employee from fully participating in BHP
activities and decision making so long as those activities and that decision making is not
particular and unique to their unit, application, contract or BHP activity.
6. Prior Employment and Change in Employment.
(a) Prior Employment: No person shall be disqualified from service with BHP as a
Board Member or employee solely because of his or her prior employment. Board
Members and employees shall not take any action with respect to their former employers
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for a period of six months from the date of termination of the prior employment if such
action involves an exercise of discretion by the Board Member or employee and provides
direct benefit to the prior employer, including but not limited to a contract, lease,
employment or regulatory approval.
(b) Disclosure by Board Members: Board Members shall report any change in their
employment status that could give rise to a conflict of interest under this Policy.
VI. GIFTS AND DONATIONS
A. GIFTS. BHP Board Members, employees, agents, grantee’s or grantee’s officers
or employees will not solicit, nor accept, anything deemed by this Policy to have a
significant monetary value from contractors, potential contractors, or parties to
agreements. This includes gifts and gratuities.
(1) No Board Member or employee or Immediate Family Member of a Board
Member or employee shall accept anything of value including, without limitation, a gift,
a favor, a discount or a promise of future employment from anyone that is known to have
or to be likely to have a transactional, business, or regulatory relationship with BHP.
(2) Exceptions and Items not Considered Gifts: The following shall not be considered
gifts for purposes of this section, and it shall not be a violation of this chapter for a person
to accept:
(a) Campaign contributions as permitted by law;
(b) An unsolicited, occasional non-cash gift of a maximum amount of $53 or less in
value. The maximum amount will be equal to the amount established by the
state of Colorado pursuant to Colorado Constitution Article XXIX, Section 6;
(c) A gift from a relative;
(d) An award, publicly presented, in recognition of public service;
(e) Items which are similarly available to all employees of the city or to the general
public on the same terms and conditions.
B. DONATIONS. BHP may solicit and accept donations to its programs, however,
all such solicitations and donations shall be open, public, recorded and disclosed at Board
Meetings and must be for the sole benefit of BHP and not particular employees,
contractors or Board Members. Furthermore, no donations shall be solicited, offered or
made while the party donating is seeking or being considered for a contract or benefit and
no donation shall be considered or accepted if it would in any way influence the award of
a contract or a benefit or give the appearance of such possible effects.
C. PARTICIPANT GIFTS OR PAYMENTS. No employee or Board Member,
or his or her Immediate Family Member, who has any authority, control or influence in
their official capacity shall accept any gift or money from a tenant, homebuyer, program
participant or applicant if it would reasonably appear or if in fact such a gift was an
attempt to influence that employee or Board Member’s actions at the BHP.
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Page 7 of 9
VII. CONFIDENTIALITY AND PRIVILEGED INFORMATION.
A. No Board Member shall disclose privileged or confidential information without a
public majority vote granting the permission of the BHP Board. The sanction for a
member of the Board shall be censure of the body or other discipline as provided under
the Board Bylaws, reached by a majority vote of the body, not including the member
charged with disclosing such confidential information.
B. No employee shall disclose privileged or confidential information, obtained as a
result of holding his or her position with BHP unless the employee has first received
approval by the Executive Director acting upon the advice of the BHP attorney.
C. No Board Member or employee shall use or disclose confidential information
obtained as a result of holding his or her position, to obtain financial gain, whether for
personal gain; gain for his or her relative; gain of any property or entity in which the
Board Member or employee has a substantial interest; or gain for any person or for any
entity with whom the Board Member or employee is negotiating for or has any
arrangement concerning prospective employment.
VIII. DISCLOSURE OF POLICY VIOLATIONS. All Board Members and
employees are required to promptly disclose to BHP their acts or conduct and all acts or
conduct by other BHP Board Members and employees, agents, grantees, contractors,
tenants, or program recipients that are illegal or are in violation of this Policy and other
BHP policies. Disclosure can be to the Executive Director, the BHP Board, individual
Board Members, or BHP attorneys. If the act or conduct was by the Executive Director,
the disclosure should be made to the Board Chair. There shall be no retaliation or other
punitive action taken against anyone who makes a disclosure under this section when the
activities disclosed turn out to be a true violation.
