AUDIT REPORT
MUSKEGON HOUSING COMMISSION
LOW RENT PUBLIC HOUSING, SECTION 8 AND
SINGLE ROOM OCCUPANCY PROGRAMS
MUSKEGON, MICHIGAN
01-CH-202-1002
NOVEMBER 29, 2000
OFFICE OF AUDIT, MIDWEST
CHICAGO, ILLINOIS
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Issue Date
November 29, 2000
Audit Case Number
01-CH-202-1002
TO: Michael A. Williams, Director, Troubled Agency Recovery Center North, PB1
/signed/
FROM: Dale L. Chouteau, District Inspector General for Audit, 5AGA
SUBJECT: Muskegon Housing Commission
Audit of Low Rent Public Housing, Section 8 and Single Room Occupancy
Programs
Muskegon, Michigan
We completed an audit of Muskegon Housing Commission’s financial operations, which included its
Low Rent Public Housing, Section 8 and Single Room Occupancy Programs. The audit was conducted
in response to a request from the Director, Troubled Agency Recovery Center North, and the Director,
Office of Public Housing, Michigan State Office. The objectives of the audit were to determine:
whether the Muskegon Housing Commission improperly transferred funds between its programs, and
complied with the Annual Contributions Contract and other applicable HUD regulations.
We found that the Housing Commission transferred $836,893 between housing programs without HUD
authorization. In addition, we estimated that $298,970 of Section 8 subsidy funds were improperly
used by the Housing Commission to pay operating expenses of the Low Rent Public Housing Program.
We also found that the Housing Commission: improperly pledged 14 Low Rent Public Housing
Program homes and proceeds from the sales of those homes as collateral for a loan; paid $51,233 of
Public Housing funds to double insure its employees; and could not provide documentation to support
expenses of $12,989 charged to its credit card accounts.
Within 60 days, please provide us, for each recommendation made in this report, a status report on: (1)
the corrective action taken; (2) the proposed corrective action and the date to be completed; or (3)
why action is 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 (312) 353-7832, or Ronald Huritz,
Assistant District Inspector General, at (312) 353-6236, Extension 2675.
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Management Memorandum
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Executive Summary
We completed an audit of Muskegon Housing Commission’s financial operations, which included its
Low Rent Public Housing, Section 8 and Single Room Occupancy Programs. The audit was conducted
in response to a request from the Director, Troubled Agency Recovery Center North, and the Director,
Office of Public Housing, Michigan State Office. Our audit objectives were to determine: whether the
Muskegon Housing Commission improperly transferred funds between its programs, and complied with
the Annual Contributions Contract and other applicable HUD regulations.
We found that the Housing Commission transferred $836,893 between housing programs without HUD
authorization. In addition, we estimated that $298,970 of Section 8 subsidy funds were improperly used
by the Housing Commission to pay operating expenses of the Low Rent Public Housing Program. The
Housing Commission pledged 14 Low Rent Public Housing Program homes and proceeds from the
sales of those homes as collateral for a loan in violation of HUD regulations. The Housing Commission
did not cease these activities after being instructed by HUD to do so.
We also found that the Housing Commission used $51,233 of Public Housing funds to pay employee
health insurance premiums for the same coverage the employees were also receiving from the City of
Muskegon. The Housing Commission could not provide supporting documentation for $12,989 in
expenses charged to its credit card accounts.
As of August 1, 2000, HUD was in the process of instituting a Limited Denial of Participation action
against the Executive Director. On the same date, the City of Muskegon Board of Housing
Commissioners terminated his employment.
Unauthorized Transfers of As of April 2000, the Housing Commission had transferred
Public Housing and Section 8 $836,893 from its Public Housing Program to fund the Single
Funds Room Occupancy Program and operating expenses of the
Family Investment Center. In addition, a combination of
administrative fees and subsidy funds totaling $665,000 were
transferred from the Section 8 account to the Low Rent Public
Housing account. Of the latter amount, we estimated that
$298,970 of Section 8 subsidy funds were improperly used to
pay operating expenses of the Low Rent Public Housing
Program. The Housing Commission had been making such
transfers in varying amounts since at least October 1995. The
Housing Commission did not comply with HUD instructions to
discontinue the transfers. Transferring funds between housing
programs is not permitted by the Annual Contributions
Contract. As a result, sufficient funds were not available to
satisfy Public Housing Program needs.
Unauthorized Use Of Public The Housing Commission obtained two loans, one from First of
Housing Assets America Bank for $480,000 secured by the Family Investment
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Executive Summary
Center building, and a second from the Michigan Housing Trust
Fund for $140,000. To secure the second loan, the City of
Muskegon, acting on behalf of the Housing Commission,
executed a blanket mortgage covering 14 Low Rent Public
Housing (Turnkey III) homes, and pledged future income
expected to be received from the sale of the homes. Part 2,
Section 313 of the Annual Contributions Contract prohibits the
Housing Commission from pledging income from the sale of
these properties without approval from HUD. The 14 homes
pledged as collateral were covered by a Declaration of Trust
agreement. The Housing Commission sold nine of the Turnkey
III homes, but did not release the Declaration of Trust for five
of the homes. Consequently, HUD regulations were violated,
and purchasers of the five homes did not receive clear title to
their properties.
Double Health Insurance The Housing Commission obtained Blue Cross/Blue Shield
Premiums health insurance coverage for all Housing Commission
employees, including the Executive Director, who were already
covered under the City of Muskegon’s health plan. Since
November 1998, the Housing Commission has paid at least
$15,379 in premiums to the City for coverage, and $47,989 to
Blue Cross/Blue Shield for the same coverage. HUD instructed
the Housing Commission on November 30, 1999, to stop
paying the second premium for employees covered under the
City of Muskegon’s health plan, but it continued to pay the
premiums. As a result, the funds, which could have been used
for Public Housing Program needs, were misspent on
unnecessary insurance.
Unsupported And Ineligible The Housing Commission had no supporting documentation for
Charges $12,989 in charges to its credit card accounts, including:
$2,199 for airline tickets; $1,485 for restaurant and retail
purchases; and $9,305 for hardware and miscellaneous items.
In addition, we noted expenses totaling $2,040 that were
charged by the Executive Director for personal items, such as
clothing and medicine. Management did not consistently follow
its procurement policy to ensure that employees returned
necessary support for credit card expenses. As a result,
provisions of OMB Circular A-87 and the Housing
Commission’s policy were violated, and HUD housing funds
may have been misspent on unallowable items.
