oversight

Housing Authority of the City of Uvalde Section 8 and Low Rent Programs

Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-12-18.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

          AUDIT REPORT




HOUSING AUTHORITY OF THE CITY OF UVALDE
   SECTION 8 AND LOW RENT PROGRAMS

              UVALDE, TEXAS


               01-FW-203-1003

            DECEMBER 18, 2000



      OFFICE OF AUDIT, SOUTHWEST DISTRICT
               FORT WORTH, TEXAS
                                                                      Issue Date
                                                                           December 18, 2000
                                                                     Audit Case Number
                                                                           01-FW-203-1003




TO:          Diana Armstrong
             Director, Office of Public Housing, 6JPH

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

SUBJECT: Section 8 and Low Rent Programs
         Housing Authority of the City of Uvalde
         Uvalde, Texas


As requested by your office, we conducted an audit of the Section 8 and Low Rent Programs of
the Uvalde Housing Authority. Before the audit, your office had already identified significant
Annual Contributions Contract violations and the severe financial condition of the Authority.
Specifically, the Authority had over-requisitioned Section 8 funds and had incurred excessive
administrative expenses over what they had earned. During this audit, we focused on the
concerns you identified. This audit contains one finding.

Within 60 days, please furnish this office, for each recommendation in this report, a status on:
(1) corrective action taken; (2) the proposed corrective action and the date to be completed; or (3)
why action is not considered necessary. Also, please furnish us copies of any correspondence or
directives issued related to the audit.

If you have any questions, please contact Jerry Thompson, Assistant District Inspector General
for Audit, at (817) 978-9309.
Management Memorandum




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01-FW-203-1003              Page ii
Executive Summary
We have completed an audit of the Housing Authority of Uvalde, Texas. The objectives of
the audit were to: (1) identify the purposes for which the Authority used unearned Section
8 administrative fees; (2) determine whether the Authority complied with its Annual
Contribution Contracts (ACC) in the use of certain Section 8 and Low Rent funds; (3)
determine whether the Authority used its Low Rent or Comprehensive Improvement
Assistance Program (CIAP) funds for other purposes; and (4) determine whether the
Authority duplicated payments of certain travel or other administrative expenses in the
Section 8 or Low Rent Programs that may have been paid by the Authority’s affiliate, the
Uvalde Housing Development Corporation. We found the Authority violated provisions of
the ACCs by spending unearned Section 8 funds and Low Rent funds for other purposes.



                                  The former Executive Director ignored HUD’s instructions
  The former Executive            and violated HUD requirements by using $563,702 in HUD
  Director spent $563,702         Program funds to pay for excessive and questionable
  in HUD funds on                 expenses. The Authority incurred $375,552 in excessive
  questionable costs.             administrative costs in the Section 8 Program and $188,150
                                  in questionable costs in the Low Rent Program. The
                                  excessive or questionable costs are: (1) $188,284 used to
                                  undertake various projects not related to the operation of
                                  these programs, including the construction of an affiliate’s
                                  apartment complex; (2) $85,012 paid in excessive salaries;
                                  (3) $167,960 in Low Rent funds transferred to Section 8;
                                  (4) $38,023 in unsupported costs; and (5) $84,423 in
                                  additional administrative expenses in excess of the amount
                                  earned.

                                  The former Executive Director had an objective to develop
                                  properties not related to the Section 8 and Low Rent
                                  Programs. To do this, he manipulated the Section 8
                                  requisition process. The former Executive Director was
                                  also the Secretary/Treasurer of the affiliate from which he
                                  arranged to receive a rent-free apartment. Therefore, a
                                  conflict of interest appears to be evident. However, the
                                  former Executive Director of the Authority, acting as the
                                  Executive Director of the Authority and the
                                  Secretary/Treasurer of the affiliate, severed the affiliate
                                  from the Authority in 1999. As a result, the Authority is
                                  currently in a severe financial condition. The Authority has
                                  reimbursed $224,194 to the Section 8 and Low Rent
                                  Programs, but the Authority still owes HUD $262,925 in
                                  unearned Section 8 funds and $76,583 to the Low Rent


                                         Page iii                              01-FW-203-1003
Executive Summary


                              Program for the excessive administrative expenses and
                              questionable costs.

                              We are making recommendations for corrective actions,
                              including a recommendation for HUD to consider taking
                              administrative sanctions against the former Executive
                              Director.

                              We also looked for duplicative payments from the Section
   We did not find            8, Low Rent, HOME, and CIAPs that the Authority’s
   duplicated payments for    affiliate may have paid. Our review did not disclose such
   administrative or travel   duplicative payments.
   costs
                              We provided a copy of this report to the interim Executive
                              Director of the City of Uvalde Housing Authority on
                              September 26, 2000, and they issued their response on
                              October 13, 2000. We had an exit conference with current
                              Authority Officials on October 19, 2000. We also
                              requested a response to our preliminary findings from the
                              former Executive Director, which we received on
                              December 22, 1999, while he was still employed by the
                              Authority. The responses generally agreed that the
                              Authority used HUD program funds for other purposes.
                              The former Executive Director attributed the Authority’s
                              severe financial condition to an embezzlement that
                              occurred prior to his employment. The Authority’s current
                              management said they are taking action to improve the
                              efficiency of the operations and to collect the funds owed to
                              HUD programs. The complete responses are contained in
                              Appendix B.




