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Issue Date
May 31, 2000
Audit Case Number
00-KC-209-1002
TO: Michael A. Williams, Director, Troubled Agency Recovery Center, PB1
FROM: Roger E. Niesen, District Inspector General for Audit, 7AGA
SUBJECT: St. Louis Housing Authority Paul Simon Tenant Association Board
We have completed an audit of the Tenant Association Board for the Paul Simon Elderly Building.
The objective of our audit was to determine if the Board followed proper procedures and fully
accounted for its funds. The audit was conducted in response to a citizen’s complaint.
We determined that the Board’s officers failed to comply with the requirements governing them. They
did not apply sound financial management principles, and as a result could not account for $15,158 in
funds they received during the audit period. They also did not perform other duties assigned to them
and did not meet individual eligibility requirements to serve on the Board. Therefore, the current
officers should be replaced. The St. Louis Housing Authority needs to establish procedures to monitor
the Association, and execute a written agreement with the Tenant Association that clearly outlines the
Association’s and its Board’s responsibilities.
Within 60 days, please provide us, for the recommendations made in this report, a status report on: (1)
the corrective action; (2) the proposed corrective action and date to be completed; or (3) why action is
considered unnecessary. Also, please provide us copies of any correspondence or directives issued
because of the audit.
Should you or your staff have any questions, please contact me at (913) 551-5870.
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Management Memorandum
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Executive Summary
We completed an audit of the Tenant Association Board for the Paul Simon Elderly Building. The
objective of our audit was to determine if the Board followed proper procedures and if it fully
accounted for its funds. The audit was conducted in response to a citizen’s complaint.
We concluded that the Board’s officers failed to comply with the requirements governing them. They
did not apply sound financial management principles, and as a result could not account for $15,158 in
funds they received during the audit period. They also did not perform other duties assigned to them
and did not meet individual eligibility requirements to serve on the Board. Therefore, the current
officers should be replaced. Additionally, the St. Louis Housing Authority needs to establish
procedures to monitor the Association, and execute a written agreement with the Tenant Association
that clearly outlines the Association’s and its Board’s responsibilities.
The Tenant Association Board for the Paul Simon Elderly
The Board Failed To Meet
Building did not comply with the requirements for
Its Requirements
performing their duties or properly conducting themselves.
The officers failed to follow HUD’s requirements, the
Association’s by-laws, the Code of Conduct, or their
dwelling leases. They did not manage their funds, document
their meetings, or meet individual eligibility requirements.
These shortcomings resulted from the Board’s
incompetence. The problems went undetected because the
St. Louis Housing Authority did not have a process to
oversee or monitor the Association. In addition, the
Authority did not enter into a written agreement with the
Tenant Association. A written agreement should have
required the Board to provide an accounting for the
Association’s funds to the Authority. As a result, HUD, the
Authority, and the Paul Simon tenants have no assurance
that $15,158 was expended appropriately.
We recommend that the Director, Troubled Agency
Recommendations
Recovery Center, take administrative action against the
Board members. Additionally, the Director should ensure
the St. Louis Housing Authority withdraws its recognition
of the current Board and takes steps to replace them.
Further, the Housing Authority should execute a written
agreement with the Tenant Association, assist them in
implementing an accounting system with effective controls,
develop and implement procedures to monitor the Tenant
Association, and assess the feasibility of recouping lost
funds in a civil legal action.
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Executive Summary
We held exit conferences and provided our draft finding to
the Finance Director of the St. Louis Housing Authority and
to the officers of the Paul Simon Tenant Association Board
on April 20, 2000. We received written comments from the
Corporate Council for the Housing Authority on May 11,
2000 and from the Tenant Board on May 15, 2000. We
considered the comments in preparing our final report and
incorporated them into the finding as appropriate.
