Industrial Development Authorities in Arizona are authorized to be created under the Arizona Revised Statutes, particularly Section 35-701, et seq. (the "IDA Act"). Specifically in IDA Act Section 35-702, an Industrial Development Authority in Arizona can be created by a governing body by resolution and "shall be a political subdivision of the state and have only such governmental powers as are set forth in this chapter, in chapter 6 of this title and the power to enter into intergovernmental agreements in accordance with Title 11, Chapter 7, Article 3". An Industrial Development Authority's ability to finance activities designed to provide housing such as the financing of single family mortgage loans and the acquisition, construction and/or renovation of residential real property is further contained in the IDA Act.

The Industrial Development Authority of the County of Pima (the "Pima IDA") was created by a resolution of the Board of Supervisors of Pima County on September 5, 1972, which resolution has not been repealed, and each member of the Board of Directors of the Pima IDA is appointed by the Board of Supervisors of Pima County, again pursuant to the IDA Act.

The Industrial Development Authority of the City of Tucson, Arizona (the "Tucson IDA") was created by a resolution of the Mayor & Council of the City of Tucson on January 15, 1979 and each member of the Board of Directors of the Tucson IDA is appointed by the Mayor & Council of the City of Tucson, again pursuant to the IDA Act.

The Pima IDA and the Tucson IDA each has the ability to finance activities designed to provide housing and related facilities.

Pursuant to 24 CFR 266.5, a "Housing Finance Agency" ("HFA") means any public body, agency, or instrumentality created by a specific act of a state legislature or local municipality empowered to finance activities designed to provide housing and related facilities, through land acquisition, construction, or rehabilitation. As noted above, as an entity created by Pima County and authorized by Arizona statute, the Pima IDA qualifies as a HFA pursuant to 24 CFR 266.5. Similarly, as an entity created by the Mayor & Council of the City of Tucson and authorized by Arizona statute, the Tucson IDA qualifies as a HFA pursuant to 24 CFR 266.5.