Agenda 5/23/2023 Item #16K3 (Resolution - Plan of Financing for prgrams for mulifamily housing for low to moderate income)16. K.3
05/23/2023
EXECUTIVE SUMMARY
Request by the Housing Finance Authority of Collier County for approval of a resolution approving a plan
of financing involving the issuance by the Authority of single-family mortgage revenue bonds in an amount
not to exceed $50 million or, in the alternative, to use volume cap allocation for mortgage credit certificate
programs or for multifamily housing for persons of low or moderate income.
OBJECTIVE: To accomplish the necessary approval to authorize a proposed revenue bond issue by the Housing
Finance Authority of Collier County (the "Authority") to be used for either single family or multifamily affordable
housing programs.
CONSIDERATIONS: This request is a duplicate of a request submitted by the Authority in June 2022, and
approved by the BCC on June 14, 2022 by Resolution No. 2022-106.
Federal law limits the amount of tax-exempt private activity bonds that can be issued in each state each year
(referred to as the "volume cap"). For a housing authority such as the Housing Finance Authority of Collier County
to issue tax-exempt bonds for affordable housing, it must receive an allocation of the state volume cap from the
Florida Division of Bond Finance. In the past several years, changing economic conditions have created a situation
where the state-wide allocation requests far exceed volume cap available, and receiving an allocation has become
almost a lottery. For example, in 2021 the Authority approved a two-phase acquisition and rehabilitation of an
existing 392-unit apartment complex called Brittany Bay. The BCC approved these two bond issues on September
14, 2021. The Authority applied for allocation for both issues, but only received allocation for Brittany Bay Phase
11. (Fortunately, the developer was able to obtain an allocation for Brittany Bay Phase I from the Florida Housing
Finance Corporation, so the entire project was done.)
To partially offset these risks, some authorities have gone to a system of approving a single-family mortgage
revenue bond issue under a plan of finance which also allows the authority to use volume cap allocation for either
single family or multifamily financing, rather than requesting allocation for a specific project, as has been the
traditional method. Under this strategy, the Authority can apply for a volume cap allocation of $50 million, which
can be used either for single family mortgage revenue bonds or a sharing of allocation with another authority that
would issue such bonds for several counties (more likely). Other options would be the sharing of allocation in a
multicounty mortgage credit certificate program, or to use the allocation for a multifamily project. The $50 million
authorization is necessary to allow the Authority to carry forward any volume cap allocation received for up to
three years. Restrictions on the use of an allocation in the year granted (e.g. 90% must be used on a single project
in the year the allocation is granted) make use of the allocation in the year granted generally infeasible, but at the
end of the year a three year carry forward can be obtained, which is not subject to the 90% rule (i.e. can be used for
multiple smaller projects). This carry forward is only available for allocations of $50 million or more. The
Authority's bond counsel has reviewed and advised this proposal.
To implement this strategy, the Authority held a publicly advertised hearing on April 12, 2023, at which members
of the public could comment on the proposal. No members of the public attended the hearing either in person or
remotely, and there were no public comments either before or at the hearing. At the conclusion of the hearing the
Authority adopted Resolution 2022-03 (the "Authority Resolution") approving the plan of finance and directing
appropriate officers of the Authority to seek approval of the issuance of bonds pursuant to such plan from the Board
of County Commissioners, as is required by the Internal Revenue Code. A copy of the Authority Resolution is
attached as Exhibit A to the County Resolution, as described below.
As stated above, the Code requires that bonds of this type be approved by the "local elected representative", which,
in the case of Collier County, is the Board of County Commissioners. This approval is signified by the adoption of
a resolution (the "County Resolution") approving the issuance of bonds by the Authority.
By statute, any bonds issued by the Authority can only be revenue bonds, payable only from revenues associated
with the project, and are not obligations of the County, the state, or any other political subdivision. There is no
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pledge of any taxes, nor a pledge of any other revenues except the revenues of the project for which the bonds are
issued. Neither the County, the Board, the Authority, nor any officer of the County is liable for their payment.
Further, the County Resolution provides that this approval by the Board does not abrogate any County regulations,
including land use regulations.
