Summary
Clients: Chicago Residential Investment Fund; Chicago Department of Housing (DOH)
Partner: DLA Piper LLP (US)
Project: A legal strategy engagement to help the Chicago Residential Investment Fund, an independent Illinois not-for-profit corporation launched through Mayor Brandon Johnson's Green Social Housing program to administer $135 million in a revolving loan fund for housing, confirm its path to 501(c)(3) status and the funding structure that comes with it.
Outcome: A legal foundation that positions the Chicago Residential Investment Fund to qualify as a 501(c)(3) and start putting public and private capital to work on new housing across Chicago.
Grounded in DLA Piper's review of peer funds that have qualified and the statutory requirements for tax-exempt status, it will deliver recommendations to the Fund's new CEO on eligibility, revenue and funding sources, and next steps.
Opportunity
Chicago needs more housing, and the traditional tools for financing it have not kept pace. Through its Green Social Housing program, the City launched the Chicago Residential Investment Fund, an independent Illinois not-for-profit corporation, as a new model: a revolving loan fund that draws together public and private dollars, starting with $135 million, to finance new housing and recycle repayments into the next round of projects.
Before the Fund can start lending, it needs a sound legal foundation. Incorporating as an Illinois not-for-profit does not on its own make the Fund tax-exempt, so a central question is whether it qualifies for federal 501(c)(3) status, including whether its work meets the IRS standard of "lessening the burdens of government." The answer matters: tax-exempt status shapes how the Fund's revenue is taxed and which funders can invest in it.
CCA was well positioned to help, having guided the Garfield Park Rite to Wellness Collaborative through a similar path to 501(c)(3) status with DLA Piper.
Action
Since April 2026, CCA and pro bono partner DLA Piper have worked alongside the Fund's new CEO to build its legal strategy.
“A revolving fund only works if it’s built on solid ground. This work is giving us the legal clarity to get capital into housing projects. That’s how we’ll develop and manage high-quality, permanently mixed-income housing and help address Chicago’s housing crisis.”
Discover: CCA scoped the Fund's legal needs and recruited DLA Piper as pro bono counsel. DLA Piper reviewed peer organizations whose applications have qualified for tax-exempt status to learn how comparable funds have made their case.
Design: DLA Piper is working through the statutory requirements for 501(c)(3) status as they apply to the Fund's model, and analyzing its potential revenue and funding sources to understand how tax-exempt status affects each.
Deliver: CCA and DLA Piper will provide the Fund's CEO with recommendations on its path to 501(c)(3) status and the legal and funding structure to support it.
Impact
By settling its legal footing early, the Fund can focus on what it was created to do: unlock public and private capital to build more housing for Chicagoans, and prove out a new model for financing it.
The work gives the Fund's new leadership clarity on one of its most consequential early decisions: whether and how to pursue 501(c)(3) status, and what that choice means for the revenue it earns and the funders it can attract. The Fund will be left with a review of peer funds that have qualified for tax-exempt status, an analysis of 501(c)(3) requirements as they apply to its model, and an assessment of potential revenue and funding sources. With that foundation in place, the Fund can begin moving capital into housing projects, and as loans are repaid and redeployed, grow its impact well beyond the initial $135 million.
“CCA brings us the challenges where pro bono legal work can shape an organization’s future. From helping the Garfield Park Rite to Wellness Collaborative achieve tax-exempt status to laying the legal groundwork for the Chicago Residential Investment Fund’s $135 million housing fund, our partnership is helping vital Chicago initiatives start on solid footing.”