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Management Memorandum i
Executive Summary iii
Introduction 1
Finding
Officers Failed To Properly Account For Funds 3
Management Controls 15
Follow Up On Prior Audits 17
Appendices
A Schedule of Questioned Costs 19
B Auditee Comments 21
C Distribution 49
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Introduction
We received a citizen complaint that the Tenant Association Board for the Paul Simon Elderly
Building had not followed proper procedures nor fully accounted for its funds since the Board
took office in 1995. In response to this complaint, we audited the Association. Paul Simon is a
public housing high-rise located at 1241 Hickory Street in St. Louis, Missouri. The Tenant
Association Board qualifies as a resident council. According to HUD’s regulations, the role of a
resident council is to improve the quality of life and resident satisfaction and participate in self-
help initiatives to enable residents to create a positive living environment for families in public
housing. The current Tenant Association Board consists of four members: a President, Vice
President, and Treasurer, who were elected to the Board in the October 1995 and re-elected in
October 1998, and a Secretary who was elected to the Board for the first time in October 1998.
The original Secretary moved and her replacement passed away. In December 1995 and 1998 the
officers were sworn in as applicable. The Tenant Association Board elected in October 1995
opened a bank account in November 1995; therefore, we began our review at that point.
Our audit objective was to determine if the Paul Simon
Audit Objectives Elderly Building Tenant Association Board followed proper
procedures and fully accounted for its funds.
We performed our on-site work in October 1999 and March
Audit Scope and through April 2000 to determine whether the Tenant
Methodology Association complied with applicable regulations related to
the Board and its financial management. We interviewed
the complainant, the Tenant Association Board, St. Louis
Housing Authority staff, and HUD staff. We analyzed
documents from the Tenant Association, their bank, and
their vending and laundry companies, including bank
statements and check copies, receipts, Board meeting
documents, and correspondence. We also analyzed
corresponding documents at the St. Louis Housing
Authority.
The audit covered the period from November 1995 through
February 2000. We conducted the audit in accordance with
generally accepted government auditing standards.
We provided a copy of our draft finding to the Executive
Director and Finance Director of the St. Louis Housing
Authority. We also provided the draft finding to each
Board officer of the Paul Simon Tenant Association.
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Finding
Officers Failed To Properly Account For Funds
The officers of the Tenant Association Board for the Paul Simon Elderly Building did not comply with
the requirements for performing their duties or properly conducting themselves. The officers did not
follow HUD’s requirements, the Association’s by-laws, the Code of Conduct, or their dwelling leases.
They did not properly manage funds, document their meetings, or meet individual eligibility
requirements. These shortcomings resulted from the Board’s incompetence, and went undetected
because the St. Louis Housing Authority did not have a process to oversee or monitor the Association.
In addition, the Authority did not enter into a written agreement with the Tenant Association. A
written agreement should have required the Board to provide an accounting for the Association’s
funds to the Authority. As a result, the Board was unable to account for expenditures of $15,158,
and HUD, the Authority, and Paul Simon tenants have no assurance the funds were appropriately used.
24 CFR 964, Tenant Participation and Tenant Opportunities in
HUD Regulations
Public Housing, says a resident council may only receive
funding from a housing authority under a written agreement
between the two parties, which obligates the resident council to
account to the housing authority for the use of the funds. The
CFR also dictates that agreements on the use of community
space for resident activities should be put in a written
Memorandum of Understanding. In addition, 24 CFR Part 85
requires all subgrantees to keep source documentation and
maintain effective control and accountability. This part also
requires grantees to monitor the subgrantees to assure
compliance.
24 CFR 964 also requires that tenants serving on the resident
council board meet the requirements described in the by-laws
and comply with their leases. If a resident council fails to
satisfy HUD minimum standards for fair and frequent elections,
or fails to follow its own election procedures as adopted, HUD
shall require the housing authority to withdraw recognition of
the council and withhold resident services funds as well as
funds provided in conjunction with services rendered for
resident participation in public housing.
The by-laws adopted by the Tenant Association in July 1995
Tenant Association require the Treasurer to keep financial records for the board
Requirements and submit written itemized reports to the board at least once a
month. The Secretary is to take minutes and keep records of
all Board meetings. All expenditures over $100 must be
authorized in advance by the Board, all Association funds shall
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Finding
be deposited in the Board’s bank account, and checks are to be
signed by 2 officers. The by-laws provide that recognition shall
be withdrawn from board members when it is proven that the
by-laws, the Code of Conduct, or the dwelling lease have been
violated.
