AUDIT REPORT
CITIWEST NEW ENGLAND, INC.
HARTFORD, CONNECTICUT
00-BO-222-1005
SEPTEMBER 29, 2000
OFFICE OF AUDIT, NEW ENGLAND
BOSTON, MASSACHUSETTS
Issue Date
September 29, 2000
Audit Case Number
00-BO-222-1005
TO: Engram Lloyd, Director, Homeownership Center, 3AHH
FROM: Stephen D. King, Acting District Inspector General, Office of Audit, 1AGA
SUBJECT: CitiWest New England, Inc.
Management and Marketing Contractor
Hartford, Connecticut
We performed an audit of HUD’s Management and Marketing Contractor, CitiWest New England,
Inc. (CitiWest). The objective of our audit was to determine whether CitiWest is managing HUD single
family properties in compliance with HUD policies, procedures, and regulations and with the terms and
conditions of CitiWest’s Management & Marketing (M&M) Contract.
The report contains two findings. We found that CitiWest is not properly inspecting and maintaining
HUD’s property inventory and that CitiWest is not complying with case management processing
requirements cited in their M&M Contract.
Within 60 days, please provide us a status report on: (1) the corrective action taken; (2) the proposed
corrective action and the date to be completed; or (3) why action is not considered necessary. Also,
please furnish us with copies of any correspondence or directives issued as a result of this audit.
Should you have any questions, please contact our office at (617) 565-5259.
Management Memorandum
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00-BO-222-1005 Page ii
Executive Summary
We performed an audit of the M&M Contractor, CitiWest New England, Inc. (CitiWest). The primary
purpose of our audit was to determine whether CitiWest is managing HUD single family properties in
compliance with HUD policies, procedures, and regulations and with the terms and conditions of its
M&M Contract (Contract). This included assessing whether CitiWest’s: (a) operations are effective,
efficient, and economical, and (b) management controls are adequate to effectively identify and address
operational deficiencies and noncompliance with requirements.
On March 29, 1999, CitiWest began to manage and market
Audit Results
HUD single family properties located in the six New England
states. Since July 1999, CitiWest reduced HUD’s property
inventory from a high of 1,336 to a low of 832 as of July 25,
2000. However, HUD’s Performance Assessment Reports
indicated a concern with CitiWest’s capacity to perform the
Contract requirements for its inventory. Our review confirmed
that CitiWest needs to improve its procedures to ensure HUD
properties in its inventory are properly inspected and
maintained, and that managing and marketing requirements are
fulfilled.
Specifically, our audit disclosed that CitiWest did not: 1)
perform initial property inspections within 24 hours; 2) always
identify imminent hazards through routine property inspections;
3) correct imminent hazards and other deficiencies when
identified through routine property inspections; 4) effectively
identify defective paint; and 5) properly secure its inventory of
properties.
CitiWest is also not complying with other contract requirements.
For example, properties are held off market for unreasonable
periods of time; case management processing is not timely; sales
closing responsibilities are not followed; and unallowable costs
are charged to HUD.
As a result, HUD’s Property Disposition Program in New
England may not be operating efficiently, effectively and
economically. Poor property conditions may contribute to
performance problems such as decreased marketability,
increased costs, and possible conditions that threaten the health
and safety of neighbors and potential homebuyers.
Page iii 00-BO-222-1005
Executive Summary
We are recommending that you: 1) instruct CitiWest to establish
Recommendations procedures to ensure timely initial property inspections; 2)
ensure CitiWest monitors its property inspection subcontractors
through quality control reviews and discontinues its use of poor
performing subcontractors; and 3) ensure imminent hazards and
other deficiencies are corrected and defective paint is properly
identified and treated. We are further recommending that you
require CitiWest to process held off market properties in a
reasonable time to reduce applicable holding costs and
increased costs to HUD, require CitiWest to accurately review
settlement statements and submit weekly reports of closing
agent noncompliance, and conduct thorough reviews of all
monthly pass through vouchers to ensure late fees, interest and
penalties are not included.
We discussed the findings in this report with CitiWest staff
Findings and during the course of the audit. On August 11, 2000, we
Recommendations provided CitiWest a copy of the draft audit report for comment.
Discussed We received CitiWest’s written response on September 5,
2000. Appropriate revisions were made where deemed
necessary. We included CitiWest’s pertinent comments in the
Findings section of this report. CitiWest’s full response is
included in Appendix B.
00-BO-222-1005 Page iv
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 Property Inspections and Maintenance Require Improvement 5
2 Management and Marketing Requirements Not Fulfilled 19
Management Controls 29
Appendices
A Standard Processing Steps 31
B Auditee Comments 33
C Distribution 39
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Table of Contents
Abbreviations
CitiWest CitiWest New England, Inc.
Contract Management and Marketing Contract
FHA Federal Housing Administration
GTR Government Technical Representative
HOC Homeownership Center
HUD Department of Housing and Urban Development
M&M Management and Marketing
PAR Performance Assessment Report
SAMS Single Family Accounting Management System
SPI Special Property Inspection Contractor
00-BO-222-1005 Page vi
Introduction
FHA’s Single Family Mortgage Insurance Program helps low and moderate income families become
homeowners by reducing downpayments and limiting lender fees. Every year, however, thousands of
borrowers default on their FHA-insured loans. When they default, FHA encourages lenders to work
with them to bring their payments current. When they cannot do this, their homes may be sold to third
parties, voluntarily conveyed to the lenders, or surrendered to lenders through foreclosure. Once
lenders obtain the properties, they generally convey title to the Secretary of the U.S. Department of
Housing and Urban Development (HUD) in exchange for payment of their insurance claim.
HUD disposes of properties through its Property Disposition Program, administered by the Office of
Single Family Housing Real Estate Owned Division. Its mission is to reduce the property inventory in a
manner that expands homeownership opportunities, strengthens neighborhoods and communities, and
ensures a maximum return to the mortgage insurance fund. The National Housing Act (Act) of 1934
confers on the Secretary the authority to manage, rehabilitate, rent, and dispose of any property
acquired under the program. Section 204(g) of the Act governs the management and disposition of
single family properties acquired by FHA. Title 24, Code of Federal Regulations (CFR), part 291
implements this statutory authority. Handbook 4310.5 REV-2, dated May 17, 1994, Property
Disposition Handbook - One to Four Family Properties, supplements the regulations.
In February 1993, HUD initiated a reinvention effort to streamline operations and reduce costs. HUD
began reducing program staff and consolidating its mortgage insurance processing, claims, and property
disposition activities from the field office into four Homeownership Centers (HOC) located in Santa
Ana, California; Denver, Colorado; Atlanta, Georgia; and Philadelphia, Pennsylvania.