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Executive Summary
Recommendations We recommended that the Director, Troubled Agency
Recovery Center, ensures that the Muskegon Housing
Commission sells the Family Investment Center building to pay
off any outstanding mortgages, implements a plan to repay the
Public Housing Program for funds transferred to other
programs; and strengthens controls to ensure compliance with
HUD regulations and its own procurement policy.
Auditee Response To Draft Housing Commission interim management indicated in its
Findings response to our Draft Findings that its positions on all issues
discussed in the audit were under review. Management began
evaluating the effectiveness of its policies and procedures only a
short time before we conducted the exit conference and could
not give us specific details as to how the issues would be
resolved.
We presented our draft findings to the Housing Commission
during the course of the audit. We held an exit conference with
the Interim Director on October 6, 2000. The Housing
Commission provided comments to our draft findings, which are
included in their entirety as an Appendix to this report.
Excerpts of the comments are included with each finding.
Where appropriate, changes were made to the draft findings to
reflect additional information or clarification resulting from the
exit conference and auditee comments.
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01-CH-202-1002 Page vi
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Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 Muskegon Housing Commission Transferred Funds Between
Housing Programs Without HUD Authorization 3
2 Low Rent Homes Pledged to Secure Loans in Violation
Of HUD Regulations 9
3 Public Housing Funds Used To Double Insure Five Employees 13
4 Unsupported and Ineligible Expenses Charged to
Housing Commission Credit Cards 17
Management Controls 21
Follow Up On Prior Audits 23
Appendices
A Schedule of Questioned Costs 25
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B Auditee Comments 27
C Distribution 33
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Introduction
The Muskegon Housing Commission was established in 1965 under the laws of the State of Michigan.
The Housing Commission was created to provide and manage decent, safe and sanitary housing for
low-income residents according to programs approved by the City of Muskegon’s Board of Housing
Commissioners. The Board consists of five unpaid members who formulate and direct the Housing
Commission’s policies. The Chairman of the Board is Boyd Arthur. The Executive Director is
responsible for the day-to-day operations. As of August 1, 2000, HUD was in the process of instituting
a Limited Denial of Participation action against the former Executive Director. On the same date, the
Board of Housing Commissioners terminated his employment. The Housing Commission’s Interim
Executive Director is Janet Williams. The Housing Commission’s official records are maintained at 1823
Commerce Street, Muskegon, Michigan.
In January 1999, Muskegon Housing Commission was declared by HUD to be a “troubled” housing
authority and was placed under supervision of the Troubled Agency Recovery Center in Cleveland,
Ohio.
Of 196 total units managed by the Housing Commission, 160 units are designated for elderly and
disabled individuals, including 36 units in the Single Room Occupancy Program. The Housing
Commission also manages six multi-family apartment units in three duplex structures, and 30 units in the
Homeownership Program. There are currently 164 Section 8 recipients. In Fiscal Years 1996 and
1999, HUD awarded the Housing Commission $15,000 and $261,843, respectively, for
Comprehensive Improvement Assistance Program grants.
A legislative change in 1996 permitted Michigan housing authorities to seek a separation from the
municipal bodies that previously controlled their operations. The State’s Housing Facilities Act
Amendment now allows a housing commission to own property in its own name and act as a separate
legal entity when entering into contracts. Since the legislative change, the Muskegon Housing
Commission had been attempting to separate from the City to control its operations. The separation
became effective August 16, 2000.
Audit Objectives The audit objectives were to determine whether the Muskegon
Housing Commission improperly transferred funds between its
programs, and complied with the Annual Contributions
Contract and other applicable HUD regulations.
Audit Scope and Methodology To achieve our objectives, we interviewed Troubled Agency
Recovery Center and other HUD staff regarding the
Commission’s operations. We reviewed Recovery Center
records, including: monitoring review reports; correspondence
with the Housing Commission; and subsidy disbursements. We
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interviewed Housing Commission staff and reviewed Housing
Commission records on-site, such as: monthly financial
statements; the procurement policy; City of Muskegon’s travel
policy and reimbursement records; the Housing Commission’s
bank account statements and cancelled checks for the audit
period; monthly credit card billing statements; and various
accounts payable invoices.
The audit, which was conducted in accordance with generally
accepted government auditing standards, covered the period
November 1, 1995, through June 30, 2000. We performed the
audit between December 1, 1999, and July 21, 2000.
We provided a copy of this report to the Commission’s Interim
Executive Director.
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Finding 1
Muskegon Housing Commission Transferred
Funds Between Housing Programs Without
HUD Authorization
The Muskegon Housing Commission transferred $836,893 from its Public Housing Program to finance
operations of its Single Room Occupancy Program and the Family Investment Center. In addition, a
combination of Section 8 administrative fees and subsidy funds totaling $665,000 were transferred from
the Section 8 account to the Low Rent Public Housing Program to pay operating expenses. Of this
latter amount, we estimated that $298,970 of the transferred funds represented an inappropriate use of
Section 8 subsidy funds. Such transfers and uses were not permitted by the Annual Contributions
Contract and other HUD regulations. The transfers took place over a four-year period beginning in
October 1995. The Housing Commission continued this activity despite being instructed by HUD to
cease the transfers. As a result, HUD requirements were violated, and sufficient funds may not have
been available to operate Muskegon Housing Commission’s Public Housing and Section 8 Programs.
Background Public housing authorities in the State of Michigan operate
under the Housing Facilities Act (Public Act 18) enacted in
1933. This act gave cities and other municipal bodies in the
State the authority to create, construct, finance and operate
housing commissions. In March 1996, the City of Muskegon
purchased a commercial building located at 1823 Commerce
Street in Muskegon, Michigan to be used as the Muskegon
Housing Commission’s administrative offices. A major portion
of the building now serves as the Housing Commission’s
headquarters. An adjacent portion was reconfigured to
accommodate 36 living units under HUD’s Single Room
Occupancy Program.
In September 1996, the Housing Commission was awarded
$403,520 in low income housing tax credits by the Michigan
State Housing Development Authority. In order to benefit from
the tax credits, the awardee must be an entity other than a
municipal body. Therefore, prior to receiving the credits, the
Housing Commission created a non-profit entity, the Family
Investment Center Limited Housing Development Corporation
(hereafter, “Family Investment Center”). In November 1996,
the Family Investment Center Limited Dividend Housing
Association Limited Partnership was formed. The Partnership
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Finding 1
is comprised of the Corporation as the general partner, and the
Executive Director of the Housing Commission as the limited
partner.