The Code of Conduct applicable to the Tenant Board is the
Tenant Affairs Board Tenant Management Corporation Tenant
Association Code of Conduct revised June 1993. It requires
Board members to accurately reflect the sentiments of the
residents they represent, and be accountable and responsible to
them. The Board members are to conduct monthly meetings
and put the meetings’ highlights in report form. The reports
are to include agendas, minutes, attendance lists, meeting
notification letters, and be submitted to the Board of
Commissioners and the Tenant Affairs Board monthly. The
Code also requires Board members to report correct income at
all times. It says Board members are responsible to make
certain that failure to perform in the above manner by any
Board member will be reported in writing to the Board of
Commissioners and the Tenant Affairs Board. In the event of a
violation by any Board Member of the Code of Conduct, the
St. Louis Housing Authority and the Tenant Affairs Board shall
immediately withdraw recognition of the Board member. The
Code of Conduct stipulates that unless a waiver has been
granted, it is a conflict of interest for a Board member to be an
employee of the St. Louis Housing Authority.
The St. Louis Housing Authority dwelling lease provides for a
"One Strike You’re Out" policy regarding a tenant’s drug use,
and prohibits consumption of alcohol in public areas. The lease
also contains a provision that residents must report in writing
any change in income within 30 days.
Board members did not comply with requirements, or properly
The Board Did Not Meet perform their duties. The members violated HUD’s
Requirements regulations, the Association’s by-laws, their dwelling lease
agreements, and the Code of Conduct.
The Board members did not fully account for the Tenant
Association’s funds, and did not produce monthly board
meeting minutes, resolutions, or treasurer’s reports. The
Board also allowed the Association’s corporate status to lapse,
did not maintain a checking account, did not obtain advance
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Finding
authorization for all expenditures over $100, and did not
deposit all funds in the Tenant Association’s bank account.
The Association received funds from the St. Louis Housing
Funds Were Not Authority. It received a $3 allowance per occupied unit
Accounted For annually, and a one time $1,000 payment for an arts and crafts
program. Further, the Authority provided $210 a month to
cover operation and maintenance of laundry facilities.
The Association also received commission payments directly
from a vending machine company and a laundry company. In
addition, the tenants paid the Association directly for activities
it sponsored for them. The following table shows the total
amount collected and expended during the audit period:
Date Description Amount
November 1995 Initial Bank Deposit $828
December 1995- Add: Income Received $30,140
February 2000
February 2000 Less: Ending Bank Balance $3,089
Total Amount Expended $27,879
The Board provided evidence of expenditures totaling $12,721
between November 1995 and February 2000, leaving $15,158
unaccounted for. More than half the receipts were for
purchases from grocery stores, convenience stores, restaurants
and gas stations. The Board said these were purchases of
prizes and refreshments for bingo games, tenant parties, holiday
meals and gifts, and gas for the vehicle used to do the
shopping. The documentation also included evidence that the
Board spent $4,450 to take tenants on trips to casinos. The
tenants contributed $4,220 toward the trips. The remaining
receipts were for pool table supplies, laundry attendant
stipends, laundry room insurance, and membership fees. The
Board was unable to provide documentation to support the
$15,158 that was not accounted for. Their only explanation
was that they are poor record keepers.
The Authority required the Association to prepare a budget for
the laundry costs; however, there was no budget in the
Association’s files.
The receipts are not sufficient evidence that all items purchased
were used for the purposes described by the Board. For
example, we observed that in a five day period, the Board
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made six trips to the grocery store to make purchases totaling
$289. Included in the receipts were purchases of medicine,
cigarettes, and alcohol. When we asked the Board about these
purchases, the Board indicated the purchases were included by
mistake. However, this statement contradicts the statement the
Board made when they provided us the receipts. They said the
receipts were all purchases for the Paul Simon tenants, and no
personal purchases were made with the Tenant Association’s
funds. We did not include the clearly unacceptable purchases
when we totaled the receipts to arrive at the $12,721 figure
that was supported. The Board is required to be accountable
to the tenants it represents; however, the tenants have no
assurance that $15,158 in funds was expended in furtherance of
the Association’s objectives.