Effective March 1999, HUD contracted out for the management and marketing of properties which are
owned by, or in the custody of, HUD. Seven contractors were awarded a total of 16 Management and
Marketing (M&M) contracts nationwide to manage and market HUD properties as part of a
nationwide restructuring of HUD’s Single Family Property Division. The M&M contractors assumed
full responsibility for the management and marketing functions.
CitiWest New England, Inc. (CitiWest), owned by Remi Geahel, was awarded the M&M contract
(Contract) for the Philadelphia HOC Area-1, which consists of properties located in the six New
England states. Its main office is located at 330 Main Street, Hartford, Connecticut. CitiWest’s
Contract is for one year with 4, one-year renewal options. The total estimated value of the Contract,
including options, is $41.5 million.
During the audit period, CitiWest was responsible for managing and marketing an average inventory of
over 1,100 properties. As of July 25, 2000, CitiWest was managing and marketing 832 properties
across the New England area: 423 - Connecticut; 167- Massachusetts; 110 - Maine; 95 - Rhode
Island; 19 - Vermont; and 18 - New Hampshire. CitiWest successfully sold 976 properties from
January 1, 2000 to June 30, 2000.
Page 1 00-BO-222-1005
Introduction
The primary objective of the audit was to determine whether
Audit Objectives CitiWest is managing HUD single family properties in
compliance with HUD policies, procedures, and regulations and
with the terms and conditions of CitiWest’s Contract. This
included assessing whether CitiWest’s: (a) operations are
effective, efficient, and economical, and (b) management
controls are adequate to effectively identify and address
operational deficiencies and noncompliance with requirements.
To accomplish our audit objectives, we performed the
Audit Scope and
following:
Methodology
• Reviewed Federal requirements including 24 CFR Part
291, HUD Handbook 4310.5 REV-2, Property
Disposition Handbook - One to Four Families, the
Monitoring Manual - Management Controls for the
Single-Family REO M&M Contracts, and CitiWest’s
Contract with HUD.
• Reviewed Performance Assessment Reports and third party
contractors’ monitoring reports and any related
correspondence, provided by the Philadelphia HOC, for
indications of problems with CitiWest’s performance.
• Reviewed CitiWest’s internal controls by interviewing staff
and testing transactions where possible, and performed a
cursory review of personnel issues to assess whether
CitiWest employees appear to be qualified to carry out the
Contract.
• Randomly selected a sample of 30 active cases; 15 -
Waterbury, Connecticut and 15 New Haven Connecticut,
which consisted of 23 newly assigned properties and 7
initially assigned properties, for review of the property case
files.
• Performed property inspections of the 30 active cases to
determine whether CitiWest maintains properties according
to requirements.
00-BO-222-1005 Page 2
Introduction
• Compared CitiWest’s most recent inspections for the 30
properties with OIG inspections for any discrepancies.
• Judgmentally selected 15 closed cases from different cities
throughout the 6 New England states, for review of the
property case files to determine if CitiWest is meeting case
processing requirements.
• Judgmentally selected and reviewed 10 held-off market
cases (greater than 6 months) to determine CitiWest’s
overall handling of the properties.
• Judgmentally selected and reviewed four vouchers, one
fixed voucher for the month of November 1999 and three
“pass through costs” vouchers dated February 1, 2000,
February 2, 2000, and March 2, 2000 to determine if
CitiWest followed proper procedures for payment of
services.
• Reviewed CitiWest’s subcontracting procedures.
• Conducted interviews with responsible CitiWest and
Philadelphia HOC staff and management as necessary.
The audit was conducted between April 2000 and July 2000
and generally covered the period between March 29, 1999 and
June 30, 2000. Where appropriate, the audit was extended to
include other periods.
Our audit was conducted in accordance with generally
accepted government auditing standards.
Page 3 00-BO-222-1005
Introduction
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00-BO-222-1005 Page 4
Finding 1
Property Inspections and
Maintenance Require Improvement
As one of HUD’s Management and Marketing (M&M) Contractors, CitiWest New England, Inc.
(CitiWest) must routinely inspect and take all actions necessary to preserve, protect, and maintain each
property in its inventory in a presentable condition at all times. Our review disclosed the following
deficiencies in CitiWest’s performance and administration of both property inspections and property
maintenance:
• Initial property inspections not performed within 24 hours as required;
• Imminent hazards not always identified through routine property inspections;
• Hazards and other deficiencies, when identified by CitiWest inspections, not always
corrected;
• Defective paint not effectively identified; and
• Properties left unsecured.
Poor property conditions contribute to performance problems such as decreased marketability,
increased costs, possible decreased value of surrounding homes, and possible conditions that threaten
the health and safety of neighbors and potential buyers. CitiWest needs to improve its property
inspection and maintenance process to reduce the risk of undetected hazards and deficiencies, and to
maximize the marketability of its property inventory to produce the highest net return to HUD.
On average, 139 properties are assigned to CitiWest on a
Initial Property Inspections monthly basis. Upon assignment of a property from a
Not Performed Timely mortgagee and/or HUD, CitiWest is required to perform an
initial property inspection within 24 hours per Section C-2
(V)(B)(3A) of their Management and Marketing Contract
(Contract). The initial property inspection is required to
determine the property condition, occupancy status, whether
personal property remains on the premises, mortgagee
performance, and whether imminent health or safety hazards
exist (HUD Handbook 4310.5 REV-2 (Property Disposition
Handbook), Chapter 3, Paragraph 3-14 (A)).
Page 5 00-BO-222-1005
Finding 1
CitiWest did not perform initial property inspections within 24
hours for 100 percent of the 23 newly assigned properties in
our sample. We noted 15 properties in which the inspections
were performed one to five days late; 4 properties in which the
inspections were performed six to ten days late; 2 properties in
which the inspections were performed eleven to fifteen days
late; and 2 properties in which the inspections were performed
sixteen to twenty days late.
CitiWest’s Senior Realty Specialist advised that inspections are
not performed within 24 hours as a result of both the inspectors
and CitiWest staff. The CitiWest inspectors, at times, have
difficulty in locating the properties and CitiWest staff are not
always diligent in ordering the property inspections in a timely
manner.
Delays in performing the initial property inspections lead to
delays in the ordering and conducting of property appraisals,
delaying the overall case processing of these properties, as
outlined in Finding 2. This may result in increased costs and
property deterioration. The possibility of identifying mortgagee
neglect is also reduced with each passing day beyond the initial
24 hour period, which may lead to repair costs passed through
to HUD.
Section C-2 (V)(B)(5) of the Contract requires CitiWest to
OIG Inspections Identify correct ANY condition that presents a health or safety hazard
Imminent Hazards (imminent hazard) to the public or to the property within 24
hours of discovery. We found that CitiWest property
inspections were either not identifying imminent hazards or,
when identified, CitiWest was not taking action within the
required 24 hours. On average, CitiWest performs routine
property inspections every 15 days.
