EJF Opportunity Zone Strategy

 

Private Capital Making a Difference in Emerging Neighborhoods

Investing in OpZones May Defer and Reduce Current Capital Gains Tax and Eliminate Future Capital Gains Tax

Investments

The 2017 Tax Cuts and Jobs Act created a rare opportunity to reduce capital gains taxes by successfully investing in real estate developments in thousands of underfunded communities throughout the U.S. EJF’s expertise in regulatory-driven investment strategies and real estate investing makes it the partner of choice for investors who want to do well by doing good. In August 2018, EJF was one of the early movers to launch a Qualified Opportunity Fund, EJF OpZone Fund I LP (“Fund I”), prior to the final regulatory guidance. Since 2018, across two funds, EJF has invested in $1.3B of real estate, including 17 joint ventures with 24 multifamily and industrial properties.

In July 2025, the “One Big Beautiful Bill” (“OBBB”) was enacted, introducing new legislation related to qualified opportunity zone investing. Changes include a permanent extension of the program, a focus on investments in rural areas, and more.

The OBBB does not affect existing EJF OpZone Funds I and II. The legislation applies to Qualified Opportunity Funds formed going forward. If you would like more information, please contact EJF Investor Relations.

 

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What is a Qualified Opportunity Zone?
  • The federal 2017 Tax Cuts and Jobs Act, as enhanced and extended under the One Big Beautiful Bill (OBBB), encourages private capital investment in designated underfunded communities known as Qualified Opportunity Zones (QOZs). The legislation allows investors to defer capital gains and, for qualifying long-term investments, eliminate capital gains tax on future appreciation through investments in Qualified Opportunity Funds (QOFs), such as EJF OpZone I LP and EJF OpZone Fund II LP.
  • Originally designated in 2018, there are more than 8,700 QOZ census tracts across the United States. Under OBBB, Opportunity Zone designations will be reset beginning July 1, 2026, with additional designation rounds occurring every ten years thereafter, reinforcing the program’s long-term role in community-focused economic development.
What Are the Potential Tax Benefits?

What are the Potential Tax Benefits?
Investments in Qualified Opportunity Funds (QOFs) may offer meaningful tax advantages compared to traditional taxable investments when capital gains are reinvested in Qualified Opportunity Zones (QOZs).

Key Potential Tax Benefits

Deferral of Capital Gains
Capital gains reinvested in a QOF may be deferred, allowing the full pre-tax gain to remain invested and compound over time, subject to applicable recognition rules under current law.

Reduction of Deferred Capital Gains (Basis Step-Up)
Under OBBB and related Opportunity Zone provisions, investors may receive a step-up in tax basis on deferred capital gains, reducing the portion of the original gain ultimately subject to tax, subject to holding period requirements.

Exclusion of Post-Investment Appreciation
For qualifying long-term investments, appreciation attributable to the QOF investment itself may be excluded from federal capital gains taxation upon exit.

Depreciation Benefits on Operating Income
In real estate-backed Opportunity Zone investments, depreciation deductions may reduce or offset taxes on rental income and, in many cases, are not recaptured, enhancing after-tax returns.

Disclosure: This summary is provided for informational purposes only and does not constitute tax, legal, or investment advice. The application of Opportunity Zone benefits, including those under OBBB, depends on an investor’s specific circumstances and applicable law, which may change. Investors should consult their own advisers.

What Are the Differences Between OpZone 1.0 (TCJA) and OpZone 2.0 (OBBB)?

Current Portfolio

 

TX NY AZ CA NV UT CO NM AK HI OK KS NE SD WY ID OR WA MT ND MN WI IA IL MO AR LA MS AL GA FL SC NC TN KY IN MI OH WV VA PA ME VT NH MA RI CT NJ DE MD

Moxy Hotel

Oakland, CA

 

A 172-key boutique hotel located in Uptown Oakland, Moxy is Marriott’s newest brand, catering to the unique desires of millennial travelers. The Moxy economic model is focused on efficiencies in terms of cost-to-build, own and operate, and maximum investment in revenue-generating amenities.

