Issue Date May 24, 2000 Audit Case Number 00-FW-222-1003 TO: Ronald C. Bailey Director, Single Family Homeownership Center, 8AHH FROM: D. Michael Beard District Inspector General for Audit, 6AGA SUBJECT: Pope & Booth Closing Agent Contract We performed an audit of Pope & Booth’s Closing Agent contract. Our attached report contains two findings. Within 60 days, please furnish this office, for each recommendation in this report, a status on: (1) 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 copies of any correspondence or directives issued related to the audit. If you have any questions, please contact Theresa A. Carroll, Assistant District Inspector General for Audit, at (817) 978-9309. Management Memorandum THIS PAGE LEFT BLANK INTENTIONALLY 00-FW-222-1003 Page ii Executive Summary We performed an audit of the law offices of Pope & Booth, P.C. (Pope & Booth), a closing agent for HUD, as part of a nationwide effort to review closing agents. Our audit objective was to determine whether management controls were adequate to ensure the prevention of fraud, waste, and abuse. To meet this objective, we performed audit steps to determine whether the closing agent complied with its contract terms and conditions. Overall, Pope & Booth’s controls were sufficient to ensure substantial compliance with its HUD contract. However, we also found that Pope & Booth split title insurance fees and overcharged HUD for wire transfer fees. Although we noted some minor exceptions, Pope & Booth Pope & Booth sufficiently performed the following contractual duties adequately: performed some closing agent duties. • Prepared extensions in writing and calculated the correct amount of extension fee; • Paid only allowable expenses; • Collected the correct fees; • Wired correct amounts and generally conducted the wires timely; • Calculated the correct amount for the taxing authority; • Collected the correct closing agent fee, and • Prepared the Warranty Deeds correctly. Pope & Booth split title Even though Pope & Booth performed no additional services insurance fees. beyond those required in the closing agent contract, it received a 40 percent split of title insurance premiums from two title insurance companies. The Real Estate Settlement Procedures Act (RESPA) prohibits fee splitting and receiving unearned fees for services not actually performed. Because Pope & Booth did not perform any additional services and received a split of title insurance premiums, Pope & Booth violated RESPA. From February 1998 to June 1999, Pope & Booth received unearned fees which range between $361,886 to $454,976. Pope & Booth’s contract required it to charge HUD the actual Pope & Booth cost of wire transfer fees. For the 45 closing files reviewed, overcharged HUD for Pope & Booth charged HUD $25 for each wire transfer. wire transfer fees. However, Pope & Booth’s bank only charged $12. As a result, Pope & Booth overcharged HUD a total of $585 on the Page iii 00-FW-222-1003 Executive Summary 45 files. In addition, Pope & Booth may have overcharged HUD on every file that it closed. Thus, Pope and Booth may owe HUD an additional $28,587 for wire transfer fee overcharges on the remaining 2,199 closings reported in SAMS. Pope & Booth did not record Special Warranty Deeds timely Special Warranty Deed after closings. Pope & Booth’s contract required them to Not Recorded Timely. record the deed on the day of closing or the next business day. Pope & Booth recorded deeds anywhere from 1 to 96 days late. However, late filing of deeds did not negatively impact home buyers. Since Pope & Booth is no longer performing closings for HUD, this compliance issue is not significant enough to warrant a separate finding and will only be reported in this summary. As a result of these findings, we recommend that HUD pursue Recommendations. Pope & Booth and the two title insurance companies for RESPA violations. HUD should seek to recover from Pope & Booth the $294,461 received from Alamo Title. HUD should also determine and recover the amount Pope & Booth received from American Title, which was between $67,425 to $160,515. In addition, we recommend that Denver Home Ownership Center require Pope & Booth to reimburse HUD $585 for documented ineligible wire transfer fees. Further, HUD should determine the actual number of closings performed by Pope & Booth. Then, HUD should recover the amount overcharged for wire fees on those closings, which could be as high as $28,587. 