HomeMy WebLinkAbout02 PROMISSORY NOTE SETTLEMENT AGREEMENT WITH DOF Agenda Item 5P2
Reviewed:
AGENDA REPORT City Manager tLto
Finance Direvor N/A
MEETING DATE: NOVEMBER 18, 2014
TO: JEFFREY C. PARKER, CITY MANAGER AND SUCCESSOR AGENCY &
HOUSING AUTHORITY EXECUTIVE DIRECTOR
FROM: CITY MANAGER'S OFFICE
SUBJECT: PROMISSORY NOTE SETTLEMENT AGREEMENT WITH THE
STATE OF CALIFORNIA DEPARTMENT OF FINANCE
SUMMARY
Approval s requested to enter into a Promissory Note Settlement Agreement
("Settlement Agreement") with the State of California Department of Finance ("DoF").
RECOMMENDATION
1. It is recommended the City Council take the following actions:
a. Approve the Settlement Agreement with DoF in a form substantially consistent
with the attachment; and
b. Authorize the City Manager to execute and transmit the Settlement Agreement to
DoF and to take all actions necessary to implement its provisions; and
c. Authorize the F nance Department to appropriate $5,000,000 from Fund 189
(Land Held for Resale) and send payment as provided in the Settlement
Agreement upon execution of the Agreement by all parties; and
d. Authorize the Finance Department to make future payments consistent with the
terms of the Settlement Agreement.
2. It is recommended the City Council, acting as the Successor Agency, take the
following actions:
a. Approve the Settlement Agreement with DoF in a form substantially consistent
with the attachment; and
b. Authorize the Executive Director to execute the Settlement Agreement and to
take all actions necessary to implement its terms.
3. It is recommended the Tustin Housing Authority Commissioners take the following
actions:
a. Approve the Settlement Agreement with DoF- in a form substantially consistent
with the attachment; and
b. Authorize the Executive Director to execute the Settlement Agreement and to
take all actions necessary to implement °ts terms.
Agenda Report
November 18, 2014
Page 2
FISCAL IMPACT
As outlined in the Settlement Agreement, the City will make a $5,000,000 payment
against the Promissory Note between the City and the former Tustin Community
Redevelopment Agency. This will leave a balance of $16,404,683 to be paid off in four
annual payments starting in December 2015. The final payment will occur by
December 31, 2018.
ALIGNMENT WITH STRATEGIC PLAN
The Settlement Agreement contributes to the City's Strategic Plan Goal C, by
negotiating a prudent agreement that fulfills a City contractual obligation while
sustaining long-term financial strength.
BACKGROUND/DISCUSSION
On December 2, 2008, the City Council adopted Resolution No. 08-83 and the former
Tustin Community Redevelopment Agency Board adopted RDA Resolution No. 08-06,
authorizing the City to issue a Promissory Note ("Note") in the principal amount of
$18,881,750 and authorizing the former Tustin Community Redevelopment Agency
("Successor Agency") to purchase the Note. The City used the funds to acquire
approximately 34 acres of land adjacent to the 55 freeway, south of Edinger Avenue.
The property was acquired for new freeway ramps and the extension of Newport
Avenue. Unless amended and/or extended, the Note incurred interest at 4.25% and
was to be paid off by December 1, 2013.
In June 2011, the State Legislature and the Governor passed legislation that dissolved
Redevelopment Agencies ("Dissolution"). As part of the Dissolution, loans where former
Redevelopment Agencies borrowed money from cities were either disallowed or
reinstated under certain conditions and at a Local Agency Investment Fund ("LAIF")
interest rate at the time of reinstatement. Despite the disparate treatment, Dissolution
requires all loans where cities borrowed funds from former Redevelopment Agencies to
be repaid and at the interest rate stated in the loan.