The Board's role in approval of financinz authority bond issues
Unlike County bonds, which are issued for public projects, the County -created financing authorities (Housing
Finance, Industrial Development, Health Facilities, and Educational Facilities Authorities) issue private activity
bonds, which are bonds issued on behalf of a private user for a legislatively declared public purpose such as
healthcare facilities, private educational facilities, qualifying manufacturing facilities, low/moderate income
housing facilities, pollution control facilities, etc.
The Internal Revenue Code ("Code") requires two types of approval for the issuance of private activity bonds:
Issuer Approval and Host Approval. Issuer Approval is the approval of the issuer of the bonds and is initially
evidenced by the adoption of an Authority Resolution such as the resolution attached to the County Resolution, and
ultimately by the execution and delivery of the bonds themselves. The Board grants Host Approval when it adopts
a resolution approving the issuance of the bonds by the Issuer (called the "County Resolution" in this Executive
Summary). Host Approval is the approval of the governmental unit with geographic jurisdiction over the location
of the project.
The primary requirement of Host Approval is that the bonds have been considered at a public hearing at which
members of the public have had an opportunity to express their views on the project and the issuance of the bonds.
The Code contains very specific requirements for the public notice of the hearing, and a copy of the public notice,
which has been reviewed by Authority Bond Counsel and determined to be Code -compliant is attached to the
Authority Resolution.
The Code does not require that the Board itself conduct the public hearing, only that Host Approval may not be
given until the public hearing has been conducted. In practice, both in Collier County and around the state, the
public hearing itself is conducted by the local financing authority and Host Approval is given after the Board
receives the report and recommendations of the financing authority in the form of the Authority Resolution. Here,
the public hearing was held as described above, and no members of the public expressed any views in opposition to
the project or the bonds.
Effect of Board Approval
Board Approval of an authority bond issue does not cause the bond to become a county bond or an obligation of the
County. By statute, bonds of this type are payable only from revenues related to the project, and no public monies
of any kind are pledged. Bonds of this type are treated as Component Unit Debt on the County's annual audit.
Board approval is necessary for the Authority to apply for volume cap allocation.
FISCAL IMPACT: This program does not require any contribution from the Board of County Commissioners
or any other County agency. As stated above, the bonds are not liabilities of the County, and the County is not
liable for payment in any way. The Authority is a self -funding agency, and no County monies are contributed to its
operation.
GROWTH MANAGEMENT IMPACT: The adoption of the attached resolution will have no adverse growth
management consequences. The Authority requires that any specific project be consistent with the LDC as a
prerequisite to consideration of an application for financing.
LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, is approved as to form and
legality, and requires majority vote for Board approval. -JAK
RECOMMENDATION: That the Board of County Commissioners adopt the attached Resolution.
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Prepared by:
Donald A. Pickworth, Counsel
Collier County Housing Finance Authority
ATTACHMENT(S)
1. Resolution - HFA bonds(PDF)
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COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.3
Doc ID: 25547
Item Summary: Request by the Housing Finance Authority of Collier County for approval of a resolution
approving a plan of financing involving the issuance by the Authority of single-family mortgage revenue bonds in
an amount not to exceed $50 million or, in the alternative, to use volume cap allocation for mortgage credit
certificate programs or for multifamily housing for persons of low or moderate income.
