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Presentation, discussion, and possible action to adopt an Agreed Final Order assessing an administrative penalty relating to Columbia Renaissance Square II Senior (HTC 18018 / CMTS 5406)
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RECOMMENDED ACTION
recommendation
WHEREAS, Columbia Renaissance Square II Senior (HTC 18018 /CMTS 5406), owned by Columbia Renaissance Square II, L.P. has uncorrected compliance findings relating to the applicable land use restriction agreements and the associated statutory and rule requirements;
WHEREAS, TDHCA identified findings of noncompliance during its regularly scheduled 2025 file monitoring review at Columbia Renaissance Square II Senior, and referred that noncompliance for an administrative penalty when it was not timely corrected;
WHEREAS, multiple issues of noncompliance remain unresolved because the development is repeatedly submitting incomplete documentation;
WHEREAS, an Enforcement Committee informal conference was held on February 19, 2026, and Owner agreed, subject to Board approval, to enter into an Agreed Final Order assessing an administrative penalty of $10,000.00, with $5,000.00 due at signing, and the remainder to be deferred and forgiven provided that fully acceptable corrections are uploaded within 30 days of the board meeting; and
WHEREAS, staff has based its recommendations for an Agreed Final Order on the Department’s rules for administrative penalties and an assessment of each and all of the statutory factors to be considered in assessing such penalties, applied specifically to the facts and circumstances present in this case.
NOW, therefore, it is hereby
RESOLVED, that an Agreed Final Order assessing a partially forgivable administrative penalty of $10,000.00, substantially in the form presented at this meeting, and authorizing any non-substantive technical corrections, is hereby adopted as the order of this Board.
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BACKGROUND
PROPERTY INFORMATION: Columbia Renaissance Square II Senior (HTC 18018 /CMTS 5406) (the Property) received an allocation of Housing Tax Credits during 2018, to build and operate one hundred 123 units in Fort Worth, Tarrant County, with 10 units restricted at 30% AMI, 39 units restricted at 50% AMI, 47 units restricted at 60% AMI, and the remainder at market rate. There are two buildings. The 15-year federal compliance period for the HTC LURA will end on December 31, 2035, and the extended use period will expire on December 31, 2055.
OWNERSHIP AND PROPERTY MANAGEMENT: The Property is owned by Columbia Renaissance Square II, L.P. James S. Grauley is the Manager and Chief Executive Officer for its general partner, New Columbia Residential, LLC. The Property is self-managed via Columbia Residential Management. Columbia has 40 multifamily developments in four states, including Texas, Louisiana, Georgia, and Florida, with 12 additional developments currently in progress.
TDHCA actively monitors three of their developments, with a fourth currently under construction.
REFERRED VIOLATIONS SUBJECT TO ADMINISTRATIVE PENALTIES:
1. 2025 HTC File Monitoring: TDHCA conducted an onsite file monitoring review on July 15, 2025, and the Compliance Division set a corrective action deadline of October 14, 2025. Partial corrections were submitted timely, and the Compliance Division issued a further cure notice, with a response deadline of December 15, 2025. There was no response, and the following noncompliance was referred for a penalty on January 21, 2026. An informal conference was mandatory because the Enforcement Committee (the Committee) previously issued a Warning Letter with a probationary period for related property Columbia Renaissance Square (HTC 15135 / CMTS 5121) in 2025.
a. Failure to market to veterans: The HTC LURA requires affirmative marketing to veterans. The Property has submitted partial corrections, but each submission is missing details needed to reasonably establish that veterans marketing has been completed. For example, the Property submitted copies of veteran marketing flyers without details about the flyer recipients on July 17, 2025, and it submitted copies of marketing emails without copies of the associated attachments mentioned in the body of those emails or any details about the recipients on March 3, 2026. This finding remains uncorrected.
b. Failure to provide social services: The HTC LURA requires the property to provide nine points worth of social services, which can be selected from a list attached to the LURA. During the onsite review, the Property provided evidence of eight points of services, including: Partnership with law enforcement (3 points), Food pantry (1 point), quarterly nutritional courses (1 point), twice monthly arts and crafts (2 points), twice monthly on-site social events (1 point). On February 18, 2026, the Property submitted notary information dated March 5, 2025 (1 point), however, during the informal conference, attendees for property management indicated they were uncertain whether the site currently has a notary due to staffing changes. The Property must either upload documentation for the current notary, or provide evidence of an additional social service worth 1 point. This finding remains uncorrected.
c. Noncompliance with lease requirements: Tenant files did not include the required Tenant Rights and Resources Guide (TRRG) Acknowledgment. Developments are required to post the TRRG in a common area of the leasing office, and to present each household with the TRRG during application and upon any changes to amenities or services. The development submitted signed TRRG Acknowledgments on March 3, 2026, but has not provided the required owner certification confirming that the TRRG Acknowledgment has been signed for all units and that the development will comply with TRRG requirements going forward. This finding remains uncorrected.
d. Failure to submit quarterly reports: Unit status reports are required to be submitted quarterly, on the 10th day of every January, April, July, and October. These reports were not timely submitted for the periods October 2020 through January 2026. Quarterly reports were submitted on December 1, 2025, and January 22, 2026, correcting this noncompliance.