Through a series of transfers, ownership of the Commerce
Street building was transferred by quit claim deed from the City
of Muskegon to the Family Investment Center Limited Dividend
Housing Association Limited Partnership. The Housing
Commission pays a monthly rental of $887 to the Family
Investment Center for the use of its office space.
HUD Requirements Article IV, Section 401, Part D, of the Annual Contributions
Contract allows the housing commission to “...withdraw monies
from the General Fund only for 1) the payment of development
costs, 2) the payment of operating expenditures, 3) the
purchase of investment securities as approved by the
Government, 4) other purposes specified in [the Annual
Contributions Contract], and 5) other purposes specifically
approved by the Government”.
Article IV, Section 422 of the Annual Contributions Contract
states the housing commission “...shall not, without the approval
of the Government, obtain, from any source whatsoever, any
loan in connection with the Projects other than those specifically
provided for under this Contract”.
HUD Handbook 7420.7, Section 8-2d(3)(a), Unauthorized
Transfers, states that transfers of amounts from the Operating
Reserve to another non-Section 8 program account does not
constitute use of the Operating Reserve for other housing
purposes, even if the account to which funds would be
transferred is designated for housing purposes. Operating
Reserve funds must be expended to be considered used for
other housing purposes.
24 CFR Part 982, Section 982.152(v)(3), states that
administrative fees may only be used to cover costs incurred to
perform housing authority administrative responsibilities for the
program in accordance with HUD regulations and requirements.
24 CFR Part 982, Section 982.155(b)(1), states that if funds in
the administrative fee reserve are not needed to cover housing
authority administrative expenses, the housing authority may use
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Finding 2
these funds for other housing purposes permitted by State and
local law. However, HUD may prohibit use of the funds for
certain purposes.
As of April 2000, the Housing Commission had transferred
Unauthorized Transfers Of
$836,893 from its Public Housing Program to fund the Single
Public Housing And Section 8
Room Occupancy Program and operating expenses of the
Funds
Family Investment Center.
In addition, a combination of Section 8 administrative fees and
subsidy funds totaling $665,000 were transferred from the
Section 8 account to the Low Rent Public Housing Program.
These transferred funds were used by the Housing Commission
to pay operating expenses of the Low Rent Public Housing
Program. Regulation 24 CFR Part 982.155(b)(1) allows funds
in the administrative fee reserve to be used for other housing
purposes permitted by State and local law, but HUD may
prohibit use of the funds for certain purposes. We were unable
to find any documentation indicating that HUD imposed a
restriction on the Housing Commission’s use of the
administrative fees. Because the administrative fees and subsidy
funds were commingled, we could not determine what portion
of the Section 8 transfers related to administrative fees.
Between fiscal year 1996 and fiscal year 2000, the Housing
Commission received $366,030 in administrative fees for the
Section 8 voucher and certificate programs. Using a
conservative approach, we estimated that $298,970 ($665,000
minus $366,030) of the Section 8 fund transfers represented an
inappropriate use of Section 8 subsidy funds.
The Housing Commission had been making such transfers in
varying amounts since at least October 1995. Transferring
funds between housing programs is not permitted by the Annual
Contributions Contract and HUD Handbook 7420.7. In
March 1999, the Troubled Agency Recovery Center became
aware of the situation and instructed the Housing Commission in
writing to cease the transfers. However, the Housing
Commission did not comply with this instruction and continued
to make periodic transfers from the two programs.
Family Investment Center Since October 1995, the Family Investment Center has not
Could Not Meet Expenses been able to generate enough revenue on its own because it has
failed to lease available office space in the Commerce Street
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Finding 1
building to other businesses or services. It has also been
unsuccessful at selling the low income housing tax credits.
Because the cost to rehabilitate the Single Room Occupancy
units and recurring operating costs exceeded the revenue
generated by the Family Investment Center, the Housing
Commission paid most of the Family Investment Center
expenses directly out of Public Housing Funds. This depleted
the Public Housing Program’s operating budget, creating the
need to transfer $665,000 in administrative fees and subsidy
funds from Section 8 to the Public Housing General Fund. The
effect of this activity was that the Housing Commission became
delinquent in paying its bills.
The Executive Director of the Housing Commission informed us
that the main deterrent to bringing businesses or services into
the building was the lack of a separate point of entry. Because
of its layout, employees and patrons of such businesses or
services would have to enter the building either through the
Housing Commission’s front office or an adjoining back alley.
A further deterrent is that businesses cannot effectively advertise
outside the building because of limited visibility from the alley
and the Housing Commission entrance.
Housing Commission Could The tax credits were awarded to the Housing Commission to
Not Sell Tax Credits fund the rehabilitation of the Single Room Occupancy units. At
the time of the award, Internal Revenue Service regulations did
not allow municipal entities to sell the tax credits. As indicated
earlier, prior to the 1996 amendment to the Housing Facilities
Act, the Housing Commission could not own property in its
own name, leading to the formation of the Corporation and
Partnership. The City of Muskegon controlled Housing
Commission operations and personnel, and at some point,
replaced the original independent Board of Directors of the
Corporation with its own appointees. Thus, the Housing
Commission failed to sell the tax credits to investors because of
the City’s ties to the Corporation’s Board of Directors.
As a result of the unauthorized transfers of funds and the
inability to sell the tax credits, two critical housing programs
were denied adequate funding.
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Finding 2
Excerpts from the auditee’s comments on our draft finding
Auditee Comments follow. Appendix B contains the complete text of the
comments:
Consultation with current on-site personnel, the Troubled
Agency Recovery Center and assigned consultants are under
review. Muskegon Housing Authority will continue its efforts to
seek recovery and/or remedy for the Public Housing Program
affected by the financial transactions identified. Strategies to
replenish funds at a sufficient level to safeguard and restore trust
in the financial and operational management systems are under
consideration.
OIG Evaluation of Discussion at the exit conference of the various options
Auditee Comments available to Housing Commission management demonstrated
their commitment to resolving the longstanding issues.
