Notification of a Proposed Revenue Bond Issuance of the District of Columbia Housing Finance Agency - Trinity Towers

April 28, 2026
The Honorable Phil Mendelson, Chairman
Council of the District of Columbia
1350 Pennsylvania Avenue, N.W., Suite 402
Washington, DC 20004
Dear Chairman Mendelson:
Pursuant to D.C. Official Code § 42-2702.07, and on behalf of the Board of Directors (the
“Board”) of the District of Columbia Housing Finance Agency (the “Agency”), you are hereby
notified that on April 14, 2026 the Board enacted an Eligibility Resolution for tax-exempt and/or
taxable multifamily housing mortgage revenue bond financing in an amount not to exceed
$55,690,000 for the rehabilitation and equipping of the Trinity Towers project (the
“Development”). The Development is expected to be located at 3023 14th Street NW, in Ward
1. After completion, the Development is expected to consist of one (1) building, containing a
total of approximately one hundred twenty-two (122) residential rental units.
A copy of the Eligibility Resolution for the DC Council’s review is enclosed as Exhibit A. A
detailed description of the Development and its intended benefits are provided in the
development financing memorandum enclosed as Exhibit B. If you have any questions, please
contact me at (202) 777-1600.
Sincerely,
Michael L. Hentrel
General Counsel
Enclosures
Sincerely,

EXHIBIT A

DCHFAResolutionNo.2026-09
TrinityTowersEligibilityResolution
DISTRICTOF COLUMBIAHOUSINGFINANCEAGENCYRESOLUTIONAS TO THEELIGIBILITYOF TRINITYTOWERS FOR TAX-EXEMPTAND/ORTAXABLEMULTIFAMILYHOUSINGMORTGAGE
REVENUEBOND FINANCING
WHEREAS, theDistrictof ColumbiaHousingFinanceAgency(the
“Agency’)receivedarequestfromStandardCommunities(the“Applicant’)thatthe
Agencyprovideacquisition,rehabilitation,andequippingfinancingforTrinity
Towers,whichuponcompletion,isexpectedtoconsistofonehundredtwenty-two
(122)residentialunitsfinancedwithmultifamilyhousingmortgagerevenuebonds
andisexpectedtobelocatedat302314"St.NW Washington,DC 20009inWard
1(the“Project");
WHEREAS,theApplicantshaveelected,pursuanttoSection142ofthe
InternalRevenueCodeof1986,as amended(the“Code"),tosetasideat
leastfortypercent(40%)of the units.for householdsat_—or
belowsixtypercent(60%)oftheareamedianincome("AMI");
WHEREAS,theApplicantsareeligibleforLowIncomeHousingTaxCredits
pursuanttoSection42oftheCode,andhaveelectedtosetasideatleastone
hundredpercent(100%)oftheunitsattheProjectforhouseholdsatorbelowsixty
percent(60%)ofAMI;
WHEREAS,theAgencyhasconducteda preliminaryreviewoftherequest
forfinancingoftheProjectinordertodetermine,amongotherthings,thatthe
Projectandthefinancingrequestedtherefor,complywiththerequirementsofthe

Districtof Columbia Housing Finance Agency Act,D.C. Law 2-135,as amended,
D.C.Code§ 42-2701.01etsea.(the“Act’);
WHEREAS, theApplicantshaverequestedfinancinginanamountnotto
exceed$55,690,000throughan offeringoftheAgency'sTax-Exemptand/or
TaxableMultifamilyHousingMortgageRevenueBonds(the“Bonds”)forthe
financing,includingthe financingof reasonablyrelatedand subordinatefacilities
andanypermissiblereimbursementexpenses,oftheProject;
WHEREAS, allora portionoftheProjectmaybefinancedwithproceedsof
theAgency'sTax-ExemptMultifamilyHousingMortgageRevenueBonds,and
suchportionthatisnotfinancedwiththeAgency'sTax-ExemptMultifamily
HousingMortgageRevenueBondsmaybefinancedwithproceedsoftheAgency's
TaxableMultifamilyHousingMortgageRevenueBonds:
WHEREAS, Agency staffrecommends the issuance of the Bonds in an
amount not to exceed $55,690,000, in one or more series,for the benefitof the
ApplicantsorotherrelatedentityaffiliatedwithorrelatedtotheApplicantsthatwill
own and operate the Project(the“Borrower’);and
WHEREAS, providingthefinancingrequestedfortheProjectwillconfera
publicbenefitandservethepublicinterestbyloweringthecostofandexpanding
availablehousingopportunitiesforlowandmoderateincomeresidentsofthe
Districtof Columbia (the“District’),allinaccordance with and infurtheranceof the
purposesoftheActinthefollowingmanner:
1 Makingavailableapproximatelyonehundredtwenty-two(122)units,
one hundred percent (100%) of which are estimated to be affordable
to households with incomes at or below sixtypercent (60%) of AMI;

2. ProvidingopportunitiesforconstructionjobstoDistrictresidentsbyrequiringthattheApplicantsandtheBorrowergiveprioritytoDistrictresidents;and
3. Contributingto the overallsocialand economic improvement of the
Ward 1 neighborhood.
NOW THEREFORE,BE ITRESOLVEDbytheBoardofDirectorsofthe
Agency(the“Board’)that
1.Basedupona reviewoftherequestbyAgencystaffasitrelatestothe
Project,thereporton suchreviewtotheBoard,thefavorable
recommendationof theExecutiveDirector/CEO,and upondue
deliberationand consultationwithAgencystaff,theBoardhereby
determinesthat,basedontherequirementsofeligibilityforfinancingby
theAgency,theProjectanditsfinancingbytheAgencywillmeetthe
requirementsoftheAct.
2.Finalapprovalofanyfinancingshallbe subjecttosuchterms,
conditions,anddocumentationacceptableordeemednecessarybythe
Agency.
3.Thisreservationofvolumecapintheamountof$55,690,000,tothe
extentavailabletotheAgency,isfora periodofonehundredeighty
(180)calendardays,whichperiodmay be extendedatthesole
discretionoftheBoard.
4.AdoptionofthisEligibilityResolutionshallnotconstitutea commitment
fromtheAgencytoissuetheBondsortoprovidefinancingforthe
Project.

5.TheExecutiveDirector/CEOisauthorizedtoundertakesuchactionsas
arerequiredtobetakenpursuanttotheActandtheregulationsofthe
Agency,includingtheselectionoftaxprofessionalservices.
6.TheExecutiveDirector/CEOisherebyauthorizedanddirectedtosend
totheChairpersonoftheCounciloftheDistrictofColumbiawritten
NotificationoftheadoptionofthisEligibilityResolutiondescribingthe
natureoftheProjectandthebenefitsdesignedtoresulttherefromas
requiredbyD.C.Code§42-2702.07
7.ThisEligibilityResolutionshalltakeeffectimmediately.

DCHFA Resolution No. 2026-09
ADOPTED ON APRIL 14,2026
AT A MEETING OF THE BOARD OF DIRECTORS.
ROLL CALL VOTE:
Heather Wellington APPROVED
ScottieIrving 2 APPROVED
Yohance Fuller : APPROVED
CarriRobinson APPROVED

EXHIBIT B

MULTIFAMILY UNDERWRITING MEMORANDUM
INDUCEMENT APPROVAL
TRINITY TOWERS
3023 14TH ST NW
WASHINGTON, DC 20009
WARD 1
122 UNITS
GENERAL TENANCY

DEVELOPER: STANDARD COMMUNITIES & HOUSING FOR ALL
SUBSTANTIAL REHABILITATION, NOT TO EXCEED $55,690,000
Maximum LTV: 80%, MINIMUM DEBT SERVICE: 1.15X, OR HIGHER, AS REQUIRED BY LENDER

KIRA ANTOINE
DATE: 4/14/26

2

Project Name:
Project Address:
Ward:
Census Tract
DDA/QCT?
# of Units
Building Type:
Primary Developer:
Tax Exempt Bond Issuance Amount:
AMI Restrictions:
Applicable Subsidy:
Development Team:
General Contractor:
Property Manager:
Architect:
Construction Lender:
Permanent Lender:
Bond Counsel:
Date Completed: RECS? Budgeted Expense:
2/27/2023 None N/A
Neighborhood:
Walk Score:
Transit Score:
Detrimental Influences:
Total Development Cost Per Unit:
Underwritten Vacancy Rate:
Underwritten OpEx Per Unit:
PAM OpEx Per Unit Range:
Appraised Value:
LTV:
Capture Rate:
Penetration Rate:
Type:
Private Placement
Tax Exempt Bond Amount Aggregate Basis/Bond Basis 50% Test
22,640,000 75,440,998 30%
Debt Execution: Freddie TEL
Underwritten:
Amount: $50,290,000
Interest Rate 5.97%
Amortization: 40
Term: 17
DSCR: 1.19x
LIHTC Equity Raise Rate: Total Amount:
Federal LIHTC Raise Rate: $0.81 $25,754,009
Yes
30
Yes
Overview:
Real Estate Considerations:
Land Considerations:
Submarket:
Environmental Study:
Columbia Heights
94
82
None
122
Standard Communities
22,640,000
60% AMI or Less
Multifamily Lending and Neighborhood Investments
Credit Approval Request
Trinity Towers
3023 14th St NW, Washington, DC, 20009
1
Substantial Rehabilitation
61%
Soto Architecture & Urban Design
Freddie Mac
Freddie Mac
TBD
Freddie Mac
Buyer:
Bozzuto Construction
Franklin Group
679,681
Permanent Debt:
7%
10,617
Name:
Bond Issuance:
Financing:
$11,437-$14,857
82,000,000
2.6%
36%
50% Test:

3

LOCATION MAP

4

TRANSACTION SUMMARY:
The Multifamily Lending and Neighborhood Investments (“MLNI”) underwriting staff requests the
inducement approval from the District of Columbia Housing Finance Agency’s (“DCHFA” or the “Agency”)
Board of Directors (the “Board”) for the issuance of tax -exempt bonds in an amount not to exce ed
$55,690,000 to finance a portion of the costs to rehabilitate 122 units at Trinity Towers (the
“Development” or the “Property” ). In accordance with DCHFA ’s 25% test policy for 4% LIHTC bond -
financed transactions, t he not to exceed amount is sized at the greater of 30% of aggregate basis or
maximum supportable debt service. The Senior Loan will be constrained to 80% stabilized Loan to Value
(LTV) and 1.15x amortizing debt service coverage ratio (DSCR).
On February 13, 2023, the Property’s current owner, Standard Trinity Venture LP, entered into a contract
to purchase the Property. The Trinity Towers Tenant Association assigned their Tenant Opportunity to
Purchase Act ( TOPA) rights to Standard Trinity Venture LP on September 8, 2023, and the transaction
subsequently closed on June 28, 2024. The new owner, Trinity Preservation LP (“Borrower”), and Standard
Trinity Venture LP entered into a Purchase and Sale Agreement dated December 18, 2025.
The LIHTC 10‑year hold rule generally prohibits the use of acquisition credits if a building was placed in
service by a prior owner within the previous ten years, in order to prevent repeated transfers of the same
property solely to generate new tax credits. When applicable, this rule eliminates acquisition eligible basis
regardless of the project’s affordability or capital needs.
Congress created a statutory exception to this rule under IRC §42(d)(6)(C) for federally assisted buildings,
recognizing that deeply subsidized housing often requires recapitalization within timeframes shorter than
ten years to remain viable. The statute excludes from the 10 ‑year restriction buildings that are
substantially assisted, financed, or operated under federal housing programs, including Section 8.
Trinity Towers qualifies for this exception because 100% of its units are supported by Project ‑Based
Vouchers under Section 8, placing the property fully within a federal housing program administered by
HUD. The PBV assistance governs rents, tenant eligibility, and ongoing operations, demonstrating
substantial federal involvement. As a result, the 10‑year placed‑in‑service restriction does not apply.
The proposed transfer of the Project in connection with the LIHTC resyndication and tax ‑exempt bond
financing also qualifies for an exemption from TOPA. The transfer is being undertaken to allow the Project
to enter into a new LIHTC credit period and complete a planned rehabilitation . Ownership of the Project
will transfer from the existing owner to a new ownership entity at closing; however, both the existing and
new owners will remain under the direct or indirect control of the same parent entity, the non-profit
Housing For All. Because the transaction meets the statutory criteria, including common control before
and after the transfer, entry into a new LIHTC credit period, and delivery of a timely and compliant Notice
of Transfer to tenants, it is not considered a sale under TOPA. Accordingly, the transaction is only subject
to the Notice of Transfer requirement and does not trigger tenant purchase rights.
The project completed its original fifteen -year compliance period in 2018 and is in need of substantial
rehabilitation. The proposed scope of work includes upgrades to residential units, common areas, building
systems, and site amenities. Unit renovations will feature new finishes, flooring, lighting, windows, and
fully modernized kitchens and bathrooms with energy ‑efficient fixtures and appliances. Common area
improvements include a reconfigured leasing office, new fitness and business centers, an upgraded
community room, and improved playground amenities. Exterior work will address faç ade repairs,

5

enhanced security systems, and accessibility upgrades, including ADA and UFAS-compliant units. Building-
wide improvements will modernize fire safety systems, elevators, and signage, while sustainability and
resident services enhancements will include a roo ftop solar system and the addition of Teladoc
telemedicine services.
The Development’s consists of one nine-story building with the unit count remaining the same at a total
of 122 units including 29 studios, 44 one-bedroom units, and 49 two-bedroom units. Units will be
restricted to residents earning 30% and 60% Area Median Income (AMI) or less with all units receiving
project based voucher (PBV) subsidies. The property does not offer street parking, but benefits from an
exceptionally walkable location, with convenient access to nearby bus and metro stops. Current amenities
include balconies, air conditioning, dishwashers, disposals, and microwaves, with planned renovations
adding a business center, fitness center, and storage. As of August 2025, the property achieved a NSPIRE
score of 90, reflecting excellent maintenance standards, proactive repair practices, and a strong emphasis
on resident health and safety.
Trinity Towers is in the Northwest section of Washington, DC (Ward 1, Census Tract 30) located in a mixed-
use area near community services and amenities (e.g., Target, CVS Pharmacy, Unity Health Care, Chase
Bank, etc.) within a one-mile radius. The property has good access to public transportation, including the
Columbia Heights Metro Station (which serves the Green Line), and several bus stops are within walking
distance. The Development is also about 0.3 miles from the Columbia Heights Community Center, a multi-
generational recreation center offering indoor programming spaces, including a boxing gym, dance studio,
arts and crafts room, recording studio, fitness room, computer lab, multi‑purpose room, a full gymnasium,
playground, and community garden.
One armed security guard will patrol the Developmen t Monday to Sunday for from 5pm-9am. The
proposed security system integrates building -wide video surveillance and electronic access control to
provide coverage of interior, exterior, and high-traffic areas. Cameras are strategically placed throughout
the property on each floor , while keycard-controlled access secures primary entrances, amenity spaces,
stairwells, and other critical points.
The capital stack for the Development will consist of permanent financing in the approximate amount of
a $50,290,000 Freddie TEL Immediate Permanent Loan that will be fully funded at closing, $4,884,755 in
Interim Income, $25,754,009 in Federal LIHTC Equity, and a $1,992,312 deferred developer fee. The total
development cost is $82,921,076 ($679,681/unit), inclusive of acquisition costs, soft and hard costs,
developer and financing fees, and reserves and escrows.
The borrowing entity for the Development is Trinity Preservation LP (the “Owner” and “Borrower”). Trinity
Manager LLC serves as the Borrower’s general partner and holds a 0.01% ownership interest. A subsidiary
of PNC will serve as the Borrower’s limited partner and federal LIHTC investor, holding a 99.99% ownership
interest. The general partner, Trinity Manager LLC, is owned by three members: Standard Acq Rehab LLC
(non‑managing member), Trinity Towers Member LLC (administrative member with 49% ownership), and
HFA Trinity Manager LLC (managing member with 51% ownership). HFA Trinity Manager LLC is owned and
controlled by the nonprofit Housing for All, Inc. A more detailed analysis of the ownership structure and
development team is provided later in the investment memorandum.
The remaining members of the Development team consist of Bozzuto Construction as the General
Contractor, Soto Architecture & Urban Design as Architect, Nexus Architecture & Design as the Owner’s
Representative, APEX as Construction Manager, and the Franklin Group as Property Manager.

6

RISKS & KEY MITIGANTS:
1. Reputational Risk: DCHFA will be providing $ 22,640,000 in tax -exempt volume cap to the
transaction, and will be publicly associated with the Development.
o Reputational Risk Mitigant: Standard Communities is an experienced affordable housing
developer with a national track record, having developed, acquired, and preserved more
than 2 7,000 units of affordable and workforce housing nationwide, including three
properties in Washington, D.C. Standard has demonstrated the financial strength,
organizational capacity, and development expertise necessary to execute affordable
housing transactions. This experience reduces reputational risk to DCHFA by increasing
the likelihood that the Developmen t will be completed on time, on budget, and in
compliance with all program and regulatory requirements.
2. Security Risk: Esri crime indices for the Property’s Primary Market Area (PMA) indicate overall
crime levels slightly above the national average and higher than the surrounding Metropolitan
Statistical Area (MSA). Total crime in the PMA is moderately elevated, driven primarily by personal
crime, which is substantially above both the national average and the MSA, particularly for violent
crime.
o Security Risk Mitigant: One armed security guard will patrol the Development Monday
to Sunday for from 5pm -9am. The proposed security system integrates building -wide
video surveillance and electronic access control to provide coverage of interior, exterior,
and high-traffic areas. Cameras are strategically placed throughout the property on each
floor, while keycard -controlled access secures primary entrances, amenity spaces,
stairwells, and other critical points.