The hotel was completed in Q1 2021.

For more information click here*

 

Riverport

Savannah, GA

 

RiverPort presents a multi-phase development opportunity in one of the nation’s fastest growing industrial markets, driven by the fastest growing and 4th largest container port in the nation, the Port of Savannah.

For more information click here*

 

Park Kennedy

Washington, D.C.

 

The Park Kennedy development project is a 262-unit mixed-use, multifamily community with approximately 13,000 gross square feet of retail space located in the historic Capitol Hill neighborhood of Washington, D.C.

Park Kennedy was completed in Q1 2021 and is leasing units.

For more information click here*

 

The Exchange

Jacksonville, FL

 

The Exchange is a 4-story, 196-unit multifamily community in the vibrant San Marco neighborhood of Jacksonville, Florida.

The Exchange was completed Q2 2021 and is leasing units.

For more information click here*

 

San Marco Promenade

Jacksonville, FL

 

San Marco Promenade is a two-building 284-unit community in the vibrant San Marco neighborhood of Jacksonville, Florida.

San Marco Promenade was completed in Q3 2020 and is leasing units.

For more information click here*

 

 

Block 10

Vancouver, WA

 

Block 10 is a mixed-use project with 110 multifamily units, 79,000 gross square feet of office space in downtown Vancouver, Washington.

Block 10 was completed in Q2 2022 and is currently leasing units.

For more information click here*

Coen & Columbia

Vancouver, WA

 

 

Coen & Columbia is a two-building 202-unit community in downtown Vancouver, Washington.

Coen & Columbia was completed in Q4 2020 and is leasing units.

For more information click here*

 

Barlow

Jacksonville, FL

 

Barlow is a 4-story, 290-unit multifamily community in the vibrant San Marco neighborhood of Jacksonville, Florida.

Barlow is complete and currently leasing units.

For more information click here*

 

Rafferty

Santa Ana, CA

 

Rafferty is a 7 story,  218-unit multifamily community in the center of downtown Santa Ana, CA.

Rafferty was completed in Q1 2024 and is leasing units.

For more information click here*

 

 

 

Eastborough

Jacksonville, FL

 

Eastborough is a two-building, 226-unit multifamily community adjacent to San Marco Promenade in the historic San Marco neighborhood in Jacksonville, Florida.

Eastborough is complete and currently leasing units.

For more information click here*

 

The Jack on Beach

Jacksonville, FL

 

The Jack on Beach is a three-building, 225-unit multifamily community in the eastern San Marco neighborhood in Jacksonville, FL

The Jack on Beach was completed in Q4 2024 and is leasing units. 

For more information click here*.

 

 

 

 

Samara

Nashville, TN

 

Samara is a five (5)-story, 375-unit wood-frame multifamily community with above-grade structured parking in the Metro Center neighborhood in immediately north of downtown Nashville, Tennessee.

Samara is projected to be complete in Q3 2025 and is leasing units. 

For more information click here*

 

The Bellevue

Hyattsville, MD

 

The Bellevue is a five-story, 362-unit multifamily community in the Hyattsville Crossing neighborhood in Hyattsville, MD.

The Bellevue is projected to be completed Q3 2025 and is leasing units.

For more information click here*.

 

 

 

 

*Please note the Inclusion of third-party sites is for informational purposes only and EJF is not responsible for the content therein.

EJF – A Trusted Partner

EJF’s investment platform, real estate expertise, regulatory knowledge, capital markets experience, partnerships and community bank network make it the partner of choice for investors seeking to benefit from QOZs.

Coen & Columbia

Vancouver, WA

The Exchange, Jacksonville, FL

Park Kennedy, Washington, DC

Seasoned Team

  • Founding members have worked together for 20+ years.
  • EJF’s dedicated real estate team has 55+ years of cumulative experience.

Real Estate Investment Expertise

  • Over $468 million of equity capital committed to Opportunity Zone investments.
  • Extensive network of partners and relationships in the private equity real estate sector.