01-FW-203-1003                         Page iv
Table of Contents

Management Memorandum                                            i


Executive Summary                                               iii


Introduction                                                     1


Finding

1    The Former Executive Director Ignored HUD’s                  5
     Instructions and Spent $563,702 in Excessive and
     Questionable Costs


Management Controls                                              21



Appendices
      A Schedule of Questioned Costs                             23

      B Auditee Comments                                         25

      C Distribution                                             37




                                Page v                  01-FW-203-1003
Table of Contents


Abbreviations
       ACC          Annual Contributions Contract
       CIAP         Comprehensive Improvement Assistance Program
       CFR          Code of Federal Regulations
       HOME         HOME Investment Partnerships Program
       HUD          U.S. Department of Housing and Urban Development
       OIG          Office of Inspector General
       OMB          Office of Management and Budget
       TDHCA        Texas Department of Housing and Community Affairs
       UHDC         Uvalde Housing Development Corporation




01-FW-203-1003                           Page vi
Introduction
               The City of Uvalde established the Housing Authority of
 Background.   Uvalde, Texas, in 1971. From 1971 through 1999 the
               mayor appointed a five-member Board of Commissioners
               to govern the Authority. Because of changes to the state
               law in 2000, the mayor now appoints 11 members to the
               Board. The Board hires an Executive Director to manage
               the Authority’s day-to-day operations. The Board
               appointed Virginia Limon as interim Executive Director on
               February 14, 2000. The Authority has 48 Low Rent units
               occupied and 193 Section 8 units leased. The Authority
               keeps its records at its office, 1700 Garner Field Road,
               Uvalde, Texas.

               The Authority hired the former Executive Director on
               February 22, 1993, and fired him by unanimous vote on
               February 10, 2000. Board minutes state various reasons for
               his termination. The most significant reasons stated are for
               “mismanagement” and “non compliance with the HUD
               Annual Contribution Contracts” during his tenure.

               During Fiscal Years 1993 through 1999, HUD provided
               $4,104,804 to provide assistance under the Authority’s
               Section 8 Programs and $290,894 in subsidy to the Low
               Rent Program. HUD also provided $861,309 in CIAP grant
               funds to improve the Low Rent units.

               In June 1994, the Authority created the Uvalde Housing
               Development Corporation (UHDC) to operate exclusively
               for the benefit of the Authority and to act as an
               instrumentality of the Authority. The UHDC’s mission is
               to provide decent and affordable housing for lower income
               residents in Uvalde. The Board of Directors of UHDC, at
               any point in time, would be the serving Board of
               Commissioners of the Authority. The former Executive
               Director was the Secretary-Treasurer of UHDC in 1994.

               In November 1997, the Texas Department of Housing and
               Community Affairs (TDHCA) awarded the Authority
               $208,000 in HUD HOME funds. Under the HOME Buyer's
               Assistance Program, the Authority is to provide, 40
               qualifying homebuyers, up to $5,000 in assistance to
               purchase a home. In September 1997, TDHCA approved a
               $200,000 HOME loan to the Granada Apartments, Ltd. for
               the construction of 100 apartments in Uvalde, Texas. The

                     Page 1                                 01-FW-203-1003
Introduction


                            Authority was the original limited partner and the UHDC is
                            still the general partner of the Granada Apartments, Ltd.

                            The objectives of the audit were to: (1) identify the
   Audit Objectives.        purposes for which the Authority used unearned Section 8
                            administrative fees; (2) determine whether the Authority
                            complied with its Annual Contribution Contracts in the use
                            of certain Section 8 and Low Rent funds; (3) determine
                            whether the Authority used its Low Rent or Comprehensive
                            Improvement Assistance Program funds for other purposes;
                            and (4) determine whether the Authority duplicated
                            payments of certain travel or other administrative expenses
                            in the Section 8, Low Rent, CIAP, or HOME Programs that
                            may have been paid by the Authority’s affiliate, the Uvalde
                            Housing Development Corporation.

                            To accomplish the audit objectives, we:
   Scope and Methodology.
                            •   Reviewed the Audit Request and Supporting
                                Documentation.
                            •   Reviewed the HUD approved reports and Independent
                                Public Accountant Audit Reports submitted by the
                                Authority for Fiscal Years ending June 30, 1993,
                                through June 30, 1999, for the Low Rent and Section 8
                                Programs.
                            •   Interviewed HUD Program Staff; Authority Staff, Fee
                                Accountants, Granada Apartments’ Manager, UHDC
                                Board Members and Officers, TDHCA Staff, and
                                current and past serving Board members of the
                                Authority.
                            •   Reviewed the Section 8 Annual Contributions Contract
                                and Public and Indian Housing (PIH) Notices to
                                identify the requirements for the: (1) estimates and
                                requisitions and (2) maintenance and use of the
                                Administrative Fee Reserves for housing purposes.
                            •   Reviewed the Low Rent Annual Contributions Contract
                                to identify the requirements and definitions for: (1)
                                operating receipts; (2) operating expenditures; and (3)
                                projects.
                            •   Reviewed the Code of Federal Regulations (CFR) and
                                OMB Circular A-87, Cost Principles to identify the
                                requirements: (1) costs eligibility and (2) cost
                                allocation.
                            •   Reviewed HUD and Authority correspondence files.


01-FW-203-1003                        Page 2
                                                                                                               Introduction


                                                 •    Reviewed Authority Board minutes, personnel and
                                                      general policies, bank statements, canceled checks,
                                                      check vouchers and other supporting documents from
                                                      July 1, 1993, through April 2000.
                                                 •    Reviewed the UHDC: board minutes, bank statements,
                                                      canceled checks, check vouchers, contracts, and other
                                                      supporting documents from September 1994 through
                                                      January 2000.1
                                                 •    Reviewed the documents provided by the Authority’s
                                                      General Counsel and Fee Accountant.
                                                 •    Reviewed the HOME grant and loan applications and
                                                      contracts to identify the program requirements.
                                                 •    Interviewed the developer and the general contractor of
                                                      the Granada Apartments.
                                                 •    Reviewed the Authority’s bank statements, canceled
                                                      checks, check vouchers for the HOME Buyers
                                                      Assistance Program account from January 1998 through
                                                      April 2000.
                                                 •    Review the Granada Apartments’ Ltd., the Project
                                                      Developer’s and the Project General Contractor’s: bank
                                                      statements, canceled checks, invoices, contracts, and
                                                      other supporting documents for the HOME
                                                      Construction Loan from January 1998 through April
                                                      1999.

                                                 We conducted the audit from November 1999 through
     Audit Period and Sites.                     August 2000 in accordance with generally accepted
                                                 government auditing standards. The audit covered the
                                                 Authority’s operations from July 1, 1992, through April 30,
                                                 2000.




1
    Various bank statements and canceled checks were missing for the period reviewed. The former Executive Director is the
    Secretary/Treasurer of the UHDC and the custodian of records. He stated that the missing bank statements and canceled
    checks were lost.