STRENGTHS:
1. Sponsorship/Guarantor: Founded in 2008, Standard Communities is a national affordable
housing developer, owner, and asset manager that has completed and preserved more than
27,000 units across 195+ properties in 22 states and Washington, D.C. The portfolio includes
approximately 18,100 LIHTC units, 11,400 Section 8 units, 2,000 workforce housing units, and
9,100 senior housing units. Standard has demonstrated the organizational capacity and financial
strength to execute large, complex affordable housing transactions, including three projects
within the District of Columbia.
2. Subsidy Contracts: Standard Communities will retain project‑based rental subsidies for 100% of
the units through the continuation of a U.S. Department of Housing and Urban Development
(HUD) Section 8 Housing Assistance Payments (HAP) contract. The transaction will involve a Mark-
Up-to-Market (MUTM) renewal with post ‑rehabilitation rents effective immediately at closing.
The renewal will allow below‑market rents to be increased to market levels to support property
rehabilitation and long‑term preservation, subject to HUD eligibility requirements and approval
of a Rent Comparability Study (RCS). The continued use of project‑based subsidy provides stable
rental revenue while mitigating the risk of subsidy loss. Since all units are subsidized and tenants

7

pay 30% of their income for rent, post-renovation rents will not result in displacement of qualified
residents.
3. Preservation of Existing Affordable Units: The Development is a proposed
acquisition/rehabilitation of an existing affordable property that operates with LIHTC restrictions.
Financing for the Development provides the opportunity to make improvements and maintain
the affordability of the project for existing and future residents.
4. Location: The Development has good access to public transportation only 0. 1 miles from the
Columbia Heights Metro Station and near bus stops serving the 52, 54, 59, and D32 Metrobus
lines. The nearest bus stop is located adjacent to the Property along 14th Street.

LOAN STRUCTURE
The Development will be financed through the issuance of $ 22,640,000 in DCHFA tax exempt long term
bonds and $27,650,000 in taxable debt.
Lument Real Estate Capital is providing an immediate 17-year Freddie Mac TEL permanent loan with a
taxable tail (taxable portion) and 40-year amortization schedule. The tax-exempt portion of the loan will
be priced at the 10-year United States Treasury plus a 166 basis points (bps) lender spread (inclusive of a
40 bps for DCHFA’s fees) while the taxable portion will be priced at the 10-year United States Treasury
plus 159 bps, resulting in a blended yield of 5.97%.
The transaction does not utilize a separate construction loan. Instead, all renovation activity is financed
within the structure of a n immediate Freddie Mac TEL permanent loan that closes once and remains in
place for the full loan term. At closing, the loan is funded as long‑term, fixed‑rate permanent debt, rather
than as short ‑term interim or construction financing, eliminating the need for a future conversion or
takeout.
Renovation funds will be available immediately at closing. The full loan proceeds will be disbursed upfront,
allowing the Borrower to commence renovation activities immediately upon closing. This structure
provides maximum flexibility and liquidity, streamlines execution, and removes administrative delays
typically associated with construction draws, inspections, or staged releases of capital.

8

SUMMARY OF CONSTRUCTION SOURCES AND USES:

FINANCIAL ASSUMPTIONS:
Senior Loan Blended Interest Rate 5.73%
Senior Loan Amortization 40 years
Senior Loan Term 17 years
Minimum Amortizing DSCR 1.15

Construction Sources $ U ses $
Freddie TEL Immediate: 50,290,000 Acquisition: 50,005,000
Interim Income: 4,884,755 Construction: 15,549,349
Federal LIHTC Equity: 21,300,214 Soft Costs: 2,281,134
Financing Fees: 7,051,230
Developer Fee: 994,395
Reserves & Escrow: 593,862
Total Construction Sources 76,474,968 Total Construction Uses 76,474,968
Permanent Sources $ Uses $
Freddie TEL Immediate: 50,290,000 Acquisition: 50,005,000
Interim Income: 4,884,755 Construction: 15,549,349
Federal LIHTC Equity: 25,754,009 Soft Costs: 2,281,134
Deferred Developer Fee: 1,992,312 Financing Fees: 7,051,230
Developer Fee: 4,962,786
Reserves and Escrows: 3,071,578
Total Permanent Sources 82,921,076 Total Permanent Uses 82,921,076

9

DCHFA FEE SCHEDULE:

The DCHFA Bond servicing fee is calculated as 40 basis points per year for the long -term bond amount.
Given this project will have an immediate permanent loan these fees will not be capitalized but instead
will be paid on an ongoing basis.

OTHER SOURCES:
Interim Income: The Development is currently operating at a 2% vacancy and an 8% collection loss. The
Sponsor has underwritten interim income of $4,884,755, representing approximately 83% of the
Property’s anticipated NOI during the 18‑month renovation period, inclusive of a 7% vacancy and
collection loss. This assumption is considered reasonable given that the majority of units are expected to
remain occupied throughout rehabilitation, with approximately nine units offline at any given time for
renovation. Additionally, 100% of the units are supported by project ‑based vouchers, which account for
approximately 89% of total revenue, with the remaining 11% derived from the tenant -paid rent portion.
Stress testing indicates that the tenant- paid portion of rent could experience a loss of up to 78 %, while
the project would still maintain a debt service coverage ratio of approximately 1.15x.

Application Fee $23,348
Financing Fee $466,968
Issuer’s Counsel $45,000
DCHFA LIHTC Allocation Fee $194,606
Construction Monitoring Fee $155,493
Total $1,131,706

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TAX CREDIT STRUCTURE
The Sponsor selected PNC as the LIHTC investor for the transaction. A subsidiary of PNC , as the limited
partner, will acquire a 99.99% limited partner interest in the Development at the purchase price of $0.805
per $1.00 of federal LIHTCs. The PNC will provide an estimated total equity investment of $25,754,009.
The investment will be sufficient to fund the required equity for the transaction. DCHFA underwriting
assumptions project a qualified basis of $79,989,394, an annual LIHTC amount of $3,199,576. The federal
LIHTC equity will be disbursed 36.5% at closing, 10% at 20% completion, 12% at 40% completion, 11.94%
at 60% completion, 5% at 60% completion, 9% at 80% completion, 2.75% at construction completion,
12.48% at stabilized occupancy, and 0.33% at issuance of the IRS Form 8609.

LIHTC Calculation Acquisition Construction
Eligible Basis $48,588,774 $24,154,322
Adjusted Basis $48,588,774 $24,154,322
Projected Applicable Fraction 100% 100%
QCT 100% 130%
Projected LIHTC Qualified Basis $48,588,774 $31,400,619
$79,989,394
Tax Credit Rate 4.00%
Annual LIHTC Amount $3,199,576
L.P. Ownership 99.99%
Investor Pay Rate 0.81
Projected LIHTC Investor Equity $25,754,009

DDA/ QCT Map:
The Development is located in a Difficult Development Area which increases eligible basis by 30%.

11

SPONSOR /DEVELOPER/ GUARANTOR ANALYSIS:
Developer: Standard Communities
Founded in 2008, Standard Communities (“Standard”) is a multifamily real estate investment,
development, and asset management firm specializing in the acquisition, rehabilitation, and long -term
preservation of affordable and workforce housing across the Un ited States. Standard is a full- service,
institutional owner-operator with a focus on maintaining high -quality housing for low - and moderate-
income households while partnering with public entities and community stakeholders.
Standard and its principals have developed, acquired, and preserved more than 27,000 affordable and
workforce housing units, and today own approximately 30,000 residential units nationwide. The firm has
over $6 billion in assets under management across 22 states and the District of Columbia.
Within the District of Columbia, Standard and its affiliates own three affordable housing communities,
including active LIHTC properties that were financed by the District of Columbia Housing Finance Agency
(DCHFA) and the Department of Housing and Community Development (DHCD). Standard has completed
several affordable housing preservation transactions in the District, including Fort Chaplin Park
Apartments, one of the largest tax- exempt bond–financed affordable housing preservation deals in D.C.
history.
In April 2023, Standard became the first affordable housing company in the United States to achieve
Certified B Corporation status, a designation awarded by B Lab to for‑profit companies that meet
standards for social and environmental performance, transparency, and legal accountability. B Lab Global,
the steward of the B Corp certification, has established a framework for stakeholder capitalism through
its governance of the B Impact Assessment and advancement of Benefit Corporation legislation, creating
a system now utilized by over 10,000 companies worldwide and providing investors with a standardized
mechanism for long‑term accountability, transparency, and risk mitigation.
Standard is led by an experienced senior management team with expertise in affordable housing finance,
development, acquisitions, and asset management. Key principals include:
Scott J. Alter, Co -Founder and Principal, oversees all aspects of investments, asset management,
construction, financial structuring, and corporate strategy. Since co-founding Standard in 2008, Mr. Alter
has led the firm’s growth into one of the largest owners of affordable housing in the country.
Jeffrey E. Jaeger, Co-Founder and Principal, is responsible for the firm’s investment strategy, acquisitions,
asset management, and financing activities. Mr. Jaeger has played a central role in sourcing and executing
complex affordable housing transactions nationwide.
Thomas (Tommy) Attridge, Vice President, is a senior member of Standard’s Acquisitions &
Redevelopment team and is based in the firm’s Washington, D.C. office. Mr. Attridge is responsible for
sourcing and executing acquisition and redevelopment opportunities, with a focus on complex affordable
housing transactions in the Mid-Atlantic region. Prior to joining Standard, he worked at Capital City Real
Estate, a boutique condominium and multifamily developer in the D.C. Metro Area, and previously served
in an acquisitions role in the region for Brookfield Residential Properties.
Brian Yang leads Standard Communities’ transaction management team, overseeing deal execution and
delivery across the firm’s national investment platform. Mr. Yang has more than 13 years of experience
in the real estate industry and has been directly invol ved in the closing of over 50 transactions with an