00-BO-222-1005 Page 6
Finding 1
Of the 30 properties inspected, we found 20% (6 of 30) with
imminent hazards. Examples are as follows:
FHA Case No. 061-152960 - Improperly covered pool
FHA Case No. 061-068871 - Decayed front Step
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Finding 1
FHA Case No. 061-069390, Health hazard - Drug paraphernalia
CitiWest inspections of the same properties, performed shortly
before or after our inspections, identified only 1 imminent
hazard, property 061-152960 - uncovered pool. Although a
CitiWest property inspection noted the uncovered pool hazard
on May 14, 2000 (four days after our inspection) and again on
May 25, 2000, CitiWest failed to issue a corrective work order
for the hazard until June 6, 2000. The unsigned work order
indicated that the hazard was corrected on June 9, 2000, well
beyond the 24 hour requirement.
In another instance, three consecutive CitiWest inspections on
property 061-167193 between October 6, 1999 and
November 10, 1999, reported a hazard of dead tree branches
hanging over the adjacent property’s driveway. CitiWest
issued a work order on October 13, 1999 instructing that the
tree be removed. The work order was signed and dated as
completed as of October 19, 1999, well beyond the 24 hour
requirement. However, the hazard remained an issue on the
November 10, 1999 CitiWest property inspection report,
which is indicative that the hazard was either not corrected or
not corrected adequately. Further, an April 13, 2000 CitiWest
00-BO-222-1005 Page 8
Finding 1
property inspection for the same property indicates “large dead
branch hangs over the curb - hazard”.
The importance of correcting hazards posing a health or safety
threat to the public or to the property itself cannot be
overstated. Without proper identification and correction, these
hazards may cause severe injury and/or death, or deterioration
of the property.
Section C-2 (V)(B)(5) of the Contract requires CitiWest to
Identified Deficiencies Not routinely inspect and take all actions necessary to preserve,
Always Corrected protect, and maintain each property in a presentable condition
at all times. This includes, but is not limited to the removal and
proper disposal of all interior and exterior debris both after
property assignment and on a continual basis, and lawn,
shrubbery and tree maintenance consistent with neighborhood
standards.
Our inspections of 30 properties found 71% (20 of 28) of the
properties had uncut lawns. Two of the thirty properties were
located in condominium complexes and the lawn maintenance
was not a CitiWest responsibility.
Just as our own property inspections indicated a severe
problem in the area of lawn maintenance, CitiWest’s property
inspections often cited uncut lawns in consecutive reports. The
fee inspector wrote such statements as; “front cut by neighbor,
not cut by Contractor this year - property 061-144252”, and
“not cut this year - property 061-092079”. CitiWest was not
responsive to these deficiencies. An example follows:
Page 9 00-BO-222-1005
Finding 1
FHA Case No. 061-134647 - Overgrown grass and Shrubbery
We further found that 30% (9 of 30) of the properties had
interior and/or exterior debris. Successive CitiWest inspection
reports identified numerous instances of the presence of debris
indicating that CitiWest was not responsive to addressing these
deficiencies. During a span of five consecutive CitiWest
inspections of property 061-096618, covering the period of
March 20, 2000 through May 13, 2000, the fee inspector
indicated that the yard and debris needed to be cleaned up and
referred to the prior inspection reports noting the same
deficiency. In a similar instance, during a span of four
consecutive CitiWest inspections of property 061-076836,
covering the period of April 2, 2000 through May 16, 2000,
the fee inspector again indicated that the yard and debris
needed to be cleaned.
00-BO-222-1005 Page 10
Finding 1
Exhibit 15, paragraph 15-1 of the Contract defines a defective
Defective Paint Not paint surface as cracking, scaling, chipping, peeling or loose
Effectively Identified paint on all interior and exterior surfaces of a residential
structure. Exhibit 15, paragraph 15-4 of the Contract states
that treatment necessary to eliminate the immediate hazards
must, at a minimum, consist of the covering or removal of the
defective paint surfaces.
Of the 30 properties inspected, we found 89% of the properties
(25 of 28) had defective paint on their interiors (one property
was a vacant lot and access was not gained to another
property) and 41% of the properties (11 of 27) had defective
paint on their exterior (one property was a vacant lot and two
properties were located within condominium complexes where
the exterior paint was not CitiWest’s responsibility). The
following are examples of defective paint:
FHA Case No. 061-070356 - Defective paint, water in light
fixture
Page 11 00-BO-222-1005
Finding 1
FHA Case No. 061-071714 - Defective paint
Although Exhibit 15, paragraph 15-6 of the contract states that
defective paint may be treated prior to offering properties for
sale or at any reasonable time prior to the closing of a sale,
CitiWest property inspections shortly before or after our
inspections identified only 32% of the properties with defective
interior paint (9 of 28) and only 30% of the properties with
defective exterior paint (8 of 27). To receive treatment,
defective paint must first be identified. When Citiwest identifies
defective paint, treatment takes place. During follow up visits to
the properties, visual examination revealed that CitiWest had
addressed the defective paint to some degree. Generally, paint
that was defective upon our initial inspection was scraped and
treated on the exterior and scraped on the interior of the
properties.
CitiWest needs to improve its effectiveness in identifying
defective paint so that it may be treated.. During our initial
inspections defective paint was identified in a high percentage of
properties, which was not identified by routine CitiWest
inspections. Without proper identification of defective paint, the
defective areas may be left untreated and detract from the
overall marketability of the property resulting in a lower net
return to HUD.
00-BO-222-1005 Page 12
Finding 1
Section C-2 (V)(B)(5) of the Contract states, in part, that
Properties Not Always CitiWest must secure the property to prevent unauthorized
Secured entry. Our inspection of 30 properties found that 55% of the
properties (16 of 29) were not properly secured (one property
was a vacant lot). There were numerous instances of insecure
windows and/or entry ways, including missing window latches,
broken and un-boarded windows, and unlocked windows and
entryways.
Of the 16 properties we noted as unsecured, CitiWest routine
property inspections shortly before or after our inspections
identified only 19% (3 of 16) as unsecured. Failure to properly
secure properties can lead to trespassing, vandalism, and
possible deterioration. CitiWest staff indicated that there are
numerous individuals who have access to the properties,
including inspectors, appraisers, and numerous real estate
brokers, who do not always re-secure the property upon
departure.
As part of HUD’s monitoring of its M&M Contractors, a
HUD Performance monthly Performance Assessment Report (PAR) is prepared by
Assessment Reports Cite a Government Technical Representative (GTR) assigned to the
Similar Deficiencies specific Contractor. The PAR consists of a narrative
description of the GTR’s observations in ten contractual areas:
Claim Review, Property Maintenance, Appraisals, Listings,
Sales Procedures, Sales Closings, Single Family Acquired
Asset Management System (SAMS) Updates, Rentals,
Occupied Conveyance, and Defective Paint. The PAR also
includes a detailed spreadsheet of property inspections
performed by HUD’s Special Property Inspection (SPI)
Contractor - a 3rd party contractor hired by HUD to inspect a
sample of each M&M Contractor’s property inventory.
