MURIEL BOWSER MAYOR May 13, 2024 The Honorable Phil Mendelson Chairman Council of the District of Columbia 1350 Pennsylvania Avenue, N.W. Suite 504 Washington, DC 20001 Dear Chairman Mendelson: Enclosed for consideration and adoption by the Council of the District of Columbia is a proposed resolution entitled "Jubilee Housing, Inc . – The Maycroft Revenue Bonds Project Approval Resolution of 2024,” the “Resolution”. The Resolution authorizes the issuance, sale, and delivery of tax-exempt revenue bonds, notes, or other obligations in an aggregate principal amount not to exceed $3,250,000. These bonds will be used for the financing, refinancing, or reimbursing of costs incurred by Jubilee Housing, Inc. for the project located at 1474 Columbia Road, N.W. in Ward 1. In accordance with Section 490 of the Home Rule Act, we have determined that the bonds, when, as, and if issued, shall be without recourse to the District. The bonds shall not be general obligations of the District; shall not be a pledge of or involve the full faith and credit or the taxing power of the District; shall not constitute a debt of the District; and shall not constitute a lending of public credit for private undertakings as prohibited in section 602 (a) (2) of the Home Rule Act. The bonds shall not give rise to any pecuniary liability of the District and the District shall have no obligation with respect to the purchase of the bonds. I urge the Council to take prompt and favorable action on the measure. Sincerely, Muriel E. Bowser Enclosures 1 2 3 4 5 6 7 8 9 10 11 12 13 14 ~ Chairman Phil Mendelson at the request of the Mayor A PROPOSED RESOLUTION IN THE COUNCIL OF THE DISTRICT OF COLUMBIA 15 To authorize and provide for the issuance, sale, and delivery in an aggregate principal amount not to 16 exceed $3.25 million of District of Columbia revenue bonds in one or more series and to 17 authorize and provide for the loan of the proceeds of such bonds to assist Jubilee 18 Housing, Inc., in the financing, refinancing, or reimbursing of costs associated with an 19 authorized project pursuant to section 490 of the District of Columbia Home Rule Act. 20 21 RESOLVED, BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this 22 resolution may be cited as the "Jubilee Housing, Inc. -The Maycroft, Revenue Bonds Project 23 Approval Resolution of2024". 24 Sec. 2. Definitions. 25 For the purpose of this resolution, the term: 26 (1) "Authorized Delegate" means the Mayor or the Deputy Mayor for Planning and 27 Economic Development, or any officer or employee of the Executive Office of the Mayor to whom 28 the Mayor has delegated or to whom the foregoing individuals have subdelegated any of the 29 Mayor's functions under this resolution pursuant to section 422(6) of the Home Rule Act. 30 (2) "Bond Counsel" means a firm or firms of attorneys designated as bond counsel 31 from time to time by the Mayor. 2 (3) “Bonds” means the District of Columbia revenue bonds, notes, or other 1 obligations (including refunding bonds, notes, and other obligations), in one or more series, 2 authorized to be issued pursuant to this resolution. 3 (4) “Borrower” means the owner of the assets financed, refinanced, or reimbursed 4 with proceeds from the Bonds, which shall be Jubilee Housing, Inc., a nonprofit corporation 5 organized and existing under the laws of the District of Columbia , qualified to do business in the 6 District of Columbia, and exempt from federal income taxes under 26 U.S.C. § Section 501(a) as an 7 organization described in 26 U.S.C. § 501(c)(3). 8 (5) “Chairman” means the Chairman of the Council of the District of Columbia. 9 (6) “Closing Documents” means all documents and agreements other than 10 Financing Documents that may be necessary and appropriate to issue, sell, and deliver the Bonds 11 and to make the Loan, and includes agreements, certificates, letters, opinions, forms, receipts, and 12 other similar instruments. 13 (7) “District” means the District of Columbia. 14 (8) “Financing Documents” means the documents other than Closing Documents 15 that relate to the financing, refinancing, or reimbursement of transactions to be effected through the 16 issuance, sale, and delivery of the Bonds and the making of the Loan, including any offering 17 document, and any required supplements to any such documents. 18 (9) “Home Rule Act” means the District of Columbia Home Rule Act, approved 19 December 24, 1973 (87 Stat. 774; D.C. Official Code § 1- 201.01 et seq.). 