12

aggregate capitalization of approximately $2.75 billion. Prior to joining Standard, he worked with publicly
traded REITs Archstone and Equity Residential, where he managed operations for Class A multifamily
properties. Mr. Yang holds a Bachelor of Science in Hotel Administration from Cornell University and is
licensed as a Real Estate Salesperson in the State of California, where he also maintains a notary public
commission.
DCHFA reviewed Cohn Reznick’s Independent Accountant’s Agreed ‑Upon Procedures Report for the
Development’s guarantor, Standard Guarantor LLC (the “Company”). The procedures were performed
using information provided by Company management and were acknowledged by the Company and its
owners, Jeffrey Jaeger and Scott Alt er, as appropriate for evaluating the Company’s financial condition.
The agreed‑upon procedures included the following:
• Liquidity testing confirming that demand notes classified as liquid assets.
• Verification of stated net worth through a review of cash, receivables, and the net present value
of projected cash flows from the Company’s portfolio of projects.
• Project‑level testing, whereby 20% of the projects included in the cash flow analysis were selected
for testing. Related cash flows, valuations, sale‑year property values, and development fees were
verified against governing agreements, audited financial statements, and management
projections, with no exceptions identified. Cash flows from the partnerships may include incentive
management fees, partnership management fees, supervisory and oversight fees, developer fee
principal and interest, and equity distributions payable to partnership owners.
• Confirmation of cash, including verification of the Company’s cash balance through bank
statements.
The report was conducted in accordance with AICPA standards for agreed‑upon procedures.

Co-Developer: Housing for All, Inc.
Housing for All, Inc. will serve as the Project’s co‑developer. Housing for All is a 501(c)(3) organization that
has maintained tax‑exempt status since 2020 whose purpose is to acquire, own, develop, manage, and
invest in affordable housing properties, including holding ownership interests and serving as a general
partner or managing member of affordable housing entities. It may receive charitable contributions,
finance and reinvest real estate assets, and operate exclusively for charitable purposes under Section
501(c)(3), including soliciting grants and con tributions to support affordable housing development and
preservation.
Housing for All is led by a board of directors with real estate, legal, and financial expertise relevant to
affordable housing development and oversight. The organization’s leadership includes Mihran Erkiletian,
President, a commercial real estate professional with over a decade of experience in multifamily
development who has been directly involved in the construction and development of more than 1,000
apartment units; David Brodsky, Secretary, a real estate attorney with extensive experience representing
institutional investors across real estate transactions; and Timothy White, Treasurer, a real estate
developer who has completed the acquisition and development of more than 5,000 apartment homes
and currently serves as an Adjunct Professor in Georgetown University’s Master’s in Real Estate Program.
Collectively, Housing for All’s directors bring decades of experience spanning multifamily development,

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institutional real estate finance, and legal structuring, positioning Housing for All with the organizational
capacity, fiduciary oversight, and technical expertise necessary to serve effectively as a co‑developer and
advance the delivery of high‑quality, long‑term affordable housing consistent with its charitable mission.
OWNERSHIP STRUCTURE
The borrowing entity is Trinity Preservation LP (the “Owner” or “Borrower”). The general partner is Trinity
Manager LLC (“General Partner”, 0.01% interest) and consists of HFA Trinity Manager LLC , (“Managing
Member”, 51% interest) and Trinity Towers Member LLC (“Administrative Member”, 49% interest). The
Managing Member is soley owned by Housing for All, Inc., a Virginia nonprofit public benefit corporation.
The Administrative Member consists of Jaeger Investments Holdings LP (73% interest) and various other
members, none of which has over 10% interest. Standard Acq Rehab LLC is also a Non-Member Manager
of the Administrative Member. Standard Acq Rehab LLC will serve as the non ‑member manager and
developer of the partnership. Because Standard Acq Rehab LLC shares more than 50% beneficial
ownership with the seller, it is not eligible to be included in the ownership structure.
As the Non -Member Manager, Standard Acq Rehab LLC, has primary responsibility for the overall
management and control of Trinity Towers Member LLC. It holds exclusive authority over the company’s
business and affairs and may take all actions necessary or desirable to carry out the company’s purposes,
including entering into contracts, managing and disposing of assets, arranging financing, and making
strategic decisions. Members do not have any management or control rights by virtue of their ownership.
Standard Acq Rehab LLC may act independently on major matters such as selling or refinancing assets,
exercising buyout options, and making protective capital calls. While the Manager retains ultimate
authority, it delegates day‑to‑day operational responsibility to the Jaeger Investment Holdings LP (the
“Operating Principal”), whom the Non -Member Manager may remove or replace at its discretion. The
Non-Member Manager also oversees regulatory filings, maintains the Company’s legal status, and
authorizes transactions with affiliates on commercially reasonable terms, all while serving without
compensation for its role as Manager.
The Borrower ownership structure is illustrated below.

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15

GENERAL CONTRACTOR:
Bozzuto Construction Company is a nationally recognized, ENR Top 400 general contractor founded in
1988, with an average annual revenue of approximately $600 million and a cumulative portfolio exceeding
$7.7 billion in completed or active construction. The firm has delivered more than 61,000 residential units
across a wide range of product types, including mixed‑income and affordable housing, senior and assisted
living, urban infill, wood‑frame over podium construction, concrete and metal‑frame structures, historic
renovations, and occupied rehabilitations.
Bozzuto has substantial experience with affordable and LIHTC housing, including 4% and 9% credit
transactions, tax‑exempt bond financing, and developments subject to local hiring goals, prevailing wage,
Section 3, First Source, and CBE/SBE participation requirements. The firm has successfully completed
numerous affordable and senior housing projects throughout the Mid‑Atlantic, demonstrating familiarity
with cost containment, constructability challenges, and compliance demands.
From a risk and capacity standpoint, Bozzuto utilizes BIM technology to improve coordination and
execution performance. All subcontractors are required to go through Bozzuto’s formal prequalification
process, which includes analysis of three years of Experience Modification Rates (EMR), three years of
OSHA logs and company metrics, and review of past internal performance to identify and evaluate
potential risk. Bozzuto also maintains significant bonding capacity through Liberty Mutual, with the ability
to support large‑scale multifamily projects on both a single‑project and aggregate basis, at $250,000,000
and $1,000,000,000 respectively. Overall, Bozzuto is considered a highly experienced and low‑risk general
contractor whose participation materially mitigates construction, completion, and cost ‑overrun risk for
affordable housing transactions.
The following scorecard summarizes Bozzuto’s recent experience delivering affordable multifamily
housing projects in the District of Columbia. The projects shown represent a mix of new construction and
substantial rehabilitation developments across multiple Wards and owners, all financed through DCHFA.
The scorecard highlights key performance metrics, including schedule adherence, cost control relative to
original GMP, unit counts, and compliance with District requirements such as CBE/MBE participation and
First Source goals. Collectively, these projects demonstrate the General Contractor’s capacity to manage
complex, large‑scale developments with varied scopes while maintaining consistency in regulatory
compliance and project execution.