Regulatory Specialists

  • DC Metro-headquartered team of professionals identifies regulatory catalysts and structural changes that produce investment opportunities.

Capital Markets Knowledge

  • Identify and unlock value by leveraging capital markets knowledge and experience.

Established Partnerships

  • Nationwide network of property owners and developers, construction and development lenders and real estate industry leaders.
  • Partnerships have allowed EJF to establish a systematic process for evaluating real estate opportunities as well as sourcing off market investment opportunities.

Bank Network

  • Active dialogue, investment and research in community banks.
  • Network for opportunity zone transaction sourcing, diligence and local knowledge.
  • Potential for financing efficiencies and incremental senior financing alternatives where there is Community Reinvestment Act (CRA) demand.

Firm & Investment Leadership

Manny Friedman

Co-Chief Executive Officer &
Co-Chief Investment Officer

Mr. Friedman co-founded EJF Capital LLC (“EJF”), a global institutional alternative asset management firm that has been at the forefront of regulatory, event-driven investing in financials and real estate.

Over the course of his 40+ year career in capital markets and asset management, Mr. Friedman has structured and built numerous innovative investment strategies that have focused on some of the most powerful trends in the financial sector driven by regulatory change. Mr. Friedman has been viewed by some as one of the thought leaders for the Opportunity Zone program, and he has spoken on the topic in many industry forums.

Prior to forming EJF, Mr. Friedman was a founder and the former Co-Chairman and Co-Chief Executive Officer of Friedman, Billings, Ramsey Group, Inc. (“FBR”). At FBR, Mr. Friedman assisted in designing property and mortgage REIT vehicles. Throughout the 1990s, Mr. Friedman was active in building out FBR’s alternative asset management platform. He was instrumental in the creation of hedge, private equity and venture capital funds at FBR, and maintains an extensive network of contacts within the CDO, hedge fund and private equity fund communities.

Mr. Friedman received his BA in Education from the University of North Carolina at Chapel Hill and his JD from Georgetown University.

Neal Wilson

Co-Chief Executive Officer

Mr. Wilson co-founded EJF in 2005 and serves as its Chief Operating Officer. In addition to serving as the Chief Operating Officer for EJF, Mr. Wilson currently serves as the Chief Executive Officer of EJF Investments Manager LLC, the external manager to a closed-end fund listed on the London Stock Exchange (LSE: EJFI).

Prior to forming EJF, Mr. Wilson served as a senior managing director for both the Alternative Asset Investments and Private Wealth Management groups at FBR. Prior to joining FBR, he was a senior securities attorney at Dechert LLP and a Branch Chief in the Division of Enforcement at the US Securities and Exchange Commission in Washington, D.C. He is a member of the Board of Directors of Urban Exposure Finance Limited and a member of the Board of Trustees of Hood College. He served as a member of the Board of Trustees of Sidwell Friends School for five years until 2018. He also served as a member of the Board of Trustees for the Montgomery County (Maryland) Public Schools Employee Pension for nine years until 2013 and in 2014 received a Distinguished Service Award from Montgomery County for his contributions. In June 2014, Mr. Wilson served as Co-Chair of the Bridges Gala for the Marriott Foundation for People with Disabilities Bridges from School to Work Program. He received his BA from Columbia University and his JD from the University of Pennsylvania.

Jason Ruggiero

Senior Portfolio Manager,
Co-Chief Investment Officer

Mr. Ruggiero joined EJF at its founding in 2005 and is a member of the Executive Committee.

Prior to joining EJF, Mr. Ruggiero was an equity trader in FBR’s Alternative Asset Investment group, where he assisted Mr. Friedman in the day-to-day operations of FBR Ashton, L.P., a long/short hedge fund. In 2004, Mr. Ruggiero assumed co-portfolio manager responsibilities for FBR Ashton, L.P. Before joining FBR, Mr. Ruggiero was an auditor for Deloitte and Touche in Washington, DC, where he focused on the financial services industry. He holds a BBA in accounting from James Madison University and an MBA in finance from the University of Maryland.