Meeting Date: 05/23/2023
Prepared by:
Title: Legal Assistant — County Attorney's Office
Name: Wanda Rodriguez
05/11/2023 4:55 PM
Submitted by:
Title: County Attorney — County Attorney's Office
Name: Jeffrey A. Klatzkow
05/11/2023 4:55 PM
Approved By:
Review:
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 05/12/2023 8:40 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 05/12/2023 10:20 AM
Office of Management and Budget Christopher Johnson Additional Reviewer Completed 05/13/2023 9:50 AM
County Manager's Office
Board of County Commissioners
Geoffrey Willig Level 4 County Manager Review
Geoffrey Willig Meeting Pending
Completed 05/15/2023 4:11 PM
05/23/2023 9:00 AM
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RESOLUTION NO.2023 -
A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF
COLLIER COUNTY, FLORIDA, APPROVING A PLAN OF FINANCE
INVOLVING THE ISSUANCE BY THE HOUSING FINANCE
AUTHORITY OF COLLIER COUNTY, FLORIDA OF ITS SINGLE
FAMILY MORTGAGE REVENUE BONDS IN AN AGGREGATE
PRINCIPAL AMOUNT NOT TO EXCEED $50,000,000 IN ONE OR
MORE SERIES; APPROVING USE OF STATE AWARDED VOLUME
CAP ALLOCATION FOR THE BONDS OR, FOR MORTGAGE CREDIT
CERTIFICATE PROGRAMS OR MULTIFAMILY BONDS OR CARRY
FORWARD; APPROVING BONDS AS REQUIRED BY SECTION 147(F)
OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED; AND
PROVIDING AN EFFECTIVE DATE.
WHEREAS, pursuant to Ordinance No. 80-66, enacted by the Board of County
Commissioners of Collier County, Florida (the "Board") on July 29, 1980 (the "Ordinance"), the
Board created the Housing Finance Authority of Collier County, Florida (the "Authority"), in
accordance with Part IV, Chapter 159, Florida Statutes (the "Act"), for the purpose of alleviating
a shortage of housing available at prices or rentals which many persons and families can afford
and a shortage of capital for investment in such housing; and
WHEREAS, pursuant to the Act, the Authority is empowered to revenue bonds for
single family or multifamily housing for persons of low, moderate or middle income as defined
in the Act; and
WHEREAS, in furtherance of its statutory purposes, the Authority desires to issue single
family mortgage revenue bonds, in one or more series, in an aggregate principal amount not to
exceed $50,000,000 (the "Bonds"), or, in the alternative, to use any private activity bond volume
cap that may be awarded to be used in conjunction with a mortgage credit certificate program,
and/or to be applied toward multifamily housing (the "Plan of Finance") within the meaning of
Section 147(f)(2)(C) of the Internal Revenue Code of 1986, as amended (the "Code"), or to be
carried forward as permitted by applicable law; and
WHEREAS, the Bonds are to be issued to make available funds to (i) purchase federally
insured or guaranteed mortgage loans originated by participating local lending institutions to
finance or refinance the purchase of new or existing owner -occupied single family residences (a)
situated within Collier County, Florida, and (b) owned by persons or families of low, moderate,
or middle income, (ii) purchase securities from a master servicer evidencing interests in or
backed by a pool of such mortgage loans, including, without limitation, securities issued by the
federal government or agencies thereof, (iii) be used in conjunction with a mortgage credit
certificate program, and/or (iv) to be applied toward multifamily housing; and
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WHEREAS, the Authority held a public hearing on April 12, 2023, as required by
Section 147(f) of the Internal Revenue Code of 1986, as amended (the "TEFRA Hearing"), after
proper notice was published (the "TEFRA Notice"), for the purpose of giving all interested
persons the opportunity to express their views in connection with the Plan of Financing and the
issuance of the Bonds (a copy of said TEFRA Notice being attached as Exhibit A to the
Authority Resolution as hereinafter defined); and
WHEREAS, at the conclusion of said TEFRA Hearing, the Authority adopted
Resolution No. 2023-03 (the "Authority Resolution"), a copy of which is attached hereto as
Exhibit A; and
WHEREAS, the Authority has requested the Board's approval of the Plan of Financing
and the issuance of the Bonds by the Authority in one or more series pursuant thereto for
purposes of Section 147(f) of the Code:
NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY
COMMISSIONERS OF COLLIER COUNTY, FLORIDA:
Section 1. Approval of Plan of Financing and Issuance of the Bonds for Purposes
of Section 147(f) of the Code. For purposes of Section 147(f) of the Code, the Board hereby
approves the Plan of Financing, the notice of public hearing, the public hearing, and the issuance
by the Authority of the Bonds in an aggregate principal amount not to exceed Fifty Million and
00/100 Dollars ($50,000,000) pursuant thereto for the purposes stated herein. The Board's
approval of the Plan of Financing and the issuance of the Bonds by the Authority shall not be
construed to obligate Collier County, Florida, to incur any liability, pecuniary or otherwise, in
connection with the issuance of the Bonds or the Plan of Financing. Provided further, however
this approval shall in no way be deemed to abrogate any regulations of the County and any
project contemplated by this resolution shall be subject to all such regulations, including, but not
limited to, the County's Growth Management Plan, all concurrency requirements contained
therein, and the Collier County Land Development Code.