The Board also did not have required documentation in
Meetings Were Not support of monthly meetings. The Board’s own by-laws
Documented require it to maintain documentation such as minutes, agendas,
attendance lists, and meeting notifications. In the 52 month
period reviewed, the Board only had 2 sets of minutes, 14 sign-
in sheets, 1 treasurer’s report, and 3 agenda sheets. The Board
could not adequately explain why the required documentation
was not maintained.
The Board also failed to maintain a checking account, deposit
Basic Business all its funds in a bank, and obtain advance authorization for all
Requirements Were Not purchases over $100. The Board said they were unable to
Followed open a checking account because the bank required corporate
papers. We found the corporation had been administratively
dissolved by the Secretary of State for failure to file required
reports. The Association had a savings account; however, the
Board did not deposit all funds in the bank. Instead, funds
were held in anticipation of upcoming purchases. The Board
said it was not aware advanced approval was required for all
purchases over $100. Good internal controls require an
organization to have a checking account so purchases can be
made using checks in lieu of cash. In addition, good controls
require all cash receipts and disbursements to flow through a
bank account to maintain accountability. If proper controls had
been in place, the Association would not have lost $280 when
its office was burglarized in July 1998.
The Board did not establish: internal controls for effective
The Authority Did Not control and accountability of funds; a checking account; or an
Detect The Problem accounting system to track income and expenses and reconcile
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Finding
its sources and applications of funds. This situation was not
detected by the Authority because it did not have a process to
oversee or review the Association. The Authority’s Resident
Initiatives office’s role was to facilitate and assist the Board as
requested. The Board submitted a budget to the Authority in
1999, but did not expend the Association’s funds in accordance
with the budget. It budgeted for a copy machine and office
supplies, but did not buy the copy machine because it was
unable to purchase one at the allocated price. Instead, the
Board reported that it used the funds allocated for a copy
machine for office supplies. However, none of the receipts
were for office supplies. The Authority did not audit the
expenditures to ensure they were for budgeted items and did
not have a written agreement that should have required the
Tenant Association to account for its expenditures of funds.
The Authority’s Finance Director said she was not aware of the
requirement to have a written agreement with the Association.
Because a written agreement was not developed, the
Authority’s and Association’s responsibilities were not defined.
Our review of the Paul Simon Tenant Association brought
these weaknesses to the attention of the St. Louis Housing
Authority. In April 2000, the Authority began taking steps to
require all tenant associations to submit financial documents for
the prior year, and a current year budget. The Authority said it
plans to review the documents on a sample basis.
In addition to the Board’s overall failure to perform its duties,
Officers Are Not Eligible several Board members violated requirements that should have
To Serve On The Board been grounds for, at a minimum, removal from the Board. One
Board member admitted to smoking drugs in her unit, and
though this statement was witnessed by other Board members
and put in writing, she remained on the Board and was not
evicted. The Board members who witnessed the statement said
they reported the problem to the St. Louis Housing Authority
and expected the Authority to initiate a hearing. However, the
Authority’s Building Manager who should have acted on the
problem left her job, and her replacement was not aware of the
situation until we brought it to her attention.
Several of the Board members held positions for which they
were compensated by the Housing Authority while serving on
the Board. One Board member was a full-time employee of
the Housing Authority while also on the Board. These
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Finding
positions were conflicts of interest according to the Tenant
Association’s own Code of Conduct.
Further, one Board member did not timely report an increase in
income. Proper reporting of income is required by the dwelling
lease. The Association’s Code of Conduct and by-laws require
Board members to be removed if they do not fulfill the terms of
their lease agreement.
In summary, the Paul Simon Tenant Association Board failed
to properly account for the funds entrusted to it, and did not
follow its own or HUD’s requirements. As a result, HUD
lacks assurance the Association met its objectives and benefited
the tenants it was created to help.
Auditee Comments Excerpts from the Paul Simon Tenant Association Board’s
comments on our draft finding follow. Appendix B, page 23,
contains the complete text of the comments.
The Paul Simon Tenant Association Board prepared a list of
expenditures from 1995 through 2000 totaling $25,233. The
Board said they have never used any money for their own
personal use and although they do not have receipts and
records, all funds were used for the residents of Paul Simon.
OIG Evaluation of The list that the Tenant Association submitted was not
Auditee Comments accompanied by supporting documentation. When we
performed our audit, we examined all documentation in the
Tenant Association’s files and found support for expenses that
totaled $12,721. HUD regulations require source
documentation be maintained to support all expenditures.