A review of the PARs, prepared by CitiWest’s GTR, identified
similar deficiencies to the ones noted above, including consistent
findings of poor property maintenance and defective paint. A
September 1999 Letter of Concern, issued by the GTR, stated
in part,
“In my monthly monitoring letters to you, I have
outlined an overall assessment of your performance as
an M&M Contractor. These reports have consistently
indicated a failure to properly maintain the physical
Page 13 00-BO-222-1005
Finding 1
condition of the HUD homes in your inventory...Proper
maintenance of the properties in your inventory is a
vital component of your contract duties and my office
is becoming increasingly concerned about your
continued poor performance in this area.”
In response, CitiWest indicated that their plan of action to
improve maintenance performance included, in part, increased
quality control inspections, hiring and training an additional in-
house property manager, educating field inspectors, and
conducting monthly meetings with subcontractors.
The GTR, in the narrative portion of both the January 2000 and
April 2000 PARs, indicated an improvement by CitiWest in the
areas of property maintenance and defective paint. The GTR
indicated that, “Defective paint treatment is clearly taking place
and there is documentation including work orders, photographs,
etc, in the files. There continue to be some findings concerning
the lack of defective paint and the Contractor will be sent a
follow up list of homes requiring additional action”. The GTR
also indicated ongoing improvement in property maintenance,
with the exception of completing initial property inspections
within 24 hours.
However, a review of both PARs attached spreadsheet,
detailing the inspections performed by the SPI Contractor,
indicated there were numerous deficiencies in the areas of
property maintenance and defective paint. The instances of
unsecured properties were less profound than during our
inspections. The number of properties inspected and the
deficiencies noted in these three areas for the months of January
2000 and April 2000 were:
Properties Properties With Properties With
Report Month Inspected Poor Maintenance Defective Paint Properties Not Secured
January 2000 148 57 (39%) 88 (59%) 15 (10%)
April 2000 150 79 (53%) 56 (37%) 10 (7%)
Total 298 136 (46%) 144 (48%) 25 (8%)
As shown above, CitiWest continues to struggle with its
property maintenance and identification of defective paint.
CitiWest needs to increase its efforts on improving its
performance.
00-BO-222-1005 Page 14
Finding 1
Poor property conditions contribute to performance problems
CitiWest Needs to Improve such as decreased marketability, increased holding costs,
its Inspection and possible decreased value of surrounding homes, and possible
Maintenance Process conditions that threaten the health and safety of neighbors and
potential buyers. By neglecting the upkeep of its property
inventory, CitiWest is not meeting one of its primary objectives
of protecting and preserving, properly managing, evaluating, and
marketing its properties in a manner which produces the highest
possible return to HUD’s mortgage insurance fund. CitiWest
needs to improve its property inspection and maintenance
process to reduce the risk of undetected hazards and
deficiencies, and to maximize the marketability of its property
inventory to produce the highest net return to HUD.
Auditee Comments CitiWest suggested that the OIG should take into account two
major elements before reaching any conclusions; Case File
Sampling and CitiWest’s Overall Performance. CitiWest
objected to the OIG’s random sampling of properties located in
the cities of New Haven and Waterbury, Connecticut because
they felt the two cities were not representative of their entire
property inventory covering the six New England states.
CitiWest contends that the OIG specifically requested
identification of the two municipalities which were the hardest to
manage and market. CitiWest expressed its objection to the
OIG’s “random sampling” of 30 properties in what the auditee
considers its two worst cities as far as ongoing breaking and
entering, vandalism, and drug neighborhoods, and then basing
the findings of those “very depressed” properties as
representative of the auditee’s entire inventory.
CitiWest also contends that it has improved the return to the
FHA fund, reduced its inventory size, and adhered to HUD’s
mission. CitiWest specifically indicated that they increased the
average sales price of properties and, as a result, increased the
average overall return to the FHA fund. Additionally, CitiWest
showed a decrease of property inventory from August 1999 -
1,332 through July 2000 - 819.
CitiWest also offered its comments and clarifications with the
conclusions reached on the following three areas: Property
Maintenance, Defective Paint, and Unsecured Properties.
Specifically, CitiWest acknowledged that the GTR expressed
Page 15 00-BO-222-1005
Finding 1
serious concern over property maintenance in a September 16,
1999 letter. However, CitiWest expressed its concern that the
OIG did not recognize that, as early as November 1999, the
GTR indicated improvement in property maintenance. CitiWest
further stated that initial property inspections are completed
timely by inspectors, but the actual paperwork may be delayed
in arriving at CitiWest due to weekends, holidays, etc.
Additionally, CitiWest stated that poor performing
subcontractors are terminated as evidenced by termination
notices provided to the OIG.
CitiWest stated that the GTR noted that it is evident that
CitiWest is treating areas of defective paint as it is found.
However, CitiWest stated that in the New England geographic
location, defective paint can keep reoccurring almost as quickly
as it is treated. Additionally, CitiWest stated that real estate
brokers holding Open Houses leave windows or sliding doors
unlatched leaving the property unsecured. This security
problem is ongoing and CitiWest stated it covers this topic at its
outreach meetings for brokers.
OIG Evaluation of With regard to Case File Sampling, we disagree with
Auditee Comments CitiWest’s comments. We asked CitiWest’s key personnel
which two cities had the most number of properties under their
management and marketing responsibility. We confirmed
through data analysis that the cities of New Haven and
Waterbury, Connecticut were the two largest cities under
CitiWest’s management and marketing responsibility in terms of
the number of properties in each city. From these two cities,
utilizing a random number table, we selected 30 properties (15
+ 15) for our sample. We did not choose these cities because
we were advised or we presupposed that these two cities
would be the hardest to manage and market because of their
“socio-economical conditions.”
We recognize and commend CitiWest for reducing its property
inventory from a high of 1,336 in July 1999 to a low of 819 in
July 2000. We are not so optimistic regarding CitiWest’s claim
of increasing the average sales price and, as a result, the overall
return to the FHA fund. Although the average sales price
increased under Citiwest’s management and marketing, so did
the average appraised value of the properties. While there is an
00-BO-222-1005 Page 16
Finding 1
increase in the overall return to the FHA fund, it is not a direct
result of CitiWest’s efforts alone.
We recognize Citiwest’s efforts to perform under its contract
terms, but we also recognize that there is a need for
improvement in the areas outlined. Our report included the
GTR’s statements that CitiWest is improving in property
maintenance. However, we also presented further analysis of
the PARs for the months of January and April 2000 which
indicated, contrary to the GTR’s statements, that numerous
deficiencies in the areas of property maintenance and defective
paint existed. Additionally, although the GTR cited an
improvement in property maintenance, he also pointed out that
initial property inspections are not being performed within the
24 hour requirement.
