oversight

Shapiro & Ingle, Inc. Closing Agent Contract, Raleigh, North Carolina

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)

     AUDIT REPORT




    SHAPIRO & INGLE, INC.
  CLOSING AGENT CONTRACT

  RALEIGH, NORTH CAROLINA


         00-FW-222-1007

      SEPTEMBER 29, 2000


OFFICE OF AUDIT, SOUTHWEST DISTRICT
        FORT WORTH, TEXAS
                                                                      Issue Date
                                                                              September 29, 2000

                                                                      Audit Case Number
                                                                              00-FW-222-1007




TO:           Charles E. Gardner
              Director
              Single Family Homeownership Center, 4AHH


FROM:         D. Michael Beard
              District Inspector General for Audit, 6AGA

SUBJECT: Shapiro & Ingle, Inc. Closing Agent Contract
         Raleigh, North Carolina


We performed an audit of Shapiro & Ingle, Inc. 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




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00-FW-222-1007           Page ii
Executive Summary
We performed an audit of the law offices of Shapiro & Ingle, Inc. (Shapiro & Ingle), 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, Shapiro & Ingle’s controls were insufficient to ensure
   Shapiro & Ingle                  substantial compliance with its HUD contract.
   insufficiently performed
   its closing agent duties.        Specifically, Shapiro & Ingle did not always:

                                    •   forward documents to HUD timely;
                                    •   deposit the sales proceeds timely;
                                    •   wire sales proceeds timely;
                                    •   collect an extension fee;
                                    •   record the North Carolina deeds timely;
                                    •   maintain sufficient documentation in its closing files;
                                    •   prepare a settlement statement with the correct sales price;
                                    •   calculate the tax proration correctly;
                                    •   exclude home warranty fees for investment properties; and
                                    •   keep within approved closing costs.

                                    Shapiro & Ingle overcharged $200 to perform title searches.
   Shapiro & Ingle received         HUD’s closing agent contract stated that Shapiro & Ingle
   additional $200 per              would clear any routine title problems and resolve any title
   closing to perform title         problems prior to closing as part of the $535 closing fee.
   searches.                        Nonetheless, Shapiro & Ingle billed an additional $200 for title
                                    searches and inappropriately collected up to $138,800 for the
                                    period April 1998 through April 1999.

                                    This report recommends that the Atlanta Homeownership
                                    Center require Shapiro & Ingle to reimburse HUD for ineligible
                                    and questioned costs. We discussed the findings in the report
                                    with Shapiro & Ingle on May 20, 1999. We provided a draft
                                    of this report to Shapiro & Ingle on August 30, 2000. They
                                    provided us with written comments on September 21, 2000,
                                    which are included in this final report.




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Executive Summary




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00-FW-222-1007       Page iv
Table of Contents

Management Memorandum                                             i


Executive Summary                                               iii


Introduction                                                      1


Findings

1    Shapiro & Ingle’s Controls Insufficient to Ensure
     Substantial Compliance with Contract                         5

2    Shapiro & Ingle Overcharged $200 per Closing to
     Perform Title Searches                                            9



Management Controls                                               13



Appendices
     A Schedule of Questioned Costs                          15

     B Auditee Comments                                      17

     C Distribution                                          27




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Table of Contents


Abbreviations
        CFR         Code of Federal Regulations
        HUD         U.S. Department of Housing and Urban Development
        OIG         Office of Inspector General
        SAMS        Single Family Asset Management System




00-FW-222-1007                    Page vi
Introduction
               The firm of Shapiro & Kreisman contracted with the
 Background    Department of Housing and Urban Development (HUD) on
               June 1, 1994, to conduct closings of HUD’s single family
               properties. The contractor changed its name on December 8,
               1997, to Shapiro & Ingle, L.L.P. (Shapiro & Ingle). Shapiro &
               Ingle had two closing agent contracts with HUD. These closing
               agent contracts were based on a geographical division of
               counties in the State of North Carolina. We audited closings
               under contract number C419S9406001 handled in Shapiro &
               Ingle’s Raleigh office. We did not review the other contract
               (C419S906002). Shapiro & Ingle had offices in Raleigh and
               Charlotte, North Carolina. Shapiro & Ingle’s Raleigh closing
               agent contract with HUD expired October 31, 1999.

               The contract was 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)
               closing occurred by date stipulated by the sales contract; (2)
               prompt and accurate payments of all closing costs were made;
               (3) net proceeds from each sale were wire transferred to
               HUD’s account with the United States Treasury on the day of
               closing or the next banking day; and (4) complete and accurate
               closing packages were submitted to HUD within 4 working
               days.