00-FW-222-1003 Page iv Table of Contents Management Memorandum i Executive Summary iii Introduction 1 Findings 1 Pope & Booth Split Title Insurance Premiums 5 2 Pope & Booth Overcharged HUD for Wire Transfer Fees 11 Management Controls 13 Appendices A Schedule of Questioned Costs 15 B Auditee Comments 17 C Distribution 27 Abbreviations Page v 00-FW-222-1003 Table of Contents CFR Code of Federal Regulations HUD U.S. Department of Housing and Urban Development OIG Office of Inspector General RESPA Real Estate Settlement Procedures Act SAMS Single Family Asset Management System 00-FW-222-1003 Page vi Introduction The law office of Pope & Booth, P. C. (Pope & Booth), Background. contracted with HUD to conduct closings of HUD’s single family properties for Dallas county. Pope & Booth’s closing agent contract1 started on February 1, 1997. Pope & Booth terminated its contract with HUD on April 15, 1999. Pope & Booth had an indefinite quantity contract that provided closing services for single family properties owned by HUD. The primary objectives of the contract were to ensure that: (1) the sale of all properties closed within 60 days; (2) lenders table-funded all closings so that the funds were available to disburse at closing; (3) prompt and accurate payment of all closing costs was made; (4) net proceeds from each sale were wire transferred to HUD’s account on the day of closing or the next banking day; and (5) complete and accurate closing packages were submitted to HUD within 2 business days. To conduct a closing, Pope & Booth’s contract required them as closing agent to: • Establish individual property files and maintain the files by FHA case number. • Coordinate with purchaser, broker, and if appropriate, mortgagee, to establish a firm closing date on or before the date specified in the Sale Contract. • Review title information and clear routine title issues2 because clear title must be conveyed on all properties. • Prepare a pre-closing package including a draft HUD-13, Sales Contract, Special Warranty Deed, and closing instructions from the lender to be submitted to HUD for its review. • On the day of closing, explain all closing papers and documents to the purchaser, complete and execute the HUD-1, accept only cash or certified check, and provide a tax certificate or sufficient documentation to show taxes have been paid. 1 Pope & Booth’s contract number was H06C97000100000. 2 Such as past due taxes, water bills, and liens. 3 The HUD-1 is the settlement statement used in the sale of HUD owned properties. Page 1 00-FW-222-1003 Introduction • On the day of closing or the next banking day, deposit sales proceeds, initiate a wire transfer, and obtain the bank’s wire transfer confirmation. • On the day of closing or the next working day, record the Special Warranty Deed. • Store title documents4 that are the property of HUD in a secure cabinet furnished by the closing agent. According to information obtained from HUD’s Single Family Asset Management System (SAMS), Pope & Booth closed 2,244 properties as a closing agent from February 1, 1997, to January 31, 1999. We were unable to confirm this figure or otherwise determine the total number of sales that Pope & Booth closed due to the significant error rate in SAMS data. 5 Neither HUD nor the closing agent could provide a more accurate number of the closings performed. For each closing performed, Pope & Booth received $90 from HUD. If a sale canceled, HUD paid Pope & Booth $22.50. Pope & Booth maintained three offices that conducted closings: Grand Prairie, Lewisville, and Dallas, Texas. Its main office was in Austin, Texas. Our audit objective was to determine whether management Audit Objectives. controls were adequate to ensure the prevention of fraud, waste, and abuse. We obtained background information by: Scope and Methodology. • Reviewing the Fort Worth Single Family Office file on Pope & Booth. • Reviewing prior closing agent audit programs. • Participating in a teleconference with KPMG regarding its findings for the fiscal year 1998 FHA Financial Statement Audit. • Reviewing the KPMG Briefing Paper regarding the fiscal year 1998 FHA Financial Statement Audit. To accomplish our audit objectives, we: 4 Such as title policy and deed. 5 Audit testing of SAMS data for the closings conducted by Pope & Booth showed that there was a 22% error rate. In our original sample of 50 files, 11 were improperly identified as being closed by Pope & Booth. 