$12,000,000 ED1 Small-Lot Affordable (32 Units) in Boyle Heights, Los Angeles, CA
By Trevor Damyan··Construction Loan
The Deal
Commercial Lending Solutions arranged $12 million in construction financing for a 32-unit affordable housing development in Boyle Heights, Los Angeles. The project utilized California's Executive Directive 1 (ED1) streamlined approval process, allowing construction of a four-story wood frame building on a small infill lot. The capital stack included 9% Low Income Housing Tax Credits through the competitive round, city soft loan funds, and county Homeless Housing, Assistance and Prevention (HHAP) program money. Construction timeline was set at 18 months.
ED1, signed by Governor Newsom in 2019, allows affordable housing projects to bypass local zoning restrictions and CEQA environmental review when they meet specific criteria including 100% affordability, prevailing wage requirements, and location within existing urban areas. This regulatory relief proved essential for making the economics work on such a small-scale development.
The Challenge
Small-lot affordable developments face inherently challenging unit economics. Fixed development costs including architecture, engineering, entitlements, and legal fees must be spread across fewer units, driving up per-unit development costs significantly compared to larger projects. In this case, the restricted rents achievable under affordable housing regulations created a narrow path to financial feasibility.
The 32-unit count put the project in an awkward middle ground: too small to achieve meaningful economies of scale, yet still requiring the full complement of professional services and regulatory compliance costs of larger developments. Traditional construction lenders were reluctant to provide competitive pricing for what they viewed as a subscale deal with complex affordable housing requirements and multiple funding sources requiring careful coordination.
The developer needed construction financing that would price aggressively enough to preserve returns while accommodating the extended timeline required for LIHTC syndication and coordination between multiple public funding sources.
The Solution
We identified a community bank with strong Community Reinvestment Act (CRA) objectives seeking qualified affordable housing lending opportunities. The bank viewed the transaction as valuable CRA credit and offered below-market construction loan pricing that made the development economics viable. Their familiarity with LIHTC structures and public funding sources streamlined the underwriting process.
The ED1 designation delivered critical value by eliminating CEQA environmental review requirements, saving over $200,000 in environmental consulting costs and removing approximately 12 months from the development timeline. This regulatory streamlining improved both project returns and reduced market risk exposure during the development period.
We structured the construction loan to accommodate the complex capital stack timing, with the permanent financing ultimately provided through LIHTC investor equity, city loan funds, and county HHAP money. The construction lender agreed to extended interest-only payments during the lease-up period and flexible conversion terms aligned with the LIHTC syndication timeline.
The financing included provisions for cost overruns common in small projects where contingencies represent a higher percentage of total development cost. We negotiated change order approval processes that balanced lender oversight with the speed required for an 18-month construction schedule.
The Outcome
The project closed on schedule and began construction with full financing in place. The ED1 streamlining proved as valuable as projected, eliminating both the environmental review costs and timeline that would have made the project financially unviable. The community bank's CRA-motivated pricing provided the margin needed to make the development economics work despite the inherent challenges of small-lot affordable housing.
The successful financing demonstrates how regulatory reform like ED1 can unlock small infill affordable housing development when combined with appropriate capital sources. Community banks seeking CRA credit represent an underutilized financing source for affordable housing developers willing to work with smaller, relationship-focused lenders rather than pursuing commodity construction financing.
The 18-month construction timeline kept carrying costs manageable while the multiple funding sources closed in coordination. The developer achieved their targeted returns despite the challenging small-lot economics, creating a replicable model for similar infill affordable housing in high-cost California markets.
This transaction illustrates the importance of matching financing sources with deal characteristics: the community bank's CRA objectives aligned perfectly with the borrower's need for below-market pricing on a socially beneficial but economically challenging development. The ED1 regulatory relief provided the additional margin required to make the economics work, demonstrating how policy tools and creative financing can combine to deliver needed affordable housing in constrained urban markets.
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