               To conduct a closing, Shapiro & Ingle’s contract required it as
               closing agent to:

               •   Establish individual property file and maintained the file 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 sales contract.
               •   Review title information and clear routine title issues (e.g.,
                   past due taxes, water bills, and liens) to convey clear title on
                   all properties.
               •   Complete all documents necessary to provide a complete
                   closing, including the HUD-1, deed, note, and mortgage, or
                   deed of trust, if applicable.
               •   Resolve any title problems.
               •   Explain all closing papers and documents to the purchaser.

                            Page 1                                 00-FW-222-1007
Introduction


                           •   Accept only cash, certified check, or money order.
                           •   Deposit the sales proceeds, initiate the wire transfer, and
                               obtain the bank’s wire transfer confirmation on day of
                               closing or next banking day.
                           •   Record the deed.

                           According to information obtained from HUD’s Single Family
                           Acquired Asset Management System (SAMS), Shapiro &
                           Ingle closed 694 properties from April 1, 1998, through
                           April 1, 1999. For each closing performed, Shapiro & Ingle
                           received $535 from HUD.

                           Our audit objective was to determine whether management
   Audit Objective         controls are adequate to ensure the prevention of fraud, waste,
                           and abuse.

                           We obtained background information by:

   Scope and Methodology   •   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 objective, we:

                           •   Examined the contract and HUD’s Property Disposition
                               Handbook.
                           •   Obtained from SAMS a listing of closings performed by
                               Shapiro & Ingle, from which we selected our sample of
                               closings for audit testing.
                           •   Interviewed HUD and Shapiro & Ingle staff regarding the
                               closing process.
                           •   Obtained an understanding of Shapiro & Ingle’s closing and
                               accounting processes.
                           •   Obtained and reviewed 78 closing files while on-site at
                               Shapiro & Ingle. We originally selected files from SAMS
                               using a random number generator. However, the SAMS
                               data erroneously included 50 sales of Shapiro & Ingle’s
                               Charlotte Office. We replaced those files with a judgmental
                               sample made on-site in the Raleigh Office. We tested


00-FW-222-1007                  Page 2
                                                                            Introduction


                            closing files for the following contractual and HUD
                            handbook requirements:

                        •   The property closed timely and, if the property did not
                            close timely, we documented the number of days late;
                        •   The closing files contained an extension request and
                            approval, if applicable;
                        •   The correct extension fee was collected, if applicable;
                        •   Only allowable expenses were paid;
                        •   The sales proceeds were not deposited timely;
                        •   The correct amount was wired timely;
                        •   The correct amount was collected for the taxing authority;
                        •   Clear title was issued;
                        •   The title insurance premium was not split;
                        •   A North Carolina deed was prepared;
                        •   The North Carolina deed was recorded timely;
                        •   The documents were forwarded to HUD timely;
                        •   The selling amount on the sales contract and the settlement
                            statement were identical;
                        •   Closing costs for the buyer were identical on both pages of
                            the HUD-1; and
                        •   The correct amount of extension fees were on the HUD-1,
                            if applicable.

                        We conducted the audit at Shapiro & Ingle’s Offices in Raleigh,
                        North Carolina, in May 1999 in accordance with generally
Audit Period and Site
                        accepted government auditing standards. The audit covered
                        closings from April 1, 1998, to April 1, 1999.




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Introduction




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00-FW-222-1007     Page 4
                                                                                            Finding 1


    Shapiro & Ingle’s Controls Insufficient to
   Ensure Substantial Compliance with Contract
Overall, Shapiro & Ingle’s controls were insufficient to ensure substantial compliance with the
terms of the closing agent contract. Specifically in 20 of the 78 (25 percent) closing files
reviewed, Shapiro & Ingle did not: (1) forward documents to HUD timely; (2) deposit the
sales proceeds timely; (3) wire sales proceeds timely; and (4) collect an extension fee.
Additionally, Shapiro & Ingle did not: (1) maintain sufficient documentation in its closing files;
(2) record the North Carolina deeds timely; (3) report the correct sales price on the settlement
statement; (4) calculate taxes correctly; (5) exclude home warranty fees for investment
properties; and (6) keep within approved closing costs.




                                     In 15 of the 78 (19 percent) of the closing files reviewed, the
   Documents not forwarded           post closing documents were not sent to HUD until the 4th day
   to HUD timely.                    after closing. The contract (Section C-2. l) stated that the
                                     closing agent was to send the final closing package so that HUD
                                     received it within 4 working days.