00-FW-222-1003 Page 2 Introduction • Examined the contract and HUD’s Property Disposition Handbook. • Obtained and tested information from SAMS. • Obtained from SAMS a listing of closings performed by Pope & Booth, from which we selected our sample of closings for audit testing. • Interviewed HUD and Pope & Booth staff at various offices regarding the closing process. • Obtained an understanding of Pope & Booth’s closing and accounting processes. • Obtained and reviewed 45 closed and 5 canceled files while on-site at Pope & Booth’s Grand Prairie and Lewisville offices. We selected files judgmentally using a random number generator. Because of the SAMS errors, the 11 files that were not closed by Pope & Booth were replaced by another judgmental sample while on-site. We tested closing files for the following contractual and HUD Handbook requirements: 1. The property closed timely and, if the property did not close timely, we documented the number of days late; 2. The closing file contained an extension request and approval, if applicable; 3. The correct extension fee was collected, if applicable; 4. Only allowable expenses were paid; 5. The correct fees were collected; 6. The sale proceeds were deposited timely; 7. The correct amount was wired timely; 8. The Deed was recorded timely; 9. The correct amount was collected for the taxing authority; 10. The correct amount was paid to the closing agent; 11. Returned funds were distributed correctly; 12. Clear title was issued; 13. The title insurance premium was not split; 14. A Warranty Deed was prepared; 15. The Warranty Deed was forwarded to HUD timely; 16. The selling amount on the sales contract and the settlement statement were identical; 17. Closing costs for the buyer were identical on both pages of the HUD-1; and Page 3 00-FW-222-1003 Introduction 18. The correct amount of extension fees were on the HUD-1, if applicable. We conducted the audit at Pope & Booth’s offices in Grand Audit Period and Sites. Prairie, Lewisville, and Austin, Texas. The audit covered closings by Pope & Booth from February 1, 1997, to January 31, 1999. We extended the scope of our review to include payments Pope & Booth received from title companies on its contract with HUD. We performed site work from February 1999 through March 1999. We conducted our audit in accordance with generally accepted government auditing standards. 00-FW-222-1003 Page 4 Finding 1 Pope & Booth Split Title Insurance Premiums Even though Pope & Booth performed no additional services beyond those required in the closing agent contract, it received a 40 percent split of title insurance premiums from two title insurance companies. The Real Estate Settlement Procedures Act (RESPA) prohibits fee splitting and receiving unearned fees for services not actually performed. Because Pope & Booth did not perform any additional services and received a split of title insurance premiums, Pope & Booth violated RESPA. From February 1998 to June 1999, Pope & Booth received unearned fees which range between $361,886 to $454,9766. Pope & Booth’s closing agent contract7 stated that the closing Criteria. fee paid by HUD was intended to be inclusive of all services and the preparation of all documents required by any party to the closing, including the lender. Further, the contract prohibited Pope & Booth from collecting any fees for services or documents required under the contract above and beyond HUD’s established closing fee. The RESPA is a consumer protection statute that was first passed in 1974. One of its purposes is to eliminate kickbacks and referral fees that increase unnecessarily the costs of certain settlement services. The RESPA section titled--Prohibition against kickbacks and unearned fees -- states in part (c) “No person shall give and no person shall accept any portion, split, or percentage of any charge made or received for the rendering of a settlement service in connection with a transaction involving a federally related mortgage loan other than for services actually performed. A charge by a person for which no or nominal services are performed or for which duplicative fees are charged is an unearned fee and violates this section.8” Simply put, RESPA prohibits fee splitting and receiving unearned fees for services not actually performed. 