We agree that the CitiWest is addressing defective paint when
discovered. We do not believe that CitiWest is effective in
identifying all instances of defective paint, as evidenced by the
PARs which consistently indicated a high number of properties
with defective paint. As recommended, HUD needs to
communicate to CitiWest the definition of defective paint so
that there is consistency amongst all property inspectors.
Recommendations We recommend that you:
1A. Instruct CitiWest to establish procedures to ensure
that initial property inspections are performed within 24
hours of property assignment.
1B. Require and ensure CitiWest monitors its property
inspection subcontractors through documented quality
control reviews to ensure all imminent hazards and other
deficiencies are identified.
1C. Require CitiWest to discontinue their use of poor
performing property inspection contractors.
1D. Monitor CitiWest to ensure imminent hazards and
other deficiencies are corrected when noted by routine
Page 17 00-BO-222-1005
Finding 1
property inspections and enforce available sanctions for
poor performance.
1E. Advise CitiWest on the HOC’s definition of defective
paint to ensure consistency among CitiWest and HUD
inspectors in identifying defective paint in all properties
inspected.
1F. Ensure CitiWest identifies defective paint during its
property inspections and continues its treatment efforts,
once clarification of defective paint is established.
1G. Continue monitoring CitiWest’s efforts to properly
secure the properties in its inventory.
00-BO-222-1005 Page 18
Finding 2
Management and Marketing
Requirements Not Fulfilled
CitiWest New England, Inc. (CitiWest) is not complying with case management processing
requirements in accordance with their Management and Marketing (M&M) Contract. As a result,
HUD’s Property Disposition Program may not be operating efficiently, effectively and economically.
HUD needs to ensure that CitiWest complies with their contractual agreement in efforts to achieve its
mission to expand homeownership opportunities and maximize the return to the mortgage insurance
fund.
The primary objectives of CitiWest, as stated in Section C-2(I)
Contractor’s Primary
of their M&M Contract include:
Objectives
• HUD owned properties are protected and preserved,
properly managed, evaluated, and marketed in a manner
which produces the highest possible return to HUD’s
mortgage insurance fund;
• Under contract properties are promptly closed and, if not,
they are returned to the sales market at an early date;
• HUD’s net sales proceeds are promptly wired to its
Treasury account; and
• Average losses on sales and the average time properties
remain in inventory are reduced.
CitiWest does not comply with their primary objectives.
Specifically, properties are held off market for unreasonable
periods of time; case management processing is not timely; sales
closing responsibilities are not followed; and unallowable costs
are charged to HUD. Consequently, CitiWest does not
properly manage and market HUD owned properties in a
manner which is both beneficial and advantageous to HUD.
HUD Permits Held Off Under certain circumstances, HUD permits “held off market
Market Properties properties”, which are properties that HUD has determined not
to offer for sale. Properties may be held off market at any point
after assignment to the Contractor, as illustrated by HUD’s
Page 19 00-BO-222-1005
Finding 2
Single Family Accounting Management System’s (SAMS) User
Guide. At May 30, 2000, CitiWest had a total of 62 held off
market properties, in which 17 properties were held off market
greater than six months. In a sample of 10, we identified 4
properties (40 percent) which we believe were held off market
for unreasonable periods of time.
Properties Held Off We believe CitiWest did not take the appropriate steps to clear
Market Longer Than the problems associated with 2 of the 4 properties in efforts to
Necessary dispose of the properties as soon as possible. For example,
problems existed with a property’s title and therefore the
property was held off market on June 12, 1999. However, the
situation was not resolved by CitiWest until April 14, 2000, and
the property remained held off market at May 30, 2000.
Further, another property had reported fire damage on May 20,
1999. However, CitiWest did not take action to remedy the
situation until November 1, 1999 and the property remained
held off market at May 30, 2000. For the remaining 2
properties, we determined that they should not have been held
off market at all, in accordance with the SAMS’ User Guide.
In retaining held off market properties for unreasonable periods
of time, CitiWest is not effectively achieving its Contract
objective to reduce the average time properties remain in
inventory. CitiWest also has an objective to reduce the average
losses on sales, however maintaining these held off market
properties is costing HUD, as well as CitiWest money. We
determined that as of May 30, 2000 the 4 properties remained
held off market for a period ranging from 305 days to 537
days. The latest actual average daily holding cost for properties
is $32.04 per day, resulting in an estimated expense for
CitiWest of $48,060 on these 4 properties. Further, HUD
incurs costs as well in the form of additional monthly taxes and
fees, utilities, repairs and deterioration of the property possibly
reducing the net return to HUD’s mortgage insurance fund. We
believe that if CitiWest took the appropriate steps to remove
these properties from held off market status in a timely manner,
their inventory and cost would be reduced.
00-BO-222-1005 Page 20
Finding 2
CitiWest is responsible to HUD to protect and preserve,
Case Management
properly manage, evaluate and market HUD owned properties
Processing
in a manner which produces the highest possible return to
HUD’s mortgage insurance fund. However, we determined
that CitiWest does not effectively fulfill its responsibilities.
CitiWest on a monthly basis averaged 1,112 properties in their
case inventory for the period, June 1999 through May 2000. In
review of a sample of 30 property case files, we determined
that CitiWest does not comply with case processing
requirements when obtaining property appraisals; approving title
evidence; meeting sales closing time frames; and following
HUD’s standard processing steps.
Section C-2(IV) of the Contract provides the Contractor is to
Property Appraisals Not order and receive a property appraisal within ten business days
Timely Obtained of a newly assigned property. In a sample of 23 newly assigned
cases, we identified 14 (61 percent) where CitiWest did not
obtain a property appraisal within the prescribed time frame.
We identified properties in which the appraisal was obtained as
much as sixteen to twenty days late. CitiWest staff advised that
they do not always order appraisals in a timely manner and the
appraisers do not always appraise the property and submit
results to CitiWest in a timely manner.
Further, we identified CitiWest did not approve the disposition
program within three days of receipt of the appraisal as
required, for 46 percent (13 of 28) of the applicable cases;
ranging from one day late to ten days late. We were advised by
CitiWest that their Realty Specialists are not always diligent in
performing the disposition analysis and submitting it for approval
in a timely manner.
Mortgagees are required to submit evidence of good and
Title Evidence Not Timely marketable title. As required by Exhibit 11, paragraph 11-1
Approved of the Contract, CitiWest is responsible to review and approve
or reject such title evidence within ten calendar days of receipt
from the mortgagee. For 20 applicable cases, CitiWest did not
approve title evidence within the prescribed time frame for 8
(40 percent), and there was no documented extensions granted.
