Attorney General Bonta Files Lawsuit Seeking Dissolution of C.C.O.A. Housing Corporation and Transfer of Millions of Dollars to Legitimate Charity Providing Affordable Senior Housing

Investigation by AG’s Office Finds Numerous Violations of State Law 

LOS ANGELES — California Attorney General Rob Bonta today announced filing a lawsuit in the Los Angeles County Superior Court to involuntarily dissolve C.C.O.A. Housing Corporation, a nonprofit public benefit corporation that incorporated in California in 1979 to provide affordable housing for “elderly persons and handicapped persons.” C.C.O.A. Housing Corporation’s sole charitable activity was the operation of Cathay Manor, a 268-unit apartment complex in downtown Los Angeles that is financed by the U.S. Department of Housing and Urban Development under a Housing Assistance Payment contract. The residents of Cathay Manor are low-income senior citizens, many with disabilities or impairments that require them to use wheelchairs or walkers to travel any distance. In 2023, C.C.O.A. Housing Corporation was forced to sell Cathay Manor as a result of pervasive and persistent mismanagement. Following an investigation by the Attorney General, today’s complaint seeks the appointment of a receiver pending the court’s resolution of this case and to transfer the proceeds from the sale of the building to another charity with a similar charitable purpose to provide affordable senior housing. In addition, the complaint seeks an accounting of all financial transactions the charity has had with its directors and any related entities. 

“There is simply no denying that C.C.O.A. Housing Corporation and its board members failed our seniors miserably when they operated Cathay Manor. It was and still is inexcusable,” said Attorney General Rob Bonta. “While C.C.O.A. Housing Corporation no longer owns or manages the building, my office is taking legal action to ensure that the proceeds from the sale of Cathay Manor cannot be used, in any way, by the organization’s current leadership. Their track record speaks for itself. They cannot be trusted to do the right thing. Instead, the funds should be distributed to one of the many legitimate charities that actually provide affordable senior housing in the Los Angeles area. At the California Department of Justice, we are committed to holding unscrupulous charities accountable and tackling our state’s housing crisis — today’s lawsuit is a continuation of those efforts.”  

“For years, I’ve heard from Cathay Manor residents about the unacceptable conditions they’ve faced under C.C.O.A. Housing Corporation,” said U.S. Representative Jimmy Gomez. “That’s why I pushed for an investigation, and I’m glad to see California Attorney General Bonta taking action. I’ll keep fighting to protect Chinatown seniors and hold landlords accountable to ensure they meet their responsibilities to our communities.” 

“C.C.O.A. and its board members demonstrated a complete and total disregard for the Chinatown community and the seniors who resided at Cathay Manor,” said Los Angeles City Councilmember Eunisses Hernandez. “They cannot be allowed to benefit from the sale of the building that they so woefully mismanaged and neglected. They have already shown us who they are and I applaud Attorney General Bonta’s efforts to hold them accountable for their egregious breach of the community’s trust.” 

C.C.O.A. Housing Corporation is currently defending multiple actions filed against it — including a lawsuit filed by Cathay Manor tenants relating to poor living conditions — and criminal charges filed by the Los Angeles City Attorney’s Office in 2021. The lawsuit filed today would not adversely impact the ongoing civil and criminal actions. The appointment of a receiver would allow a neutral party to manage C.C.O.A. Housing Corporation’s affairs, including oversight of the existing lawsuits. If the court grants dissolution of the charity, the receiver would also manage the winding up of C.C.O.A. Housing Corporation’s affairs. Further, C.C.O.A. Housing Corporation would still need to satisfy debts and liabilities in order to dissolve.

Following the sale of Cathay Manor and the payment of existing debts and liabilities, C.C.O.A. Housing Corporation currently has more than $8.5 million in a restricted bank account. As a condition for approving the sale of Cathay Manor, the Attorney General required all proceeds to be put in a restricted bank account. In June 2025, a final payment of $70 million is due to C.C.O.A. Housing Corporation from the sale of the building, which will also be placed in the restricted bank account. During the course of the Attorney General’s investigation, C.C.O.A. Housing Corporation’s current board members failed to provide any kind of plan as to how the funds would be properly used to provide low-income housing in the future.

Gong Donald Toy, also known as Don Toy, is named as a defendant in today’s complaint. He has been a Director of C.C.O.A. Housing Corporation and its President and Chief Executive Officer since the incorporation of the organization in 1979. In addition, Janet Lim, Sing Foo, and Jimmy Victoria — all of whom are former and current C.C.O.A. Housing Corporation board members — are named as defendants.  