6 Because of the time it takes to process payments, Pope & Booth received payments form Alamo Title until June 1999. 7 Section B.5. 8 Title 24 CFR 3500.14. Page 5 00-FW-222-1003 Finding 1 In 49 percent of the closing files reviewed9, Pope & Booth Pope & Booth received a received a 40 percent split of the premiums from two title percentage of the title companies that provided title insurance to lenders and/or insurance premiums. homeowners. In each of the 22 cases, either the title commitment or the title company invoice documented that Pope & Booth would receive 40 percent of the title premium. Further audit work revealed that Pope & Booth had written agreements to split title insurance premiums with two title companies: American Title and Alamo Title. Pope & Booth’s agreements with the two title companies Title company consisted of duties that duplicated the work that HUD required agreements duplicate of its closing agents. Specifically, Pope & Booth’s tasks under work required in closing the title company agreements included: agent contract. • performing closings in compliance with the terms and conditions of the sales contract; • closing in accordance with normal legal and business practices; • closing in strict compliance with the title commitment terms and requirements; • disbursing consideration and proceeds through Pope & Booth’s escrow account properly; • recording documents properly or delivering the documents and recording fees to the title company for recording; and • reviewing the title commitment provided and clearing any exceptions. All of these tasks were also required by Pope & Booth’s closing agent contract with HUD. In addition, HUD’s contract specifically prohibited Pope & Booth from collecting any additional fees for services or documents already required as part of the closing agent contract. Pope & Booth performed no additional work for the title Pope & Booth performed companies beyond what was required of a HUD closing agent. no additional work for the Yet, the two title companies paid Pope & Booth 40 percent of title company fee. the title premium. RESPA considers such payments to be unearned fees. HUD’s closing agent contract allowed 9 22 out of the 45 closing files reviewed. 00-FW-222-1003 Page 6 Finding 1 additional compensation for services other than closing activities. Yet, Pope & Booth performed no additional duties that were outside the scope of its HUD contract. Thus, HUD and the title companies paid Pope & Booth for performing the same services. Additional audit work was performed to determine the amount Pope & Booth received as part of the fee splitting arrangements with the two title companies. Both title companies were issued subpoenas to obtain payment information. In response to the subpoena, Alamo Title provided check $294,461 paid by Alamo registers and other supporting information for payments to Pope Title to Pope & Booth. & Booth. Based on the information provided, Alamo made payments to Pope & Booth from February 1998 to June 4, 1999. During that time period, Alamo Title’s records showed that Pope & Booth was paid $294,461 for insurance premiums paid for by purchasers or HUD. American Title could not provide the total amount that it paid Pope & Booth. American Title provided database records that indicated that HUD was a party to 435 closings for properties in the Dallas county area.10 American Title did not provide the amount of fees paid to Pope & Booth for each of these 435 properties. However, they did provide the amount of title insurance premiums paid to Pope & Booth for seven properties identified during audit testing. American Title paid Pope & Booth $2,360 for these seven properties. The amounts paid ranged from $155 to $369 per property. Thus for the 435 closings, Pope & Booth could have potentially received from $67,425 to $160,515 in unearned fees from American Title. In discussions with its management, Pope & Booth Pope & Booth acknowledged that the title companies paid it a percentage of acknowledged receiving a the title insurance premium. However, Pope & Booth percentage of title management offered no explanation for the allowability of this premium. practice. 