We identified two extreme cases in which the properties had
approval 60 days and 157 days late. CitiWest staff advised
that they were not aware of the time frame requirement.
Page 21 00-BO-222-1005
Finding 2
Exhibit 8, paragraph 8-2 of the Contract provides the
Sales Closing Time Frames Contractor must establish a closing time frame within the range
Not Met of 30 to 60 calendar days after acceptance of the sales
contract. We identified 4 of 13 applicable properties where
CitiWest did not meet the time frame on the sales contract. The
time frame was not met as a result of expiring contract
extensions. Upon expiring contract extensions, sales contracts
should be canceled or another extension granted. When the
contract is canceled, the property should be re-listed for sale in
accordance with the Contract. CitiWest staff advised that their
Realty Specialists are not always diligent in completing the
extension forms in a timely manner.
SAMS is HUD’s automated system that provides data for
Unreasonable Management management, processing, and monitoring of acquired and
Processing steps custodial single family properties. SAMS tracks ten case
management processing steps, beginning with the acquisition of
a property and ending with the reconciliation of funds from the
final sale or disposal of the property. The case management
tasks are monitored and tracked by HUD in accordance with
standard processing times, including standard processing time
for each step. See Appendix A.
We identified 6 of 30 cases (20 percent) where the property’s
current management processing step was not reasonable;
meaning HUD’s standard processing time was not met. For 2
cases, the property was in the current processing step longer
than the time prescribed; exceeding the standard processing
time by 8 days and 11 days. For the remaining 4 cases, the
property remained in the accepted sales offer phase although
the contract extension expired; ranging from an expiration of 9
days to 71 days.
It is essential for CitiWest to process cases timely in efforts to
meet their objectives to properly manage, evaluate and market
properties, and to maximize the highest possible return to
HUD’s mortgage insurance fund. HUD needs to ensure that
CitiWest complies with Contract requirements, including
HUD’s standard processing times.
CitiWest is responsible to ensure that properties under sales
Sales Closing contract are promptly closed and that HUD’s net sales
Responsibilities proceeds are promptly wired to its Treasury account.
00-BO-222-1005 Page 22
Finding 2
However, we determined that CitiWest is not fulfilling their
responsibilities in processing closed property cases.
Specifically, in review of a sample 15 property case files we
identified instances where inappropriate cost were charged to
HUD, and problems with closing agents, including the delay in
wire transfers, were not reported to HUD as required.
Exhibit 8, paragraph 8-4B of the Contract provides the
Possible Inappropriate Cost Contractor must ensure the accuracy of all closing
documentation and assure that all costs charged to HUD are
appropriate. We determined that CitiWest does not ensure that
all cost charged to HUD are appropriate. In review of 15
closed cases, we determined that CitiWest is not resolving
outstanding balances of taxes, water and/or sewer, including
interest and penalties prior to sales closing. These cost should
be paid by the lender prior to conveyance to HUD. However,
we identified instances where the cost are included on the HUD
1 settlement statement as an expense to HUD. CitiWest has
the responsibility to ensure that only allowable cost are charged
to HUD, whereas they need to take the appropriate action to
exclude all inappropriate cost.
Exhibit 8, paragraph 8-7D of the Contract provides the
Deficiencies With Closing Contractor shall notify HUD in instances where the closing
Agents Not Transmitted agent has failed to timely submit the final sales closing package,
including instances where the closing agent has failed to comply
with the wire transfer procedures specified in the closing agent’s
contract. This is to ensure that the closing agent is assessed the
proper liquidated damages for late delivery. The Contractor is
required to submit weekly reports illustrating areas of the
closing agent’s noncompliance.
By letter dated April 13, 2000, CitiWest transmitted a quality
control report to their HUD Government Technical
Representative, analyzing 31 closing packages received during a
2-3 week period ending February 18, 2000,. The report
identified several deficiencies with sales closing packages
submitted by the closing agents; including late wire transfers,
late receipt of closing package, closing agents signing HUD 1
settlement statement as seller, and overcharging HUD for
closing costs. Although this quality control report was
transmitted to HUD, the Contract requires CitiWest to prepare
and submit weekly reports disclosing instances of
Page 23 00-BO-222-1005
Finding 2
noncompliance by closing agents. This reporting mechanism is
required because liquidated damages are assessed for
noncompliance. CitiWest does not prepare and submit weekly
reports, in adherence with Contract requirements.
The importance of these reports become even more apparent
with the identification of closing agent noncompliance. During
our review we identified two instances of the closing agents’
noncompliance, similar to what CitiWest reported in the quality
control report. We identified 8 in a sample of 10 applicable
closed cases (80 percent) where property sale proceeds were
not wire transferred to the Department of Treasury on the
following business day as required. We identified the transfers
ranged from one to three days late. We also identified an
instance where prepaid interest and up-front mortgage
insurance was charged to HUD. These cost should have been
paid by the buyer, not charged to HUD.
HUD needs to ensure that CitiWest complies with Contract
requirements and submits weekly reports of closing agent
noncompliance. HUD further needs to ensure that CitiWest
takes appropriate action with closing agents to ensure
compliance with their contractual obligation. In efforts to ensure
compliance, HUD will increase the likelihood of a successful
Property Disposition Program.
CitiWest is allowed full compensation for their contract services
Late Fees, Interest and and reimbursement for actual expenses specifically identified by
Penalties are Prohibited the Contract as a pass through cost. However, Section C-
4(III)(C) of the Contract provides, “Payments made by the
Contractor for penalties, fees or interest incurred by the
Contractor due to late payment to other parties are unallowable
cost”. As a result, these type of expenses are prohibited to be
requisitioned from HUD in monthly pass through vouchers
unless the GTR grants prior approval.
CitiWest is requisitioning reimbursement for penalties, fees and
interest incurred due to late payment on condo fees and utilities.
CitiWest advised that condo late fees result from not receiving
bills promptly, and outstanding utility costs are inherited upon
receiving the property. We were advised that these cost did
not result from a late or non payment by CitiWest.
00-BO-222-1005 Page 24
Finding 2
Although the cost were determined to be minor, based upon a
review of 3 pass through vouchers, CitiWest should not be
requisitioning these types of penalties, fees and interest from
HUD. It is CitiWest’s responsibility to ensure that bills are
received promptly. Condo fees are at a consistent monthly
amount, and CitiWest should make every attempt to initially
determine the amount, make timely payment, and not wait for a
bill. If an actual bill is preferred, CitiWest should actively
pursue the issue with the Condo Association.
Outstanding utility costs should not be inherited by CitiWest
subsequent to property transfer. CitiWest should be receiving
properties clean of any past encumbrances whereas the lender
should pay any outstanding utility costs prior to conveyance to
HUD. If not, it is CitiWest responsibility to actively pursue
payment of the bills with the lender, and not include such costs
in pass through vouchers. CitiWest should consider working
with HUD in efforts to reduce the lender’s claim by the amount
due.