Bozzuto Construction Project 1 Project 2 Project 3 Project 4 Project 5
Project Name Belmont Crossing Phase 2 Lisner Senior Edgewood V Worthington Woods HR Crawford
Project Address 4283 & 4373 Barnaby Rd. SE,
Washington, DC
5425 Western Ave, Washington,
DC
525 Edgewood St NE, Washington,
DC 4419 3rd St SE, Washington, DC 737 50th St NE, Washington, DC
Ward 8 3 5 8 7
Owner / Developer Gilbane Development Urban Atlantic Enterprise Community
Development MHP CRP Affordable
Construction Commencement Date 1/27/2025 9/15/2023 11/30/2023 7/11/2023 9/11/2023
Construction Completion Date 9/16/2026 8/1/2025 3/10/2026 2/23/2026 8/11/2025
Original Schedule Duration (Months) 19.26 22.1 22.3 28.1 20
Final Actual Duration (Months) 19.68 22.3 27.1 31.2 23
Original GMP / Construction Budget $71,211,524 $35,959,728 $71,478,766 $50,744,757.44 $31,325,741.00
Final Construction Cost $72,245,443 $35,561,413 $74,047,139 $56,863,741.37 $32,259,517.04
% Self-Performed Work 0% 0% 0% 0% 0%
Total Number of Units 219 93 151 394 76
Total Construction Cost/Unit $329,888 $382,381 $490,378 $144,324 $424,467
Project Description (New
Constuction/Substantial Rehab) New Construction New Construction New Construction Substantial Rehab New Construction
CBE & MBE Goals Achieved? (Yes/No) Yes- on track Yes Yes Yes Yes
First Source Goals Achieved? (Yes/No) Yes- on track Yes Yes Yes Yes
DCHFA Financed? (Yes/No) Yes Yes Yes Yes Yes

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CONSTRUCTION MANAGER: APEX CFM LLC
APEX Construction & Facilities Management (“APEX”) will serve as Construction Manager for the
Development. APEX is a nationwide construction and facilities management firm specializing in the
rehabilitation, renovation, and preservation of multifamily hous ing. APEX provides construction
management services from pre ‑construction planning and due diligence through closeout, stabilization,
and ongoing capital oversight. APEX’s services include scope development, cost estimating, procurement
oversight, contractor coordination, construction administration, compliance tracking, and closeout.
APEX has served as Construction Manager on multiple Standard‑owned affordable housing developments,
delivering projects on time and within original scheduled durations. Representative projects include the
substantial rehabilitation of Ritch Homes Apartments (46 units, Ward 4) and Fort Chaplin Park Apartments
(549 units, Ward 7), both of which were financed by DCHFA and required adherence to District
requirements, including CBE/MBE participation and First Source hiring. In both cases, APEX achieved all
applicable local participation and workforce goals and delivered construction within the original
scheduled timelines of 16 months and 26 months, respectively.
Ed Brennan, Vice President of Construction, brings over 30 years of construction experience, overseeing
the planning and execution of construction and rehabilitation projects across a national portfolio of
multifamily affordable housing properties. He spec ializes in tenant ‑in‑place rehabilitations, including
phased construction, resident access, and relocation logistics, with a focus on minimizing disruption to
occupancy. Throughout his career, Mr. Brennan has led or played a key role in more than 131 construction
projects totaling over 20,150 units, working closely with development, design, and asset management
teams to deliver durable, community‑focused housing.
Patrick Lyons, Senior Vice President of Construction, has nearly 15 years of experience in the construction
industry, with expertise spanning both the General Contractor and Owner/Developer perspectives. He
oversees portfolio ‑wide construction efforts, with a particular focus on complex tenant ‑in‑place
rehabilitation projects. Over his career, Mr. Lyons has led the successful delivery of 50+ construction and
rehabilitation projects representing more than 8,000 housing units. He holds both a Bachelor ’s and a
Master of Science in Civil Engineering, with a concentration in Structural Engineering, from the University
of Rhode Island.
The APEX leadership team brings decades of experience overseeing large ‑scale affordable housing
renovations across thousands of units nationwide and includes former construction managers for major
institutional owners and developers. Collectively, the team has managed capital improvement projects
involving high‑rise, mid‑rise, and garden‑style communities, senior housing, historic rehabilitations, and
large multi‑property portfolios.

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PROPERTY MANAGEMENT:
The Franklin Group (“Property Manager”) is the current Property Manager for the Development and will
continue to serve in this role. The Franklin Group launched in 2013 manages 36,000 units at 250
communities in the Mid-Atlantic and Southeast. Of those communities in the Mid-Atlantic, Franklin Group
manages 30 in the District of Columbia, including several DCHFA -financed transactions such as Henson
Ridge I, 17 Mississippi, Villages of East River, Congress Park I and II, Ritch Homes, Galen Terrace, and Trinity
Towers.
Laurie Arehart is a Senior Vice President of Property Operations at Franklin Group overseeing the
management of a portfolio of communities throughout Rhode Island, New Jersey, DC, Maryland, and
Northern Virginia. Laurie has been in the property management industry for over 24 years and holds a
Certified Apartment Manager designation from the National Apartment Association. Ms. Arehart
previously served as the Regional Vice President of Panco Management, a national property management
firm with properties in Maryland and Virginia.
According to DCHFA’s Portfolio and Asset Management Third Quarter 2025 audit, the Franklin Group
manages 1,345 affordable housing units within DCHFA’s portfolio, including several properties that were
transitioned from TM Associates following a documented period of operational deficiencies which
necessitated a change in management . Currently, the portfolio reports a debt service coverage ratio
(DSCR) of 1.97x.
The Franklin Group also serves as the property manager for the Property, which is currently operating at
a DSCR of approximately 1.24. This experience and demonstrated ability to stabilize assets reinforces the
Project’s overall management capacity from construction completion through long‑term stabilized
operations.
The staff for the Development include one manager, one assistant manager, one maintenance
superintendent, and one maintenance technician.

ARCHITECT:
Soto Architecture & Urban Design (“Soto”) will serve as Architect of Record for the Development. Soto is
an architectural firm founded in 2014 with active registrations in the District of Columbia, Maryland, and
Virginia. The firm is a certified Minority ‑Owned Business Enterprise (MBE), Small Business Enterprise
(SBE), Disadvantaged Business Enterprise (DBE), and Certified Business Enterprise (CBE). Soto specializes
in the planning, design, and delivery of community, commercial, residential and mix-use developments.
Since its inception, Soto has designed more than 5,300 multifamily units, including approximately 3,300
affordable housing units, representing over $600 million in aggregate construction value. The firm has
participated in at least 15 LIHTC transactions, including both 4% and 9% credits, and reports no terminated
contracts or material claims, indicating a strong performance history.

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OWNERS REPRESENTATIVE:
Nexus Architecture and Design Inc. (“Nexus”) will operate as Owner’s Representative on the project and
is an affiliate of Standard Communities responsible for ensuring consistency and quality of rehabilitations
across Standard’s national portfolio. In this role, Nexus will supervise the third‑party Architect of Record,
Soto Architecture & Urban Design, and serve as the owner’s primary liaison during construction.
Nexus is a full‑service architectural firm specializing in multifamily affordable housing, adaptive reuse,
capital renovations , new construction, and historic preservation . The firm is led by President James
Benjamin, a registered architect with more than 35 years of experience across the affordable, multifamily,
hospitality, and mixed‑use sectors. While Nexus is a relatively new entity, its leadership brings substantial
institutional knowledge, having previously operated an integrated architecture and construction practice
and served as in ‑house architect for Standard Communities with a focus on LIHTC ‑financed acquisitions
and redevelopments.

SITE CONTROL:
The current owner and the proposed new owner have entered into a Purchase Option Agreement that
provides site control for the Property. Under the agreement, the seller has agreed to sell, and the
purchaser has agreed to purchase, all right, title, and inte rest in the land, improvements, leases,
assignable personal and intangible property, and related entitlements, subject to customary exclusions,
upon exercise of the option at or prior to financial closing. The option structure provides the purchaser
with adequate site control to proceed with financing and predevelopment activities through closing.

ENVIRONMENTAL REPORT:
A Phase I Environmental Site Assessment (ESA) report was completed by EBI Consulting (“EBI”) on
February 27, 2023, in accordance with ASTM Standard E1527 ‑13, the Freddie Mac Environmental
Requirements, and the Fannie Mae Property Condition Report. The assessment evaluated the Property’s
physical characteristics, historical land use, current conditions, surrounding property uses, and applicable
regulatory records. This scope included a review of topographic, geologic, soils, and hydrologic data;
historical s ources such as land deeds, fire insurance maps, aerial photographs, city directories, prior
reports, and interviews; and a review of federal, state, and local environmental databases within
applicable search distances. Certain non ‑ASTM considerations, including asbestos ‑containing materials,
lead‑based paint, lead in drinking water, radon, and mold, were also considered subject to stated
assumptions and limitations.
Based on the findings of the Phase I ESA, no Recognized Environmental Conditions (RECs) were identified
at the Subject Property.
Several environmental considerations outside the scope of ASTM Practice E1527 ‑21 were reviewed for
the Property. A limited asbestos screening survey identified suspect friable (easily crumbled) and
non‑friable materials; however, laboratory analysis of representative samples did not detect asbestos,
and observed materials were in good condition at the time of inspection.
According to the report, radon usually enters a building through openings in the foundation, and therefore
the greatest health concern is to residents of the lowest level of a building. Radon was not assessed due

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to the absence of ground‑floor residential units. Washington, D.C. is located in an EPA Radon Zone 3 area,
indicating a low potential for elevated radon levels.
Lead‑based paint testing was not conducted as part of the assessment; however, a Lead‑Based Paint Free
certificate was issued in 2008, painted surfaces were in good condition, and no peeling or chipping paint
was observed. Similarly, lead in drinking water was not sampled, as the property is served by DC Water
and the municipal supply meets Safe Drinking Water Act standards.
A limited visual microbial (mold) survey of accessible areas identified no observable moisture issues or
indicators of mold growth. Interviews with property personnel also did not indicate mold concerns.
Lastly, a review of District of Columbia environmental regulations confirmed that the District does not
have Environmental Superlien laws in place.

