Read and Considered

Monitoring of compliance with Affordable Housing regulations has been inconsistent and often inadequate. Disag'ee with this finding - The City has an established compliance program and conducts annual compliance reporting for all deed-restricted afordable housing projects. Thb includes review of annual audits, tenant rent roll to ensure rent and income level of units, and annual operations budgets. Per the City of Petaluma Regulatory Agreement, the property owner, an annual audit is required to be completed by a third parly, independent Cetrified Public Accountant.

The use of self-reported data in monitoring is the accepted norm. Disagree with this findhg - As part of the ongoing compliance program, the Ci$ conducts site visits. Site visits include a physical site inspection, unit inspection, and resident file ret iew. City staf revians to ensure tenanl income is documented via third-parly verification, annual unit inspections are conducted, and all maintenance requests are tracked and completed. An independent third-pafiy licensed Certified Public Accountant prepares an annual audit regarding propefiy operations and conducts sampling of tenant files, funding agreements, and unit mix to ensure compliance with regulatory agreements-

On-site (in-person) monitoring beyond that required by law is rare due to insufficient personnel, budgetary limitations, and relatively low incentives. Agree with this finding - At this time, the City does not have the resources to conduct annual on- site inspections for all properties. The City is in the process of adding additional staff to the department and will implement bi-annual site inspections for all deed-restricted rental unils.

COVD-l9 further reduced in-person, on-site monitoring due to public health restrictions. Agree with this finding - On-site monitoring was reduced and/or waived by federal funders to ensure the safety of the community and staff

Surprise or unscheduled monitoring of individual units is not done, for reasons of privacy, availability, efficiency, and practicality. pior Agree with this finding - For privacy and due process concerns, notice for site visits is scheduled to accommodate on-s e snf and residents- The lease agreements between the residents and the ownership of the property include a clause that requires the tenant to receive 24-hour written notice pior to any inspectjons or entry of the unit.

Unscheduled monitoring of properties and management in order to review tenant files, grounds, and the amenities is not done. Agree with this finding - Prior notice is provided to accommodate on-site saff and resident schedules.

The Community Development Commission has informational documents and policies to provide upfronttraining in the monitoring process. Partially ag'ee vith this .finding - There have been recent improvements in the documents and policies to support programs and training in the monitoing Process, speciftcally in the area of Homeless Services-

There is limited or no standardized training in Affordable Housing compliance regulations for developers and managers of inclusionary housing within the nine Cities. Partially agree with this finding - While the City has a program focused on specific fundinq sources (CDBG and HOME) and works closely with afordable housing Managers, there b no ongoing standardized training coun1^eide.

The cities of Petaluma and Rohnert Park use computerized compliance monitoring programs to facilitate and improve the quality of their work. Agree with this finding - The City implemented an online database system in the spnng of 2019 and continues to build out the online system.

The property titles of Affordable single-family houses have not always been flagged as deed restricted. Partitlly agree with this .finding - Prior to the release of any new .funding, resale, or financial restruchtring of existing rental developments and homeowner program properties, city staf works in partnership with the legal team to revieut regulatory agreements, title reports, deal documents, and escrow instructions tlJ ensure all transactions including recorded documents and deed restriction are in place, and recorded in the proper order. The City is in the process of reviewing the homeowner program to ensure lhe deed restrictions are accurate. As this workb completed, the program vtilt be built into the online database to ensure ongoing compliance. Fll. 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 compfance monitor. Partially disagree with this finding - The report does not accurately rellect the stafing capacity listed within the report. It should be modified to 50% of I FTE. City of Petaluma Responses to Recommendations Rl.By December 31.-2022, the Sonoma County Community Development Commission and the nine Cities meet and develop agreed-upon standerds and procedures for the monitoring of Affordable Housing. (F7, F8) The recommendation requires more analysis. The Ciq' is happy to meet with the County and other cities to collaborate on standards and procedures, where standudizing those is possible and makes sense. However, different rules, agreements and standards may apply tn dfferent juisdictions, limiting the extent to vhich procedures can be standardized. The City has a mon ortng handbook esnblished for federal and state-funded progrdms, which require extensive monitoring. Information b gathered for cily financed projects, but not to the same level of denil as state and federal projects.