Section 2. Approval of Use of Single Family Bond Allocation. The Board hereby
authorizes the allocation for single family revenue bonds to be used in connection with (i)
mortgage credit certificate authority, and/or (ii) multifamily revenue bonds. The Authority is
authorized to determine if such allocation will be (i) carried forward for use in future years,
and/or (ii) converted for use with mortgage credit certificates and/or multifamily revenue bonds,
as the Authority may deem most advisable.
Section 3. Resolution Effective. This Resolution shall take effect immediately
upon adoption.
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PASSED AND ADOPTED THIS day of May, 2023.
(SEAL)
ATTEST: BOARD OF COUNTY COMMISSIONERS
Crystal K. Kinzel, Clerk of Courts OF COLLIER COUNTY, FLORIDA
By: By:
Deputy Clerk Rick LoCastro, Chairman
Approved a4to [or&,anid legality:
Jeffrey A.Wlktz*w, County Attorney
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RESOLUTION NO.2023-03
A RESOLUTION OF THE HOUSING FINANCE AUTHORITY OF
COLLIER COUNTY, FLORIDA APPROVING A PLAN OF FINANCE
INVOLVING THE ISSUANCE BY THE AUTHORITY OF ITS SINGLE
FAMILY MORTGAGE REVENUE BONDS IN AN AGGREGATE FACE
AMOUNT OF NOT TO EXCEED $50,000,000 IN ONE OR MORE SERIES;
APPROVING USE OF STATE -AWARDED PRIVATE ACTIVITY BOND
ALLOCATION ("ALLOCATION") FOR MORTGAGE CREDIT
CERTIFICATE PROGRAMS OR MULTIFAMILY CARRY FORWARD;
AUTHORIZING THE PROPER OFFICERS OF THE AUTHORITY TO DO
ALL THINGS NECESSARY OR ADVISABLE IN CONNECTION WITH
THE PLAN OF FINANCE; AND PROVIDING AN EFFECTIVE DATE FOR
THIS RESOLUTION.
WHEREAS, the Housing Finance Authority of Collier County, Florida (the "Authority")
intends to issue its single family mortgage revenue bonds (the "Single Family Bonds"), in one or
more series, in an aggregate principal amount of not to exceed $50,000,000, or to participate in
one or more issues of single family mortgage revenue bonds issued by other housing finance
authorities pursuant to interlocal agreements between the Authority and such other housing finance
authorities to (i) make funds available to purchase federally insured or guaranteed mortgage loans
originated by participating local lending institutions to finance or refinance the purchase of new or
existing owner -occupied single-family residences (a) situated within Collier County, Florida (the
"County") and/or other Florida Counties as authorized by Chapter 159, Part IV, Florida Statutes,
as amended, and (b) owned by persons or families of low, moderate or middle income, (ii) purchase
securities from a master servicer evidencing interests in or backed by a pool of such mortgage
loans, including, without limitation, securities issued by the federal government or agencies
thereof, (iii) be used in conjunction with a mortgage credit certificate program, and/or (iv) be
applied toward multifamily housing; and
WHEREAS, the State of Florida's (the "State") allocation procedures require that (i) a
public hearing be held under the Tax Equity and Fiscal Responsibility Act ("TEFRA") with respect
to the Single Family Bonds, and (ii) the issuance of the Single Family Bonds be approved by the
Board of County Commissioners of Collier County, Florida, for purposes of Section 147(f) of the
Internal Revenue Code of 1986, as amended (the "Code") prior to requesting private activity bond
allocation ("Allocation") for said Single Family Bonds; and
WHEREAS, the Authority desires to in the alternative provide mortgage credit certificates
for the benefit of the citizens of the County and to convert single family mortgage revenue bond
Allocation awarded by the State for Allocation applicable to mortgage credit certificate authority;
and
WHEREAS, the Authority may elect to apply or carry forward any unused single family
Allocation awarded by the State for use with either single family revenue bonds or multifamily
revenue bonds; and
EXHIBIT A
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WHEREAS, in order to satisfy certain of the requirements of Section 147(f) of the
Internal Revenue Code of 1486, as amended, the Authority did on this date hold a public hearing
on the proposed Plan of Finance, which date is at least 7 days following the publication of a
notice of such public hearing as required by law (proof of publication of such notice is attached
hereto as Exhibit A). Such public hearing, which occurred prior to the adoption of this
Resolution, was conducted in a manner that provided a reasonable opportunity for persons with
differing views to be heard, both orally and in writing, on the Plan of Finance; and
WHEREAS, the Authority hereby desires to adopt a plan of financing within the meaning
of Section 147(f)(2)(C) of the Code.