ZONING & ENTITLEMENTS:
The Property is located within the MU -7 zoning district. This zoning classification is intended to permit
moderate- to high -density, mixed -use development, including multifamily residential uses, and is
generally applied to properties located along arterial streets, in urban and regional centers, and near rapid
transit corridors.
The zoning district allows multifamily residential development consistent with the existing and intended
use of the Property.
Following a review of municipal zoning records, the DC Department of Buildings Office of Zoning
Administration confirmed that there are no known zoning or land ‑use violations associated with the
Property. Based on this review, the existing improvements are considered legally conforming with all
applicable zoning regulations.
Accordingly, the Property’s current use is considered legally permissible and compliant, and no zoning -
related issues were identified that would adversely affect the continued operation, marketability, or
finance ability of the asset.

DEVELOPER-TENANT ASSOCIATION AGREEMENT:
The Tenant Association and the Developer agreed to a framework under which the Developer will acquire
the property, assume ownership and management responsibilities, and undertake a comprehensive
rehabilitation of the building while preserving long-term af fordability and minimizing tenant
displacement. As part of the agreement, the Tenant Association will assign its TOPA rights to the
Developer contingent upon the successful closing of the acquisition. The Developer committed to
pursuing financing, including LIHTC and other governmental incentives, and agreed that if the acquisition
does not close, the TOPA rights will fully revert to the Tenant Association.
Following acquisition, the Developer will manage and operate the property in coordination with the
Tenant Association, including holding regular meetings, engaging a new property management company
and security provider, and addressing resident concerns related to management, safety, and
maintenance. The Developer committed to funding resident services through an annual budget adjusted
for inflation, holding and coordinating the use of additional funds set aside by the seller, and improving

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common areas and building systems. Substantial unit -level renovations are planned, including
replacement of cabinets, windows, flooring, appliances, HVAC systems, and bathroom upgrades, with
construction anticipated to occur primarily while tenants remain in place and with ongoing
communication regarding scope and timing.
Critically, the Developer agreed to preserve affordability for at least 30 years through compliance with
LIHTC, HUD, and other applicable restrictions, pursue renewal of the Section 8 HAP contract, and ensure
that no tenants are permanently displaced as a result of the renovations. Detailed relocation protections
were established, requiring the Developer to cover all relocation, storage, packing, and moving costs when
temporary relocation is necessary. The agreement further outlines inspection protocols, repair timelines,
confidentiality obligations, and mutual cooperation requirements, with the shared objective of
rehabilitating the property, improving safety and quality of life, and maintaining housing stability for
existing residents.

SCOPE OF WORK:
The proposed rehabilitation program includes comprehensive interior unit renovations, common area
upgrades, exterior improvements, and building modernization. Unit interior renovations will consist of
fresh paint throughout all units, luxury vinyl tile flooring, replacement of existing lighting with new
energy‑efficient LED fixtures, and installation of new window blinds. All Packaged Terminal Air
Conditioners (PTACs) and all windows in each unit will be replaced.
Kitchen renovations will include the installation of new energy ‑efficient stainless ‑steel appliance,
including replacement dishwashers and the addition of over ‑the‑range microwave ovens. Kitchens will
also receive new countertops, cabinetry, sinks , and faucets. Bathroom upgrades will include new vanity
fixtures, countertops, medicine cabinets, and toilets, tubs, and shower surrounds, as well as updated bath
accessories. Renovations will include WaterSense ‑labeled products that are independently third ‑party
certified and meet EPA specifications for water efficiency and performance.
Common area renovations will include a complete reconfiguration of the leasing office, the addition of a
business center and fitness center, and the renovation of the community room. Playground areas will be
updated with new equipment and a poured‑in‑place rubber safety surface.
Exterior improvements will include façade repairs as necessary, along with security enhancements will
including the installation of a new camera system and improved ingress and egress controls throughout
the property.
The scope further includes significant property ‑wide ADA improvements, including the conversion of
select units to UFAS standards. Building safety systems will be upgraded through modernization of the
fire life‑safety systems in both common areas and residential units. Elevators will undergo full
modernization, and all interior building signage will be replaced.
Overall, the scope of work represents a substantial capital improvement program aimed at modernizing
the property to current standards while supporting long‑term operational stability and compliance.
According to the Physical Needs Assessment prepared by EBI Consulting, the cost of identified critical
repairs is estimated at approximately $1,200. Total projected capital expenditures over the 12‑year

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analysis period are estimated at $291,887, or $199.38 per unit. The proposed scope of work for the
Development is designed to fully address all capital needs identified in the report.

RELOCATION PLAN:
The proposed renovation is designed to allow residents to be relocated to vacant on-site units throughout
the construction process with temporary off-site relocation used only when necessary. The vacant on-site
units used for relocation will be fully renovated prior to tenants relocating to them. Preference for on-site
units will be provided for households with children and seniors. In the case of off-site relocation, Standard
and the Franklin Group have identified two hotels within a 10 -minute drive of the property, Lyle
Washington (in Dupont) and Pure Voyage (in Shaw), as options for tenant extended stays . Off-site hotel
accommodations will be at extended stay hotels with kitchenettes in the District.
The property manager, Franklin Group , will oversee all aspects of tenant coordination and
communication. A designated Relocation Coordinator will be appointed to manage tenant needs, ensure
compliance with notice requirements, and provide individualized support throughout the renovation
process.
The Franklin Group will distribute a General Information Notice outlining the planned renovation. A
60-Day or 90-day Notice identifying estimated renovation start dates will be delivered concurrently or
shortly thereafter. Management will host a property -wide resident meeting to discuss the plan and
schedule. Additional reminder notices summarizing the scope of work, construction timeline, and unit
preparation requirements will be issued no later than 30 days prior to construction commencement and
again one week before work begins.
Renovations will be completed in phases, with approximately six to nine units renovated concurrently.
Each phase is expected to take approximately 20 business days, while UFAS-designated units will require
approximately 30 days. No resident will be displaced from their unit for more than 60 days, and
professional movers will be provided to ensure the secure handling of tenant belongings.
A structured grievance procedure will be in place, allowing tenants to submit complaints directly to the
Relocation Coordinator. Written complaints will receive a response within 48 hours, with unresolved
matters escalated to Franklin Johnson’s Regional Manager for final resolution.
The total relocation budget is estimated at approximately $2,939 per unit, or $358,600, and is considered
sufficient to support all temporary relocation and tenant assistance needs during construction. This
includes $191,000 for movers and supplies, $67,600 for the Relocation Coordinator, and $100,000 for
hotel expenses, miscellaneous expenses, and contingency.

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TENANT SERVICES:
Tenant services at the Property will be provided by Ounce of Care (“Ounce”), a third -party resident
services provider, through the on -site presence of trained Coordinators whose primary responsibility is
resident engagement and service delivery. Ounce will dedicate an average of at least eight (8) hours per
week of in -person support at the Property. Following an initial two -month period, staffing levels and
schedules will be adjusted as needed based on property-specific requirements and resident demand.
Ounce is responsible for recruiting, training, and supervising the Coordinators, who will proactively engage
residents and respond to resident needs. Services are structured around ongoing feedback and identified
resident interests, and Ounce will provide monthly reporting to Property management summarizing
services delivered and resident participation.
Resident programming will include planned community -building events, with at least one event hosted
during the first full month of service. Ounce will submit a monthly event calendar for approval, ensure
activities remain within the approved budget, and provide documentation of expenditures in accordance
with the Property’s budget process. The Property has budgeted $25,000/yr for tenant services. Ounce of
Care has assigned one Community Navigator ( “Tenant Services Coordinator”) and one Community
Navigator Manager to the Property.
Services are organized around four primary pillars:
• Financial Stability: Connecting residents to public benefits, assisting with benefit applications,
providing job training and employment support referrals, and coordinating Family Self-Sufficiency
program outreach.
• Health and Wellness : Assistance with obtaining or maintaining health insurance, support for
primary and preventative care, coordination of specialty and mental health services, chronic care
support, transportation assistance, and food security resources.
• Safety: Partnerships with local law enforcement and emergency services for safety workshops,
community presentations, and access to additional resident resources as needed.
• Community Development : Hosting social and holiday -related events, fostering resident
connections, supporting safe and accessible common spaces, and linking residents to educational
resources such as tutoring, childcare, literacy programs, and extracurricular activities.