                                     In 8 of the 78 (10 percent) closing files reviewed, the sale
   Sales proceeds not                proceeds were deposited from 1 to 6 days late. The closing
   deposited timely.                 agent contract required Shapiro & Ingle to deposit the sales
                                     proceeds on the day of closing or the next banking day.

                                     In 11 of the 78 (14 percent) closing files reviewed, Shapiro &
   Sales proceeds not wired          Ingle wired the sales proceeds from 1 to 6 days late. Section
   timely.                           C-1. 3. of the closing agent contract states that Shapiro & Ingle
                                     was to wire the sales proceeds on the day of closing or the next
                                     banking day.

                                     In one instance, HUD did not receive the extension fee it was
   Extension fee not paid.           due because the purchaser did not pay the extension fee.
                                     Section C-2 v. of the closing agent contract stated that the
                                     closing agent was to administer extension fees. HUD charged
                                     $20 per day for each day a closing was beyond the date agreed
                                     to on the sales contract. In this instance, the closing was 14
                                     days late. Thus, because Shapiro & Ingle was not diligent in its
                                     review of the closing documents, HUD did not receive $280
                                     that it should have.


                                                  Page 5                                00-FW-222-1007
Finding 1


                               Of the 78 closing files reviewed, 38 (49 percent) did not
   Recorded North Carolina     contain a recorded North Carolina deed. The recorded deeds
   deed not in file.           were sent directly to the purchasers. Thus, Shapiro & Ingle did
                               not receive a copy to maintain in the file.

                               Of the 78 files reviewed, 8 (10 percent) lacked documentation
   Files lack documentation.   that a North Carolina deed was prepared, 2 (2 percent) wire
                               confirmations, and 1 (1 percent) lacked extension requests.
                               Section C-2. 2. i.1 of the closing agent contract stated that the
                               closing agent was to complete all documents necessary to
                               provide a complete closing.

                               In one instance, the sales amount was changed on the sales
   Incorrect sales amount      contract making it hard to read. As a result, an incorrect
   reported to HUD.            amount was recorded on the HUD-1. Section C-2. 2. i.1 of
                               the closing agent contract stated that the closing agent was to
                               complete all documents necessary to provide a complete
                               closing. Further, prudent business practice dictates that the
                               correct sales price be used when preparing the HUD-1. As a
                               result, HUD received $1,000 less in sales proceeds than it was
                               entitled. However, during its post closing review, HUD found
                               the error and the purchaser paid the correct price.

                               In 41 of the 78 (52 percent) of the closing files reviewed,
   Tax proration calculated    Shapiro & Ingle incorrectly prorated the taxes. The computer
   improperly.                 program used by Shapiro & Ingle did not include the day of
                               sale as required by the contract. Instead the computer program
                               only calculated the tax proration through the day before the
                               sale. Thus, the tax proration on the settlement statement was
                               incorrect by 1 day’s proration. Shapiro & Ingle agreed with
                               this finding and agreed to take steps to correct this.

                               HUD paid for two home warranty fees when the purchaser was
   HUD charged investor’s      an investor. HUD allows a home warranty fee above the
   home warranty fee.          approved closing costs, but only if the purchaser is to be an
                               owner-occupant. In two instances (FHA case numbers 381-
                               273602 and 381-486089), HUD paid for the home warranty
                               fee when the purchasers were investors because Shapiro &
                               Ingle was not diligent in its review of the closing documents.
                               Thus, HUD paid $750 that it should not have paid.




00-FW-222-1007                      Page 6
                                                                                  Finding 1


                         In one instance (FHA case number 381-370818), HUD paid
 HUD approved closing    $25 more in attorney fees than was reasonable and customary
 cost amount exceeded.   for the area. Specifically, in the North Carolina area the
                         reasonable and customary fee for outside attorney services was
                         $200. On the HUD-1 the outside attorney fee was $225.
                         Section B-5 of the closing agent contract stated that the closing
                         agent shall pay only those closing costs determined to be
                         reasonable and customary for the local real estate market area.
                         Because the amount for the outside attorney fee was above the
                         local real estate market area’s reasonable and customary fee,
                         the amount of the fee that was above the reasonable and
                         customary fee should have been paid for by the purchaser.




                         Shapiro & Ingle responded that it maintained a level of
 Auditee Comments        performance that met or exceeded “substantial compliance”
                         with its contractual obligations. Further, it responded that site
                         reviews performed by the field office indicated that Shapiro &
                         Ingle substantially complied with its closing agent contract.
                         Further, whenever problems or issues were identified the
                         matters were always promptly addressed by Shapiro & Ingle.