Recommendations We recommend that the Director, Troubled Agency Recovery
Center, in conjunction with the Director, Office of Public
Housing, Michigan State Office, assures that the Muskegon
Housing Commission:
1A. Repays $298,970 to the Section 8 Program for subsidy
funds that were inappropriately used by the Housing
Authority to pay operating expenses of the Low Rent
Public Housing Program;
1B. Sells the Family Investment Center building to pay off
any outstanding mortgages, and applies the balance of
the sale proceeds to repay the Public Housing Program
$836,893 that were improperly transferred to the Single
Room Occupancy Program;
1C. Sells any excess or unused assets it may have, such as
vehicles or real estate, to repay the programs;
1D. Establishes procedures and controls to preclude
prohibited inter-program fund transfers in the future.
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Finding 2
Low Rent Homes Pledged To Secure Loans In
Violation of HUD Regulations
The Muskegon Housing Commission pledged 14 Low Rent Public Housing Program homes, and
proceeds from the future sale of the homes, as collateral for a $140,000 loan obtained from the
Michigan Housing Trust Fund. The purpose of the loan was to purchase and remodel the Family
Investment Center building used for the Single Room Occupancy Program. As of May 2000, the
Housing Commission had reduced the loan balance by $90,000 resulting from the sale of nine homes. A
Declaration of Trust in favor of HUD was not released for five of the property sales. This arrangement
was not approved by HUD, and violates the Annual Contributions Contract, Administrative Use Plan
and Declaration of Trust restrictions.
Background In March 1996, the Muskegon Housing Commission sought to
purchase and renovate a commercial building to serve as the
site of its Single Room Occupancy Program and the Housing
Commission’s administrative offices.
The City of Muskegon would not issue its full faith and credit to
enable the Housing Commission to acquire one loan of sufficient
amount to purchase the site, which was to become known as
the Family Investment Center. Therefore, the Housing
Commission obtained two loans, one from First of America
Bank for $480,000 secured by the Family Investment Center
building, and a second from the Michigan Housing Trust Fund
for $140,000. To secure the second loan, the City of
Muskegon, acting on behalf of the Housing Commission,
executed a blanket mortgage covering the 14 homes, and
pledged future income expected to be received from the sale of
the homes, known as “Turnkey III” properties. The homes are
part of the Housing Commission’s inventory of Low Rent Public
Housing Program homeownership properties.
The Turnkey III Homeownership Opportunity Program is a
lease-purchase approach to help eligible low-income families
buy homes in certain public housing projects developed
specifically for homeownership.
HUD Requirements The HUD Declaration of Trust requires the Housing
Commission to retain title to public housing property and to
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“...refrain from transferring, conveying, assigning, leasing,
mortgaging, pledging, or otherwise encumbering or
permitting...any transfer, conveyance, assignment, lease
mortgage, pledge or other encumbrance of said property…”.
Part 2, Section 313 of the Annual Contributions Contract
prohibits the Housing Commission from pledging income from
low rent public housing without approval from HUD.
Declaration Of Trust Not In November 1993, the Housing Commission signed a
Released Declaration of Trust giving HUD a secured interest in the
properties listed in the agreement. The 14 homes pledged as
collateral for the Michigan Housing Trust Fund Loan were
covered by the Declaration of Trust agreement. The Housing
Commission sold nine of the Turnkey III homes between 1997
and 1999. Of the nine, only four had a Partial Release of
Declaration of Trust executed. The other five homes are still
under the Declaration of Trust, according to a HUD attorney in
the Michigan State Office. The title insurance company that
closed the home sales apparently overlooked the Declaration of
Trust that was recorded by the Muskegon County Registrar of
Deeds on November 1, 1993.
In May 1999, HUD was aware that the Trust Fund had
accepted the homes as collateral encumbered by the
Declaration of Trust agreement. HUD was also aware that the
Housing Commission did not initiate requests for Partial
Releases for the five homes sold between 1997 and 1999. The
Director of Public Housing for HUD’s Michigan State Office
told us that she discussed this matter verbally with the Housing
Commission Executive Director, but that no reference was
made to the problem in HUD’s monitoring report dated June
18, 1999. She indicated further that HUD was waiting for the
OIG to issue this Audit Report before taking corrective action.
The Housing Commission is presently working with the title
company to remove the clouded title from those homes.
When a property is sold that is encumbered by a Declaration of
Trust, it is the Housing Commission’s responsibility to initiate a
request to HUD to execute a Partial Release of Declaration of
Trust. The Housing Commission did not have controls in place
to ensure that Partial Releases were consistently obtained from
HUD prior to the sales, and that the title insurance company
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Finding 2
was notified of the Declaration of Trust at the time title searches
were conducted. As a result, the Declaration of Trust was
violated, and purchasers of the homes will not receive clear title
to their properties until all Partial Releases have been executed.
Unauthorized Use Of Public As of May 2000, the Housing Commission had reduced the
Housing Assets Michigan Housing Trust Fund loan balance by $90,000 through
the sale of nine of the Turnkey III homes. This amount was a
portion of the total obligation owed to the Public Housing
Program by the Family Investment Center. As discussed in
Finding 1, the Family Investment Center was obligated to the
Public Housing Program in the amount of $836,893 as of April
2000. This situation resulted from the Housing Commission’s
unauthorized interprogram transfers of funds from the Public
Housing Program to the Single Room Occupancy Program.
In addition to the monthly mortgage payments of $359, the
Housing Commission was responsible for paying the Michigan
Housing Trust Fund the lesser of $10,000 or the net sale
proceeds from the sale of each mortgaged home. This action is
not permitted by the Declaration of Trust or the Annual
Contributions Contract. The City of Muskegon Housing
Commissioners told us they were not aware they were violating
HUD regulations by pledging the 14 homes and a portion of the
sales proceeds.
In a letter dated March 3, 1999, HUD instructed the Housing
Commission that the use of sales proceeds in this manner was
prohibited. The Housing Commission had been granted waivers
by HUD in 1992 allowing it to retain and use the proceeds of
Turnkey III home sales to provide housing assistance for low-
income families. The waivers did not allow the sales proceeds
to be used for any other purpose. The City of Muskegon
Housing Commissioners voted in March 1999 to amend the
Administrative Use Plan for the Turnkey III homes to allow the
Housing Commission to use the sales proceeds for any program
related to low-income families. However, the Housing
Commission Executive Director failed to submit a formal
request to HUD to amend the Administrative Use Plan.
As a result, the Housing Commission violated the Annual
Contributions Contract and Administrative Use Plan.