                                                       Page 3                                               01-FW-203-1003
Introduction




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01-FW-203-1003        Page 4
                                                                                                                    Finding



            The Former Executive Director Ignored
            HUD’s Instructions and Spent $563,702
             in Excessive and Questionable Costs
The former Executive Director ignored HUD’s instructions and used $563,702 in HUD
Program funds to pay for excessive administrative expenses and questionable costs not
directly related to the HUD Programs. He violated provisions of the Annual Contribution
Contracts by spending Section 8 funds requisitioned from HUD but not earned and Low
Rent funds for non-Low Rent purposes. He manipulated the requisitioning process of the
Section 8 Programs. From July 1992 through November 1999, the Authority incurred
$375,552 in excessive administrative expenses in the Section 8 Programs2 and $188,150 in
questionable expenses in the Low Rent Program. The excessive or questionable costs are:
(1) $188,284 used to undertake various projects not related to the operation of these
programs, including the construction of an affiliate’s apartment complex; (2) $85,012 paid
in excessive salaries; (3) $167,960 in Low Rent funds transferred to Section 8; (4) $38,023 in
unsupported costs; and (5) $84,423 in additional administrative expenses in excess of the
amount earned. The former Executive Director had an objective to develop properties not
related to the Section 8 and Low Rent Programs. Also, because the former Executive
Director arranged to receive a rent-free apartment from the affiliate, a conflict of interest
appears to be evident. As a result, the Authority is currently in a severe financial
condition. The Authority has reimbursed $224,194 to the Section 8 and Low Rent
Programs, but the Authority still owes HUD $262,925 in unearned Section 8 funds and
$76,583 to the Low Rent Program for the excessive administrative expenses and
questionable costs.



                                                  The Low Rent Annual Contribution Contract (ACC)
     Requirements.                                between HUD and the Authority incorporates by reference
                                                  the regulations for Public and Indian Housing Authorities
                                                  contained in Title 24 of the Code of Federal Regulations
                                                  (CFR). Title 24 of the CFR, part 85, establishes the
                                                  uniform administrative rules for federal grants and
                                                  cooperative agreements and sub-awards to State, local and
                                                  Indian tribal governments. This part also establishes OMB
                                                  Circular A-873 as the cost principles for housing authorities
                                                  to follow when determining allowable costs to federal
                                                  programs.



2
    Section 8 Programs refers to the Section 8 Voucher and Section 8 Certificate Programs of the Authority.
3
    Cost Principles for State and Local Governments.

                                                          Page 5                                              01-FW-203-1003
Finding


                 Section 11 of the Section 8 ACC provides the requirements
                 for the use of program receipts. The Authority:

                 •   Must use program receipts only to pay program
                     expenditures; and

                 •   Must not make any program expenditures, except in
                     accordance with the HUD-approved budget estimate
                     and supporting data for a program.

                 Section 12 of the Section 8 Programs’ ACC provides the
                 requirements of the establishment and use of the
                 administrative fee reserve. The Authority:

                 •   Must maintain an administrative fee reserve for a
                     program. The Authority must credit to the
                     administrative fee reserve the total of the amount by
                     which program administrative fees paid by HUD for a
                     fiscal year exceed the Authority’s administrative
                     expenses and

                 •   Must use funds in the administrative fee reserve to pay
                     administrative expenses in excess of program receipts.
                     If any funds remain in the administrative fee reserve,
                     the Authority may use the administrative reserve funds
                     for other housing purposes.

                 Section 2 of the Low Rent Program ACC provides the
                 definition of terms. The following definitions are relevant
                 to this audit:

                 •   “Act” means the United States Housing Act of 1937, as
                     amended.

                 •   “Operating Receipts” shall mean all rents, revenues,
                     income, and receipts accruing from, out of, or in
                     connection with the ownership or operation of such
                     project.

                 •   “Operating Expenditures” shall mean all costs incurred
                     by the Authority for administration, maintenance, and
                     other costs and charges that are necessary for the
                     operation of the project.



01-FW-203-1003             Page 6
                                                                                                                         Finding


                                                   •    “Project” means public and Indian housing developed,
                                                        acquired, or assisted by HUD under the Act, other than
                                                        Section 8 of the Act, and the improvement of such
                                                        housing.

                                                   Section 11 of the Low Rent Program’s ACC states the
                                                   Authority shall not incur any operating expenditures except
                                                   pursuant to an approved operating budget.

                                                   Regarding conflicts of interest, the Low Rent Program
                                                   ACC, Part A, Section 19, Subsection (A)(1), provides that
                                                   neither the Authority nor any of its contractors or their
                                                   subcontractors may enter into any contract, subcontract, or
                                                   arrangement in connection with a project under this ACC,
                                                   in which any employee of the Authority who formulates
                                                   policy or who influences decisions with respect to the
                                                   projects(s), has interest, direct or indirect, during his tenure
                                                   or for one year there after.

                                                   OMB Circular A-87, Attachment A, Part C, Basic
                                                   Guidelines, requires costs to be necessary, reasonable, and
                                                   adequately documented for proper and efficient
                                                   performance and administration of federal awards. The
                                                   Circular also provides that costs are allocable to a particular
                                                   cost objective if the goods or services involved are
                                                   chargeable to such cost objectives according to the relative
                                                   benefits received. In addition, any cost allocable to a
                                                   particular award or cost objective may not be charged to
                                                   other federal awards to overcome fund deficiencies, to
                                                   avoid restrictions imposed by law or terms of the federal
                                                   awards, or for other reasons.

                                                   Every year the Authority requisitions Section 8 funds from
                                                   HUD to make housing assistance payments, cover audit
                                                   costs, hard to house fees, and their Administrative Fee
                                                   Earned.4 HUD requires the requisitions to be based on
                                                   reasonable estimates of units authorized and leased. At the
                                                   end of each fiscal year the Authority submits a yearend
                                                   settlement statement showing the actual amount of annual
                                                   HUD contributions earned. At this time, HUD adjusts the
                                                   amount paid during the year to the actual amount the
                                                   Authority earned. If the Authority has requisitioned too
                                                   much, funds are due HUD, and if not enough, funds are due

4
    The Administrative Fee is published yearly in the Federal Register. The fee rate is multiplied by the number of actual units
    leased to determine the total of the Administrative Fees Earned for the fiscal year.