                         We disagree with Shapiro & Ingle’s comments that it was in
OIG Evaluation of        substantial compliance and addressed issues promptly. As
Comments                 noted in Finding 1, our sample of 78 selected files contained an
                         error rate of 25 percent with contract term compliance.
                         Further, HUD’s on-site reviews show a history of problems.
                         For example, the review of August 3, 1998, noted that Shapiro
                         & Ingle had late submissions of closing packages, errors on the
                         HUD-1s, and late wires. Again on September 24, 1998,
                         according to the Atlanta Homeownership Center, Shapiro &
                         Ingle had late submissions of closing packages. Further, in May
                         1999, the Atlanta Homeownership Center wrote to Shapiro &
                         Ingle that the number of HUD-1 errors and the late wires
                         indicated a need for continued concern and attention. Because
                         Shapiro & Ingle did not address concerns regarding errors and
                         late wires for over 1 year, Shapiro & Ingle’s management
                         controls were insufficient to ensure substantial compliance with
                         its closing agent contract.


                                    Page 7                                   00-FW-222-1007
Finding 1



   Recommendations   We recommend the Director, Atlanta Single Family
                     Homeownership Center to:

                     1A. Require Shapiro & Ingle to reimburse HUD $750 for the
                         home warranty fees.

                     1B. Require Shapiro & Ingle to reimburse HUD for the $25
                         of outside attorney fees that were not reasonable and
                         customary for the area and thus, in violation of the
                         contract terms.

                     Further recommendations are moot because Shapiro & Ingle’s
                     contract expired October 31, 1999.




00-FW-222-1007           Page 8
                                                                                                                 Finding 2



                 Shapiro & Ingle Overcharged $200
                per Closing to Perform Title Searches
Shapiro & Ingle overcharged HUD and/or the purchaser an additional $200 to perform title
searches. Shapiro & Ingle charged this amount in addition to its $535 in closing fees. HUD’s
contract required Shapiro & Ingle to clear any routine title problems and resolve any title
problems prior to closing. Thus, the contract already required title searches. Because
Shapiro & Ingle closed 694 properties for the period April 1998 through April 1999, it could
have been overpaid up to $138,8001 for performing work it was already under contract to
perform.




                                                Section B-2 (b) 4 of the contract stated that the contractor may
     Criteria.                                  not collect from any party, any fees associated with closings
                                                conducted under the contract and beyond the unit price.
                                                Additionally, Section C-2 2.c of the contract required that the
                                                contractor clear routine title problems. Further, Section C-2.
                                                2.i of the contract stated that the closing agent is to resolve any
                                                and all title problems prior to closing.

                                                Shapiro & Ingle’s closing agent contract stated that it may not
     Shapiro & Ingle’s                          collect from any party, any fees associated with closings
     contract inclusive of all                  conducted under the contract beyond the unit price set forth in
     closing costs.                             the contract. The contract amount agreed upon by HUD and
                                                Shapiro & Ingle was $5352. However, HUD, the purchaser, or
                                                both, may have paid an additional $200 per closing to Shapiro
                                                & Ingle for title searches. The $200 per closing was deducted
                                                from HUD’s share of the proceeds and shown on the HUD-1
                                                or included as part of the purchaser’s closing costs. Per the
                                                contract, title searches are part of obtaining the information
                                                needed to clear title problems.




1
    $200 X 694 closings under the contract = $138,800
2
    The base contract amount in 1994 was for $475. This amount increased annually with each contract option exercised by HUD
    and by 1999 increased to $535.

                                                                Page 9                                      00-FW-222-1007
Finding 2



                                In discussions with HUD, only the foreclosed properties that
   $200 on HUD-1 no             did not contain title documents would be allowed the $200 in
   different from contractual   additional title search fees. Additionally, HUD believed that the
   required title search.       $200 might be for a more in-depth title search on behalf of the
                                purchaser when the mortgage lender required a lender’s policy.
                                However, Shapiro & Ingle stated that there was no difference
                                between a title search and what it charged $200 for on the
                                HUD-1. HUD allowed Shapiro & Ingle to pay $200 in outside
                                attorney fees as a reasonable and customary fee for legal
                                services performed. However, if the $200 was not used by an
                                outside attorney, then Shapiro & Ingle charged HUD the $200
                                for title search services. Thus, Shapiro & Ingle charged the
                                additional $200 for closings performed and could have received
                                $138,800 for the 694 closings performed in its Raleigh Office
                                from April 1998 through April 1999.

                                The following table illustrates 14 closings for which Shapiro &
                                Ingle charged the additional $200 title search fee.

