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 THIS PAGE LEFT BLANK INTENTIONALLY 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 Page v 00-BO-222-1005 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 THIS PAGE LEFT BLANK INTENTIONALLY 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 Page 7 00-BO-222-1005 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 THIS PAGE LEFT BLANK INTENTIONALLY 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 THIS PAGE LEFT BLANK INTENTIONALLY Page 32 00-BO-222-1005 Appendix B Auditee Comments Page 33 00-BO-222-1005 Appendix B 00-BO-222-1005 Page 34 Appendix B Page 35 00-BO-222-1005 Appendix B 00-BO-222-1005 Page 36 Appendix B Page 37 00-BO-222-1005 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)