"Affordable Housing: Monitoring and Compliance." The following responses have been reviewed and approved by the City

- Monitoring of compliance with Affordable Housing regulations has been inconsistent and often inadequate The City disagrees that affordable housing monitoring has been inconsistent and inadequate. The extent of affordable housing monitoring can vary based on funding source and funder which may incorporate additional data to be collected and monitored. Not all affordable housing projects within Sonoma County receive funding from the identical sources and programs which may result in differing reporting requirements.;. During COVID-19, on-site monitoring was suspended, but the reviewing of monitoring reports submitted by property owners and managers continued to be performed by City staff. Additionally, affordable housing projects often have multiple funding and reporting requirements by the California Tax Credit Allocation Committee, the California Debt Limit Allocation Committee, and the California Department of Housing and Community Development, as well as the requirements of private lenders. Affordability requirements have changed over time with new or additional monitoring requirements being placed on newer projects; revisions to affordability agreements for in-service projects may require the review and approval of outside, private funders and institutions who underwrote the financial investment based on the compliance and monitoring requirements identified at time of development.

- The use of self-reported data in monitoring is an accepted norm The City partially disagrees with this finding. Self+eported data is a common practice, but the data is reviewed for errors and inconsistencies. Affordable housing units are frequently monitored by multiple agencies increasing the ability to identify errors or omissions in self-reported data.

- The cities of Petaluma and Rohnert Park use computerized compliance monitoring programs to facilitate and improve the quality of their work The City uses a computerized system to monitor its loans; it also uses other electronic programs and platforms to track and monitor compliance for the various forms of financial assistance provided to projects. The use of a particular computerized compliance monitoring system is not an indicator of the of the quality in the monitoring

- The property titles of Affordable single-family houses have not always been flagged as deed restricted. The City disagrees with this finding in that it is overly general and does not take into account other instruments that can be recorded against a property to regulate the affordability or re-sale- Older properties and developments may not have the same restrictions or documentation that are used in current transactions. For homeownership units, the City will record a Deed of Trust if financial assistance has been provided, additional documents that are executed restrict Owner Occupancy and Resale Restrictions. For rental units, again the City will record a deed of trust if financial assistance has been provided and also will record a Regulatory orAfiordability Agreement identiffing the number of income restricted units, the income levels for those restricted units, the duration of time the units are restricted, and identifying the compliance and reporting requirements of the development.

- The majority of the housing representatives the Grand Jury interviewed felt that there is not enough staff within their departments to make anyone a full-time compliance monitor The City disputes this finding as it not is not privy to the individuals that were interviewed to prepare the report or the testimony that was provided. The City has a full-time staff person that performs compliance monitoring for affordable housing units and added an additional full-time position in the Fiscal Year 2022-2023 budget to assisting in compliance monitoring for the approximately 500 new affordable housing units that are under construction. lt is anticipated that the new staff member will begin assisting with compliance monitoring in tall2022. The report requires the City to respond to recommendations R1, R2, R3,