20 (10) “Issuance Costs” means all fees, costs, charges, and expenses paid or incurred 21 in connection with the authorization, preparation, printing, issuance, sale, and delivery of the Bonds 22 and the making of the Loan, including, but not limited to, underwriting, legal, accounting, rating 23 3 agency, and all other fees, costs, charges, and expenses incurred in connection with the development 1 and implementation of the Financing Documents, the Closing Documents, and those other 2 documents necessary or appropriate in connection with the authorization, preparation, printing, 3 issuance, sale, marketing, and delivery of the Bonds and the making of the Loan, together with 4 financing fees, costs, and expenses, including program fees and administrative fees charged by the 5 District, fees paid to financial institutions and insurance companies, initial letter of credit fees (if 6 any), compensation to financial advisors and other persons (other than full-time employees of the 7 District) and entities performing services on behalf of or as agents for the District. 8 (11) “Loan” means the District’s lending of proceeds from the sale, in one or more 9 series, of the Bonds to the Borrower. 10 (12) “Project” means the financing, refinancing, or reimbursing of the Borrower for 11 all or a portion of the Borrower’s costs incurred in connection with: 12 (A) (i) the refinancing of certain indebtedness, the proceeds of which 13 were used to acquire, finance or refinance the costs of improvements to commercial rental space 14 including leasehold improvements of the Applicant’s facility located at 1474 Columbia Road, 15 NW, Units C-1, C-2 and C-3, Washington, DC (A&T Lots 2110, 2111 and 2112 in Square 16 2669) (the “Facility”); (ii) the purchase of certain equipment and furnishings for the Facility, 17 together with other property, real and personal, functionally related and subordinate thereto; and 18 (iii) funding any credit enhancement costs, liquidity costs or debt service reserve fund relating to 19 the Bonds; and 20 (B) the funding of certain Issuance Costs. 21 Sec. 3. Findings. 22 The Council finds that: 23 4 (1) Section 490 of the Home Rule Act provides that the Council may by resolution 1 authorize the issuance of District revenue bonds, notes, or other obligations (including refunding 2 bonds, notes, or other obligations) to borrow money to finance, refinance, or reimburse costs, and to 3 assist in the financing, refinancing, or reimbursing of the costs of undertakings in certain areas 4 designated in section 490 and may e ffect the financing, refinancing, or reimbursement by loans 5 made directly or indirectly to any individual or legal entity, by the purchase of any mortgage, note, 6 or other security, or by the purchase, lease, or sale of any property. 7 (2) The Borrower has requested the District to issue, sell, and deliver revenue bonds, 8 in one or more series, in an aggregate principal amount not to exceed $3 .25 million and to make the 9 Loan for the purpose of financing, refinancing, or reimbursing costs of the Project. 10 (3) The Project is located in the District and will contribute to the health, education, 11 safety, or welfare of, or the creation or preservation of jobs for, residents of the District, or to the 12 economic development of the District. 13 (4) The Project is an undertaking in the area of commercial development within the 14 meaning of section 490 of the Home Rule Act. 15 (5) The authorization, issuance, sale, and delivery of the Bonds and the Loan to 16 the Borrower are desirable, are in the public interest, will promote the purpose and intent of 17 section 490 of the Home Rule Act, and will assist the Project. 18 Sec. 4. Bond authorization. 19 (a) The Mayor is authorized pursuant to the Home Rule Act and this resolution to assist in 20 financing, refinancing, or reimbursing the costs of the Project by: 21 (1) The issuance, sale, and delivery of the Bonds, in one or more series, in an 22 aggregate principal amount not to exceed $3.25 million; and 23 5 (2) The making of the Loan. 1 (b) The Mayor is authorized to make the Loan to the Borrower for the purpose of financing, 2 refinancing, or reimbursing the costs of the Project and establishing any fund with respect to the 3 Bonds as required by the Financing Documents. 4 (c) The Mayor may charge a program fee to the Borrower, including, but not limited to, an 5 amount sufficient to cover costs and expenses incurred by the District in connection with the 6 issuance, sale, and delivery of each series of the Bonds, the District’s participation in the monitoring 7 of the use of the Bond proceeds and compliance with any public benefit agreements with the 8 District, and maintaining official records of each bond transaction and assisting in the redemption, 9 repurchase, and remarketing of the Bonds. 10 ( d) The Bond authorization set forth in this resolution includes the authorization to issue 11 refunding Bonds to refinance any Bonds previously issued under this resolution to finance the 12 Project; provided, that the maximum principal amount of Bonds outstanding at any time does not 13 exceed the maximum principal amount of Bonds authorized hereunder. 14 Sec. 5. Bond details. 