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Finding 2
The center of this issue appears to rest with financial projections
Auditee Comments for the purchase and renovation of the property located at 1823
Commerce, which is the site of the Single Room Occupancy
program as well as the Housing Commission administrative
offices. A full analysis of all existing systems is currently
underway, which includes the impact of the conceptual and
financial projections originally calculated, versus project viability
for the SRO project. Real property transactions and
procedures for sales of all homes in the portfolio are under
development.
The Interim Director and Housing Commission staff indicated to
OIG Evaluation of
us at the exit conference that they were considering terminating
Auditee Comments
the Single Room Occupancy Program, an action that would be
necessary if the Commerce Street building was sold. The
Housing Commission’s administrative offices would then be
relocated to Hartford Terrace, one of the high-rise properties
operated by the Housing Commission.
Recommendations We recommend that the Director, Troubled Agency Recovery
Center, in conjunction with the Director, Office of Public
Housing, Michigan State Office, assures that the Muskegon
Housing Commission:
2A. Takes action to sell the Family Investment Center
building and payoff any outstanding mortgages on the
building;
2B. After the mortgages are retired, applies the remaining
proceeds to pay down the Family Investment Center
debt owed to the Public Housing Program;
2C. Immediately ceases using proceeds from Turnkey III
home sales to pay the Michigan Housing Trust Fund
loan; and
2D. Establishes a control procedure to notify HUD when
Partial Releases of Declaration of Trust should be
executed at the time homes are sold.
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Finding 3
Public Housing Funds Used To Double Insure
Five Employees
The Muskegon Housing Commission used $51,233 of Public Housing funds to pay insurance premiums
to private insurance companies for the same types of coverage it was paying the City of Muskegon to
provide. The Housing Commission paid twice for health, life and disability benefits for five of its
employees who were also provided the same coverage by the City of Muskegon. In addition, duplicate
premiums were paid for the Executive Director’s health insurance coverage. As a result, Public Housing
funds that could have been used for program needs were misspent on unnecessary insurance.
OMB Requirement OMB Circular A-87, Attachment A, Paragraph C.1 states that
to be allowable under Federal awards, a cost must be
necessary and reasonable for proper and efficient performance
and administration of Federal awards.
Double Health Insurance The Housing Commission obtained Blue Cross/Blue Shield
Premiums health insurance coverage for all Housing Commission
employees, including the Executive Director, who were already
covered under the City of Muskegon’s health plan. Since
November 1998, the Housing Commission has paid at least
$15,379 in premiums to the City for coverage, and $47,989 to
Blue Cross/Blue Shield for the same coverage. This double
coverage has existed since the process of separating the
Housing Commission from the City of Muskegon began. (See
Background section of Finding 1.) The Housing Commission
informed us that the private insurance was purchased to avoid
any lapse of coverage when the separation took place;
however, the separation has been delayed for several years due
to a number of unresolved legal issues.
HUD instructed the Housing Commission on November 30,
1999, to stop paying the second premium for employees
covered under the City of Muskegon’s health plan, but it
continued to pay the premiums.
Duplicate Health Insurance In addition to the double coverage cited above, the Housing
Premiums Paid For Executive Commission has paid duplicate health insurance premiums to
Director Blue Cross/Blue Shield for the Executive Director since
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Finding 3
November 1998. The duplicate premiums total $3,775 (this
amount is included in the $47,989).
The Housing Commission began paying the duplicate premiums
because Blue Cross/Blue Shield required a minimum of ten
employees to be enrolled in the plan to qualify for group health
coverage. However, we noted that double paying for the
Executive Director actually resulted in a total of 11 subscribers
to the plan. We could not determine why the Executive Director
was listed twice on premium invoices under slightly different
Social Security numbers. The Executive Director offered no
explanation for the duplicate coverage, but did indicate that only
one of the two Social Security numbers was valid.
The City of Muskegon’s Board of Housing Commissioners was
aware of the duplicate payments for the Executive Director;
however, the Board took no action to stop the duplicate
payments. The effect of these duplicate payments for private
coverage, in combination with the double coverage from the
private carrier and the City, was that the Executive Director
was triple-insured for the same type of insurance. (As of
August 1, 2000, HUD was in the process of instituting a
Limited Denial of Participation action against the Executive
Director. On the same date, the City of Muskegon Board of
Housing Commissioners terminated his employment.)
Double Life And Disability The Housing Commission paid double life and disability
Insurance Payments insurance premiums for five employees who were already
covered by another life and disability plan offered through the
City of Muskegon. Since December 1998, the Housing
Commission has paid a least $1,514 to the City of Muskegon
for this insurance, and paid $3,244 to the Business Men’s
Assurance Company of America for the same employees.
The reason for this double coverage is the same as that for the
double health insurance. The Executive Director attempted to
avoid any lapse of coverage when the Housing Commission
separated from the City.
The double coverage and duplicate payments for health, life and
disability insurance resulted in $51,233 of Public Housing funds
being misspent on unnecessary insurance.
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Finding 3
These funds could have been put to better use to support
Public Housing program needs.
This particular issue is under analysis regarding the relationship
Auditee Comments to the separation/autonomy agreement with the City of
Muskegon and its ultimate impact on protection of the current
and future personnel.
OIG Evaluation of Discussion at the exit conference addressed the possibility of
Auditee Comments recovering some portion of the overpaid premiums directly from
the insurance carrier. We consider this a viable option that
should be pursued by Housing Commission management.
Recommendations We recommend that the Director, Troubled Agency Recovery
Center North, assures that the Muskegon Housing Commission:
3A. Establishes a repayment plan to repay the Public
Housing Program $51,233 for the double insurance
payments paid to the private insurance companies;
3B. Cancels the former Executive Director’s insurance
coverage with both the City of Muskegon and the
private carrier.
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Finding 4
Unsupported and Ineligible Expenses Charged to
Housing Commission Credit Cards
The Muskegon Housing Commission could not provide documentation to support $12,989 in expenses
charged to its two Visa credit card accounts. The unsupported expenses were for restaurant and retail
purchases and airline tickets. In addition, expenses totaling $2,040 were charged by the Executive
Director for personal items. The Housing Commission did not consistently follow its procurement policy
that required all expenses to be documented. As a result, provisions of OMB Circular A-87 and the
Housing Commission’s policy were violated, and HUD housing funds may have been misspent on
unallowable items.