                                                         Page 7                                                 01-FW-203-1003
Finding


                                                  the Authority. The Authority earns an Administrative Fee
                                                  for administering the Section 8 Program based on the
                                                  number of units leased monthly. HUD pays the
                                                  administrative fee to cover the administrative costs. It’s the
                                                  Authority’s responsibility to operate within the limits of the
                                                  administrative fee earned and to put into reserve any
                                                  amounts earned in excess of its administrative costs.

                                                  Beginning January 1, 1995, HUD Notice PIH 94-64
                                                  required housing authorities to review, no later than 90 days
                                                  into the fiscal year, their estimate of Section 8 annual
                                                  contributions required. HUD requires housing authorities
                                                  to revise their estimates if it appears that they will receive 5
                                                  percent more in total annual contributions than required.

                                                  As of January 31, 2000, the Authority had spent $262,9255
     The Authority owes
                                                  of unearned Section 8 funds. From July 1992 through
     HUD $262,925 of Section
                                                  January 2000, the Authority requisitioned $944,632 more
     8 funds it spent but had
                                                  than it earned for its Administrative Fee and program costs.
     not earned.
                                                  HUD was only able to offset $681,707 of the over-
                                                  requisitioned amount because at various times when the
                                                  authority had submitted yearend settlement statements, the
                                                  Authority had already spent all it had over-requisitioned on
                                                  other projects or on excessive administrative expenses. The
                                                  table below shows the over-requisitioned amounts, the
                                                  funds offset by HUD and the amounts due at the time of
                                                  settlement for each fiscal year.

                          Fiscal     Section 8 HUD           Amount         Funds     Current
                          Year       Funds       Scheduled Over-            Offset    Amount
                          End        Required    Payments    Requisitioned by HUD Due HUD
                          06/30/1993 $ 628,940     $ 698,877     $ -69,937 $ 69,937 $         0
                          06/30/1994     596,765     617,492        -20,727 -16,944      37,671
                          06/30/1995     588,432     607,841        -19,409         0    19,409
                          06/30/1996     516,260     710,649      -194,389     37,669 156,720
                          06/30/1997     517,037     710,649      -193,612 177,660       15,952
                          06/30/1998     485,690     710,290      -224,600 107,004 117,596
                          06/30/1999     452,793     596,810      -144,017 172,479      -28,462
                          01/31/2000     323,076     401,017        -77,941 133,902     -55,961
                          Totals      $4,108,993 $5,053,625     ($944,632) $681,707 $262,925




5
    This figure is correct through 1/31/2000. The Authority has not submitted the Year End Settlement Statements for 6/30/2000
    which were due to the FMC on August 15, 2000. The FMC still has to process and approve the statements to determine the
    final amount “Due HUD” through the date of this report.

01-FW-203-1003                                                 Page 8
                                                                                 Finding


                           The former Executive Director used $188,284 in Section 8
The former Executive
                           and Low Rent funds on various other housing related
Director over-
                           projects. He spent $181,176 in unearned Section 8 funds
requisitioned Section 8
                           and $7,108 in Low Rent funds for these other projects.
funds, ignored HUD’s
                           Although, the Section 8 ACC allows any funds remaining
instructions, and spent
                           in the administrative fee reserve to be used for other
$188,284 on housing
                           housing purposes, the Authority had no administrative fee
projects in violation of
                           reserve or the Authority owed HUD the amounts it over-
contract provisions.
                           requisitioned. HUD’s Low Rent contract provisions and
                           applicable cost principles require the Authority to use Low
                           Rent funds on costs that are necessary for the operation of
                           the Low Rent project. The Authority’s use of $7,108 in
                           Low Rent funds did not benefit the Low Rent project. The
                           former Executive Director ignored HUD’s instructions and
                           continued to approve and use the Section 8 and Low Rent
                           funds for those other projects.

                           The former Executive Director undertook these housing
                           projects with Board approval. He used Section 8 and Low
                           Rent funds to obtain Low Income Housing Tax Credits for
                           the Granada Apartments, Ltd. This project, as mentioned
                           earlier, is owned by the UHDC. He tried to obtain HUD
                           HOME funds from the TDHCA. Also, he attempted to
                           obtain funds from Rural Development, formerly Farmer’s
                           Home Administration under the United States Department
                           of Agriculture (USDA). However, his primary goal was to
                           build the Granada Apartments using Tax Credits and HUD
                           HOME funds from the State. The table below shows the
                           amount of Section 8 and Low Rent funds used for the
                           UHDC and other housing projects.

                           Housing Projects            Section 8   Low Rent Totals
                              UHDC Expenses             $137,376      $2,785 $140,161
                              UHDC Salaries               19,692       4,323   24,015
                           Subtotal UHDC                $157,068      $7,108 $164,176
                             Other Housing Projects       24,108               24,108
                           Totals                       $181,176      $7,108 $188,284


                           Of the $188,284 used for other housing projects, the
                           Authority used $164,176 to fund UHDC and the Granada
                           Apartments. Of this $164,176, the Authority used
                           $140,161 of the funds for travel, legal fees, land, consulting
                           fees, application fees, training, and seminar costs. The
                           Authority used $24,015 in salaries for the benefit of
                           UHDC. The former Executive Director traveled 141 days

                               Page 9                                     01-FW-203-1003
Finding


                             on UHDC business. For calendar years 1994 through 1999,
                             the Low Rent Program paid for 23 days of travel and the
                             Section 8 Program paid for 81 days of travel. UHDC paid
                             for his travel covering a period of 37 days. Although
                             UHDC paid his travel costs, the Authority paid his salary
                             during those 37 days. His salary is paid with Low Rent and
                             Section 8 funds. The Low Rent and Section 8 Programs
                             did not benefit from his travel for UHDC.