15 (a) The Mayor and each Authorized Delegate is authorized to take any action reasonably 16 necessary or appropriate in accordance with this resolution in connection with the preparation, 17 execution, issuance, sale, delivery, security for, and payment of the Bonds of each series, including, 18 but not limited to, determinations of: 19 (1) The final form, content, designation, and terms of the Bonds, including a 20 determination that the Bonds may be issued in certificated or book- entry form; 21 (2) The principal amount of the Bonds to be issued and denominations of the 22 Bonds; 23 6 (3) The rate or rates of interest or the method for determining the rate or rates of 1 interest on the Bonds; 2 (4) The date or dates of issuance, sale, and delivery of, and the payment of interest 3 on the Bonds, and the maturity date or dates of the Bonds; 4 (5) The terms under which the Bonds may be paid, optionally or mandatorily 5 redeemed, accelerated, tendered, called, or put for redemption, repurchase, or remarketing before 6 their respective stated maturities; 7 (6) Provisions for the registration, transfer, and exchange of the Bonds and the 8 replacement of mutilated, lost, stolen, or destroyed Bonds; 9 (7) The creation of any reserve fund, sinking fund, or other fund with respect to the 10 Bonds; 11 (8) The time and place of payment of the Bonds; 12 (9) Procedures for monitoring the use of the proceeds received from the sale of the 13 Bonds to ensure that the proceeds are properly applied to the Project and used to accomplish the 14 purposes of the Home Rule Act and this resolution; 15 (10) Actions necessary to qualify the Bonds under blue sky laws of any jurisdiction 16 where the Bonds are marketed; and 17 (11) The terms and types of credit enhancement, if any, under which the Bonds may 18 be secured. 19 (b) The Bonds shall contain a legend, which shall provide that the Bonds are special 20 obligations of the District, are without recourse to the District, are not a pledge of, and do not 21 involve the faith and credit or the taxing power of the District, do not constitute a debt of the 22 7 District, and do not constitute lending of the public credit for private undertakings as prohibited in 1 section 602(a)(2) of the Home Rule Act. 2 (c) The Bonds shall be executed in the name of the District and on its behalf by the manual 3 or facsimile signature of the Mayor, and attested by the Secretary of State of the District of 4 Columbia by the Secretary of State of the District of Columbia’s manual or facsimile signature. The 5 Mayor’s execution and delivery of the Bonds shall constitute conclusive evidence of the Mayor’s 6 approval, on behalf of the District, of the final form and content of the Bonds. 7 (d) The official seal of the District, or a facsimile of it, shall be impressed, printed, or 8 otherwise reproduced on the Bonds. 9 (e) The Bonds of any series may be issued in accordance with the terms of a trust instrument 10 to be entered into by the District and a trustee to be selected by the Borrower subject to the approval 11 of the Mayor, and may be subject to the terms of one or more agreements entered into by the Mayor 12 pursuant to section 490(a)(4) of the Home Rule Act. 13 (f) The Bonds may be issued at any time or from time to time in one or more issues and in 14 one or more series. 15 Sec. 6. Sale of the Bonds. 16 (a) The Bonds of any series may be sold at negotiated or competitive sale at, above, or 17 below par, to one or more persons or entities, and upon terms that the Mayor considers to be in the 18 best interest of the District. 19 (b) The Mayor or an Authorized Delegate may execute, in connection with each sale of the 20 Bonds, offering documents on behalf of the District, may deem final any such offering document on 21 behalf of the District for purposes of compliance with federal laws and regulations governing such 22 8 matters and may authorize the distribution of the documents in connection with the sale of the 1 Bonds. 2 (c) The Mayor is authorized to deliver the executed and sealed Bonds, on behalf of the 3 District, for authentication, and, after the Bonds have been authenticated, to deliver the Bonds to the 4 original purchasers of the Bonds upon payment of the purchase price. 5 (d) The Bonds shall not be issued until the Mayor receives an approving opinion from Bond 6 Counsel as to the validity of the Bonds of such series and, if the interest on the Bonds is expected to 7 be exempt from federal income taxation, the treatment of the interest on the Bonds for purposes of 8 federal income taxation. 9 Sec. 7. Payment and security. 10 (a) The principal of, premium, if any, and interest on, the Bonds shall be payable solely from 11 proceeds received from the sale of the Bonds, income realized from the temporary investment of 12 those proceeds, receipts and revenues realized by the District from the Loan, income realized from 13 the temporary investment of those receipts and revenues prior to payment to the Bond owners, other 14 moneys that, as provided in the Financing Documents, may be made available to the District for the 15 payment of the Bonds, and other sources of payment (other than from the District), all as provided 16 for in the Financing Documents. 