‹ Harris County Improvement District No. 14 · All districts' issues
question
Developer reimbursement
3 conflict questions
money moved
Confirm the 2025A reimbursement report was filed with TCEQ within 10 days of the December 16, 2025 approval.
30 TAC §293.70.
The board action behind it
2025-12-16: Approved developer reimbursement report for the $10,000,000 Series 2025A and $8,000,000 Series 2025B bonds and authorized disbursement of bond proceeds
What else happened at that meeting
The Board approved the developer reimbursement report for the Series 2025A and 2025B bonds and authorized disbursement of bond proceeds. It deferred utility service terminations for December and authorized the operator to ask the TCEQ to approve an online system for backflow and inspection records. The Board approved a $80,500.49 pay estimate for Section 19 paving and accepted a Waiver of Special Appraisal from Dunham Pointe covering 121 acres. The roll lists all five directors, but the minutes record Director Dawson as absent for the early votes and joining the meeting during the operations item.The law and guidance in force on 2025-12-16
| CPA performs set procedures on every item before the developer is paid from bonds; report filed with TCEQ within 10 days of approval 30 TAC §293.70
§293.70: Same text in force then and now |
Not shown in the record | Board approved the report and disbursement (p.2). Filing with TCEQ is not recorded. For the 2025B park bonds, which need no TCEQ approval, the rule may not apply. |
| Developer interest no higher than the bonds' net effective interest rate and generally limited to two years after final payment 30 TAC §293.50
§293.50: Same text in force then and now |
Question | Estimated developer interest was $1,716,537 (2025A) and $308,471 (2025B); the rates and periods are in the report, not the minutes. |
| Land priced at the developer's cost (lower of cost and appraisal in the floodplain) 30 TAC §293.51
§293.51: Same text in force then and now |
Question | 2025B includes $1,629,873 for park land; whether §293.51 applies to park bonds is uncertain. |
| Directors with a substantial interest file an affidavit and abstain Local Gov't Code ch. 171
|
Question | May apply only if a director has a substantial interest in the developer (§171.002). Three of the four directors who voted hold developer-conveyed qualifying tracts subject to deeds of trust to the developer; no affidavits have been seen. |
| Conflicts disclosure statements about vendors Local Gov't Code §176.003
§176.003: Same text in force then and now |
Question | Whether the qualifying-tract conveyances require statements depends on their terms (deeds and deeds of trust, Harris County Clerk RP-2024-118132 to -118137, RP-2024-136812 and -136813). |
| Public money only for a public purpose, with control and return benefit Tex. Const. art. III §52
art. III §52: Same text in force then and now |
Shown | Reimbursement follows an auditor's report on bond-approved items; the HCID 13-titled items ($359,186 across 2025A/2025B) raise the return-benefit question discussed under April 15, 2025. |
Who's involved
Dunham Pointe Development LLC (developer)
Forvis Mazars, LLP (auditor)
BGE, Inc. (district engineer (presented and recommended))
Allen Boone Humphries Robinson LLP (ABHR) (general counsel)
Masterson Advisors LLC (financial advisor)
Possible conflicts
Directors Lashbrook, Mather, Dawson and Hooper: Each qualifies through a 0.20-acre tract deeded by the developer in April 2024 with a deed of trust back to the developer; no ch. 171 affidavits or ch. 176 statements have been seen. (Director tract deeds, Harris County Clerk RP-2024-118132, -118134, -118136 and RP-2024-136812, with deeds of trust back to the developer RP-2024-118133, -118135, -118137 and RP-2024-136813)
Forvis Mazars, LLP: Prepared the reimbursement report while also serving as the district's annual auditor and HCID 13's auditor. (Consultant schedules in the FY2025 audits of HCID 14 (annual-financial-report_FYE-2025-11-30.pdf, PDF p.48) and HCID 13 (hcid013_financereport_20251130.pdf, PDF p.38))
Dunham Pointe Development LLC: Payee of the reimbursement; its representatives attended the meeting. (minutes p.1)
Cost to the district
Amount disbursed not stated in the minutes. By the official statements' use of proceeds, roughly $8.9M of 2025A (net of issuance costs; $9.16M of items less $260,000 surplus funds) and $3.95M of 2025B (net of issuance costs and the $3.0M district-built park line) relate to developer reimbursement, including about $2.0M of estimated developer interest. About $47.7M of developer costs remained unreimbursed after these issues (Nov 2025 official statement, hcid14-site/bond-official-statements/HCID14_Series2025A_FOS_SAMCO.pdf, PDF p.17-18 and p.39; Texas Open Books calculation).Money or costs moved
HCID 14 (2025A and 2025B bond proceeds) → Dunham Pointe Development LLC Reimbursement of construction, land, engineering, operating advances and developer interest.
HCID 14 → HCID 13 (titled facilities): $359,186 Lift Station No. 1 fencing, Phase 1 Detention Outfall, and Jack Road reserve lakes FG4/FG5 paid to the developer for facilities titled to HCID 13.
Why the board approved it
Recorded: “Ms. Vasquez (Forvis) discussed the reimbursement process and presented the report; approved 4-0 with Director Dawson absent for the vote. No amount recorded.”
The CPA report is the required check before payment, and the minutes record its approval. They do not state the amount paid, any items disallowed, the interest rate used, or whether the report was filed with TCEQ.