* * *
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Page 8 of 9
APPENDIX A
Section 19 - Conflict of Interest
HUD Annual Contributions Contract, Form HUD-53012A (7/95)
Section 19 – Conflict of Interest.
A)(1) In addition to any other applicable conflict of interest requirements, neither the HA
nor any of its contractors or their subcontractors may enter into any contract,
subcontract, or arrangement in connection with a project under this ACC in which
any of the following classes of people has an interest, direct or indirect, during his
or her tenure or for one year thereafter:
i. Any present or former member or officer of the governing body of the
HA, or any member of the officer’s immediate family. There shall be
excepted from this prohibition any present or former tenant
commissioner who does not serve on the governing body of a resident
corporation, and who otherwise does not occupy a policymaking
position with the resident corporation, the HA or a business entity.
ii. Any employee of the HA who formulates policy or who influences
decisions with respect to the project(s), or any member of the
employee’s immediate family, or the employee’s partner.
iii. Any public official, member of the local governing body, or State or
local legislator, or any member of such individuals’ immediate family,
who exercises functions or responsibilities with respect to the
project(s) or the HA.
2) Any member of these classes of persons must disclose the member’s interest or
prospective interest to the HA and HUD.
3) The requirements of this subsection (A)(1) may be waived by HUD for good
cause, if permitted under State and local law. No person for whom a waiver is
requested may exercise responsibilities or functions with respect to the contract
to which the waiver pertains.
4) The provisions of this subsection (A) shall not apply to the General Depository
Agreement entered into with an institution regulated by a Federal agency, or to
utility service for which the rates are fixed or controlled by a State or local
agency.
5) Nothing in this section shall prohibit a tenant of the HA from serving on the
governing body of the HA.
B)(1)The HA may not hire an employee in connection with a project under this ACC if
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Page 9 of 9
the prospective employee is an immediate family member of any person belonging
to one of the following classes:
i. Any present or former member or officer of the governing body of the
HA. There shall be excepted from this prohibition any former tenant
commissioner who does not serve on the governing body of a resident
corporation, and who otherwise does not occupy a policymaking
position with the HA.
ii. Any employee of the HA who formulates policy or who influences
decisions with respect to the project(s).
iii. Any public official, member of the local governing body, or State or
local legislator, who exercises functions or responsibilities with
respect to the project(s) or the HA.
2) The prohibition referred to in subsection (B)(1) shall remain in effect
throughout the class member’s tenure and for one year thereafter.
3) The class member shall disclose to the HA and HUD the member’s familial
relationship to the prospective employee.
4) The requirements of this subsection (B) may be waived by the HA Board of
Commissioners for good cause, provided that such waiver is permitted by
State and local law.
C) The requirements of subsections (A) and (B) of this section do not apply to
contracts entered into by an Indian Housing Authority, its contractors or
subcontractors, although such contracts remain subject to other applicable conflict
of interest requirements.
D) For purposes of this section, the term “immediate family member” means the
spouse, mother, father, brother, sister, or child of a covered class member (whether
related as a full blood relative, or as a “half” or “step” relative, e.g., a half-brother
or stepchild).
* * *
24
3. Open Meetings Provisions
At the last meeting we suffered some confusion about the number of Commissioners that
constitute a meeting. Thanks to Claire for clarifying the Open Meetings Law requirement
that differentiates between a “local public body” and a “state public body”. It turns out that
a local public body has the standard that three or more gathered officials (or a quorum)
constitute a meeting.
By motion of the Board we would like to modify our Governance Document as follows:
Board members agree to adhere to the provisions of the Colorado laws concerning
Open Meetings. The Colorado Legislature first passed its “Sunshine Law” in 1973
requiring disclosure of private interests by public officials; regulating lobbying ,
and requiring open meetings of all meetings of local public bodies of two three or
more members of any board, committee, commission, or other policy making or rule
making body of any state agency or authority.
