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 THIS PAGE LEFT BLANK INTENTIONALLY 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. Page iii 00-FW-222-1007 Executive Summary THIS PAGE LEFT BLANK INTENTIONALLY 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 Page v 00-FW-222-1007 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. Page 3 00-FW-222-1007 Introduction THIS PAGE LEFT BLANK INTENTIONALLY 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). Page 13 00-FW-222-1007 Management Controls THIS PAGE LEFT BLANK INTENTIONALLY 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. Page 15 00-FW-222-1007 Appendix A THIS PAGE LEFT BLANK INTENTIONALLY 00-FW-222-1007 Page 16 Appendix B Auditee Comments Page 17 00-FW-222-1007 Appendix B 00-FW-222-1007 Page 18 Appendix B Page 19 00-FW-222-1007 Appendix B 00-FW-222-1007 Page 20 Appendix B Page 21 00-FW-222-1007 Appendix B 00-FW-222-1007 Page 22 Appendix B Page 23 00-FW-222-1007 Appendix B 00-FW-222-1007 Page 24 Appendix B Page 25 00-FW-222-1007 Appendix B 00-FW-222-1007 Page 26 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. 00-FW-222-1007 Page 28
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)