The Tenant Association Board said no money from the Tenant
Auditee Comments Association was used to provide trips to gambling casinos, and
records were kept of who paid.
OIG Evaluation of We did not question the expenses for the gambling trips since
the difference between the amount collected from tenants and
Auditee Comments
the amount spent was not significant. We included the
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Finding
expenses in our analysis because we also included the
associated income collected from the tenants for the trips.
The Paul Simon Board said the residents played bingo once a
Auditee Comments week until mid 1999 when they began playing twice a week.
Residents were charged 25 cents per board only at the second
session of bingo each week. The Tenant Association
purchased all prizes for bingo and paid a caller $5 per session.
OIG Evaluation of The 25 cent charge per board at the second session of bingo
each week and the caller fees were not disclosed to us during
Auditee Comments
our audit. The Tenant Association did not have records to
support these payments and receipts and they did not provide
any with their comments. Our analysis only included
information that was supported by documentation. HUD
requires Tenant Associations to maintain documentation to
support their income and expenses.
Auditee Comments The Paul Simon Tenant Association Board said attendance
sheets, notices of tenant meetings, and agendas were kept in a
folder in a file cabinet in the office. When the office was
burglarized, the folder came up missing. Also, during their
tenure the Board had 3 secretaries: Two moved and one is
deceased. Some of the records kept by the secretaries were
not retrieved.
OIG Evaluation of The police report filed subsequent to the break-in reported a
Auditee Comments theft of cash. The report quotes the President as saying,
“There was nothing else inside the office or the filing cabinet
disturbed.” When we discussed the lack of records with the
Board during the audit, they said the current Secretary does not
prepare minutes, and they did not think the prior Secretary
prepared them either. The Code of Conduct requires the
Board to submit records to the Board of Commissioners and
the city-wide Tenant Board monthly. We determined the
records were not being submitted.
Auditee Comments The Tenant Association said they were unable to open a
checking account without their corporate papers, so they
opened a savings account to which they deposited funds and
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Finding
then made withdrawals. They attempted to obtain their
corporate papers, but were unable to despite contacts with the
Secretary of State, the Housing Authority, and an attorney.
OIG Evaluation of Our review of records disclosed that the Board had corporate
Auditee Comments status from 1995 until 1998 when its corporate status lapsed
for failure to file an annual report. Their attempts to contact
the Secretary of State’s office did not take place until 1998.
The Board opened a savings account in 1995 but did not
always deposit all funds to its account as required by its by-
laws. The Board did not open a checking account; therefore,
its requirement that checks be signed by 2 officers was not
followed.
Auditee Comments The Tenant Association Board said the Secretary’s drug usage
was reported to the Building Manager and her successor, the
city-wide Tenant Board President, and the Housing Authority.
Action was not taken because concerned parties did not believe
there was adequate proof.
The President also said she was told by the then city-wide
Tenant Board President and the Housing Authority Executive
Director that there was no conflict of interest between her
employment at the Housing Authority and her position on the
Board. Also, the next Executive Director told her it was a
conflict for her to work in the building where she lived, but did
not say there was a problem with her being a member of the
Board. She further said she took advantage of payroll
deduction for her rent while employed by the Housing
Authority, and was never delinquent on her rent. She reported
changes in her pay to the Manager by providing a Personnel
Transaction form.
OIG Evaluation of We agree that the President was under a payroll deduction plan
for her rent. We determined the late payments were not her
Auditee Comments
fault and have deleted the reference to late payments from our
finding. The tenant files contained documentation supporting
the other statements in our report. The Secretary’s file
contained an oral admission of drug usage that was witnessed
by three individuals who signed a document stating such. Drug
usage is a violation of a tenant’s lease. We determined action
was not taken by the Authority due to an oversight resulting
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Finding
from a change in the Building Manager position. The
President’s file contained documentation of some reported
income changes. However, all pay raises given by the Housing
Authority were not reported in the interim between annual
recertifications. The Tenant Association’s by-laws provide that
recognition shall be withdrawn from the Board members when
it has been proven that the by-laws, Code of Conduct, or
dwelling lease have been violated.