4. Sales Tax Exemption Clarification
You’ll read below in the Development Report that the bill to clarify and extend sales tax
exemption for LIHTC, and other, partnerships has now passed both the House and the
Senate and awaits the Governor’s signature. What you won’t read is the key role that
Jeremy Durham played on the team that worked on bill passage. Jeremy was instrumental
in crafting the final language and helping Representative KC Becker find solutions to
challenges as they emerged. Thanks to Jeremy.
5. Successful NAHRO, MTW and Bringing School Home Meetings
As described last month, Betsey spent two weeks in April attending the NAHRO and MTW
conferences, as well as participating in the NAHRO delegation to Canada to talk about best
practice principles for affordable housing. Highlights include:
Thanks to Karen Klerman and Penny who attended the NAHRO Legislative
Conference in D.C. and led our delegation visit to Congressman Polis’ office. We
re-established our good contacts with his office and outlined our legislative
priorities for 2017.
Thanks to Karen Kreutzberg who served on the MTW conference planning
committee and was responsible for three sessions at that annual conference. Rene
also presented a workshop on Dream Big/Bringing School Home and Betsey did a
keynote also on Bringing School Home. The BHP team was rounded out by Jim and
Karin Stayton.
The four-country convening drafted the following set of principles that is now being
circulated for finalization:
o Public investment must be structured as a perpetual or permanent covenant
25
o Affordable housing should be employed as a key tool in creating healthy
communities
o Affordable housing needs to be managed within a measurement-driven
outcome framework
o Communities must consider the broad spectrum of housing needs in their
housing strategies
o Developing sustainability in the social housing structure must be factored
into funding for housing projects
o National housing strategies need to have local implementation flexibility
o Public funds invested in land require ownership by a public or mission-
focused entity.
o Governments need to invest in an institutional approach to developing talent
and knowledge in the housing sector
o The private sector needs to be responsibly engaged in affordable housing
strategies
The Bringing School Home meetings led to a growing and interested network of
fans of the concept. The meetings, particularly with the Rockefeller Foundation,
affirmed that our approach of providing an evidence basis for our request for large
grants funds is the right one. There is reason to be hopeful that a slow and steady
campaign for research funding will be successful.
26
2. ACTION/DISCUSSION AGENDA: OPERATIONS AND FINANCE
a. Finance Committee Report
b. March 2016 Financial Summary
27
Bringing School Home
At the last Board meeting, Commissioner Hagerty asked for a breakdown of how much Bringing
School Home was costing BHP. The following is a summary reminder of what Bringing School
Home is and how we are looking at the costs for 2016.
BHP adopted a Strategic plan in 2014 with five strategic goals. Goal #3 included the following:
Invest in focused service and educational programming to improve the economic futures
of children in BHP households. Develop successful partnerships to provide service
coordination to work-abled adults, seniors, and people living with disabilities in order to
improve or preserve independence and quality of life.
Strategy – 3.A:
BHP will partner with resident families and organizations to provide comprehensive
educational and support programs as a means of minimizing barriers to learning and
preparing BHP youth for success.
Bringing School Home (BSH) is the name of the educational programming we are providing
families to help close the achievement gap for children in BHP housing. It includes early
childhood education, I Have Dream programing and pre-collegiate support for students.
There are some incremental costs related to (1) Betsey’s travel which was, along with her time to
work on her fellowship, approved in advance by the Board and is largely focused on fundraising
to bring more resources to the Bringing School Home program, and (2) our contribution of
$5,000 this year to the larger Dream Big initiative that has now leveraged almost $600,000 of
support from Boulder community organizations.
The new community centers at the Boulder Community sites where we expect to have IHAD
programming were planned as additions to the project before we knew what the programming
would be, so while important to our ability to deliver this program to our residents they should
not be considered as a cost of BSH. The cost of operating the centers will be mostly IHAD.
Boulder Communities will participate in the costs of cleaning and maintenance related to the
office space we will be using at the sites.