                             As of November 30, 1999, the UHDC had reimbursed the
                             Authority $115,033 for the costs the Authority incurred.
                             The Authority applied $112,627 to the Section 8 Programs
                             and $2,406 to the Low rent Program, leaving the
                             Corporation still owing $44,441 to the Section 8 Program
                             as part of the $262,925 owed HUD and $4,702 to the Low
                             Rent Program. Therefore, the Authority needs to collect an
                             additional $49,143 from the UHDC and repay the HUD
                             Programs in this amount.

                             The Authority also used $24,108 of unearned Section 8
                             money on other housing projects besides the Granada
                             Apartments. Most of these expenses were for travel to
                             attend training seminars or workshops related to and to
                             apply for Farm Labor, USDA, and TDHCA HOME
                             housing programs. We are recommending the Authority
                             repay the $24,108 to HUD from nonfederal funds as part of
                             the $262,925 it over-requisitioned from HUD.

                             From October 1998 through February 2000, the Granada
   The Granada
                             Apartments provided a "rent free" apartment to the former
   Apartments provided a
                             Executive Director. He lived in a three-bedroom apartment
   rent-free apartment to
                             from October 1998 through September 1999 when the
   the Director.
                             average rent charged was $440. He later moved to a two-
                             bedroom apartment from October 1999 through February
                             2000 when the average rent charged was $395. The
                             Granada Apartments also provided UHDC a “rent-free” and
                             “utility-free” office. The former Executive Director uses
                             this office for UHDC business. This situation appears to be
                             a direct conflict of interest for the former Executive
                             Director.

                             One of the reasons the Authority had no funds to repay the
   The Authority paid
                             amount of Section 8 funds over-requisitioned from HUD
   $85,012 in excessive
                             was that the Authority used $85,012 in unearned Section 8
   salaries with Section 8
                             funds to pay excessive salaries from 1995 through 1999.
   funds.

01-FW-203-1003                         Page 10
                                                                                   Finding


                              The Authority exceeded the HUD approved salaries from
                              1995 through 1997. Several times, HUD specifically
                              modified the approved budgeted salaries to reflect the
                              salary comparability information and the financial
                              condition of the Authority. HUD did not require approval
                              and did not approve the operating budgets for 1998 and
                              1999 because the Authority had passed the Public Housing
                              Management and Performance financial indicators. We
                              estimated the excessive salaries using the highest salaries
                              HUD had previously approved. The excessive salaries are
                              allocated between the Low Rent and Section 8 Programs.

                             HUD Approved Salaries          Excessive Excessive
                             Salaries for    Paid by        Salaries     Salaries
                  Calendar Authority         Authority Per Paid          Chargeable to
                  Year       Employees       W2 Forms       by Authority Section 8
                        1995        $ 95,490       $ 96,588     $ 1,098         $ 900
                        1996          76,775         99,834       23,059         18,908
                        1997          97,490        109,496       12,006          9,845
                        1998          97,490        136,349       38,859         31,865
                        1999          97,490        126,141       28,651         23,494
                  Totals           $464,735       $568,408     $103,673         $85,012

                              The former Executive Director ignored HUD’s instructions
                              and paid the excessive salaries anyway. Consequently, the
                              Authority paid $85,012 in excessive salaries with unearned
                              Section 8 funds when they did not have any Administrative
                              Fee Reserves to cover these costs. We are recommending
                              the Authority repay the $85,012 to HUD from nonfederal
                              funds as part of the $262,925 in unearned funds the
                              Authority still owes HUD.

                              The Authority used $38,023 program funds on unsupported
The Authority records         expenditures. The Authority spent $24,941 in unearned
lack adequate support         Section 8 funds and $13,082 of Low Rent funds on these
for $38,023 in                expenditures. The Authority records did not contain
administrative expenses.      adequate supportive documentation to show that these costs
                              were eligible or necessary for the operation of the Section 8
                              and Low Rent Programs. For example, we found instances
                              where payments had: no invoices, no purpose stated on the
                              check voucher, no names of the individual traveling on the
                              check voucher, and no supporting documents for the
                              amount of the check. OMB Circular A-87 says that all
                              costs must be necessary, reasonable, and adequately
                              documented for proper and efficient performance and

                                 Page 11                                    01-FW-203-1003
Finding


                              administration of federal awards. Since the Authority could
                              not provide adequate support for these costs, we are
                              recommending the Authority repay the $13,082 to the Low
                              Rent Program from nonfederal funds. The Authority needs
                              to repay HUD $24,941 as part of the $262,925 in unearned
                              Section 8 funds they spent on these unsupported costs from
                              nonfederal funds.

                              The Authority spent $84,423 in unearned Section 8 funds
   The Authority paid         on other miscellaneous administrative expenses in the
   $84,423 for operating      Section 8 Programs. These expenses represent the amount
   costs with funds they      of administrative expenses incurred and paid with money
   had not earned.            they over-requisitioned and spent during the period. The
                              $84,423 does not include costs identified for the various
                              housing related projects, excessive salaries, and
                              unsupported costs. These administrative expenses would
                              be considered program operating costs and could have been
                              paid with Section 8 Administrative Fees Earned if the
                              Authority had any. We are recommending the Authority
                              repay HUD the $84,423 from nonfederal funds as part of
                              the $262,925 in unearned Section 8 funds they spent on
                              these miscellaneous administrative expenses.

                              The former Executive Director authorized and approved the
   The Authority              transfer of $167,960 of Low Rent funds to the Section 8
   transferred $167,960 in    Programs during the period beginning July 1993 through
   Low Rent funds to cover    February 2000. The Low Rent funds covered the shortfalls
   Section 8 shortfalls.      in the Section 8 Program. According to the interim
                              Executive Director, they needed the funds to make housing
                              assistance payments. The Authority has reimbursed the
                              Low Rent Program $109,161 from Section 8 funds and
                              currently owes the Low Rent Program $58,799. OMB
                              Circular A-87 says funds from one federal award cannot
                              cover fund deficiencies in other federal awards. Also, the
                              Low Rent ACC definition of a “project” specifically
                              excludes any project under Section 8 of the Act. We are
                              recommending the Authority repay the Low Rent Program
                              $58,799 from nonfederal funds.