On May 13, 2013, the Successor Agency submitted a request to DoF for a Finding of
Completion ("Finding"). The Finding would allow the Successor Agency to utilize the
MCAS Tustin 2010 Tax Allocation Bonds for their intended purpose and to seek
reinstatement of loans where the Successor Agency borrowed funds from the City. In
July 2013, the DoF declined issuing the Successor Agency a Finding, stating the Note
was effectively due at the time the City requested a Finding as opposed to the Note's
December 1, 2013 due date. On August 29, 2013, the City, the Successor Agency and
the Tustin Housing Authority filed a Petition for Writ of Mandate with the Superior Court
Agenda Report
November 18, 2014
Page 3
of the State of California, challenging DoF's denial of the Finding. On April 24, 2014,
the Honorable Timothy M. Frawley California Superior Court Judge. 'ssued a Writ of
Mandate compelling DoF to issue a Finding. DoF issued the Finding on May 1 2014.
Since that time, staff have been negotiating a Settlement Agreement with DoF to pay off
the Note. Although DoF has denied the Successor Agency's efforts to reinstate loans
where the Successor Agency owes the City over $42,000,000, staff have moved
forward with attempting to reach an agreement on the Note.
What has been agreed upon by staff and DoF is as follows:
1. Although the City staff sought from DoF a similar application of the LAIF variable
rate calculat-on being used on funds owed to a jurisdiction, the DoF has agreed
to use the LAIF rate as of December 2008, which was 2.54%. This is a
significant reduction to the interest rate in the Note of 4.25%.
2. The Principal balance to be paid off is $21,404,683, the amount that was due on
December 31, 2013 at..54% interest rate.
I Upon execution of the Settlement Agreement, the City will make a $5,000,000
payment.
4. The remaining Principal i $16,404,683 and will be paid in four annual
installments of $4,101,171_ The final payment will be due on December 31, 2018.
The Principal balance will not accrue interest during this four year period.
5. The Settlement Agreement will resolve claims related to the Note, and those
claims only.
6. The Settlement Agreement will not prejudice the parties' rights with respect to
any other disputes between them.
7. DoF will dismiss its pending cross-appeal regarding the Finding issue.
Staff is requesting approval of the Settlement Agreement and authorization for the City
Manager/Executive Director to execute the Settlement Agmement. In order to make the
initial payment, $5,000,000 will need to be appropriated from Fund 189. Staff will be
available to answer any questions the City Council may have.
Jerry Craig
Economic velo t & ousing Manager
A me . Promissory Note Settlement Agreement
SETTLEMENT AGREEMENT
Successor Agency to the Tustin Community Redevelopment Agency v. Michael Cohen, et al.
(formerly Successor Agency to the Tustin Community Redevelopment Agency, et al v. Ana J.
Matosantos, et al), Sacramento Superior Court, Case No. 34-2013-80001623 (appeal pending in
California Court of Appeal, Third Appellate Disirict, Case No. C076836)
PARTIES
This Settlement Agreement ("Agreement")is entered into by the following parties: (1)
the Successor Agency to the Tustin Redevelopment Agency, a public entity("Successor
Agency"); (2)the City of Tustin, a California municipal corporation("Tustin"); (3) the Tustin
Housing Authority, a public body corporate and politic("Housing Authority"); and (4) Michael
Cohen, in his official capacity as Director of the California Department of Finance("Finance")
(collectively, the"Parties").
RECITALS
A. The cross-appeal resolved by this Agreement relates to the wind down of the Tustin
Redevelopment Agency("RDA")pursuant to Assembly Bill 26 of the 2011-12 First
Extraordinary Session of the California Legislature("AB xl 26") and Assembly Bill 1484 of the
2011-12 Regular Session of the California Legislature("AB 1484") (AB xl 26 and AB 1484,
collectively the"Dissolution Law").