In today’s complaint, Attorney General Bonta alleges the following: 

• Defendants breached their fiduciary duty to ensure that C.C.O.A. Housing Corporation was fulfilling its charitable purpose by properly operating Cathay Manor. Among other things: 

• Defendant Toy conducted the activities and affairs of C.C.O.A. Housing Corporation without meaningful oversight from its directors.
• Defendant Toy in his sole discretion, selected, hired, and oversaw the company charged with managing and maintaining Cathay Manor – in violation of C.C.O.A. Housing Corporation’s bylaws.
• After Defendants Lim, Foo, and Victoria became aware that Defendant Toy hired the management company without their approval, they failed to question or address the hiring of the management company, the process by which the management company was selected, whether alternatives were considered, or the terms of the management contract. 
• Since at least 2021, Defendants failed to ensure that C.C.O.A. Housing Corporation maintained basic health and safety conditions at Cathay Manor. For example, they failed to maintain a fire code-compliant fire safety system and failed to maintain or repair two inoperable elevators at Cathay Manor for periods between approximately September 2021-November 2021, effectively trapping many elderly residents in the building.

• Failure to observe basic corporate formalities, and failure to keep and maintain records in breach of fiduciary duty and standard of care entrusted to Board of Directors. For example: 

• Under state law and its bylaws, C.C.O.A. Housing Corporation’s officers are to be elected annually by directors. C.C.O.A. did not hold annual elections of officers. Defendant Toy in his sole discretion selected and appointed Defendants Lim, Foo, and Victoria to their director and officer positions.
• Defendant Toy selected Defendants Lim, Foo, and Victoria as directors because he knew they would fail to fulfill their duties and responsibilities as directors, thereby providing Toy control over C.C.O.A. Housing Corporation with no meaningful oversight by them.
• Nonprofit public benefit corporations are required to keep written records of minutes of the proceedings of its board members, among other requirements, in the operation of the nonprofit. C.C.O.A. Housing Corporation did not conduct meetings of the board of directors required by state law or its bylaws.

• Filing of false statements and misrepresentations in filings with the Attorney General’s Registry of Charities and Fundraisers (Registry). For example:

• For the years 2006-2016, Defendant Toy signed IRS Forms 990, under penalty of perjury, and filed them with the Registry. These IRS Form 990s identify Tung Sheng Liu as a director of C.C.O.A. Housing Corporation. Tung Sheng Liu died on or around May 3, 2009.
• Although C.C.O.A. Housing Corporation filed IRS Form 990s with the Registry asserting that Defendant Lim was C.C.O.A.’s Secretary from 2016-2021, Defendant Lim was unaware of holding such a position and never performed any of the duties of Secretary. 
• From 2016 to 2022, C.C.O.A. Housing Corporation’s IRS Form 990s filed with the Registry all falsely asserted that C.C.O.A. Housing Corporation contemporaneously documents board meetings and actions, and reported that Defendants Lim, Foo, and Victoria held officer positions with C.C.O.A. Housing Corporation. 

• Failure to provide information to the Attorney General. For example: 

• C.C.O.A. Housing Corporation’s IRS Form 990s for the fiscal years ending June 30, 2021 and June 30, 2022 falsely assert that C.C.O.A. Housing Corporation is not related to any tax-exempt entity. In reality, Defendant Toy operates three additional nonprofit organizations: The Teen Post Corporation, The Chinese Committee on Aging of Los Angeles, and Chinatown Area Post, Inc.
• Further, C.C.O.A. Housing Corporation’s audited financial statements for the fiscal years ending June 30, 2021 and June 30, 2022 disclose that Defendant Toy transferred more than $550,000 from C.C.O.A. Housing Corporation to The Teen Post Corporation for “temporary staffing assistance” over the two fiscal years. The Teen Post Corporation has its principal place of business in a suite at Cathay Manor, and Defendant Lim is its Secretary and Chief Financial Officer. 
• The Attorney General requested in writing that C.C.O.A. Housing Corporation produce documents and information related to all transactions between C.C.O.A. Housing Corporation and any entity for which Defendant Toy, any relative of Toy, or any C.C.O.A. Housing Corporation director has had a financial interest or has served as an officer or director. C.C.O.A. Housing Corporation has not responded to the request, in violation of state law. 

The Attorney General is charged with the general supervision of nonprofit public benefit corporations and all entities and individuals who solicit, obtain, hold, or control property in trust for charitable purposes in California. Under California law, nonprofit public benefit corporations must be formed for public or charitable purposes and may not be organized for the private gain of any person. A public benefit corporation cannot distribute charitable assets to any person for their personal benefit. 

A copy of the lawsuit can be found here.