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MARKET DESCRIPTION:
A market study prepared by Novogradac & Company LLP was provided for the on February 17, 2023. The
Property is situated in the Columbia Heights/Cardozo area of Northwest DC featuring a diverse mix of
residential, institutional, and commercial uses, including grocery and pharmacy retailers, restaurants,
schools, healthcare facilities, nonprofit organizations, and recreation amenities. The Subject’s location is
designated a Walk Score of 94, indicating that daily errands do not require a car. The Subject is located
approximately 0.1 miles from the Columbia Heights WMATA Metro station, providing access to Metrorail
service and multiple Metrobus routes. Within close proximity, residents h ave access to a wide range of
educational, medical, retail, financial, and public services, including a shopping center with national
retailers.
The Property does not offer street parking, but benefits from an exceptionally walkable location, with
convenient access to nearby bus and light rail stops. A menities include balconies, air conditioning,
dishwashers, disposals, and microwaves, with planned renovations adding a business center, fitness
center, and storage.
The Property is an existing, occupied property and will not require re ‑leasing of units. Accordingly, the
absorption analysis presented by Novogradac is hypothetical and assumes a scenario in which the
property is 100 percent vacant. Absorption data was obtained from nine comparable properties located
between 0.3 and 2.7 miles from the Property, with reported absorption rates ranging from 6 to 33 units
per month and an average of approximately 20 units per month. Based on the Subject’s size, location, and
transit‑oriented nature, Novogradac projects an absorption rate of 25 units per month, which would
equate to an estimated absorption period of approximately five months, if vacant.
Comparable properties report strong occupancy performance with a weighted average vacancy rate of
4.4%. Of the LIHTC comparable properties analyzed, four of five managers reported full occupancy, and
the affordable comparables exhibited an average vacancy rate of 2.7 %, which is notably lower than the
4.9% weighted average vacancy rate reported by the market‑rate properties.
The Property is currently 9 8% occupied and maintains a waitlist, indicating strong demand. Given the
Property’s current physical occupancy of and economic occupancy of approximately 91%, the Agency has
conservatively underwritten a vacancy and collection loss (VCL) of 7%.
A crime index below 100 is below the national average and anything over 100 is above the nation’s crime
index average. A crime index of 75 in a Primary Market Area (PMA) would be 25 percent below the
national average while a crime index of 200 would be twice that of the national average. This property's
market area has a violent crime index of 160, indicating the violent crime is 60 percent more prevalent
than the national average.

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To mitigate these risks, one armed security guard will patrol the Development Monday to Sunday for from
5pm-9am. The proposed security system integrates building-wide video surveillance and electronic access
control to provide coverage of interior, exterior, and high -traffic areas. Cameras are strategically placed
throughout the property on each floor, while keycard -controlled access secures primary entrances,
amenity spaces, stairwells, and other critical points. The proposed security system integrates building-
wide video surveillance and electronic access control to provide coverage of interior, exterior, and high -
traffic areas. Cameras are strategically placed throughout the property on each floor, while keycard -
controlled access secures primary entrances, amenity spaces, stairwells, and other critical points.
A new market study will be required for final bond.

APPRAISAL:
DCHFA underwriting staff reviewed the February 27, 2023 appraisal prepared by Tobin Real Estate
Advisors, Inc. for the Developmen t. The appraisal concludes an “As Renovated /Stabilized” value of
$82,000,000, assuming restricted rents. The Property is projected to have a $50,290,000 senior loan and
a loan LTV of 85%, which is within DCHFA Senior loan mortgage loan requirements.
The Market “As Is As Restricted” value of the Property is $71,500,000 and the land value “As Restricted”
is $5,600,000
A new appraisal will be required for final bond.

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UNDERWRITING NOTES: UNIT MIX
Please see the unit mix below:
Unit Type # of Units AVG Unit Size (SqFt)
Efficiency 29 358
1 BR 44 589
2 BR 49 776
Total 122 609

Please see the affordability mix below:
% AMI # of Units % of Units
30% 38 31%
50% 13 11%
60% 71 58%
Total 122 100%

INCOME:
The MLNI Underwriting Staff has underwritten Gross Potential Rent based on Development’s anticipated
Mark-Up-To-Market (MUTM) HUD rents at closing. The property will consist of 122 units, with 31% of
units set aside for households earning 30% of AMI or less and 100% of the units set aside for households
earning 60% of AMI or less.
Trinity Towers currently has an active Housing Assistance Payment (HAP) contract. At closing, the owner
will renew the HAP Contract with MUTM post rehabilitation rents . The MLNI staff ha ve conservatively
underwritten rent increases at 2.0%.
Hessel, Aluise & O’Leary P.C. is the law firm serving as special HUD counsel for the transaction in
connection with the assignment and renewal of the Project’s Section 8 HAP Contract. At closing, and
subject to HUD approval, the existing Option 1 HAP renewal covering all 122 units will be early terminated
and replaced with a new 20‑year Mark‑Up‑to‑Market (MUTM) contract under Chapter 15 of the Section
8 Renewal Policy Guide, with post‑rehabilitation rents taking effect at closing.
The early termination is permitted because current rents are below both as ‑is and post ‑rehabilitation
comparable market rents. HUD is authorized to allow post ‑rehabilitation rents to commence at closing
since the transaction involves financing that requires full debt service at closing. To achieve this, the
Proposed Owner will execute a HUD‑93182 Addendum confirming its commitment to complete specified
capital repairs and acknowledging that post ‑rehabilitation rents will be effective as of the renewal
contract start date.

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The table below illustrates the stabilized rents at the property:

The required Rent Comparability Study (RCS) was submitted to HUD in December. F inal HUD approval is
anticipated in April 2026.
The property also generates income from a Verizon Wireless cell tower that located on the property and
is expected to remain in operation. The License Agreement between the current property owner and
Verizon Wireless has been extended to include four additional renewal terms, each with a duration of five
years. These renewal terms renew automatically unless Verizon provides written notice of its intent to
terminate at least six months prior to the commencement of a subsequent renewal term. Absent such
notice, the agreement continues through the applicable renewal period.
The current annual license fee is $38,000, payable in equal monthly installments, and increases by two
percent annually.
Under the terms of the agreement, Verizon is permitted to use designated areas within the property to
support its telecommunications operations. This includes approximately 480 square feet of basement
space for equipment, an additional 96 square feet for a generator, and rooftop space accommodating
fifteen antennas and two GPS antennas, along with all related cabling, conduits, wiring, and piping
necessary for operation.

NET OPERATING INCOME:
The MLNI Staff has underwritten the property’s NOI to $ 3,934,883 which supports a senior mortgage of
$50,290,000 with an amortizing DSCR of 1.23x in Year 1.
Vacancy: The MLNI Staff has underwritten the property’s vacancy to 7.0% (3% for vacancy and 4% for
collection loss).
Effective Gross Income (EGI): The EGI has been underwritten to $ 5,230,121 or $ 42,870/unit. The
developer has assumed an increase in rents at a rate of 2% per year.

Market/
Affordable
Efficiency 30% Affordable PBV 9 358 $2,785 $60 $2,725
Efficiency 50% Affordable PBV 3 358 $2,785 $60 $2,725
Efficiency 60% Affordable PBV UFAS 17 358 $2,785 $60 $2,725
1 BR 30% Affordable PBV 14 589 $3,593 $63 $3,530
1 BR 50% Affordable PBV 5 589 $3,593 $63 $3,530
1 BR 60% Affordable PBV UFAS 25 589 $3,593 $63 $3,530
2 BR 30% Affordable PBV 15 776 $4,793 $128 $4,665
2 BR 50% Affordable PBV 5 776 $4,793 $128 $4,665
2 BR 60% Affordable PBV UFAS 29 776 $4,793 $128 $4,665
Total/Avg
ffordable
Net Underwriting
Rents / Wtd Avg.
122 609 $3,883 $88 $3,795
Rent/Wtd
Avg.% AMI Subsidy
Assumption # of Units Unit Size
(Sq. Ft)
Utility
AllowanceAccessibility Unit Type

27

RENT COMPARABLES
MLNI staff reviewed a market study prepared by Novogradac & Company LLP dated February 17, 202 3.
The Trinity Towers rents presented in the table below reflect post‑rehabilitation MUTM rents anticipated
to be effective at closing.
Novogradac concluded that the Property’s proposed in‑unit amenities are generally similar to, and in
some cases slightly superior to, those offered by the LIHTC comparable properties, and slightly inferior to
similar when compared to market ‑rate developments. The Property’s proposed studio, one ‑bedroom,
and two‑bedroom rents at the 60 percent AMI level, absent subsidy, fall within the adjusted rent range of
the comparable properties.
This conclusion is considered reasonable, given that the Property’s condition is assessed as slightly inferior
to slightly superior relative to the LIHTC comparables following rehabilitation. Based on the market study
findings, it is concluded that the Subject can reasonably achieve the maximum allowable rents at the 60
percent AMI level absent subsidy. This is a hypothetical analysis, given that the HAP contract is anticipated
to be renewed for 20 years with no indication of cancellation.