CitiWest is not successfully achieving their objectives, nor
Objectives Are Not Met complying with Contract requirements. Properties are held off
market for unreasonable periods of time. Property case
management processing is not timely. Instances of closing agent
noncompliance is not reported to HUD, and there are no
assurances that all closing documents are accurate and that only
appropriate costs are charged to HUD. Finally, reimbursement
for late fees, interest and penalties is requisitioned by CitiWest
although it is prohibited by their Contract. HUD needs to
ensure contractual agreements are followed and objectives are
met to ensure the Property Disposition Program achieves its
mission efficiently, effectively and economically.
Auditee Comments CitiWest offered its comments and clarifications with the
conclusions reached on the following six areas: Case
Management Processing, Held-Off-Market Properties, Title
Approval, Closing Extensions, Taxes and Utility Bill Processing,
and Closing Agent Issues. Specifically, CitiWest believes the
comments of unreasonable management processing steps is
unfair because SAMS report CMEPSD01, which is used by
HUD to measure contractor performance in timely case
Page 25 00-BO-222-1005
Finding 2
movement, was not correctly reflecting exceeding dates for
approximately the first 15 months of the contract. HUD has
recently corrected the report.
CitiWest stated that the OIG held many conversations to
discuss specific reasons why properties were held off the
market, and that the case files are documented to reflect these
actions. Additionally, CitiWest stated that they are in regular
contact with the GTR, as the remedy to these situations
regularly falls outside of the decisions CitiWest can make
without HUD’s permission.
CitiWest also stated that it was their efforts that resulted in the
foreclosing agents finally forwarding the title packages to them.
Further, CitiWest stated that their staff is aware of the time
limitations to approve title and received training from the HOC
with regard to such.
It is the responsibility of the real estate agents to maintain the
sales contract in force and request an extension through the
closing agent, which is then approved. CitiWest stated that no
contracts are closed without valid extensions when required.
CitiWest does not agree with the OIG’s concern re- payment
of late fees and penalties when reimbursed by HUD. CitiWest
cited its contract which provides that payment of unpaid taxes,
water, sewer, or other assessments is the responsibility of the
Contractor. It goes without saying that if you have an unpaid
tax or other bill that there will be penalties and interest. With
regard to pre-conveyance bills, CitiWest stated they inherit
these bills on a daily basis and the case moves to a closing stage
relatively quickly. In all such cases, the GTR is contacted and
the circumstances explained. In each case, the GTR directs
CitiWest to either pay the outstanding amount or instruct that
the amount be paid out of settlement at closing.
Finally, CitiWest constantly reports issues and concerns relating
to closing agents timely performance and accuracy to the HOC.
All extraordinary conditions are directly reported to the GTR
for guidance.
00-BO-222-1005 Page 26
Finding 2
OIG Evaluation of We recognize CitiWest’s efforts to perform under its contract
Auditee Comments terms, but we also recognize that there is a need for
improvement in the areas outlined.
We did not utilize SAMS report CMEPSD01 in determining
CitiWest’s effectiveness in case management processing. We
used the “Standard Processing Steps” (see Appendix A) to
determine whether a property remained in a case management
processing step for an unreasonable amount of time.
Additionally, we did not find adequate documentation in the
case files for the held off market properties considered to have
management deficiencies. The files did not delineate the reason
that a property was held off market or that CitiWest was
working to market the property as soon as possible. We
considered OIG properties, but concluded that these properties
were not held off market for an unreasonable amount of time.
With regard to title evidence approval, we concluded that these
time frames were not met in eight of twenty applicable cases.
Adequate staff training is not a guarantee of performance.
We agree that real estate agents are responsible for maintaining
the sales contract in force and requesting extensions through the
closing agents. However, when extensions are not requested, it
is CitiWest’s responsibility to take action to either cancel the
contract or determine if a request for an extension is
forthcoming. We found that CitiWest staff would complete
contract extensions retroactively upon discovery that one was
needed prior to closing or upon our inquiry. As a result, we
concluded sales closing time frames were not met due to
expired contracts with no approved extensions.
Outstanding balances of taxes and utilities, including late fees
and penalties, should be paid by the lender prior to conveyance
to HUD. We found instances where these costs are included
on the HUD 1 settlement statement as an expense to HUD.
Although we recognize payment of these items is required to
proceed with the property closing, our concern is that CitiWest
is not taking the necessary actions to notify HUD of these
instances and minimize future occurrences.
Page 27 00-BO-222-1005
Finding 2
CitiWest is required to submit weekly reports illustrating areas
of the closing agent’s noncompliance. We were provided one
such report dated April 13, 2000.
Recommendations We recommend that you:
2A. Ensure that CitiWest processes held off market
properties in reasonable time to reduce any applicable
holding cost to CitiWest, and additional cost to HUD.
2B. Require CitiWest to develop a system of control which
would enable timely case management processing to
comply with Contract requirements and HUD’s
standard processing time.
2C. Require CitiWest to accurately review HUD 1
settlement statements and exclude unallowable cost
charged to HUD in accordance with Contract
requirements.
2D. Require CitiWest to prepare and submit weekly reports
of closing agent noncompliance in accordance with
Contract requirements.
2E. Require CitiWest to immediate suspend requisition of
late fees, interest and penalties in accordance with
Contract requirements.
2F. Conduct thorough reviews of all monthly pass through
vouchers to ensure that late fees, interest and penalties
are no longer included.
00-BO-222-1005 Page 28
Management Controls
In planning and performing our audit, we considered management controls of Management and
Marketing Contractor for New England, CitiWest New England, Inc.(CitiWest), specifically as related
to its responsibility for the ongoing management and marketing of HUD single-family properties in New
England, in order to determine our auditing procedures and not to provide assurance on management
controls.
Management controls consist of a plan of organization and methods and procedures adopted by
management to ensure that resource use is consistent with laws, regulations, and policies; that resources
are safeguarded against waste, loss, and misuse; and that reliable data is obtained, maintained, and fairly
disclosed in reports.
We determined the following management controls were
Relevant Management
relevant to our audit objectives:
Controls
• Overall Case Processing
• Property Maintenance
• Quality Control
• Marketing
• Data Entry
A significant weakness exists if management controls do not
Assessment Results give reasonable assurance that resource use is consistent with
laws, regulations, and policies; that resources are safeguarded
against waste, loss, and misuse; and that reliable data is
obtained, maintained, and fairly disclosed in financial statements
and reports.
Our review identified significant weaknesses over CitiWest’s
Significant Weaknesses ability to properly administer its case processing, property
maintenance, and quality control responsibilities. Specific
weaknesses were identified in the management control areas
disclosed above, with exception to Marketing and Data Entry.