B. In 2008,Tustin arranged to borrow $18,881,750 i'rom is RDA by means of a promissory
note issued by Tustin to the RDA ("promissory note"). Under the tennis of the promissory note,
the RDA immediately provided Tustin with $18,881,750. Tustin was required to repay the
principal, plus interest, by December 31, 2013. Following the dissolution of the RDA, the
promissory note owned by the RDA was transferred to the Successor Agency by operation of
law.
C. On January 14, 2013, the Successor Agency submitted to Finance an independent
auditor's due diligence review of the unencumbered"other funds and accounts" ("OFA DDR")
to be remitted to the Auditor-Controller of the County of Orange("Auditor-Controller") for
distribution to local taxing entities. The Successor Agency submitted the OFA DDR as required
by the Dissolution Law. The OFA DDR noted that the accumulated principal and interest on the
promissory note amounted to $21,877,282 as of January 2013.
D. Finance issued a letter, dated May 5, 2013, which included, among other things, a final
determination that the Successor Agency must remit the$2I,877,282 to be clue under the
promissory note as a precondition to receiving a"finding of completion."
E. Successor Agency, Tustin, and Housing Authority filed the above-referenced action on
August 29, 2013 in Sacramento County Superior Court("RDA Action"). An amended petition
was filed on January 14, 2014.
F. After a hearing on March 28, 2014, the Sacramento Superior Court rendered its ruling,
dated April 7, 2014, in which the Court noted that the promissory note matured on December 31,
2013 and that the Successor Agency was obligated to remit unencumbered balances to the
Auditor-Controller. At the same time, the Court held that Finance erred in insisting that the
Successor Agency remit the$21,877,282 due under the promissory note as a precondition to
receiving a"finding of completion."
G. On April 25, 2014, the Sacramento Superior Court entered its order and judgment in the
RDA Action. The judgment granted the petition for writ of mandate in part and denied it in part.
H. Pursuant to the peremptory writ of mandate subsequently issued by the Court, Finance
issued a finding of completion to the Successor Agency, effective May 15, 2013.
I. On June 19, 2014, Successor Agency, Tustin, and Housing Authority filed a notice of
appeal from the judgment in the RDA Action("the RDA Appeal"). On July 8, 2014, Finance
filed a notice of cross-appeal to challenge the judgment that Finance had abused its discretion in
refusing to issue a"finding of completion" until the amount due under the promissory note had
been remitted ("the RDA Cross-Appeal"). Both the RDA Appeal and RDA Cross-Appeal are
currently pending in the California Court of Appeal, Third Appellate District, case number
C076836.
J. No amount due and payable on the promissory note has yet been paid or remitted.
K. By entering into this Agreement, the Parties have agreed to resolve two issues only: (1)
the terms and conditions for Tustin's payment of the amount due on the promissory note and (2)
the pending RDA Cross-Appeal. This Agreement does not resolve the issues raised by the RDA
Appeal.
AGREEMENT
Accordingly, in consideration of the mutual promises contained herein, the Parties agree
as follows:
1. Principal Terms: The Parties agree to the following resolution of the RDA Cross-Appeal:
(a) Finance agrees to abandon or dismiss the RDA Cross-Appeal in exchange for
Tustin's payment to the Successor Agency of the eighteen million eight hundred eighty-one
thousand seven hundred fifty dollar($18,881,750)principal due on the promissory note plus two
million five hundred twenty-two thousand nine hundred thirty-three dollars ($2,522,933) in
interest (which accrued from December 31, 2008 at a rate of 2.54 percent compounded
annually), for a total payment of twenty one million four hundred four thousand six hundred
eighty-three dollars ($21,404,6$3) (the"Cross-Appeal Settlement Payment"), in accordance with
the provisions of sections 1(b)—(e)below.