The Tenant Association Board said the Housing Authority and
Auditee Comments the city-wide Tenant Board made arrangements for all tenant
elections and also verified eligibility. The Board also said they
realized their mistakes and will open a checking account and
keep proper records given proper guidance.
OIG Evaluation of Although the Board members’ eligibility to serve was verified
prior to their election, the Board members acted contrary to
Auditee Comments their by-laws, Code of Conduct, and dwelling lease while in
office. HUD regulations require Board members to meet the
requirements described in the by-laws and comply with their
leases. Since the Board members acted contrary to these
requirements, they are not eligible to continue to serve on the
Board.
Auditee Comments Excerpts from the St. Louis Housing Authority’s comments on
our draft finding follow. Appendix B, page 21, contains the
complete text of the comments.
The Housing Authority expressed its concern about the
apparent irregularities in the Tenant Association’s conduct.
The Authority said it could withdraw recognition of the entire
current board, forcing the residents of the Paul Simon
Development to elect a new tenant board. The Authority is
currently in the process of developing Memorandums of
Agreement with each tenant board/association, requiring the
tenant groups to submit to the Authority detailed budgets and
documentation regarding expenditures. The Authority will also
require the tenant groups to publish periodic reports to their
respective resident communities regarding budgets and
expenditures.
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Finding
The Authority indicated that the by-laws for the Tenant Affairs
Board of St. Louis, Missouri provide that the resident manager
or management agent from each development serve as a non-
voting member for their respective subordinate local board.
The Authority said it should insist on enforcement of this
provision in the future. This will serve to dismantle the wall
which exists between the tenant associations and the Authority,
as the City Wide Board would serve as a vehicle for
management agents to work with the representatives from the
various tenant associations.
The Housing Authority believed our references to the Code of
Conduct were unclear in some instances. The Authority said
the draft finding inferred it was responsible for enforcement of
the Tenant Association’s Code of Conduct.
OIG Evaluation of The Housing Authority’s planned actions described in its’
response, when implemented, should help correct most of the
Auditee Comments
problems we identified. However, the Authority needs to
replace the Paul Simon Board with individuals who meet
eligibility requirements and are trained to serve in the respective
positions. The Authority needs to perform monitoring to verify
that expenditures are appropriate and supported by the budget.
In addition, the Housing Authority should require the Tenant
Association to implement an accounting system and effective
controls that include the use of a checking account. Further,
we recommend the Housing Authority assess the feasibility to
recoup lost funds in a civil action.
We adjusted our finding to clarify our reference to the Code of
Conduct. We agree it is the Board members’ responsibility to
adhere to their Code of Conduct, including the conflict of
interest clause. However, we believe the written agreement
between the Housing Authority and the Tenant Association
should integrate all the significant requirements for Tenant
Associations, including the Association’s own policies and
procedures. It is the Housing Authority’s responsibility to
enforce the terms of the written agreement.
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Finding
Recommendations We recommend the Director, Troubled Agency Recovery
Center:
1A. Takes appropriate administrative action against the
Association’s Board members.
1B. Ensures the St. Louis Housing Authority takes steps to
replace the Board.
1C. Ensures the Housing Authority executes a written
agreement with the Tenant Association that clearly
outlines the Association’s and its Board’s
responsibilities.
ID. Ensures the Housing Authority requires the Tenant
Association to implement an accounting system with
effective controls. The controls should include the use
of a checking account and maintenance of sufficient
source documentation for all transactions.
1E. Ensures the Housing Authority develops and
implements procedures to monitor the Tenant
Association.
1F. Ensures the Housing Authority assesses the feasibility
to recoup lost funds in a civil action.
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Management Controls
In planning and performing our audit, we considered the management controls of the Paul Simon
Tenant Association in order to determine our auditing procedures, not to provide assurance on the
controls. Management controls 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 control was relevant
Relevant Management
to our audit objectives:
Controls
· Assuring effective financial management.
We assessed the relevant control identified above.
It is a significant weakness if management controls do not
provide reasonable assurance that the process for planning,
organizing, directing, and controlling program operations will
meet an organization’s objectives.
Based on our review, we believe the following item is a
Significant Weaknesses significant weakness:
· The Tenant Association did not implement financial
management controls (see Finding).