There is no new cost associated with BSH for BHP because existing staff are now focused on
children in an education context rather than a family services coordination focus. Therefore
there is no new cost to providing the services. The staff focused on BSH are all in the 2016
budget (not new FTE) and paid for from resident services fees paid by the sites (mostly tax credit
sites) to BHP.
The following chart shows the 2016 budgeted sources and uses for the program.
128
Bringing School Home - Direct Cost Analysis
Sources:
Property: Units Annual Fee
Boulder Communities - Family Sites 134 80,400$
Broadway East 44 22,176$
Red Oak Park 59 22,656$
Totals 237 125,232$
Uses:
Program Staffing:
Early Childhood Coordinator 55,000$
Pre Collegiate Coordinator (vista) 12,000$
Oak Class - Support for IHAD 32,000$
Totals 99,000$
Net Income from program for overhead 26,232$
Other related costs:
Betsey fellowship travel approved by Board 6,000$
Cash Contribution to Dream Big 5,000$
11,000$
229
MTW funding for Development Projects
Board Action requested:
Approval of Resolution 2016-7 committing MTW reserves in the amount of up to $850,000 to
reimburse BHP for its equity investment in Orchard Grove and Hayden Place Two.
Background:
Related to the MTW contract extension reported under Matters from the Executive Director,
HUD has added a contract provision that would allow Congress to take action to recapture MTW
reserves. Given this new possibility, any MTW reserves in excess of four months of operating
costs (excluding HAP) could be at risk of recapture by HUD. In consideration of the number of
projects for which reserve funds are needed, we want to take action now to protect those funds
for BHP projects in progress.
HUD reported the balance of BHP’s HUD held funds as of January 13, 2016 as $1,124,585. In
addition, BHP currently has accumulated HAP funds as of March 31, 2016 of $729,725.
Proposed Plan:
In 2015 HUD approved the following activity in our MTW plan:
Activity 2015-1: Affordable housing acquisition and development fund. This activity
allows BHP to utilize MTW reserves to purchase land and/or improvements, or
participate in project ownership/development by providing financial support, or
contribute on direct construction or rehabilitation costs….Costs of site acquisition and
construction or rehabilitation of sites may be borne directly by BHP or in a joint venture
with another developer/partner.
We are proposing that we utilize some of the funds that we have accumulated both in HUD-held
funds and our reserves to pay for some development activities. This action will replenish BHP’s
unrestricted reserves and better position us for quick action on future opportunities. Attached is
a full analysis of the funds currently held, a set-aside for potential overspending of HAP in 2016
in the event we do not see the attrition expected in the budget and an additional set-aside of one
month of HAP funds resulting in funds available of $1,161,539.
Proposed Action steps:
1) Request that HUD provide us with HUD-held reserves of $484,635 to repay BHP for our
2015 investment in the Orchard Grove land.
2) Utilize our BHP-held reserves to repay BHP for the amount of equity we will have in
Hayden 2. This amount will be defined with the completion of the appraisal and the
related calculation of the amount of financing we are able to get and confirmation of the
City’s investment. The BHP equity invested is expected to be no more than $365,365.
330
3) Determine the 2016 public housing funding.
4) Assess priorities for using the balance of the reserves. The current top priorities are:
• Provide funding of additional contingency for Boulder Communities, LLLP for
Sales Tax or other costs, if needed.
• Provide gap funding for Palo Park, if needed.
431
532
RESOLUTION # 7
SERIES OF 2016
COMMITMENT OF MTW RESERVES FOR DEVELOPMENT ACTIVITIES
WHEREAS, Boulder Housing Partners is a Moving-to-Work (“MTW”) agency; and
WHEREAS, MTW agencies have the authority to utilize MTW funds for any approved MTW
activity; and
WHEREAS, the Board has approved the operating and capital budget and reserve contributions
for 2016, and
WHEREAS, BHP has made certain investments into land and units that are allowable under
MTW Activity 2015-1: Affordable housing acquisition and development fund, and
WHEREAS, The Board of Commissioners intends that MTW reserves be committed and used
to reimburse BHP for equity invested in the land acquisition of Orchard Grove and the
acquisition of 6 units of affordable housing at Haden Place Two.
