Season 6 of the No Cap podcast kicks off with a deep dive into one of the more complex—and quietly evolving—corners of commercial real estate: Opportunity Zone capital. Co-hosts Jack Stone and Alex Gornik bring on Jordan Brustein and Andrew Rudy of Ackman-Ziff, a boutique capital advisory firm that solves deals that don’t pencil through traditional financing.
As capital tightens and equity becomes harder to secure across the board, the conversation centers on how structured finance is evolving in real time. Brustein and Rudy explain how Opportunity Zone capital goes beyond development, actively recapitalizes assets, reshapes capital stacks, and gives deals the time they need to survive in today’s market.
Conversation Highlights
Alex: For listeners who don’t know, what is it that you guys actually do day to day?
Jordan Brustein: We focus entirely on debt and equity placement, but mostly in structured finance. We’re usually brought into deals that are complicated and require creativity beyond standard financing.
Andrew Rudy: Most of what we do has an equity component. We’re not in a high-volume business. We’re solving situations where capital doesn’t fit cleanly into a typical structure.
We’re not in the high velocity, high volume business. we’re in the structured finance business.
Jack: So where is the niche today?
Jordan: We took on a Boston deal around $100M and explored both OZ and non-OZ options. What stood out was we got seven term sheets from OZ funds, which is extremely rare.
Andrew: And they were all structured differently. None looked like traditional pref. That’s when we realized there was real opportunity here because funds still have capital to deploy and they’re being forced to get creative.
Alex: What actually makes these structures different?
Andrew: The 10-year hold changes everything. Traditional pref doesn’t work over that timeline. These structures act more like a hybrid where you’re not forced into a takeout. You can pay the capital down over time.
The capital that’s going into these opportunity zones wants to be preserved more than it wants to be appreciated.
This is where it shifts from tax strategy to capital strategy.
Alex: So what does that look like in a real deal?
Andrew: On a $100M deal, you might have $60M of debt and $40M of equity. Instead of raising all common, you split it. Maybe $20M from an OZ fund and $20M from your own investors. At refinance, you don’t have to take them out. You can pay them down, which lowers your cost of capital.
Jordan: And there’s no forced exit. That capital can stay in for 10 years, which aligns better with how real estate actually stabilizes.
Jack: So this isn’t just for development anymore?
Jordan: No. We found this on a deal in Provo. Inject OZ equity into a deal post-construction as long as the structure remains compliant and you use the capital properly, like paying down debt.
Andrew: That’s what makes it interesting. You can use it to fix capital stacks, not just build them. Funds can get similar returns without taking development risk.
Now it becomes less about yield and more about buying time.
Alex: Give us a real example.
Andrew: We’re working on a 450-unit deal in DC. It delivered at $8M NOI but dropped to $7M. The deal had about $145M of leverage, so it was fully stretched.
Jordan: The problem wasn’t just cost of capital. It needed time. Traditional pref would force a resolution too quickly.
Andrew: So we brought in Opportunity Zone equity. It resets the clock, but it gives the deal a 10-year runway. That allows NOI to recover instead of forcing a bad outcome.
From there, the conversation zooms out to what’s happening across capital markets.
Jack: What does this say about the broader market?
Andrew: There’s too much capital chasing too few deals, especially in private credit. Returns are compressing, and people are taking real risk for mid-teens returns.
Jordan: That’s why common equity has to come back. If you’re taking that risk, you want upside, not just a fixed return.
Alex: What happens with OZ 2.0?
Andrew: We expect more capital. Probably double what’s been raised so far. If the program becomes permanent, more players will enter.
Jordan: Right now you’ve got three groups. High-net-worth driven funds, impact funds, and large developers raising their own capital. That mix will only grow.
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