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Follow Up On Prior Audits
This is the first audit of the Paul Simon Tenant Association performed by the Office of Inspector
General.
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Appendix A
Schedule Of Questioned Costs
Type of Questioned costs
Issue Ineligible 1/ Unsupported 2/
Funds unaccounted for $15,158.47
1/ Ineligible costs are costs charged to a HUD-financed or HUD-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 charged to a HUD-financed or HUD-insured program or
activity and 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.
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Appendix B
Auditee Comments
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Appendix C
Distribution
Deputy Secretary, SD (Room 10100)
Chief of Staff, S (Room 10000)
Special Assistant to the Deputy Secretary for Project Management, SD (Room 10100)
Acting Assistant Secretary for Administration, S (Room 10110)
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Senior Advisor to the Secretary, Office of Public Affairs, S (Room 10132)
Director of Scheduling and Advance, AL (Room 10158)
Counselor to the Secretary, S (Room 10234)
Deputy Chief of Staff, S (Room 10226)
Deputy Chief of Staff for Operations, S (Room 10226)
Deputy Chief of Staff for Programs and Policy, S (Room 10226)
Deputy Assistant Secretary for Public Affairs, W (Room 10222)
Special Assistant for Inter-Faith Community Outreach, S (Room 10222)
Executive Officer for Administrative Operations and Management, S (Room 10220)
General Counsel, C (Room 10214)
Director, Office of Federal Housing Enterprise Oversight, O
Assistant Secretary for Housing/Federal Housing Commissioner, H (Room 9100)
Office of Policy Development and Research, R (Room 8100)
Assistant Secretary for Community Planning and Development, D (Room 7100)
Government National Mortgage Association, T (Room 6100)
Assistant Secretary for Fair Housing and Equal Opportunity, E ( Room 5100)
Chief Procurement Officer, N (Room 3152)
Assistant Secretary for Public and Indian Housing, P (Room 4100)
Chief Information Officer, Q (Room 3152)
Director, Office of Departmental Operations and Coordination, I (Room 2124)
Chief Financial Officer, F (Room 2202)
Director, Enforcement Center, V (200 Portals Building)
Director, Real Estate Assessment Center, X (1280 Maryland Avenue, SW, Suite 800)
Director, Office of Multifamily Assistance Restructuring, Y (4000 Portals Building)
Secretary’s Representative, Great Plains, 7AS
Senior Community Builder, Iowa State Office
Senior Community Builder, Omaha Area Office
Senior Community Builder, St. Louis
Director, Office of Public Housing, 7APH
Section 8 Financial Management Center, PCFD
St. Louis Public Housing Program Center, Coordinator, 7EPH
Deputy Chief Financial Officer for Finance, FF (Room 2202)
Director, Office of Budget, FO (Room 3270)
Headquarters Audit Liaison Officer, HQC
Deputy Secretary, Special Assistant, SD (Room 10126)
Public and Indian Housing, PF (Room 5156)
Primary Field Audit Liaison Officer, 6AF
Acquisitions Librarian, Library, AS, (Room 8141)
Chairman, Committee on Governmental Affairs, 340 Dirksen Senate Office Building,
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United States Senate, Washington, DC, 20510
Ranking Member, Committee on Governmental Affairs, 706 Hart Senate Office Building,
United States Senate, Washington, DC 20510
Chairman, Committee on Government Reform, 2185 Rayburn Building, House of
Representatives, Washington, DC 20515
Ranking Member, Committee on Government Reform, 2204 Rayburn Building,
House of Representatives, Washington, DC 20515
Subcommittee on Oversight and Investigations, Room 212, O’Neil House Office Building,
Washington, DC 20515
Director, Housing and Community Development Issue Area, United States General Accounting
Office, 441 G Street, NW, Room 2474, Washington, DC 20548
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human
Resources, B373 Rayburn House Office Building, Washington, DC 20515
Chief, Housing Branch, Office of Management & Budget, 725 17th Street, NW, Room 9226,
New Executive Office Building, Washington, DC 20503
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St. Louis Housing Authority Paul Simon Tenant Association Board
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-05-31.
Below is a raw (and likely hideous) rendition of the original report. (PDF)