NOW, THEREFORE, be it resolved that the Board of Commissioners consistent with HUD’s
requirement for MTW agencies adopts the following Committed MTW Reserves for affordable
housing and acquisition development fund.
Purpose Amount
Equity contribution for Orchard Grove land $484,635
Equity contribution for Hayden Place Two $365,365
$850,000
Adopted this 9th day of May, 2016
(SEAL)
_______________________________
Karen Klerman,
Chair, Board of Commissioners
Boulder Housing Partners
ATTEST:
_______________ __________
BETSEY MARTENS
Executive Secretary
33
March 2016 – Financial Summary
The following summarized financial statements show BHP and the Component Units (Tax Credit LLLPs) side by side. With the addition in 2015 of Boulder Communities, the Component Units have become a more significant part of the BHP portfolio. BHP owns only .01% interest in the Component Units and adding the two columns together is not an appropriate disclosure, however the report will provide you with a better understanding of the full scope of the real estate under BHP management. BHP is the operating company that manages all of our programs. The BHP column below includes development, property management, maintenance, resident services, finance, administration, the Housing Choice Voucher program and the BHP-owned portfolio of properties. The BHP portfolio is made up of 507 units: 47 public housing units, 116 project based contract units and 350 workforce and market rate units. The Component Units includes strictly the property operations for the nine tax credit partnerships which currently include 596 units. The partnerships are expected to have a positive net operating income and a net loss each year after deducting debt and depreciation.
Component Units
BHP (Tax Credit LLLPs)
REVENUE
Operations Revenue 1,754,351 1,425,114
Fee Revenue 405,170 0
Grants and Subsidies 2,574,101 0
Other Revenue 767,748 39,684
Total Revenue 5,501,371 1,464,798
EXPENSES
Salaries and Benefits 1,306,932 140,726
Property Costs 544,444 631,593
Operating Costs 2,833,277 181,988
Total Operating Expenses 4,684,653 954,307
Total Operating Income 816,718 510,491
Less: Non Operating Expenses
Depreciation 732,110 858,959
Mortgage and Note Interest 311,335 356,967
Total Other Unrealized Gain/Loss 0 (39,094)
TOTAL NET INCOME (LOSS) (226,727)$ (744,528)$
BHP and Component Units
Statement of Activities
Year to date - March 31, 2016
634
Component Units
BHP (Tax Credit LLLPs) ASSETS
Current Assets
Unrestricted Cash and Cash Equivalents 3,509,524 1,316,483
Reserved Cash - Replacements and Other 1,622,864 1,657,009
Accounts Receivable 453,481 15,963
Accounts Receivable-Tax Credits 93,739 0
Notes Receivable – Current 13,353 0
Prepaid Expenses 87,429 143,987
Supplies-Inventory 2,831 0
Other Current Assets 650,833 159,950
Total Current Assets 5,783,222 3,133,442
Restricted Cash 731,645 467,635
Capital Assets 44,449,195 104,593,951
Other Assets
Notes Receivable 56,612,762 0
Interest Receivable Notes 1,747,604 0
Partnership Investments 399,530 0
Net Amortized Costs 1,123,314 782,150
Total Other Assets 59,883,210 782,150
TOTAL ASSETS 110,847,272$ 108,977,177$
LIABILITIES & EQUITY
LIABILITIES
Current Liabilities 2,096,647 1,895,331
Long-Term Liabilities
Notes Payable 3,070,006 57,105,499
Accrued Interest Payable 55,075 1,747,604
Mortgages Payable 32,517,065 21,258,547
Bonds Payable - 2,172,027
Net Pension Liability 5,330,694
Total Long-Term Liabilities 40,972,840 82,283,677
TOTAL LIABILITIES 43,069,487 84,179,009
EQUITY 67,777,785 24,798,169
TOTAL LIABILITIES AND EQUITY 110,847,272$ 108,977,177$
BHP and Component Units
Balance Sheet
March 31, 2016
735
Boulder Housing Partners Results - March, 2016
March YTD results for Boulder Housing Partners are tracking very close to budget with a positive variance in revenue related to HAP funding from HUD offset by additional HAP costs. No major variances have arisen yet this year.