Asheel Shah

Senior Managing Director,
Head of Real Estate Development

Mr. Shah joined EJF in 2018 as the Senior Managing Director, Head of Real Estate Development and has over 20 years of experience in the real estate industry.

Prior to joining EJF, Mr. Shah was the President and Chief Investment Officer of the Multifamily division at Kettler Inc. He also served as the Senior Vice President of Real Estate Investments. During his 11 years at Kettler, Mr. Shah oversaw acquisitions, asset management, development, construction, equity capital sourcing and was the primary point of contact for partner relationships. In addition, Mr. Shah determined the strategic direction for the Multifamily division while also acting as chair of the Kettler Investment Committee. Prior to joining Kettler, Mr. Shah worked at Monument Realty, BroadBand Office Inc. and CarrAmerica Realty Corp. Mr. Shah received his BS in Financial Management from St. Joseph’s University in Philadelphia, PA and an MBA in Corporate Finance from the University of North Carolina in Chapel Hill, NC. He is an active member of the Urban Land Institute and serves on its Washington District Council Advisory Board.

Regina Richardson

President,
Senior Portfolio Manager

Ms. Richardson joined EJF in 2006 and is a member of the Executive Committee.

Ms. Richardson serves as the head of Trading focusing primarily on fixed income and derivative trading, and oversees the equity and other asset class trading. Prior to joining EJF, she spent 15 years at FBR, most recently serving in the Alternative Asset Investment where she worked with Neal Wilson. Previously, Ms. Richardson was a Vice President in FBR’s institutional sales group covering high yield accounts and an analyst in the Financial Institutions Investment Banking group. Ms. Richardson holds a BS in Finance from West Virginia University.

Steve Stelmach

Senior Managing Director,
Portfolio Manager

Mr. Stelmach joined EJF in 2015 and is responsible for the analysis of U.S. and residential housing opportunities as well as assisting in the analysis of the insurance sector.

Prior to joining EJF, Mr. Stelmach spent 12 years at FBR as a senior analyst in the financial services research group. With over a decade of equity research experience, Mr. Stelmach has covered a broad array of companies and sectors throughout the financial services and housing industries, including government-sponsored entities, mortgage banking companies, small- and large-cap banks, homebuilders, mortgage and title insurance, broker-dealers and the single-family rental sector. Prior to FBR, Mr. Stelmach worked on the U.S. bank research team at UBS Securities LLC helping to cover mid- and large-cap banks. In 2013, Mr. Stelmach was recognized in The Wall Street Journal’s Best on the Street awards as the No. 2−ranked equity analyst overall in the U.S. and No. 1 analyst in the home construction and furnishings sector. Mr. Stelmach has also provided expert testimony before the United States House of Representatives regarding U.S. housing policy, as well as advising a number of government agencies on policies and regulations affecting both housing and capital markets. Mr. Stelmach received his BS in Finance from the University of Maryland, College Park.

*Opportunity Zone Investment Committee Member.

Investor Relations & Business Development

Derrick G. Preuss

Managing Director, Business Development

Mr. Preuss joined EJF in 2024. As a member of EJF’s business development team he is responsible for
building relationships with existing and prospective investors. Mr. Preuss brings with him over 19 years
of financial services experience. Prior to EJF, Mr. Preuss was a Partner at Winston Partners where he
spent nearly 13 years leading the firm’s business development efforts and supporting the firm’s client
service program. Mr. Preuss started his career at Merrill Lynch & Co., where he was a member of the U.S.
Prime Brokerage Sales team responsible for originating new financing relationships with hedge fund
managers while working closely with the broader global markets division to cross-sell Merrill Lynch’s
suite of products and services. Mr. Preuss received his BA in Economics from the University of Virginia.

