Primary Department: Miscellaneous
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Regular or Supplemental RCA: Regular RCA
Type of Request: Miscellaneous Section
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Justification for 0% MWBE Participation Goal: N/A - Goal not applicable to request
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Justification for 0% Grant Indirect Costs Rate (if applicable): N/A - Not a grant item
Request Summary (Agenda Caption):
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Request by Leon, Alcala, Morse & Reynolds, PLLC, as bond counsel, for approval of a resolution approving, solely for purposes of Section 147(f) of the Internal Revenue Code, a tax-exempt financing in a maximum principal amount of $21,000,000 by the Hilshire Village Cultural Education Facilities Finance Corporation for the benefit of St. Francis Episcopal School of Houston to finance and refinance educational facilities located in Harris County; the obligations are not a debt of, and create no liability for, the County.
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Background and Discussion:
1. The Hilshire Village Cultural Education Facilities Finance Corporation (the "Corporation"), created by the City of Hilshire Village under Chapter 337, Texas Local Government Code, proposes to issue tax-exempt obligations in a maximum principal amount of $21,000,000 and loan the proceeds to St. Francis Episcopal School of Houston, a 501(c)(3) nonprofit school, to refinance its existing bank loans and finance and refinance educational facilities at 335 Piney Point Road, Houston, Texas 77024 and 2300 South Piney Point Road, Houston, Texas 77063, both in Harris County. The loan is currently sized at approximately $10.6 million.
2. Section 147(f) of the Internal Revenue Code requires, as a condition of tax exemption, that the financing be approved by the elected legislative body of the governmental unit in which the facilities are located, after a public hearing held on reasonable public notice. Because the facilities are in Harris County, Commissioners Court is that body. The City of Hilshire Village, as the Corporation's sponsor, gives its own approval separately.
3. Notice of the public hearing was published in the Houston Chronicle on October 7, 2026, and the hearing was held on October 14, 2026 by toll-free telephone conference call, as permitted by Revenue Procedure 2022-20, on behalf of the Corporation, the City and the County. The hearing officer's certificate (Exhibit A to the resolution) documents the notice, the hearing and any comments received.
4. The resolution approves the financing solely for purposes of Section 147(f) and ratifies the hearing notice, hearing officer and hearing. It is not an endorsement of the School or an approval of any loan document. Commissioners Court approved a similar request for a Corporation financing for Providence Classical School on June 28, 2022.
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Additional notes related to the Strategic Plan:
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Anticipated Court Date: 10/29/2026
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Emergency/Disaster Recovery Note: Not an emergency, disaster, or ARPA related item
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