17 (b) Payment of the Bonds shall be secured as provided in the Financing Documents and by 18 an assignment by the District for the benefit of the Bond owners of certain of its rights under the 19 Financing Documents and Closing Documents, including a security interest in certain collateral, if 20 any, to the trustee for the Bonds pursuant to the Financing Documents. 21 (c) The trustee is authorized to deposit, invest, and disburse the proceeds received from the 22 sale of the Bonds pursuant to the Financing Documents. 23 9 Sec. 8. Financing and Closing Documents. 1 (a) The Mayor is authorized to prescribe the final form and content of all Financing 2 Documents and all Closing Documents to which the District is a party that may be necessary or 3 appropriate to issue, sell, and deliver the Bonds and to make the Loan to the Borrower. Each of the 4 Financing Documents and each of the Closing Documents to which the District is not a party shall 5 be approved, as to form and content, by the Mayor. 6 (b) The Mayor is authorized to execute, in the name of the District and on its behalf, the 7 Financing Documents and any Closing Documents to which the District is a party by the Mayor’s 8 manual or facsimile signature. 9 (c) If required, the official seal of the District, or a facsimile of it, shall be impressed, 10 printed, or otherwise reproduced on the Financing Documents and the Closing Documents to which 11 the District is a party. 12 (d) The Mayor’s execution and delivery of the Financing Documents and the Closing 13 Documents to which the District is a party shall constitute conclusive evidence of the Mayor’s 14 approval, on behalf of the District, of the final form and content of said executed Financing 15 Documents and said executed Closing Documents. 16 (e) The Mayor is authorized to deliver the executed and sealed Financing Documents and 17 Closing Documents, on behalf of the District, prior to or simultaneously with the issuance, sale, and 18 delivery of the Bonds, and to ensure the due performance of the obligations of the District contained 19 in the executed, sealed, and delivered Financing Documents and Closing Documents. 20 Sec. 9. Authorized delegation of authority. 21 10 To the extent permitted by District and federal laws, the Mayor may delegate to any 1 Authorized Delegate the performance of any function authorized to be performed by the Mayor 2 under this resolution. 3 Sec. 10. Limited liability. 4 (a) The Bonds shall be special obligations of the District. The Bonds shall be without 5 recourse to the District. The Bonds shall not be general obligations of the District, shall not be a 6 pledge of or involve the faith and credit or the taxing power of the District, shall not constitute a 7 debt of the District, and shall not constitute lending of the public credit for private undertakings as 8 prohibited in section 602(a)(2) of the Home Rule Act. 9 (b) The Bonds shall not give rise to any pecuniary liability of the District and the District 10 shall have no obligation with respect to the purchase of the Bonds. 11 (c) Nothing contained in the Bonds, in the Financing Documents, or in the Closing 12 Documents shall create an obligation on the part of the District to make payments with respect to 13 the Bonds from sources other than those listed for that purpose in section 7. 14 (d) The District shall have no liability for the payment of any Issuance Costs or for any 15 transaction or event to be effected by the Financing Documents. 16 (e) All covenants, obligations, and agreements of the District contained in this resolution, 17 the Bonds, and the executed, sealed, and delivered Financing Documents and Closing Documents to 18 which the District is a party, shall be considered to be the covenants, obligations, and agreements of 19 the District to the fullest extent authorized by law, and each of those covenants, obligations, and 20 agreements shall be binding upon the District, subject to the limitations set forth in this resolution. 21 (f) No person, including, but not limited to, the Borrower and any Bond owner, shall have 22 any claims against the District or any of its elected or appointed officials, officers, employees, or 23 11 agents for monetary damages suffered as a result of the failure of the District or any of its elected or 1 appointed officials, officers, employees, or agents to perform any covenant, undertaking, or 2 obligation under this resolution, the Bonds, the Financing Documents, or the Closing Documents, or 3 as a result of the incorrectness of any representation in or omission from the Financing Documents 4 or the Closing Documents, unless the District or its elected or appointed officials, officers, 5 employees, or agents have acted in a willful and fraudulent manner. 