                                 FHA Case No.        Buyer Paid      HUD Paid
                                  381-351953           $200
                                  381-273602            200
                                  381-490399                            $200
                                  381-429625             200
                                  381-488632             200
                                  381-478441                             200
                                  381-470040             188              12
                                  381-470503             200
                                  381-332220             139              61
                                  381-469510                             200
                                  381-466253             200
                                  381-486089             200
                                  381-398796             200
                                  381-430907                            200
                                    Totals            $1,937           $873           $2,800




                                Shapiro & Ingle denies that it overcharged HUD. They state
   Auditee Comments
                                the $200 fee was a reasonable charge for their professional
                                service of issuing a title opinion. Shapiro & Ingle state the

00-FW-222-1007                       Page 10
                                                                              Finding 2


                    minutes of a 1991 pre-bid conference allowed closing agents to
                    charge the purchasers when a policy of title insurance was
                    issued “through the rendering of an Attorney’s Title Opinion.”




                    We disagree with Shapiro & Ingle’s comments. First, the pre-
OIG Evaluation of   bid minutes do not discuss attorney’s title opinions. Second,
Comments            during the audit Shapiro & Ingle stated that the $200 fee was
                    for a title search that included a preliminary title opinion and a
                    final title opinion to the title underwriter. Shapiro & Ingle further
                    stated that there was no difference in the work they performed
                    for the $200 title underwriter’s required “Attorney’s Title
                    Opinion” and the work they performed for HUD’s “title
                    rundown certificate” required in section J, attachment I of the
                    closing agent contract. Although the closing agent contract
                    allowed Shapiro & Ingle to charge for title work performed
                    outside of its contract, the $200 charge, according to Sharpio
                    & Ingle, is for typing a letter. As noted in the finding, HUD
                    allowed a $200 fee for title searches performed by third-party
                    attorneys when third parties required such a search. In these
                    instances, HUD essentially pays for two title searches: one for
                    the third party done by a third-party’s attorney and the second
                    for HUD performed by the closing agent. When third-party
                    attorneys were not involved in the closing, Sharpiro & Ingle
                    collected the $200 from closing costs.




                              Page 11                                    00-FW-222-1007
Finding 2


                                    We recommend the Director, Atlanta Homeownership Center
    Recommendations                 to:


                                    2A. Require Shapiro & Ingle to reimburse HUD and/or the
                                        buyers for the $2,800 in title search overcharges.

                                    2B. Determine the number of sales closed by Shapiro & Ingle
                                        as part of its closing agent contract with HUD.

                                    2C. Require Shapiro & Ingle to reimburse HUD for any
                                        amounts that Shapiro & Ingle received in excess title
                                        search fees, which could potentially amount to
                                        $136,0003.




3
    $138,800 - $2,800 = $136,000.

00-FW-222-1007                           Page 12
Management Controls

In planning and performing our audit, we obtained an understanding of the management
controls relevant to our audit. Management is responsible for establishing effective
management controls. Management controls, in the 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.
                                   •   The closing agent contract’s terms and conditions.
                                   •   HUD’s Single Family Property Disposition Handbook sales
                                       procedures.
                                   •   Policies and procedures of the sales proceeds receipts and
                                       disbursements controls at the closing agent.

                                   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 the report.

                                   Shapiro & Ingle did not adhere to the closing agent contract’s
                                   terms and conditions (Finding 1).




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Management Controls




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00-FW-222-1007          Page 14
                                                                                                                Appendix A


Schedule of Questioned Costs


                                                                         Type of Questioned Costs
           Issue                                                        Ineligible 1/  Unsupported 2/


1A Ineligible home warranty fees                                           $ 750

1B Ineligible outside attorney fees                                            25

2A Ineligible title search overcharges                                       2,800

2C Potential excess title search fees                                                          $136,000 3/

           Totals                                                          $3,575              $136,000




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 officials. This decision, in addition to
    obtaining supporting documentation, might involve a legal interpretation or clarification of Departmental policies and
    procedures.
3
    This is an estimated amount based on 694 closings performed in the Raleigh Office from April 1998 through April 1999 less
    those shown in this report.



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                              Appendix B

Auditee Comments




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Appendix B




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           Appendix B




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           Appendix B




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                                                                                      Appendix C

Distribution
Secretary's Representative, 6AS
Comptroller, 6AF
Director, Accounting, 6AAF
Director, Single Family Homeownership Center, 4AHH
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)
Atlanta ALO, 4AF

                                                Page 27                             00-FW-222-1007
Appendix C



                                  DISTRIBUTION (Cont’d)

Housing ALO, HF (Room 9116) (2)
Dept. ALO, FM (Room 2206) (2)
Acquisitions Librarian, Library, AS (Room 8141)
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
Shapiro & Ingle, Inc.




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