(b) Within two business days of the Effective Date of this Agreement(defined in
Section 16 below), Finance shall file a notice in the Sacramento County Superior Court that it is
abandoning the RDA Cross-Appeal or, if the record on appeal has been filed on or before the
Effective Date of this Agreement, Finance shall file in the Court of Appeal a request for
dismissal of the RDA Cross-Appeal. Finance shall serve the notice of abandonment or request
for dismissal upon the Successor Agency's counsel of record by electronic mail on the date of
- 1) -
filing. Within 7 days after Finance has filed a notice of abandonment, or if Finance instead must
file a request for dismissal in the Court of Appeal, within 7 days after the Court of Appeal has
dismissed the appeal, Tustin shall pay Successor Agency five million dollars ($5,000,000). That
amount shall be used to pay approved enforceable obligations of Successor Agency during the 12
months immediately following payment. To the extent the five million dollars received by the
Successor Agency exceed the amounts needed to pay Successor Agency's approved enforceable
obligations in the 12 months immediately following payment, the excess amount shall be
remitted to the Auditor-Controller by December 15, 2015 for distribution to the taxing entities.
(c) Within 24 hours of its receipt of Tustin's payment in accordance with section 1(b)
above, Successor Agency shall inform Finance's litigation counsel designated below by e-mail
that it has received the payment and provide counsel with confirmation of payment, such as a
copy of the wire transfer, check, or warrant.
(d) On or before December 31, 2015, and again on or before December 31 of each of
the following three years (2016, 2017, and 2018), Tustin shall make an additional payment to the
Successor Agency, each time in the amount of four million one hundred and one thousand one
hundred seventy dollars and seventy-five cents($4,101,170.75). Each time, Successor Agency
shall send an e-mail to Redevelopment_Administration@dof.ca.gov informing Finance that it
has received the payment and providing confirmation of the payment, such as a copy of the wire
transfer, check, or warrant. Each time, the additional payment shall be used to pay the approved
enforceable obligations of Successor Agency during the 12 months immediately following
payment. To the extent payment received by the Successor Agency exceeds the amounts needed
to pay Successor Agency's approved enforceable obligations in the 12 months immediately
following the payment, the excess amount shall be remitted to the Auditor-Controller by
December 15 of the year following each payment for distribution to the taxing entities.
(e) By December 31, 2018, Tustin shall have paid the full Cross-Appeal Settlement
Payment of twenty-one million four hundred and four thousand six hundred eighty-three dollars
($21,404,683) to Successor Agency.
(t} Should Successor Agency or Tustin fail to comply with the provisions of sections
I(b)—(e) above, Finance shall have the right to enforce the original terms of the promissory note
and seek full and immediate recovery according to those terms.
2. Claims Disputed: The Agreement does not constitute, nor shall it be construed as, an
admission or concession by any of the Parties for any purpose. This Agreement is a compromise
settlement, and by executing this Agreement, none of the Parties admits wrongdoing, liability, or
fault in connection with either the Action or the allegations asserted in the Action.
3. Mutual Release: The Parties specifically and mutually release and discharge each other,
including their respective officers, directors, commission members, trustees, agents, employees,
representatives, attorneys, insurers, departments, divisions, sections, successors and assigns from
all obligations, damages, costs, expenses, liens, attorney fees of any nature whatsoever, whether
known or unknown, suspected or not suspected to exist, claimed or not claimed, disputed or
undisputed, pertaining to the RDA Cross-Appeal, and pertaining to the promissory note The
- 3 -
finding of completion issued to the Successor Agency effective May 15, 2013 shall remain in full
force and effect at all times.
4. Successors and Assigns: This Agreement shall be binding upon the Parties' respective
officers, directors, commission members, trustees, agents, employees, representatives, attorneys,
departments, divisions, sections, successors and assigns.
5. Assumption of Risk: The Parties each represent that they fully understand that if the
facts pertaining in any way to the RDA Action, the RDA Appeal, or the RDA Cross-Appeal are
later found to be different from the facts now believed to be true by any Party, each of them
expressly accepts and assumes the risk of such possible differences in facts and agrees that this
Agreement shall remain effective notwithstanding such differences in facts. The Parties also
each represent that this Agreement was entered into under the laws current as of the effective
date, and agree that this Agreement shall remain effective notwithstanding any future changes in
the law.