10 Since Pope & Booth was the only closing agent for HUD in Dallas county that had an agreement with American Title, we concluded that Pope & Booth was the closing agent for all 435 properties. Thus, Pope and Booth would have received 40% of the title insurance premium from American title for all 435 properties. Page 7 00-FW-222-1003 Finding 1 American Title responded that because American Title Auditee Comments complied with the rules and regulations of the Texas Insurance Code it did not violate RESPA. Further, because American Title complied with the Texas Insurance Code no RESPA violation occurred. Alamo Title responded that Alamo Title entered into a standard contract with Pope & Booth for closing services rendered on Alamo Title’s behalf and complied with the rules and regulations of the Texas Insurance Code. Additionally, Alamo Title stated that Pope & Booth received duplicative fees for performance of the same services, one from HUD and one from Alamo. Further, Alamo Title stated that Pope & Booth should either reimburse HUD or Alamo the amount it was overpaid. However, Alamo Title stated that it is not responsible to HUD for any overpayments that Pope & Booth received. Based on our evaluation of American Title and Alamo Title’s OIG Evaluation of responses, the raising of the issue of Texas Insurance law versus Comments Federal RESPA law is unfounded. If it were, Federal law would prevail, but the two are not at odds. Both title companies are raising Texas Insurance Code because they believe that the report states that title companies cannot pay a closing agent for closing services. The audit report does not state that. Texas law does allow title companies to pay for closing services. However, what the audit found was that the closing fees were indeed duplicative and thus, the title companies were paying something for nothing. Recommendations We recommend that the Director, Denver Homeownership Center: 1A. Pursue Pope & Booth and/or Alamo Title for the RESPA violations and recover $294,461 in questioned unearned fees. 00-FW-222-1003 Page 8 Finding 1 1B. Require Pope & Booth to research and report the amount of payments that it received from American Title for closing performed under the HUD contract. 1C. Pursue Pope & Booth and/or American Title for the RESPA violations and recover the questioned unearned fees of $67,425 to $160,515. Page 9 00-FW-222-1003 Finding 1 THIS PAGE LEFT BLANK INTENTIONALLY 00-FW-222-1003 Page 10 Finding 2 Pope & Booth Overcharged HUD for Wire Transfer Fees Pope & Booth overcharged HUD to wire transfer the proceeds from sales that it closed for HUD. Pope & Booth’s contract required it to charge HUD the actual cost of the wire transfer fee. For each of the 45 closing files reviewed, Pope & Booth charged $25 for a wire transfer. However, Pope & Booth’s bank only charged $12. As a result, Pope & Booth overcharged HUD $585 on the 45 files reviewed. In addition, Pope & Booth may have overcharged HUD on every file that it closed. Thus, Pope and Booth may owe HUD an additional $28,587 for wire transfer fee overcharges on the remaining 2,199 closings reported in SAMS.11 The closing agent contract12 required Pope & Booth to “charge Criteria. the actual cost of the wire transfer of sales proceeds to HUD and include it with settlement charges to the seller ... and deduct the cost from the sales proceeds due HUD.” In addition, Pope & Booth was required to review settlement statements prior to closing and certify that the information and costs they contained were correct. For each of the 45 files reviewed, Pope & Booth charged HUD Testing showed Pope & $25 on the settlement statement to wire the sales proceeds to Booth overcharged for HUD. According to its contract, Pope & Booth was to charge wire transfer fees. HUD its actual costs for wire transfer fees. However, Pope & Booth’s bank only charged $12 for an outgoing wire transfer. Thus, Pope & Booth overcharged HUD $13 per wire transfer for a total overcharge of $585 for the 45 loans reviewed. Management of Pope & Booth asserted that it had information Pope & Booth stated wire that the cost of the wire transfer fee was $25 and that the cost fee used to be $25. decreased without their knowledge. However, Pope & Booth did not provide documentation to support these statements. Further, a brochure from its bank listed the cost of outgoing non-repetitive wire transfer fees at $12. The brochure shows that the stated fees were effective on October 31, 1997. 