                              HUD staff responsible for processing Section 8 yearend
   HUD could not offset the   settlement statements said HUD could not offset the entire
   entire amount because      over-requisitioned amount for several reasons including a
   the Authority had spent    HUD system conversion that occurred during 1995 and
   the money.                 1996. HUD did not process the offset for the over-

01-FW-203-1003                          Page 12
                                                                              Finding


                          requisitioned amount for Fiscal Year 1994 until during the
                          fiscal year ended June 30, 1996. By the time HUD
                          processed and approved the Year End Settlement
                          Statements, HUD could not offset the entire amount that
                          was over-requisitioned. The main reason they could not
                          offset the entire amount due for each fiscal year was
                          because the Authority had already spent the over-
                          requisitioned funds. If HUD had offset the entire amounts,
                          the Authority would not have had enough money in the
                          bank to pay Section 8 landlords the remaining housing
                          assistance payments during each fiscal year.

                          The Fee Accountant that prepared the 1993 through 1997
The Fee Accountant and    Section 8 estimates and requisitions said that the former
HUD increased Section 8   Executive Director said several times that the Authority
requisitions with         would be fully leased up in the next fiscal year. The former
information provided by   Executive Director said the Authority was getting Low
the former Executive      Income Housing Tax Credits. He said the tax credits would
Director.                 allow UHDC to construct the Granada Apartments and this
                          would increase the housing stock in Uvalde for Section 8
                          applicants. The fee accountant, relying on the statements
                          by the former Executive Director, estimated more leased
                          units than necessary during 1993 through 1997.

                          On one occasion, the former Executive Director did not
                          agree with the Fee Accountant’s 1999 estimate and
                          requisition. The former Executive Director contacted a
                          HUD Financial Management Specialist and told her that the
                          Fee Accountant’s estimate was too low. He said the
                          Authority would be fully leased up by October 1998
                          because the Granada Apartments would be in operation.
                          The HUD Financial Management Specialist, also relied on
                          his statements and revised and increased the 1999 fiscal
                          year estimate and requisition. However, the completion of
                          the Granada Apartments did not increase the number of
                          units leased in the HUD Section 8 Programs. The
                          Authority had leased 170 Section 8 units as of June 30,
                          1998, and only leased 158 units by June 30, 1999, including
                          33 units at the Granada Apartments. The Authority actually
                          leased 12 less units than the prior fiscal year.

                          We interviewed various Authority Commissioners that
The former Executive      served from 1993 through 1999. The Commissioners
Director did not inform   acknowledged that they approved the housing related
Commissioners of HUD      projects, including the Granada Apartments, initiated by the
requirements.
                             Page 13                                   01-FW-203-1003
Finding


                                                former Executive Director. They also recall positive
                                                reports and comments from HUD saying that the Authority
                                                went from a “Troubled” agency to a “High Performer”6
                                                during the tenure of the former Executive Director. The
                                                former Executive Director told the Commissioners that they
                                                could use Section 8 funds for those housing projects.
                                                However, the Commissioners said that the former
                                                Executive Director did not fully inform the Board about the
                                                problems with:

                                                •    Over-requisitioning Section 8 funds;
                                                •    Spending more than administrative fees earned;
                                                •    Negative Section 8 Administrative Fee Reserves;
                                                •    Spending Section 8 funds for “housing related
                                                     purposes” when the Authority had no Administrative
                                                     Fee Reserves, violating the ACC requirements; and
                                                •    Spending Low Rent funds on non Low Rent housing
                                                     projects violating the ACC requirements.

                                                They believe the former Executive Director should have
                                                informed them of the serious financial condition of the
                                                Authority and the ACC violations. Commissioners also
                                                said they would have followed HUD’s instructions and not
                                                undertaken the housing projects if he had adequately
                                                informed them.

                                                Collecting the $49,143 due from the UHDC may present a
     The former Executive                       problem because neither the UHDC nor the Granada
     Director severed the                       Apartments are now affiliated with the Authority. When
     Uvalde Housing                             the Authority established the UHDC, the Authority
     Development                                Commissioners also served on the UHDC Board of
     Corporation from the                       Directors. When they created the limited partnership, the
     Authority.                                 Granada Apartments, Ltd., in December 1996, the
                                                Authority was a limited partner with 99 percent interest.
                                                The UHDC was the general partner with a 1 percent
                                                interest. In December 1997, the former Executive Director,
                                                representing both entities as the Secretary/Treasurer of
                                                UHDC and the Executive Director of the Authority, signed
                                                and executed an amendment to the original partnership
                                                agreement. The amendment withdrew the Authority from
                                                the partnership and admitted a new limited partner, THOF
                                                III, whose general partner is the Texas Housing Finance

6
    The terms “Troubled” and “High Performer” relate only to HUD’s assessment of the Low Rent Program and not to Section 8.
    During that period HUD used the Public Housing Management and Assessment Program to assess the Authority’s
    performance in the Low Rent Program.

01-FW-203-1003                                               Page 14
                                                                                 Finding


                            Corporation. The Authority Board minutes do not reflect
                            any record of a vote to withdraw their interest from the
                            Granada Apartments, Ltd. Thus, it appears the former
                            Executive Director acted on his own to withdraw the
                            Authority from the partnership.

                            On February 23, 1999, the UHDC Directors adopted
                            resolutions to amend the By-laws of the Corporation,
                            terminate the terms of and replace certain Directors, and to
                            not require the Directors to be Authority Board members.
                            The resolutions passed by a 60 percent vote, although,
                            based on the original By-laws, such resolutions would have
                            required a 66 percent favorable vote for passage. Currently
                            no Authority Commissioners serve on the Board of
                            Directors of UHDC. The former Executive Director of the
                            Authority remained the Secretary/Treasurer of the UHDC
                            and has control of the bank accounts and custody of the
                            UHDC records.

                            The resolutions that passed on February 23, 1999, did not
                            have the required two-thirds votes by the Directors as
                            required by the original UHDC Corporate By-laws.
                            Therefore, the resolutions that severed the relationship with
                            the Authority may not be valid. The Authority may need to
                            consider legal action against UHDC to collect the $49,143,
                            regain control of the UHDC Board of Directors, and
                            recover its interest in the Granada Apartments, Ltd.
                            Whatever the outcome, we are recommending the Authority
                            repay HUD $44,441, as part of the $262,925 in unearned
                            Section 8 funds requisitioned, and $4,702 to the Low Rent
                            Program from nonfederal funds for funds the UHDC used
                            and still owes the Authority.