FACTORS CONSIDERED TO DETERMINE ADMINISTRATIVE PENALTY: The Committee analyzed the required statutory factors for determining an appropriate administrative penalty as follows:
1. Eligible for debarment? No. There are no violations that would cause a debarment referral.
2. The seriousness, extent, and gravity of the violations, and whether a hazard is posed to the health, safety, or economic welfare of the public:
a. Health and safety: The referral did not include physical noncompliance; however, the Committee considered the physical condition in general. The 2025 physical inspection only showed noncompliance in the laundry room, with exposed electrical conductors and a missing clamp behind the dryers, all of which were timely corrected. There were no other unit or site findings.
b. Economic: Noncompliance is generally minor from an economic standpoint, however, the property consistently failed to submit quarterly reports for five years. This information is important because it feeds into the Department’s Vacancy Clearinghouse Property Search. Occupancy data was timely submitted as part of annual reports that are due every April, however, the Property failed to submit any quarterly vacancy reports in the intervening months for five years, meaning that potential tenants using that system were getting inaccurate information. Failure to market to veterans can also have an economic impact on veterans who may be looking for housing. This is offset by the low vacancy rate; occupancy as of the informal conference date was at 98%.
3. History of previous violations: There are no prior orders, however, the ownership group previously received a Warning Letter with a probationary period for related property Columbia Renaissance Square (HTC 15135 / CMTS 5121) in 2025.
4. Efforts made to correct the violations: Onsite management submitted a timely initial response to the Compliance Division, but it was incomplete. They then failed to submit any further corrections until the night before the scheduled informal conference with the Committee, stating during the conference that they were confused about the applicable property phase, and thought the referral was for Columbia Renaissance Square (HTC 15135 / CMTS 5121), the property for which TDHCA had previously issued a Warning Letter during 2025. Failure to track deadlines and maintain communication with TDHCA is a repeated issue. Ownership discussed a compliance tracking system that seems adequate, however, it was not implemented for this property, for reasons the Committee did not understand. The only explanation seemed to be staff turnover at the site, but that did not make sense since the tracking system was implemented at the supervisory level. Ownership also stated it could be checking CMTS more frequently, but the Committee noted that it seems to have no standard procedures for doing so even though it has a small portfolio, and this would be easy to implement.
Overall, onsite property management is inexperienced, and their submissions to TDHCA do not appear to be adequately supervised despite repeatedly submitting documentation that is being rejected by TDHCA. All of the uncorrected noncompliance should be easy to resolve; there is no reason it should need to be escalated to the penalty stage, and even less justification for it to remain uncorrected. Noncompliance is not extensive, but there is poor focus on attention to detail, and corrective uploads to CMTS are frequently incomplete, failing to follow minimum TDHCA instructions from monitoring letters even for simple noncompliance. Some examples are described above with the multiple submissions for veterans marketing, each incomplete, but for different reasons.
5. Any other matters that justice may require: Columbia has a large portfolio, but only three actively monitored TDHCA developments, with a fourth in development. They are a sophisticated organization, capable of complying with TDHCA requirements, but not deploying adequate resources to do so. There are also concerns about the number of tenant complaints received regarding related property 2100 Memorial (HTC 21419 / CMTS 1500), but ownership believes this problem has been resolved by replacing an unpopular property manager.
6. Amount necessary to deter future violations: Noncompliance remains unresolved despite technical support provided by TDHCA staff, and multiple corrective action reviews. This is a large organization, and the property is cash flowing well. Failure to submit complete and timely corrective documentation takes limited TDHCA staff time that would be better allocated elsewhere, and it is appropriate to recommend an administrative penalty here even though the referred noncompliance is relatively minor. In light of the above factors, the Committee recommends an Agreed Final Order assessing administrative penalties of $10,000.00, with $5,000.00 due at signing, and the remainder to be forgiven if complete corrections are submitted, per the Order, to incentivize corrections.
RECOMMENDATION: Accordingly, after consideration of all appropriate factors, the Enforcement Committee and Executive Director recommend an Agreed Final Order for an administrative penalty in the amount of $10,000.00, with $5,000.00 due at signing, and the remainder to be forgiven if complete corrections are submitted, per the Order, against Columbia Renaissance Square II, L.P.