6 Sec. 11. District officials. 7 (a) Except as otherwise provided in section 10(f), the elected or appointed officials, officers, 8 employees, or agents of the District shall not be liable personally for the payment of the Bonds or be 9 subject to any personal liability by reason of the issuance, sale or delivery of the Bonds, or for any 10 representations, warranties, covenants, obligations, or agreements of the District contained in this 11 resolution, the Bonds, the Financing Documents, or the Closing Documents. 12 (b) The signature, countersignature, facsimile signature, or facsimile countersignature of 13 any official appearing on the Bonds, the Financing Documents, or the Closing Documents shall 14 be valid and sufficient for all purposes notwithstanding the fact that the individual signatory 15 ceases to hold that office before delivery of the Bonds, the Financing Documents, or the Closing 16 Documents. 17 Sec. 12. Maintenance of documents. 18 Copies of the specimen Bonds and of the final Financing Documents and Closing 19 Documents shall be filed in the Office of the Secretary of State of the District of Columbia. 20 Sec. 13. Information reporting. 21 12 Within 3 days after the Mayor’s receipt of the transcript of proceedings relating to the 1 issuance of the Bonds, the Mayor shall transmit a copy of the transcript to the Secretary to the 2 Council. 3 Sec. 14. Disclaimer. 4 (a) The issuance of Bonds is in the discretion of the District. Nothing contained in this 5 resolution, the Bonds, the Financing Documents, or the Closing Documents shall be construed as 6 obligating the District to issue any Bonds for the benefit of the Borrower or to participate in or assist 7 the Borrower in any way with financing, refinancing, or reimbursing the costs of the Project. The 8 Borrower shall have no claims for damages or for any other legal or equitable relief against the 9 District, its elected or appointed officials, officers, employees, or agents as a consequence of any 10 failure to issue any Bonds for the benefit of the Borrower. 11 (b) The District reserves the right to issue the Bonds in the order or priority it determines in 12 its sole and absolute discretion. The District gives no assurance and makes no representations that 13 any portion of any limited amount of bonds or other obligations, the interest on which is excludable 14 from gross income for federal income tax purposes, will be reserved or will be available at the time 15 of the proposed issuance of the Bonds. 16 (c) The District, by adopting this resolution or by taking any other action in connection with 17 financing, refinancing, or reimbursing costs of the Project, does not provide any assurance that the 18 Project is viable or sound, that the Borrower is financially sound, or that amounts owing on the 19 Bonds or pursuant to the Loan will be paid. Neither the Borrower, any purchaser of the Bonds, nor 20 any other person shall rely upon the District with respect to these matters. 21 13 Sec. 15. Expiration. 1 If any Bonds are not issued, sold, and delivered to the original purchaser within 3 years of 2 the date of this resolution, the authorization provided in this resolution with respect to the issuance, 3 sale, and delivery of the Bonds shall expire. 4 Sec. 16. Severability. 5 If any particular provision of this resolution or the application thereof to any person or 6 circumstance is held invalid, the remainder of this resolution and the application of such provision 7 to other persons or circumstances shall not be affected thereby. If any action or inaction 8 contemplated under this resolution is determined to be contrary to the requirements of applicable 9 law, such action or inaction shall not be necessary for the purpose of issuing of the Bonds, and the 10 validity of the Bonds shall not be adversely affected. 11 Sec. 17. Compliance with public approval requirement. 12 This approval shall constitute the approval of the Council as required in section 147(f) of the 13 Internal Revenue Code of 1986, as amended, and section 490(k) of the Home Rule Act, for the 14 Project to be financed, refinanced, or reimbursed with the proceeds of the Bonds. This resolution 15 approving the issuance of the Bonds for the Project has been adopted by the Council after a public 16 hearing held in accordance with section 147(f) of the Code, as such section may be amended, and 17 the corresponding regulations promulgated by the United States Department of the Treasury. 18 Sec. 18. Transmittal. 19 The Council shall transmit a copy of this resolution, upon its adoption, to the Mayor. 20 14 Sec. 19. Fiscal impact statement. 1 The Council adopts the fiscal impact statement in the committee report as the fiscal impact 2 statement required by section 4a of the General Legislative Procedures Act of 1975, approved 3 October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1- 301.47a). 