These weaknesses are described in the Findings section of this
report.
Page 29 00-BO-222-1005
Management Controls
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00-BO-222-1005 Page 30
Appendix A
Standard Processing Steps
Step Description Days (Allowed)
1 Add property to inventory - acquisition 17
2 Record appraisal of property 3
3 Determine method to dispose of property 3
4 Identify and approve repairs to property - optional 20
5 Identify properties that are ready to list for sale 10
6 List property for sale 30
7 Accept preliminary offer for property 7
8 Accept sales offer/contract 60
9 Record sales or settlement of property 7
10 Close/archive property -
Total Processing Days 157
Step 1 - The recording of information from Form-27011, Single Family Application for Insurance
Benefits, or through other means of acquisition as indicated in the contract.
Step 2 - The recording of initial data from the appraisal.
Step 3 - The design and approval of a Disposition Program.
Step 4 - The approved Disposition Program requires repairs and it is not specified as a property that is
“ready to list”.
Step 5 - Properties with an approved Disposition Program, not Held Off Market, and Ready to List.
Required repairs must be completed beforehand.
Step 6 - The property is advertised for sale.
Step 7 - A preliminary offer is received and recorded in SAMS.
Step 8 - Recording the accepted sales offer.
Step 9 - The closing or settlement package is received and the Form HUD-1, Settlement Statement is
entered into SAMS.
Step 10 - Reconciliation of the HUD-1 data with the funds received by Treasury and the financial
accounts associated with the case.
Page 31 00-BO-222-1005
Appendix A
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Page 32 00-BO-222-1005
Appendix B
Auditee Comments
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Appendix B
00-BO-222-1005 Page 34
Appendix B
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Appendix B
00-BO-222-1005 Page 36
Appendix B
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Appendix B
00-BO-222-1005 Page 38
Appendix C
Distribution
Deputy Secretary, SD, Room 10100 (1)
Chief of Staff, S, Room 10000 (1)
Special Assistant to the Deputy Secretary for Project Management, SD, Room 10100 (1)
Acting Assistant Secretary for Administration, S, Room 10110 (1)
Assistant Secretary for Congressional and Intergovernmental Relations, J, Room 10120 (1)
Senior Advisor to the Secretary, Office of Public Affairs, S, Room 10132 (1)
Director of Scheduling and Advance, AL, Room 10158 (1)
Counselor to the Secretary, S, Room 10234 (1)
Deputy Chief of Staff, S, Room 10226 (1)
Deputy Chief of Staff for Operations, S, Room 10226 (1)
Deputy Chief of Staff for Policy, S, Room 10226 (1)
Deputy Chief of Staff for Program, S, Room 10026 (1)
Deputy Assistant Secretary for Public Affairs, W, Room 10222 (1)
Special Assistant for Inter-Faith Community Outreach, S, Room 10222 (1)
Executive Officer for Administrative Operations and Management, S, Room 10220 (1)
Senior Advisor to the Secretary for Pine Ridge Project, W, Room 10216 (1)
General Counsel, C, Room 10214 (1)
Director, Office of Federal Housing Enterprise Oversight, O, 9th Floor Mailroom (1)
Assistant Secretary for Housing/Federal Housing Commissioner, H, Room 9100 (1)
Office of Policy Development and Research, R, Room 8100 (1)
Inspector General, G, Room 8256 (1)
Assistant Secretary for Community Planning and Development, D, Room 7100 (1)
Government National Mortgage Association, T, Room 6100 (1)
Assistant Secretary for Fair Housing and Equal Opportunity, E, Room 5100 (1)
Chief Procurement Officer, N, Room 5184 (1)
Assistant Secretary for Public and Indian Housing, P, Room 4100 (1)
Chief Information Officer, Q, Room 3152 (1)
Director, Office of Departmental Operations and Coordination, I, Room 2124 (1)
Chief Financial Officer, F, Room 2202 (1)
Director, Enforcement Center, V, 200 Portals Building (1)
Director, Real Estate Assessment Center, X, 1280 Maryland Avenue, SW, Suite 800 (1)
Director, Office of Multifamily Assistance Restructuring, Y, 4000 Portals Building, (1)
Secretary’s Representative, 1AS (2)
Assistant Deputy Secretary for Field Policy and Management, SDF, Room 7108 (2)
Deputy Chief Financial Officer for Finance, FF, Room 2202 (1)
Director, Office of Budget, FO, Room 3270 (1)
Primary Field Audit Liaison Officer, 3AF1(2)
Headquarters Audit Liaison Officer, HF, (2)
Departmental Audit Liaison Officer, FM, Room 2206 (2)
Acquisitions Librarian, Library, AS, Room 8141 (1)
Page 39 00-BO-222-1005
Appendix C
Deputy Inspector General, G, Room 8256 (1)
Assistant Inspector General for Audit, GA, Room 8286 (1)
Deputy Assistant Inspector General for Audit, GA, Room 8286 (1)
Assistant Inspector General for Investigation, GI, Room 8274 (1)
Appropriate Special Agent-In-Charge, 1AGI (1)
Director, Program Research and Planning Division, GAP, Room 8180 (1)
Director, Financial Audits Division, GAF, Room 8286 (1)
Director, Information Systems Audit Division, GAA, Room 8172 (1)
Counsel to the Inspector General, GC, Room 8260 (1)
Central Records, GF, Room 8256 (4)
Semi-Annual Report Coordinator, GF, Room 8254 (1)
Office of Inspector General Webmanager - Electronic Format (1)
Public Affairs Officer, G, Room 8256 (1)
Auditee (2)
Director, Philadelphia Single Family Homeownership Center, 3AHH (1)
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human Resources,
B373 Rayburn House Office Building, Washington, DC 20515
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340 Dirksen Senate
Office Building, United States Senate, Washington, DC 20510 (1)
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, 706 Hart
Senate Office Bldg., United States Senate, Washington,DC 20510 (1)
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn Bldg.,
House of Representatives, Washington, DC 20515 (1)
Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204 Rayburn Bldg.,
House of Representatives, Washington, DC 20515 (1)
Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O’Neill House Office
Building, Washington, DC 20515 (1)
Director, Housing and Community Development Issue Area, United States General Accounting Office,
441 G Street, NW, Room 2474, Washington, DC 20548 (Attention: Judy England-Joseph) (1)
Steve Redburn, Chief, Housing Branch Office of Management & Budget, 725 17th Street, NW, Room
9226, New England Executive Office Building, Washington, DC 20503 (1)
00-BO-222-1005 Page 40
Appendix B
Page 41 00-BO-222-1005
CitiWest New England, Inc., Management and Marketing Contractor, Hartford, Connecticut
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-09-29.
Below is a raw (and likely hideous) rendition of the original report. (PDF)