Variances are further explained on the attached financial statements
Year to Date Results - March 31, 2016
Actual Revised Budget Variance
Revenue 5,501,371$ 5,054,613$ 446,758$
Expenses (5,728,097) (5,757,262) 29,165
Total Net Income (Loss) (226,727)$ (702,649)$ 475,923$
March-16
Net Rental
Income - YTD
Net Rental
Income -
Budget
Revised
Budget
Variance
Variance
%
Physical
Occ YTD
Physical
Occ
Budget
Occupancy
Variance to
Budget
Public Housing $169,328 $155,235 $14,093 9.08% 98.58% 97.00% 1.58%
Note: Physical Occupancy is measured as of 1st of the month. Units may be occupied after the 1st of the month resulting in
rental income greater than physical occupancy would suggest. Rents on occupied units may also be greater or less than
budgeted resulting in additional variances.
(1) Canyon Pointe budget erroneouly included a rental subsidy increase that will not go into effect until April 2016. Should
begin to catch up .
836
Financial Measures
The following three measures are indicators of financial stability. Goals are based on HUD standards for PHAs. All three meet or exceed our target.
Component Units (Tax Credit LLLPs) Results The following is a Summary Income Statement for our Tax Credit Entities which are component units of BHP. BHP is subject to Government Accounting Standards Board (GASB) Statement 61 which requires component units to be reported on the audit statement. These Tax Credit Entities are related to BHP but do not meet the criteria for consolidation. Component units are reported in the audit combined together but not combined with the statements of BHP. The current component units are Boulder Communities, Broadway East, Broadway West, Holiday, High Mar, Lee Hill, Red Oak Park, Vistoso and Westview. Year-to-date results are in line with budget.
Financial Measure Explanation Goal March-15
BHP Debt to Equity Ratio Measures ratio of Actual Debt and Interest to
Equity
Less than
1.50.5
BHP Quick Ratio - Unrestricted
cash/current liabilities
Measure of how many times we can pay current
liabilities with Cash on Hand or "liquidity"
Greater
than 2.02.9
Months Expendable Net Assets Ratio
(MENAR) Measures adequacy of reserves
Greater
than 4.06.2
Tax Credit Entities (Component Units) Summary Statement of Activities
Year to Date Results - March 31, 2016
Actual Budget Variance
Operations Revenue 1,425,114$ 1,381,611$ 43,503$
Other Revenue 39,684 30,953 8,732
Total Revenue 1,464,798$ 1,412,564$ 52,234$
Salaries and Benefits 140,726$ 153,057$ 12,331$
Property Costs 631,593 591,130 (40,463)
Operating Expenses 181,988 206,336 24,349
Total Operating Expenses 954,307 950,524 (3,783)
Net Operating Income 510,491 462,040 48,451$
Depreciation and Amortization 858,959 985,951 126,992 A
Mortgage and Note Interest 356,967 497,998 141,031 B
Gain Loss on Swap (39,094) 0 (39,094)$
Total Net Income (Loss) (666,341)$ (1,021,909)$ 277,381$
Note: these properties are expected to have a Net Loss resulting from depreciation and amortization.
They are cash flow positive yet provide the investor with expected tax losses.
A
B Boulder Communities interest is being capitalized rather than expensed during construction.
Budgeted Depreciation for Boulder Communities was based on an estimate of when units would be
completed.
937
The following is a summary of the Balance Sheet for the Tax Credit Entities. BHP is the general partner and owns a .01% interest in these Entities.
This chart shows our YTD occupancy statistics for the combined Tax Credits and Boulder Communities. Boulder Communities is shown separately due to the higher vacancy resulting from the construction process.