4 Sec. 20. Effective date. 5 This resolution shall take effect immediately. 6 Jubilee Housing, Inc. – The Maycroft Revenue Bond Project FACT SHEET Jubilee Housing, Inc. has requested that the District issue tax-exempt revenue bonds in an aggregate principal amount not to exceed $3.25 million to refinance costs of their office space located at 1474 Columbia Road, NW, Washington, DC in Ward 1. The Applicant Jubilee Housing, Inc. (Jubilee) is an organization that safeguards the long- term affordability of housing in the Adams Morgan, Columbia Heights, and Mount Pleasant neighborhoods while providing programs and services that support family success. Jubilee currently owns and operates 13 buildings with 464 residential units and 20,000 square feet of program space. Jubilee currently serves a diverse community of over 1,000 people, made up of individuals, families, children, seniors, formerly homeless, and returning citizens recently released from incarceration. Approximately 900 people are current residents of properties that Jubilee owns and operates. Proposed Project Jubilee Housing is seeking a $3.25 million revenue bond issuance to refinance existing debt on office space it owns at 1474 Columbia Road, NW, in the Columbia Heights neighborhood of Washington, DC. No renovations are currently needed on the property. Proceeds from the proposed bond issuance will be used to finance, refinance, or reimburse Jubilee for all or a portion of the costs incurred in connection with: (A) improvements, including leasehold improvements, of Jubilee’s facility located at 1474 Columbia Road, NW, (the “Facility”); (B) the purchase of certain equipment and furnishings for the Facility, together with other property, real and personal, functionally related and subordinate thereto; (C) funding any credit enhancement costs, liquidity costs or debt service reserve fund relating to the bonds; and (D) funding certain bond issuance costs. Financing Plan A summary of the proposed sources and uses of funds is attached (see Table 1). Feasibility/Structure/Security of the Bonds United Bank, the underwriter for this transaction, has deemed this transaction financially feasible based on its assessment and analysis . Public Purpose Benefits The Jubilee Housing transaction will help minimize the office space cost for the organization. This will allow the Jubilee team to continue to assist District residents with affordable housing and social services. Legal and Regulatory Affairs The law firm of Tiber Hudson, bond counsel to the DC R evenue Bond Program, has preliminarily determined that the applicant is a 501(c)(3) organization, and the project constitutes a permissible undertaking under Section 490(a)(1) of the District of Columbia Home Rule Act. Based on the foregoing, OAG, Bond Counsel, and the IRB have determined that the proposed project complies with criteria for approval of a proposed financing through the District’s Revenue Bond Program, and that the proposed project will allow the Jubilee to continue to provide affordable housing social services the District Washington, DC. TABLE 1 FINANCING PLAN SOURCES Bond Proceeds $3,250,000 USES Project Costs New Construction — Refinance/Refunding $3,020,347 Costs of Issuance: Underwriter/Placement Fee $11,375 IRB Program Fee $8,125 United Bank Legal $15,000 Equity Plus Financing Fee $32,500 Borrower’s Counsel Fee $15,000 Other Counsels’ Fee $15,000 Contingency $132,653 TOTAL: $3,250,000 GOVERNMENTOFTHEDISTRICTOFCOLUMBIA OfficeoftheAttorneyGeneral xk * CommercialDivision = ‘TaxandFinanceSection a ‘MEMORANDUM TO: WilliamLiggins,Director D.C.RevenueBond-EnterpriseZoneProgram OfficeoftheDeputyMayorforPlanning andEconomicDevelopment FROM:AndreaR.Littlejohn’?& SeniorAssistantAttorneyGeneral DATE: March20,2024 SUBJECT:LegalSufficiencyReview:JubileeHousing,Inc.~TheMaycroft,Revenue BondsProjectApprovalResolutionof2024 “Thisrespondstoarequestfromyourofficetoreviewforlegalsufficiencytheattacheddraftofthe above-referencedproposedresolution.Forpurposesofthisreview,thisOfficepremisesits conclusionontheassumptionthatyourofficehasdeterminedthattheBorrowerasdefinedinthe aforementionedresolutionisa“qualifiedapplicant”withinthemeaningofSection490ofthe DistrictofColumbiaHomeRuleAct. Areviewoftheattacheddraftoftheabove-referencedproposedresolutionindicatesthatthedraft proposedresolutionconformswiththeModelRevenueBondResolutionjointlydraftedand determinedtobelegallysufficientbytheGeneralCounseloftheCouncil,theOfficeoftheAttomey General,andtheDistrict'sbondcounsel.Accordingly,wefindtheattacheddraftoftheabove- referencedproposedresolutionlegallysufficient. Pleasecontactmeat724-7761ifyouhavefurtherquestionsorconcerns. Attachment:JubileeHousing,Inc.~TheMaycroft,RevenueBondsProjectApproval Resolutionof2024 ARLarl 400SixthStreet,N.W.,Suite9100,Washington,DC20001Tel.:(202)724-7761Fax:(202)730-0486