6. Independent Advice of Counsel: The Parties each represent that they know and
understand the contents of the Agreement and that this Agreement has been executed voluntarily.
The Parties each further represent that they have had an opportunity to consult with an attorney
of their choosing and that they have been fully advised by the attorney with respect to their rights
and obligations and with respect to the execution of this Agreement.
7. Entire Agreement: No promise, inducement, understanding, or agreement not expressed
has been made by or on behalf of the Parties, and this Agreement contains the entire agreement
between the Parties related to the subject matter of this Agreement.
8. N_oA_ssigpment : Each Party represents that it has not assigned, transferred, or purported
to assign or transfer to any person or entity any matter released herein.
9. Amendments in Writin : This Agreement may not be altered, amended, modified, or
otherwise changed in any respect except by a writing duly executed by the Parties. The Parties
agree that they will make no claim at any time or place that this Agreement has been orally
altered or modified or otherwise changed by oral communication of any kind or character.
10. Construction: The Parties agree that this Agreement is to be construed and interpreted
without regard to the identity of the party drafting this Agreement.
11. Additional Acts: The Parties agree to take such actions and to execute such documents as
are necessary to carry out the terms and purposes of this Agreement.
12. Attorneys Fees: The Parties shall each bear their respective attorneys fees and costs
incurred in the RDA Cross-Appeal, and incurred with respect to the promissory note.
13. Enforcement: If any Party to this Agreement files a lawsuit to enforce or interpret this
Agreement, including an action to force payment of any unpaid portion of the Cross-Appeal
Settlement Payment, or an action to enforce any part of the finding of completion, the prevailing
- 4 -
Party in any such suit shall be entitled to reimbursement for its reasonable attorney fees and
costs.
14. Choice of Law and Jurisdiction: This Agreement shall be governed by the laws of the
State of California. If any Party to this Agreement brings a lawsuit to enforce or interpret this
Agreement, the lawsuit shall be filed in the Superior Court for the County of Orange, California.
15. Counterparts: This Agreement may be executed in counterparts by electronic mail or by
facsimile, each of which is deemed an original and all of which shall constitute this Agreement.
16. Effective Date: The Agreement shall become effective on the date on which the last
counterpart of this Agreement is executed such that it is executed in full.
17. Authority to Execute: Each Party represents that they have the authority to enter into and
perform the obligations necessary to provide the consideration described in this Agreement. .
This Agreement consists of Recital Paragraphs A—K and Paragraphs 1-17.
DATED: SUCCESSOR AGENCY TO THE TUSTIN
REDEVELOPMENT AGENCY
By
Its
DATED: CITY OF TUSTIN
By
Its
DATED: TUSTIN HOUSING AUTHORITY
By
Its
DATED: MICHAEL COHEN, IN HIS OFFICIAL
CAPACITY AS DIRECTOR OF THE
CALIFORNIA DEPARTMENT OF FINANCE
By
KARI KROGSENG
Its Chief Counsel
- 5 -
Approved as to Form and Content:
RICHARDS, WATSON & GERSHON
By:
T. PETER PIERCE, Esq.
Outside Counsel
Attorneys for Petitioners/Plains s Successor
Agency to the Tustin Redevelopment Agency, City of
Tustin, and Tustin Housing Authority
Approved as to Form and Content-
KAMALA D. HARRIS
Attorney General of California
By:
KAMALA D. HARRIS
Attorney General of California
TAMAR PACHTER
Supervising Deputy Attorney General
REI R. ONISHI
Deputy Attorney General (SBN 283946)
California Attorney General's Office
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: (415) 703-1613
Fax: (415) 703-1234
E-mail: Rei.Onishi@doj.ca.gov
Attorneys for Respondent/Defendant Michael
Cohen, Director of California Department of
Finance
- 6 -