OMB Regulation OMB Circular A-87, Section C (1a) states that allowable costs
And Housing Commission must be necessary and reasonable for proper and efficient
Policy performance and administration of Federal awards.
OMB Circular A-87, Section C (1j) states that costs must be
adequately documented to be allowable.
Muskegon Housing Commission’s Procurement Policy and
Procedures Amendment, Paragraph 4, requires all procurement
of equipment, material, supplies and repairs or service to be
documented.
Unsupported And Ineligible The Housing Commission maintained two separate credit card
Charges accounts. One card is used primarily for expenses associated
with out-of-town conferences attended by Housing Commission
personnel; the other card is used for local purchases in
Muskegon. Both cards bear the names “Muskegon Housing
Commission” and that of the Executive Director. Visa would
not issue a corporate card without including an individual’s
name.
We reviewed 58 monthly billing statements for both of the
Housing Commission’s Visa credit card accounts. Our review
covered all charges to each account for the period September
1997 through January 2000. The Housing Commission had no
supporting documentation for $12,989 in charges, including:
$2,199 for airline tickets; $1,485 for restaurant and retail
purchases; and $9,305 for hardware and miscellaneous items.
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Finding 4
In addition, we noted expenses totaling $2,040 that were
charged by the Executive Director for personal items, such as
clothing and medicine. We determined that the Housing
Commission paid all credit card charges from either Public
Housing or Section 8 program funds. These unsupported and
ineligible charges are not allowed by OMB Circular A-87 or
the Housing Commission’s Procurement Policy and Procedures
Amendment.
As of August 1, 2000, HUD was in the process of instituting a
Limited Denial of Participation action against the Executive
Director. On the same date, the City of Muskegon Board of
Housing Commissioners terminated his employment.
Housing Commission Staff The Assistant Director informed us that the Housing
Were Aware Of Commission staff were aware of the policy requiring receipts to
Documentation Requirement be submitted for all credit card purchases, but they sometimes
failed to do so. The Executive Director admitted that he did not
always return receipts after making credit card purchases. He
said he was unaware that personal items could not be charged
to the accounts. Although he indicated that he reimbursed the
Housing Commission for his personal purchases, we could not
independently verify his statement. Management did not
consistently follow-up to ensure that employees returned
necessary support for credit card expenses.
We noted that controls over the credit cards were weak.
Credit Cards Not Properly Although a lockable container was generally used to store the
Controlled cards when not in use, on two occasions we observed that one
card was in the Executive Director’s possession although he
had no need for the card at the time. In addition, the Housing
Commission did not maintain a usage log for recording to whom
the cards were issued and for what purpose. Improperly
safeguarding the credit cards exposes a Housing Commission
asset to possible misuse.
The Housing Commission’s failure to obtain receipts from its
employees to support all credit card purchases violated OMB
Circular A-87 and its own procurement policy. As a result,
HUD housing funds may have been misspent on non-program
uses.
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Finding 4
Analyses are underway to establish a coherent and consistent
Auditee Comments
policy addressing credit card issuance and usage. This effort
will be coordinated with the review and re-development of all
existing and required policies and procedures. It is the current
consensus that a clear and consistent procurement policy will
provide the necessary guidance for all areas affected by
stronger internal controls within the organization .
OIG Evaluation of The Housing Commission’s interim management indicated
Auditee Comments during the exit conference that it recognized the urgent need to
adopt and enforce a policy controlling this Housing Commission
asset.
Recommendations We recommend that the Director, Troubled Agency Recovery
Center North, assures that the Muskegon Housing Commission:
4A. Directs the credit card issuer to remove the former
Executive Director’s name from both accounts, and
reissues new cards in the names of the Housing
Commission and the successor Executive Director;
4B. Obtains receipts from its employees to support the
$12,989 in undocumented charges, to the extent
possible;
4C. Enforces its Procurement Policy and Procedures
Amendment for future charges made to the credit cards;
and
4D. Establishes a usage log to strengthen controls over
credit card activity.
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Management Controls
In planning and performing our audit, we considered the management controls of the Muskegon
Housing Commission 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.
Relevant Management Controls We determined the following management controls were
relevant to our audit objectives:
· Program Operations - Policies and procedures that
management has implemented to reasonably ensure that a
program meets its objectives.
· Validity and Reliability of Data - Policies and procedures
that management has implemented to reasonably ensure that
valid and reliable data are obtained, maintained, and fairly
disclosed in reports.
· Compliance with Laws and Regulations - Policies and
procedures that management has implemented to
reasonably ensure that resource use is consistent with laws
and regulations.
· Safeguarding Resources - Policies and procedures that
management has implemented to reasonably ensure that
resources are safeguarded against waste, loss, and misuse.
We assessed all of the relevant controls 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.
Significant Weaknesses Based on our review, we believe the following items are
significant weaknesses:
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Management Controls
· Program Operations
The Housing Commission’s controls did not ensure that
adequate oversight was exercised by the Commission’s Board
of Directors and the City of Muskegon’s Housing
Commissioners. In discussions with the Housing Commission’s
Chairman of the Board, we learned that a number of actions
taken by the former Executive Director were not discussed with
the Chairman or other directors, particularly the pledging of
Turnkey III homes and proceeds of the home sales to secure a
loan. (See Finding 2).
· Compliance with Laws and Regulations
The Housing Commission’s former Executive Director did not
comply with instructions received from HUD on various
occasions. Specifically, HUD and the Troubled Agency
Recovery Center directed the Housing Commission to
discontinue making transfers of funds from its Low Rent Public
Housing and Section 8 Programs to its Single Room
Occupancy Program. In addition, the Housing Commission
ignored HUD’s instructions to discontinue paying double
insurance premiums to obtain coverage for its employees. (See
Findings 1 and 3).
· Safeguarding Resources
Controls over the Housing Commission’s credit cards were
weak. It did not ensure that only authorized persons used the
cards for official Housing Commission business, and did not
enforce its procurement policy requiring receipts to be
submitted for all expenses charged to the credit cards. (See
Finding 4).
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Follow Up On Prior Audits
The Office of Inspector General issued an audit report on March 30, 1994, pertaining to the Muskegon
Housing Commission’s Low Income Housing and Turnkey III Homeownership Programs (Report 94-
CH-202-1020). The audit objectives were to determine whether the Housing Commission
administered its public housing and homeownership activities in an efficient, effective and economical
manner, and complied with the terms of its Annual Contributions Contract and other applicable laws.