NOW, THEREFORE, BE IT RESOLVED BY THE HOUSING FINANCE AUTHORITY
OF COLLIER COUNTY, FLORIDA:
Section 1. Appmval of Plan of Finance and Issuance of the Bonds. The Authority
hereby authorizes the issuance of the Single Family Bonds in an aggregate face amount of not to
exceed $50,000,000 for purposes stated herein. The Authority also hereby approves a plan of
financing consisting of the issuance of one or more series of Single Family Bonds at one or more
times and from time to time, which provides funds to originate new mortgages for first-time
homebuyers within the meaning of Section 143 of the Code (the "Plan of Finance"), Neither the
Authority's approval of the Plan of Finance, or the issuance of the Single Family Bonds by the
Authority, shall (i) obligate or be construed to obligate the Authority to issue all or any portion of
such Single Family Bonds, or (ii) cause the Authority or the County to incur any liability, pecuniary
or otherwise, in connection with the Plan of Finance or the issuance of the Single Family Bonds
and/or the decision not to issue all or any portion of the Single Family Bonds.
Section 2. Approval gf Use of Single Family Bond Allocation. The Authority hereby
authorizes the Allocation for single family revenue bonds (i) to be converted for mortgage credit
certificate authority, and/or (ii) to be used as Allocation for multifamily revenue bonds. The
Chairman of the Authority is hereby authorized to determine (i) if such Allocation should be
carried forward, and/or (ii) if such Allocation should be converted for use with mortgage credit
certificates and/or used for multifamily revenue bonds.
Section 3. Delegation of AuthorijX to hold a Public Hearing. If, after consultation with
the Authority's Bond Counsel it is deemed necessary to hold further public hearings with respect
to the issuance of single family or multifamily bonds, the attorney for the Authority or his designee
is hereby authorized to publish a notice and to conduct a public hearing in accordance with Section
147(f) of the Code, and shall report the results of such hearing to the Authority.
Section 4. Further Actions and Ratification of Prior Actions. The officers, agents and
employees of the Authority are hereby authorized and directed to do all acts and things required
of them by this Resolution and to execute and deliver any and all instruments, affidavits,
certificates, and notices necessary or advisable to effectuate the issuance of the Single Family
Bonds and the implementation of the PIan of Finance. All actions heretofore undertaken by the
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attorney for the Authority, officers, agents and employees of the Authority with respect to the
Single Family Bonds and/or the Plan of Finance are hereby authorized and ratified.
Section S. Effective Date. This Resolution shall take effect immediately upon its
adoption.
PASSED AND ADOPTED, this 12' day of April 2023.
3
HOUSING FINANCE AUTHORITY OF
COLLIER COUNTY, FLORIDA
By.
C air 67"
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EXHIBIT A -PROOF OF PUBLICATION OF NOTICE OF HEARING
Q
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Published Daily
Naples, FL 34110
PICKWORTH DONALD P.A .