11 See Introduction and footnote 5 concerning SAMS data errors and error rate. 12 Section B.9.c. Page 11 00-FW-222-1003 Finding 2 Since Pope & Booth overcharged HUD on each of the 45 files Pope & Booth may have reviewed and those files closed anywhere from April 1997 to overcharged on every January 1999, it probably overcharged HUD on every sale it sale it closed. closed. According to SAMS data for the period February 1997 to January 1999, Pope & Booth closed 2,244 properties. Thus, Pope & Booth may have overcharged HUD $28,587 on the 2,199 closings that were not reviewed. No comments were received on Finding 2. Auditee Comments Recommendations We recommend that the Director, Denver Homeownership Center: 2A. Require Pope & Booth to reimburse HUD $585 for ineligible wire transfer fees on the 45 files reviewed. 2B. Determine the number of sales closed by Pope & Booth as part of its closing agent contract with HUD. 2C. Require Pope & Booth to reimburse HUD for any additional ineligible wire transfer fees on any other HUD closings, which could potentially amount to $28,587. 00-FW-222-1003 Page 12 Management Controls In planning and performing our audit, we obtained an understanding of the management controls that were relevant to our audit. Management is responsible for establishing effective management controls. Management controls, in its broadest sense, include the plan of organization, methods, and procedures adopted by management to ensure that its goals are met. Management controls include the processes for planning, organizing, directing, and controlling program operations. They include the systems for measuring, reporting, and monitoring program performance. We determined the following management controls were Relevant Management relevant to our audit objectives: Controls. • Policies and procedures of the sales process at HUD. • Administrative controls to ensure that accurate data is input from the settlement statement into the Single Family Asset Management System. • Policies and procedures of the cash receipts and disbursements controls at the closing agent. • Administrative controls to ensure the closing documents were kept secure. A significant weakness exists if management controls do not give reasonable assurance that resource use is consistent with Significant Weakness. laws, regulations, and policies; that resources are safeguarded against waste, loss, and misuse; and that reliable data are obtained, maintained, and fairly disclosed in reports. Based on our review, we believe the following item is a significant weakness as discussed in this report: Pope & Booth split the title insurance premium based on a percentage of the total amount (Finding 1). Page 13 00-FW-222-1003 Management Controls THIS PAGE LEFT BLANK INTENTIONALLY 00-FW-222-1003 Page 14 Appendix A Schedule of Questioned Costs Type of Questioned Costs Issue Ineligible 1/ Unsupported 2/ 1A Questioned unearned fees $294,461 1C Questioned unearned fees $67,425 2A Ineligible wire transfer fees $585 2C Additional wire transfer fees $28,587 1 Ineligible costs are costs charged to a HUD-financed or insured program or activity that the auditor believes are not allowable by law, contract, or federal, state, or local policies or regulations. 2 Unsupported costs are costs questioned by the auditor because the eligibility cannot be determined at the time of audit. The costs are not supported by adequate documentation or there is a need for a legal or administrative determination on the eligibility of the costs. Unsupported costs require a future decision by HUD program Page 15 00-FW-222-1003 Appendix A officials. This decision, in addition to obtaining supporting documentation, might involve a legal interpretation or clarification of Departmental policies and procedures. THIS PAGE LEFT BLANK INTENTIONALLY 00-FW-222-1003 Page 16 Appendix B Auditee Comments Page 17 00-FW-222-1003 Appendix B 