EXPENSES
Total expenses are underwritten to $1, 412,483 or $11,578/unit. Below are expense comps provided by
DCHFA’s Portfolio Asset Management Staff:
0BR 1BR 2B R
Trinity Towers 2,785 3,593 4,793
32 Thirty
‑
two Apartments 60% 1,454 1,556 1,845
Justice Park 60% – 1,359 1,643
Park Place at Petworth 60% 1,499 1,611 1,934
Petworth Station 60% – 1,833 2,126
Walbraff Apartments 60% – 1,289 1,489
Shipley Park Apartments 60% – 1,332 1,714
Average 1,477 1,497 1,792
LIHTC Maximum 1,624 1,740 2,089
Subject Compared to LIHTC Maximum 71% 106% 129%
60% LIHTC Rental Comps - Trinity Towers

28

The properties analyzed are similar to the subject in age (within 15 years), income restrictions, tenant -
paid utilities, occupancy type (general) and property type (mid -rise). The annual, per unit operating
expenses including bad debt (before reserves, trustee fees, and LIHTC monitoring fees) for the comparable
set ranges from $ 11,437 to $14,857. The projected per unit operating expense of $ 11,578/year for the
subject property is within the range of the comparable properties.

CURRENTLY
Property Name Trinity Towers Trinity Towers K ing Towers The Bridge (2442 MLK)
Audit Year N.A. Q 4 2025 2024 2024
Year Built 2026 2001 2011 2021
Building Type Mid-Rise Mid-Rise Mid-Rise Mid-Rise
Number of Units 122 122 129 112
AMI 1% @ 30% + 11% @ 50% + 58%@ 60% 31% @ 30% + 11% @ 50% + 58%@ 60% 100% @ 60% 5% @ 30% + 95% @ 50%
EGI 5,396,776$ 4,630,932$ 2,339,931$ 2,148,797$
Occupancy 0% 0% 97% 98%
Risk Share or Private Placement Non-Risk Share Non-Risk Share Non-Risk Share Non-Risk Share
Real Estate Tax Status Exempt Exempt Exempt Non-Exempt
Ward 1 1 2 8
Operating Expenses
Administrative 695,254$ 817,800$ 655,117$ 566,099$
Operating and Maintenance 327,433 539,072 667,515 379,181
Utilities 315,548 405,389 363,318 197,742
Tax, Insurance, & License 74,246 50,322 99,184 331,357
Total 1,412,481$ 1,812,583$ 1,785,134$ 1,474,379$
Per Unit Per Annum
Administration 5,699 6,703 5,078 5,054
Maintenance 2,684 4,419 5,175 3,386
Utilities 2,586 3,323 2,816 1,766
Tax, Insurance, & License 609 412 769 2,959
Total 11,578$ 14,857$ 13,838$ 13,164$
Expense/Income Ratio 26% 39% 76% 69%
Distance Subject n.a. 1.8 Miles 6.2 Miles
DSCR 1.16 1.24 0.86 1.03
Real Estate Taxes 0.00 3,881.00 193,905.00
Total Adjustments (Real Estate Taxes) 0.00 3,881.00 193,405.00
Total Expenses after adjustment 1,812,583.00 1, 781,253.00 1,280,974.00
Total Expense (per unit) 14, 857.24 13,808.16 11,437.27
DCHFA Portfolio and Asset Management Comparables

29

REGULATORY REQUIREMENTS:
Regulatory Use Restriction
In accordance with IRS Section 142 requirements for tax exempt bonds, the Sponsor has elected to set
aside a minimum of 40 percent of the units for households with incomes at or below 60 percent of AMI.
Pursuant to IRS Section 42 requirements for tax credits and to maximize tax credit equity, the Sponsor has
elected to set aside 100 percent of the units at or below 60 percent of AMI for 15 years following the year
the Project is placed in service. The tax-exempt bonds qualified project period will be reflected in the Tax
Regulatory Agreement between DCHFA and the Sponsor. The 15 -year tax credit compliance period and
the 25-year extended use period (which runs concurrently) will be reflected in the Indenture of Restrictive
Covenants for Low Income Housing Tax Credits between DHCD and the Sponsor.
Minority and Local Business Entities’ Participation
The borrower will be required by the Tax Regulatory Agreement to comply with all District and federal
laws concerning contracting and procurement, including the Small, Local, and Disadvantaged Business
Enterprise Development and Assistance Act of 2005, as amended (DC Code § 2-218.01 et seq.), the
Workforce Intermediary Establishment and Reform of First Source Amendment Act of 2011, as amended
(DC Code § 2-219.01 et seq. (First Source Act)), D.C. Law 2 -156, Section 5 (Apprenticeship Program), and
will execut e a First Source Employment Agreement (First Source) with the District of Columbia
Department of Employment Services (DOES) and a subcontracting agreement with the Department of
Small and Local Business Development. District Government contracts exceeding $250,000 require a 35
percent subcontracting set-aside with small businesses certified under the CBE Program.
Closing Timeline
DCHFA Inducement Approval/Review 4/14/2026
TEFRA Hearing TBD
TEFRA Mayoral Approval TBD
Completion of third party reports TBD
Construction Contract Finalized TBD
Lender Approvals TBD
Investor Approval TBD
Permits TBD
DCHFA Board Meeting Final Bond Approval TBD
Close 8/31/2026

30

Green Building Requirements
The Sponsor will be required to fulfill the requirements of the Green Building Act. It is anticipated that the
Project will design the project to meet Enterprise Green Communities 2020 Green Building Standards.
The Project will receive its permits before closing. As part of the permitting process, the Department of
Building’s (DOB) Green Building Division or approved third party will conduct a Green Review for projects
over 10,000 square feet. The Green Review ensures compliance with District’s Energy Conservation Code
and Green Building Act or Green Construction Code.
Inclusionary Zoning
In July 2010, the District of Columbia Zoning Commission approved emergency amendments specifying
that projects with the following characteristics will be exempt from the inclusionary zoning (“IZ”)
regulations:
• At least 80% of units must be affordable.
• Rent and sale prices must not be above maximum limits for the affordability program.
• Units must remain affordable for at least 30 years.
• A Covenant for affordability must be recorded against the properties.
Based on the above standards, the Project is exempt from IZ regulations during the 30 year period that
the DHCD LIHTC Indenture of Restrictive Covenants is enforced. However, an IZ covenant must still be
recorded. The IZ covenant will be subordinate to DCHFA and DHCD’s covenants while they are active and
will only take effect when the two covenants expire.
SUMMARY/CONCLUSION/RECOMMENDATION:
Having reviewed the Development’s budget, planned financing and operating projections, the transaction
appears to be feasible. The development consists of 29 studio units, 44 one-bedroom units, and 49 two-
bedroom units for a total of 122 units. One hundred percent of the units will continue to be set aside for
residents making of 30% or 60% AMI or below. The MLNI underwriting staff recommends that the Board
authorizes initial credit approval of bonds in an amount not to exceed $55,690,000 to finance a portion
of the costs to rehabilitate the existing community.

31

TRINITY TOWERS - PROJECT INFORMATION SHEET

Item Facts
Development Type: Substantial Rehabilitation
Project Type: Conduit Issuance
Project Name: Trinity Towers
Location: 3023 14th St NW
Ward: 1
Tax Exempt Bond Amount: $50,290,000
Credit Ehancement: Freddie TEL
Total Acqusition Costs/Unit: $409,877
Construction, Site work Costs/Unit: $99,626
Total Development Costs/ Unit: $679,681
Evidence of Site Control: Purchase option
Sponsor: Standard Communities
General Contractor: Bozzuto Construction
Architect of Record: Soto Architecture & Urban Design
Management Agent: Franklin Group
Sponsor's Attorney: TBD
# of Buildings: 1
# oif Units: 122
# of Parking Spaces: 0
Current Zoning: MU-7B
Census Tract/ QCT: 30.00/Yes
Land Size: 0.41 Acres
Building Size: 111,500 sq ft

32

APPENDIX
1. Financial Model
2. Construction Comps
3. General Contractor Score Card
4. DCHFA Portfolio and Asset Management Comparables