David Gallagher

Director, Business Development

Mr. Gallagher joined EJF in 2025 and serves as a Director of Business Development. In this role, he is
responsible for cultivating relationships with existing and prospective institutional investors. He brings
over a decade of experience in financial services, with a focus on institutional equity sales, policy and
regulatory research, and capital markets distribution. Prior to joining EJF, Mr. Gallagher was a Managing
Director at Compass Point Research & Trading, where he worked in the Institutional Sales group. Before
that, he served as Director and Head of Capital Markets at Capstone LLC, advising institutional asset
managers on policy and regulatory developments affecting the public securities markets. Earlier in his
career, he served in institutional sales roles at FBR & T. Rowe Price. Since 2015, Mr. Gallagher has served
on the Board of the Marion I. & Henry J. Knott Foundation and is currently a member of its Investment and
Finance Committee. He holds a B.A. in Political Science from the University of the South: Sewanee.

 

News

EJF Capital Closes On $80 Million Loan to Support Nashville Multifamily Property in Qualified Opportunity Zone

www.businesswire.com

EJF Capital and North Signal Capital Secure $102 Million Refinancing for RiverPort Industrial Portfolio

www.businesswire.com

Crop growth firm plots new manufacturing facility with 52 workers

www.bizjournals.com

CBRE Arranges $32,840,000 Refinancing of New 226-Unit, on behalf of the borrower, an affiliate of Chance Partners and EJF OpZone Fund II

www.cbre.com

EJF Capital and Crimson Canyon Refinance Buckeye Warehouse Outside Phoenix, AZ

www.businesswire.com

EJF Capital and North Signal Capital Refinance RiverPort Building 4 at the RiverPort Commerce Park Near the Port of Savannah, GA

www.businesswire.com

EJF Capital and the NRP Group Close $61M Construction Loan for Hyattsville, Maryland Multifamily Development

www.businesswire.com

EJF Capital and North Signal Capital Close $75 Million in Construction Financing for Warehouses at RiverPort Commerce Park in Opportunity Zone

www.businesswire.com

EJF Capital and Toll Brothers Apartment Living Announce Joint Venture to Create 313-Unit Multifamily Community in Downtown Phoenix Opportunity Zone

www.businesswire.com

EJF Capital and Chance Partners Break Ground on 295-Unit Multifamily Community in Jacksonville, FL

www.businesswire.com

EJF Capital and Crimson Canyon Close $23.4 Million Construction Loan for a Warehouse in the Accelerating Phoenix Market

www.businesswire.com

EJF Capital and Chartwell Residential Close on $67 Million Construction Loan for Multifamily Development in Nashville, TN

www.businesswire.com

EJF Capital and Green Street Real Estate Ventures Partner to Develop Three Warehouse Buildings in St. Louis

www.businesswire.com

EJF Capital and Chance Partners Announce Plans for 295-Unit Multifamily Community in Jacksonville Opportunity Zone

www.businesswire.com

EJF Capital and Toll Brothers Apartment Living Announce Joint Venture to Develop Two-building, 218-unit Multifamily Community in Santa Ana, CA

www.businesswire.com

EJF Capital and Chance Partners Break Ground On 226-Unit Multifamily Community In Jacksonville, FL Opportunity Zone

www.businesswire.com

EJF Capital and North Signal Capital Complete $32 Million Construction Financing on Two Buildings at RiverPort Commerce Park in Opportunity Zone

www.businesswire.com

EJF Capital and Chartwell Residential Joint Venture to Develop Multifamily Apartments in Downtown Nashville Opportunity Zone

www.businesswire.com

EJF Capital, Chartwell to Invest $80M in Nashville OZ

www.multihousingnews.com

EJF Capital Raises Approximately $280 Million for Inaugural OpZone Fund

bizjournals.com

EJF Capital and Holland Partner Group Joint Venture to Acquire and Operate Two Buildings in Downtown Vancouver, WA

bizjournals.com

EJF Capital and Holland Partner Group to Develop 110-Unit Multi-Family, Mixed-Use Project in Downtown Vancouver, WA Opportunity Zone