                            As previously noted, the excessive administrative expenses
Authority travelers did     in the Section 8 Program and the questioned costs in the
not follow its Board        Low Rent Program included travel. The travel was for the
approved travel policies.   former Executive Director, Commissioners, and employees.
                            The expenses relating to UHDC, other housing projects,
                            and unsupported costs include $40,490 of the travel costs.
                            Not only did the Authority violate HUD regulations they
                            also did not follow their own travel policies regarding
                            advances. The Authority issued 183 travel advances during
                            the audit period. The travelers in only eight instances filed
                            a travel voucher to reconcile the differences between the
                            advance and actual costs. The Authority personnel policies

                               Page 15                                    01-FW-203-1003
Finding


                                                 allow travel advances for officials and employees for
                                                 traveling out-of-town. The policies require the traveler to
                                                 submit a travel voucher no later than 30 days after the travel
                                                 is completed. If the traveler does not submit a voucher, the
                                                 traveler is abusing the advance system and can be placed on
                                                 a reimbursable basis only. We are recommending the
                                                 Authority ensure that all travel is eligible under the program
                                                 requirements and that they follow their own travel policies.

                                                 The former Executive Director’s actions have placed the
      The Authority is in                        Authority in severe financial distress and have bankrupted
      severe financial                           the Authority’s Section 8 Program. The Authority has
      condition.                                 consistently increased the deficit in its Section 8 Program
                                                 since 1993. Now it owes HUD $262,925 in over-
                                                 requisitioned funds and the Low Rent Program $76,583 for
                                                 excessive administrative expenses and questionable costs.
                                                 At the end of the 1994 fiscal year, the Authority’s Section 8
                                                 Programs had a combined deficit of $51,859. This is
                                                 because the Authority has consistently charged
                                                 administrative expenses to the programs in excess
                                                 administrative fees earned. The current financial condition
                                                 has affected the Authority’s ability to provide future
                                                 housing opportunities for the citizens of Uvalde. The table
                                                 below shows the Authority’s expenditures have exceeded
                                                 its administrative fee earned each year since 1993 by
                                                 $15,000 to $74,000 to reach the current deficit of $370,747
                                                 in the Section 8 Programs.

                                           Administrative    Total         Excessive     Administrative
                                               Fee        Administrative Administrative Fee Reserve
                               FYE           Earned         Expenses       Expenses        Balance7
                            06/30/1993         $ 61,721        $ 87,310       ($ 25,589)        $47,884
                            06/30/1994             64,120        107,299        (43,179)      ($51,859)
                            06/30/1995             75,608          90,762       (15,154)      ($53,997)
                            06/30/1996             74,656        106,092        (31,436)     ($116,133)
                            06/30/1997             74,204        118,010        (43,806)     ($218,308)
                            06/30/1998             68,818          92,699       (23,881)     ($297,859)
                            06/30/1999             66,902        140,466        (73,564)     ($370,747)
                            TOTALS              $486,029        $742,638     ($256,609)

                                                 HUD requested the Authority to submit a workout plan and
                                                 rejected the first one the Authority submitted. It called for
                                                 a pay back period of 10 years. The workout plan should

7
    HUD adjusts the Authority’s Administrative Fee Reserve Balance when they approve the Year End Settlement Statements.

01-FW-203-1003                                                Page 16
                                                                       Finding


                   show how the Authority plans to bring the Section 8
                   Administrative Fees Reserve into a positive balance and
                   how they plan to reimburse the Low Rent Program for the
                   funds they used to pay Section 8 housing assistance
                   payments. They also say it is difficult to gage how long it
                   will take the Authority to pay back HUD and the Low Rent
                   Program.



                   Comments by Former Executive Director
Auditee Comments
                   The former Executive Director in a written response dated
                   December 22, 1999, attributes the current financial
                   situation to a $200,000 embezzlement by his predecessor
                   (see Appendix B). In addition to the theft, the Authority
                   paid unpaid vendors, delinquent federal payroll taxes and
                   penalties, and large amounts of bank overdraft fees. The
                   Authority also paid the bank $5,000 to reproduce canceled
                   checks related to the investigation.

                   The former Executive Director also said that the over-
                   requisitioning of Section 8 funds was due to the lack of
                   affordable housing stock in Uvalde. Section 8 customers
                   had a difficult time finding rental units in Uvalde causing
                   the Authority to be under leased. The Authority incurred
                   excessive administrative expenses over administrative fees
                   earned because of the under leasing of units.

                   To address the lack of affordable housing in Uvalde, the
                   former Executive Director used Section 8 and Low Rent
                   funds. The former Executive Director said HUD told the
                   Authority to diversify by seeking funding from other
                   agencies. Thus, the Board and Authority used Section 8
                   and Low Rent funds to apply for funding for the various
                   housing projects including the Tax Credits used to
                   construct the Granada Apartments owned by UHDC.
                   UHDC borrowed Section 8 funds from the Authority to
                   purchase the site for the construction of the Granada
                   Apartments.

                   Comments by Interim Executive Director

                   The interim Executive Director provided a tentative
                   response to the finding on October 13, 2000 (see Appendix

                      Page 17                                   01-FW-203-1003
Finding


                 B). She said the Authority Board of Commissioners and
                 the former Executive Director responsible for overseeing
                 the operations during the period of the questionable
                 expenditures are no longer serving or working for the
                 Authority.

                 The Board of Commissioners fired the former Executive
                 Director on February 10, 2000, and appointed Ms. Virginia
                 Limon as the interim Executive Director. As the interim
                 Executive Director she increased Section 8 leasing by 23
                 percent to maximize income and has initiated several cost
                 cutting measures to immediately reduce operating cost.
                 The measures have:

                 •   Reduced administrative office and travel expenses to
                     keep within budgets;
                 •   Reduced staff salaries to agree with HUD approved
                     amounts; and
                 •   Eliminated unnecessary expenses that have been
                     identified.