Seven recommendations resulted from this audit. All recommendations were closed by Management
Decisions during 1994, and posted to the Departmental Automated Audit Management System.
None of the issues identified in the 1994 Audit Report were repeated in this report.
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Appendix A
Schedule of Questioned Costs
Type of Questioned Costs
Recommendation
Number Ineligible 1/ Unsupported 2/
1A $298,970
1B 836,893
3A $51,233
4B _______ 12,989
Total $1,135,863 $64,222
1/ Ineligible costs are questioned costs charged to a HUD 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 A
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Appendix B
Auditee Comments
September 25, 2000
Mr. Ronald F. Huritz, Asst. Director
U.S. Dept. of Housing & Urban Development
Office of Inspector General for Audit, Midwest
77 West Jackson Blvd., Suite 2646
Chicago, IL 60604-3507
Dear Mr. Huritz:
This is in response to your correspondence of September 15, 2000 which contained Draft
Audit Findings resulting from your review of the Muskegon Housing Commission (MHC). The purpose
of this reply is to acknowledge receipt of the summary of issues, with subsequent responsive comment
as appropriate, with indication of agreement/disagreement of each area identified, and followed by
preliminary/alternative options, to the extent possible at this time. Attached, please find MHC
response(s) to the Draft Findings, in the order presented.
Understanding that final conclusions have not been made at this time, MHC would like to clarify
that management position(s) at all levels are currently under review, with the intent to establish more
functional/accountable means and methods for effective internal/management controls for an agency
suited to accommodate the needs of the populace, i.e., program beneficiaries.
That said, MHC would like to extend a cooperative stance in addressing the issues at hand.
We expect additional exchanges of information in the future; please remain in contact. Thanking you in
advance for a prompt and courteous reply.
Sincerely,
MUSKEGON HOUSING COMMISSION
Janet Williams, Interim Director
Encl.
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Appendix C
OIG/DRAFT & MHC/RESPONSE
MUSKEGON HOUSING COMMISSION TRANSFERRED $1,501,893
BETWEEN HOUSING PROGRAMS WITHOUT HUD AUTHORIZATION
OIG/DRAFT FINDING: MHC transferred $836,893 from its Public Housing Program to
finance operations of its Single Room Occupancy Program. Transfers of $665,000 in administrative
fees and Section 8 subsidy funds made from the Section 8 account to the General Fund account were
used to pay operating expenses. Such transfers and uses are not permitted by the Annual Contributions
Contract and other HUD regulations. The transfers took place over a four-year period beginning in
October 1995. The Housing Commission continued this activity despite being instructed by HUD to
cease the transfers. As a result, HUD requirements were violated, and sufficient funds may not have
been made available to operate Muskegon Housing Commission’s Public Housing and Section 8
Programs.
OIG/RECOMMENDATION assures that MHC:
1A. Sells the Family Investment Center building to pay off any outstanding mortgages, and applies
the balance of the sale proceeds to repay the Public Housing and Section 8 programs; and
1B. Sells any excess or unused assets it may have, such as vehicles or real estate, to repay the
programs.
MHC/Initial Response:
Consultation with current on-site personnel, HUD/TARC, and TARC-assigned consultants are under
review, including the chronological and accuracy of information available at this time regarding the
identified issues. These tasks involve extreme internal management review, coordinated with financial
analyses of all current systems, which may ultimately impact alternative solutions to the draft
recommendations to date. Certainly the sale of excess and/or unused assets may be viable
considerations; however, MHC would like a coordinated approach to better address the issues,
including the equation of past revenues generated by tenants into the financial overview, as well as
projections for the future. It is our belief that short- and long-term solutions may be influenced by more
detailed information at some point in the future. In the meantime, MHC will continue its efforts to seek
recovery and/or remedy for the Public Housing Program, affected by the financial transactions identified.
Additionally, strategies to replenish funds at a sufficient level to safeguard and restore trust in the
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Finding 4
financial and operational management systems are under consideration, with consultation(s) with all
interested parties.
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Appendix C
LOW RENT HOMES PLEDGED TO SECURE LOANS IN VIOLATION OF HUD
REGULATIONS
OIG/DRAFT FINDING: The Muskegon Housing Commission pledged 14 Low Rent Public Housing
Program homes, and proceeds from the future sale of the homes, as collateral for a $140,000 loan
obtained from the Michigan Housing trust Fund. The purpose of the loan was to purchase and remodel
the Family Investment Center building used for the Singe Room occupancy Program. As of May 2000,
the Housing Commission had reduced the loan balance by $90,000 resulting from the sale of nine
homes. A Declaration of trust in favor of HUD was not released for five of the property sales. This
arrangement was not approved by HUD, and violates the Annual Contributions Contract,
Administrative Use Plan and Declaration of Trust restrictions.
OIG/RECOMMENDATION assures that MHC:
2A. Takes action to sell the Family Investment Center building and payoff any outstanding
mortgages on the building;
2B. After the mortgages are retired, applies the remaining proceeds to pay down the Family
Investment Center debt owed to the Public Housing Program;
2C. Immediately ceases using proceeds from Turnkey III home sales to pay the Michigan Housing
Trust Fund loan; and
2D. Establishes a control procedure to notify HUD when partial Releases of Declaration of Trust
should be executed at the time homes are sold.
MHC/Initial Response:
As above, a review of the historical context and accuracy of information available at this time regarding
this issue is underway. Also as above, the center of this issue appears to rest with financial projections
for the purchase and renovation of the property located at 1823 Commerce, which is the site of the
Single Room Occupancy (SRO) program, as well as the MHC administrative offices. A full analysis of
all existing systems is currently underway, which includes the impact of the conceptual and financial
projections originally calculated, versus project viability for the SRO project. Included in the analysis is
the applicability of remaining debt to the Public Housing Program, possible re-use of current functions of
the (Commerce) facility, the status of remaining units under the Turnkey III home sales and the
projected revenue outcome with the Michigan Housing Trust fund balance. Real property transactions
and/or procedures for sales of all homes in the MHC portfolio are under development, in conjunction
with standard real estate property transactions, which include full disclosure on behalf of MHC upon
transfer of ownership.