725 HiGH PINES DR
NAPLES, FL 34103
Affidavit of Publication
STATE OF WISCONSIN
COUNTY OF BROWN
Before the undersigned they serve as the authority,
personally appeared said legal clerk who on oath says that
he/she serves as Legal Clerk of the Naples Daily News, a
daily newspaper published at Naples, in Collier County,
Florida; distributed in Collier and Lee counties of Florida;
that the attached copy of the advertising was published In
said newspaper on dates listed. Afflant further says that the
said Naples Daily News is a newspaper published at
Naples, in said Collier County, Florida, and that the said
newspaper has heretofore been continuously published in
said
Collier County, Florida; distributed in Collier and Lee
counties of Florida, each day and has been entered as
second class mail matter at the post office in Naples, in
said Collier County, Florida, for a period of one year next
preceding the first publication of the attached copy of
advertisement; and affiant further says that he has neither
paid nor promised any person, or corporation any discount,
rebate, commission or refund for the purpose of securing
this advertisement for publication in said newspaper
issue(s) dated or by publication on the newspaper's
website, if authorized, on
Issue(s) dated: 04104/2023
Subscribed and swom to before on April 4, 2023:
4
w
N to of WI, County of Brown
t5"'1,-,S'-
My commission expires
Publication Cost: $420.00
Ad No: 0005652785
Customer No: 1307145
PO #:
# of Affidavits 1
This Is not an invoice
NOTICE OF PUBLIC HEARING
HOUSING FINANCE AUTHORITY OF COLLIER COUNTY, FLORIDA
NOTICE IS HEREBY GIVEN of a public hearing by the Housing Fi•
nance Authority of Collier County, Florida (the 'Authority' to
be held on April 12, 2023, at 8:3 a.m. (local time), in the in the
County Manager's Conference Room, second floor, Building F,
Suite 202, Collier County Government Center, 3299 East
Tamlanhi Trail, Naples, Florida 34112, for the purpose of receiv-
ing comments and hearing discussion concerning a plan of fi-
nancingsubject to the internal Revenue Code of 1986, as
amended (the 'Code'), pursuant to which the Authority will is-
sue Its Single Family Mortgage Revenue Bonds, in one or more
series, in an aggregate principal amount of not to exceed
$50,000,000 pursuant to the plan of finance (the 'Bands'), the
proceeds oFwhich will be used to make available funds to pur-
chase federally insured or guaranteed mortgage loans originat-
ed by participating local lending institutions to finance or refi-
nance the purchase of new or existing owner -occupied single—
family residences situated within Collier County Florida, and by
persons or families of low, moderate or middle income (the
Pro)ect'), to purchase securities from a master servicer evidenc-
ing Interests in or backed by a pool of such mortgage loans, in-
cluding, without limitation, securities issued by the federal
government or agencies thereof or to be used in conjunction
with a Mortgage Credit Certificate program or for multifamily
housing. Persons may attend the hearing through the participa-
tion options set forth below.
The Bonds shall not be a debt, liability or obligation of the Au-
thority or of Collier County, Florida, or the State of Florlda, or of
any political subdivision thereof, but shall be payable sole)yy
from the above -referenced mortgage loans or securities ev(-
dencing an Interest in or backed by a pool of such mortgage
loans. The Bonds are not a debt of the United States of America
or any agency thereof, or of GNMA, Fannie Mae or Freddie Mac,
and are not guaranteed by the full faith and credit of the Unit-
ed States of America.
Participation options: (1) Physical attendance. Seating capacity
In the conference room is limited and not all may be accommo-
dated. (2) Call -in number 929.205.6099; Meeting ID 287 094
7702; Pasuode 555757.
All Interested persons are invited to attend the meeting
through the options set forth above, and may submit questions
or comments or request copies of the application for financing
by email to tine Authoritys executive director at don6clappalaw
.corn. Persons are advised that, if they decide to appeal any de-
cision made at this hearing, they will need a record of the pro-
ceedings, and, for such purpose, they may need to ensure that a
verbatim record of the proceedings is made, which record in-
cludes the testimony and evidence upon which the appeal is to
be based. Please contact Don Pickworth at 239-404.1475 with
any questions or concerns_
HOUSING FINANCE AUTHORITY OF COLLIER COUNTY
By: Donald A. Pickworth
General Counsel and Executive Director
April 4, 2023 #5652785
RYAN SPELLc,i
Notary Pubii:
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