bizjournals.com

Construction underway for San Marco Crossing apartments

jaxdailyrecord.com

EJF Capital and Chance Partners Acquire 284-unit Multifamily Housing Community in Jacksonville Opportunity Zone

bizjournals.com

Donatelli, Blue Skye Land Equity Partner for Hill East Opportunity Zone Project

bizjournals.com

Major Opportunity Zone Fund Invests in San Marco Crossing

bizjournals.com

Industrial park set for RiverPort

savannahnow.com

Exclusive: Tapping into opportunity zone, second Uptown Oakland hotel to break ground

bizjournals.com

Real estate investors see riches in a tax break meant to help the poor

bloomberg.com

Opportunity Zones offer powerful potential for investors and communities

forbes.com

Opportunity Zones are transforming places and people that have been capital starved for decades

thehill.com

Hogan to bolster “opportunity zones” with state investments

washingtonpost.com

Sen. Tim Scott Leads Bipartisan Effort Encouraging Treasury To Deliver On Opportunity Zone Rules Clarification

bisnow.com

Questions and Answers

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When is my tax liability due on the original capital gains I invested in EJF OpZone Fund I or Fund II?

All deferred capital gains invested in Qualified Opportunity Funds are subject to taxation in tax year 2026. Payment of this liability will be due in April 2027. Please consult with your tax adviser for details on your individual situation.

When will the Funds begin selling properties in the portfolios?

EJF OpZone Fund I: The Fund’s final close was on January 15, 2021, and its term ends in January 2031. At that time, the Fund will become eligible to sell assets. We anticipate the disposition process will take 1–2 years in order to maximize value and sell assets in an orderly manner.

EJF OpZone Fund II: The Fund’s final close was on August 1, 2023, and its term ends in August 2033. At that time, the Fund will become eligible to sell assets. We anticipate the disposition process will take 1–2 years in order to maximize value and sell assets in an orderly manner

What are the benefits of investing in Opportunity Zones under the TCJA legislation?

Investors in Qualified Opportunity Funds under the Tax Cuts and Jobs Act (“TCJA”) may benefit in three ways:

  • Tax deferral: Recognition of original capital gains is deferred until year-end 2026 (taxes payable in April 2027).
  • Partial tax forgiveness on original gains:
    15% reduction if the investment was made by December 31, 2019 (held for 7 years).
    10% reduction if the investment was made by December 31, 2021 (held for 5 years).
  • Tax-free appreciation: Capital gains from Qualified Opportunity Fund investments are exempt from federal tax if held for 10 years or longer (including potential elimination of depreciation recapture on real property).
When will I receive distributions?

Distributions vary by fund and depend on property performance and broader market conditions. Please refer to your most recent performance report for EJF’s outlook on future distributions specific to your fund.

How can I view the performance of my investment?

Your investor statement, capital balance, and capital activity are available on the EJF Investor Portal. If you require login assistance, please contact administration@ejfcap.com.

Do recent legislative updates (the “One Big Beautiful Bill”) impact my EJF OpZone investment?

No. The proposed legislation does not affect existing EJF OpZone Funds I or II. It only applies to Qualified Opportunity Funds formed under the new framework going forward.

Can I roll my gains from an existing EJF OpZone Fund into another OpZone Fund under the new legislation?

No. Gains realized within EJF OpZone Funds are not considered capital gains and therefore cannot be reinvested into a future Qualified Opportunity Fund.

When does the new Opportunity Zone legislation become effective?

Opportunity Zones 2.0 will take effect on January 1, 2027, and remain in place for a ten-year period.

Does EJF plan to launch another OpZone Fund under the new legislation?

EJF is currently evaluating its plans for future Opportunity Zone funds. If you would like to receive updates, please email ir@ejfcap.com to be added to our distribution list.

Learn, Share, Invest.

Please fill in the form below if you want to: learn more about opportunity zones, share an investment opportunity or invest.

If you are a current investor, please reach out to InvestorRelations@ejfcap.com.