00-FW-222-1003 Page 18 Appendix B Page 19 00-FW-222-1003 Appendix B 00-FW-222-1003 Page 20 Appendix B Page 21 00-FW-222-1003 Appendix B 00-FW-222-1003 Page 22 Appendix B Page 23 00-FW-222-1003 Appendix B 00-FW-222-1003 Page 24 Appendix B Page 25 00-FW-222-1003 Appendix B 00-FW-222-1003 Page 26 Appendix B Page 27 00-FW-222-1003 Appendix C Distribution Secretary's Representative, 6AS Comptroller, 6AF Director, Accounting, 6AAF Director, Single Family Homeownership Center, 8AHH Saul N. Ramirez, Jr., Deputy Secretary, SD (Room 10100) Kevin Simpson, Deputy General Counsel, CB (Room 10214) Jon Cowan, Chief of Staff, S (Room 10000) B. J. Thornberry, Special Asst. to the Deputy Secretary for Project Management, SD (Rm 10100) Joseph Smith, Acting Assistant Secretary for Administration, A (Room 10110) Hal C. DeCell III, A/S for Congressional and Intergovernmental Relations, J (Room 10120) Ginny Terzano, Sr. Advisor to the Secretary, Office of Public Affairs, S (Room 10132) Roger Chiang, Director of Scheduling and Advance, AL (Room 10158) Howard Glaser, Counselor to the Secretary, S (Room 10218) Rhoda Glickman, Deputy Chief of Staff, S (Room 10226) Todd Howe, Deputy Chief of Staff for Operations, S (Room 10226) Jacquie Lawing, Deputy Chief of Staff for Programs & Policy, S (Room 10226) Patricia Enright, Deputy A/S for Public Affairs, W (Room 10222) Joseph Hacala, Special Asst for Inter-Faith Community Outreach, S (Room 10222) Marcella Belt, Executive Officer for Admin Operations and Management, S (Room 10220) Karen Hinton, Sr. Advisor to the Secretary for Pine Ridge Project (Room 10216) Gail W. Laster, General Counsel, C (Room 10214) Armando Falcon, Office of Federal Housing Enterprise Oversight (Room 9100) William Apgar, Assistant Secretary for Housing/FHA, H (Room 9100) Susan Wachter, Office of Policy Development and Research (Room 8100) Cardell Cooper, Assistant Secretary for CPD, D (Room 7100) George S. Anderson, Office of Ginnie Mae, T (Room 6100) Eva Plaza, Assistant Secretary for FHEO, E (Room 5100) V. Stephen Carberry, Chief Procurement Officer, N (Room 5184) Harold Lucas, Assistant Secretary for Public & Indian Housing, P (Room 4100) Gloria R. Parker, Chief Information Officer, Q (Room 8206, L’Enfant Plaza) Frank L. Davis, Director, Office of Dept Operations and Coordination, I (Room 2124) Office of the Chief Financial Officer, F (Room 2202) Edward Kraus, Director, Enforcement Center, V, 200 Portals Bldg., Wash. D.C. 20024 Donald J. LaVoy, Acting Director, REAC, X, 800 Portals Bldg., Wash. D.C. 20024 Ira Peppercorn, Director, Office of MF Asst Restructuring, Y, 4000 Portals Bldg., D.C. 20024 Mary Madden, Assistant Deputy Secretary for Field Policy & Mgmt, SDF (Room 7108) (2) Deputy Chief Financial Officer for Operations, FF (Room 2202) David Gibbons, Director, Office of Budget, FO (Room 3270) Rebecca J. Holtz, Housing Program Officer, HUCI (Room 9146) FTW ALO, 6AF (2) Denver ALO, 8AF Page 28 00-FW-222-1003 Appendix B Housing ALO, HF (Room 9116) (2) Dept. ALO, FM (Room 2206) (2) Acquisitions Librarian, Library, AS (Room 8141) DISTRIBUTION (Cont’d) Director, Hsg. & Comm. Devel. Issues, US GAO, 441 G St. NW, Room 2474 Washington, DC 20548 Attn: Judy England-Joseph Henry A. Waxman, Ranking Member, Committee on Govt Reform, House of Rep., Washington, D.C. 20515 The Honorable Fred Thompson, Chairman, Committee on Govt Affairs, U.S. Senate, Washington, D.C. 20510 The Honorable Joseph Lieberman, Ranking Member, Committee on Govt Affairs, U.S. Senate, Washington, D.C. 20510 Cindy Fogleman, Subcomm. on Gen. Oversight & Invest., Room 212, O'Neill House Ofc. Bldg., Washington, D.C. 20515 The Honorable Dan Burton, Chairman, Committee on Govt Reform, House of Representatives, Washington, D.C. 20515 Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human Resources, B373 Rayburn House Ofc. Bldg., Washington, D.C. 20515 Steve Redburn, Chief, Housing Branch, Office of Management and Budget 725 17th Street, NW, Room 9226, New Exec. Ofc. Bldg., Washington, D.C. 20503 Inspector General, G Pope & Booth, P.C. Alamo Title Company American Title Company Page 29 00-FW-222-1003
Pope and Booth Closing Agent Contract, Austin, Texas
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-05-24.
Below is a raw (and likely hideous) rendition of the original report. (PDF)