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Finding 4
PUBLIC HOUSING FUNDS USED TO DOUBLE INSURE
FIVE EMPLOYEES
OIG/DRAFT FINDING: The Muskegon Housing Commission used $51,233 of Public Housing
funds to pay insurance premiums to private insurance companies for the same types of coverage it was
paying the City of Muskegon to provide. The Housing Commission paid twice for health, life and
disability benefits for five of its employees who were also provided the same coverage by the City of
Muskegon. In addition, duplicate premiums were paid for the Executive Director’s health insurance
coverage. As a result, Public Housing funds that could have been used for program needs were
misspent on unnecessary insurance.
OIG/RECOMMENDATION assures that MHC:
3A. Establishes a repayment plan to repay the Public Housing Program $51,233 for the double
insurance payments paid to the private insurance companies;
3B. Cancels the Executive Director’s insurance coverage with both the City of Muskegon and the
private carrier.
MHC/Initial Response:
This particular issue is under analysis regarding the relationship to the ‘separation/autonomy’ agreement
with the City of Muskegon and its ultimate impact on development of viable protection of the current
and future personnel compliment. The financial review of this issue is underway including this amount,
also for consideration in the equation for restoration to the Public Housing Program.
It is important to note at this time that the autonomy/separation issue has been resolved, effective August
16, 2000 and the impact upon on all real property assets, personnel compliment and associated benefit
calculations will also be determined by the following areas in consideration for a viable and recoverable
Housing Authority:
1. Governance – MHC and/or Family Investment Center;
2. Viability of PHA Programs vs. SRO;
3. Current and potential appraised valuation of all assets, including equipment, real
property; and
4. A well-defined and coordinated strategy to replenish/restore the appearance of
misappropriation of Public Housing and other funding sources, therefore restoring a
level of public trust by affected client populations.
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Appendix C
UNSUPPORTED AND INELIGIBLE EXPENSES CHARGED TO HOUSING
COMMISSION CREDIT CARDS
The Muskegon Housing Commission could not provide documentation to support $12, 989 in expenses
charged to its two Visa credit card accounts. The unsupported expenses were for restaurant and retail
purchases and airline tickets. In addition, expenses totaling $2,040 were charged by the Executive
Director for personal items. The Housing Commission did not consistently follow its procurement policy
that required all expenses to be documented. As a result, provisions of OMB Circular A-87 and the
Housing Commission’s policy were violated, and HUD housing funds may have been misspent on
unallowable items.
OIG/RECOMMENDATION assures that MHC:
4A. Directs the credit card issuer to remove the former Executive Director’s name from both
accounts, and reissues new cards in the names of the Housing Commission and the successor
Executive Director;
4B. Obtains receipts from its employees to support the undocumented charges to the extent
possible;
4C. Enforces its Procurement Policy and Procedures Amendment for future charges made to the
credit cards; and
4D. Establishes a usage log to strengthen controls over credit card activity.
MHC/Initial Response:
As with all other financial issues, analyses are underway to establish a coherent and consistent policy
addressing credit card issuance and usage. This effort will be coordinated with the review and re-
development of all existing and required policies and procedures, with a particular focus toward
regulatory and OMB compliance objectives. It is the current consensus that a clear and consistent
procurement policy will provide the necessary guidance for all areas affected by stronger internal
controls within the organization.
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Appendix B
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Appendix C
Distribution
Secretary
Deputy Secretary
Chief of Staff
Office of Administration
Acting Assistant Secretary for Congressional and Intergovernmental Relations
Deputy Assistant Secretary, Office of Public Affairs
Deputy Assistant Secretary for Administrative Services, Office of the Executive Secretariat
Deputy Assistant Secretary for Intergovernmental Relations
Acting Deputy Chief of Staff
Deputy Chief of Staff for Policy
Deputy Chief of Staff for Programs
Special Counsel to the Secretary
Senior Advisor to the Secretary
Special Assistant for Inter-Faith Community Outreach
Executive Officer for Administrative Operations and Management
General Counsel
Assistant Secretary for Housing/Federal Housing Commissioner
Assistant Secretary for Policy Development and Research
Assistant Secretary for Community Planning and Development
Assistant Deputy Secretary for Field Policy and Management
Office of Government National Mortgage Association
Assistant Secretary for Fair Housing and Equal Opportunity
Director, Office of Departmental Equal Employment Opportunity
Chief Procurement Officer
Assistant Secretary for Public and Indian Housing
Director, Office of Departmental Operations and Coordination
Office of the Chief Financial Officer
Chief Information Officer
Acting Director, Enforcement Center
Acting Director, Real Estate Assessment Center
Director, Office of Multifamily Assistance Restructuring
Secretary’s Representative, Midwest (2)
Senior Community Builder, Michigan State Office
Director, Office of Public Housing, Michigan State Office
Director, Troubled Agency Recovery Center North (2)
Acting General Deputy Assistant Secretary, Public and Indian Housing
Deputy Assistant Secretary, Office of Administration and Budget/Chief Financial Officer
Deputy Assistant Secretary, Office of Native American Programs
Deputy Assistant Secretary for Public and Assisted Housing Delivery
Deputy Assistant Secretary, Office of Troubled Agency Recovery
Deputy Assistant Secretary for Public Housing Investments
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Appendix C
Audit Liaison Officer, Office of Public and Indian Housing
Deputy Assistant Chief Financial Officer for Financial Management
Director, Audit Coordination Division, Departmental Audit Liaison Officer
Director, Risk Management Division
Chief Financial Officer, Audit Liaison Officer
Primary Audit Liaison Officer – Eastern Districts (Philadelphia)
Acquisitions Librarian
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340 Dirksen Senate
Office Building, United States, Senate, Washington, DC 20510
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, 706
Hart Senate Office Building, United States, Senate, Washington, DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
Building, House of Representatives, Washington, DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204
Rayburn Building House of Representatives, Washington DC 20515
Armando Falcon, Director, Office of Federal Housing Enterprise Oversight, 1700 G Street, NW
Room 4011, Washington, DC 20552
Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212 O’Neil House
Office Building, Washington, DC 20515
Stanley Czerwinski, Associate Director, Resources, Community and Economic Development
Division, United States General Accounting Office, 441 G Street, NW, Room 2T23, Washington
DC 20548
Steve Redburn, Chief, Housing Branch, Office of Management & Budget, 725 17th Street, NW,
Room 9226, New Executive Office Building, Washington, DC 20503
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Muskegon Housing Commission, Audit of Low Rent Public Housing, Section 8 and Single Room Occupancy Programs, Muskegon, Michigan
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-11-29.
Below is a raw (and likely hideous) rendition of the original report. (PDF)