                 The interim Executive Director is working closely with the
                 Board of Commissioners and HUD to keep them informed
                 of the financial condition of the Authority. She:

                 •   Provided each Commissioners with the appropriate
                     HUD Contracts, Regulations, Handbooks and OMB
                     Circulars;
                 •   Instructed the Fee Accountant to monthly prepare for
                     HUD and the Board reports showing a detailed income,
                     expense, balance and status for each program; and
                 •   Is working closely with the Fee Accountant and HUD to
                     establish an acceptable budget and timeline for the
                     reimbursement of funds to HUD and the Low Rent
                     Program.

                 The interim Executive Director will be proposing additional
                 corrective actions to the Board of Commissioners
                 concerning the legal action against UHDC including the
                 collection of the funds owed Authority. A recommendation
                 will also be made to the Board to revise the current travel
                 polices to clarify procedures on the issuance of travel funds.

                 The complete responses from the former and the interim
                 Executive Director are contained in Appendix B.

01-FW-203-1003             Page 18
                                                                         Finding




                    Evaluation of Comments by Former Executive Director
OIG Evaluation of
Comments            The response by the former Executive Director does not
                    change our position in the report. The former Executive
                    Director agreed the Authority used over-requisitioned
                    Section 8 funds and Low Rent funds for other housing
                    purposes and spent more money than they had earned. We
                    reviewed all available documentation relating to the
                    embezzlement including the United States District Court
                    Judgment and Independent Audit Reports of the Authority.
                    The results of our review did not show that the
                    embezzlement by the prior Executive Director caused the
                    current financial condition of the Authority.

                    Evaluation of Comments by Interim Executive Director

                    Comments by the interim Executive Director appear
                    responsive and indicate the Authority has begun taking
                    positive corrective actions to reduce administrative costs,
                    increase administrative fees earned, and operate within
                    program budgets.



                    We recommend the Office of Public Housing:
 Recommendations
                    1A. Require the Authority repay HUD $262,925 from
                        nonfederal funds for the Section 8 funds they over-
                        requisitioned and spent. Also, identify other
                        additional funds “Due HUD” following HUD’s
                        approval and revision of the Year End Settlement
                        Statements for June 30, 2000;

                    1B. Require the Authority to recover $49,143 from
                        UHDC for expenses paid on their behalf. The
                        Authority should reimburse $44,441 to the Section 8
                        account and $4,702 to the Low Rent account (We
                        consider the $44,441 that UHDC owes the Section 8
                        Programs as part of the $262,925 the Authority owes
                        HUD and included under recommendation 1A.);

                    1C. Require the Authority to repay the Low Rent Program
                        $58,799 from nonfederal funds for ineligible transfers

                       Page 19                                    01-FW-203-1003
Finding


                      that have not been reimbursed by the Section 8
                      Program. The Authority should also reimburse the
                      Low Rent Program for any transfers that have
                      occurred from April 2000 to the report date;

                 1D. Require the Authority to provide support for $13,082
                     in unsupported costs charged to the Low Rent
                     Program for the audit period and any subsequent
                     unsupported costs from the cut-off date in the audit
                     report. For the amounts the Authority cannot support,
                     those costs should be considered ineligible and be
                     repaid from nonfederal funds;

                 1E. Require the Authority to follow its own travel
                     policies;

                 1F. Monitor the administrative expense levels until
                     satisfied that the Authority is complying with HUD
                     budgets and program requirements by obtaining
                     monthly income and expense reports for Section 8
                     and Low Rent Programs from the Board of
                     Commissioners;

                 1G. Monitor the Section 8 estimates and requisitions until
                     satisfied that the Authority is not over-requisitioning
                     more annual contributions than is required by
                     obtaining monthly reports on the amount of Section 8
                     Administrative Fees Earned and Expended and lease-
                     up activity; and

                 1H. Consider taking appropriate administrative sanctions
                     against the former Executive Director for violations
                     of the Annual Contribution Contracts that have
                     affected the integrity of the Section 8 and Low Rent
                     Programs.




01-FW-203-1003             Page 20
Management Controls
In planning and performing our audit, we obtained an understanding of the management
controls that were relevant to our audit. Management is responsible for establishing
effective management controls. Management controls, in the broadest sense, include the
plan of organization, methods, and procedures adopted by management to ensure that its
goals are met. Management controls include the processes for planning, organizing,
directing, and controlling program operations. They include the systems for measuring,
reporting, and monitoring program performance.



                                 We decided the following management controls were
  Relevant Management            relevant to our audit objectives:
  Controls.
                                 •   Section 8 Estimates and Requisitions Process
                                 •   Program Contracts and Administrative Costs
                                 •   Cost Eligibility

                                 We assessed all the relevant control categories identified
                                 above, to the extent they impacted on our audit objectives.

                                 A significant weakness exists if management controls do
  Significant Weaknesses.        not give reasonable assurance that resource use is consistent
                                 with laws, regulations, and policies; that resources are
                                 safeguarded against waste, loss, and misuse; and that
                                 reliable data are obtained, maintained, and fairly disclosed
                                 in reports.

                                 Based on our review, we believe the following items were
                                 significant weaknesses:

                                 •   The former Executive Director violated the Section 8
                                     Annual Contribution Contract requirements and spent
                                     Section 8 funds they had not earned on housing related
                                     projects, excessive salaries, unsupported costs, and
                                     other excessive administrative costs (finding).

                                 •   The former Executive Director manipulated the Section
                                     8 Estimates and Requisitions process to access
                                     additional Section 8 funds (finding).




                                      Page 21                                  01-FW-203-1003
Management Controls


                      •   The former Executive Director violated the Low Rent
                          Annual Contribution Contract requirements and
                          program regulations and spent Low Rent funds on
                          ineligible housing projects, ineligible transfers, and
                          other unsupported costs (finding).




01-FW-203-1003                  Page 22
                                                                                                             Appendix A


Schedule of Questioned Costs


                                                                                Type of Questioned Costs
          Issue                                                                 Ineligible 1/ Unsupported 2/


1A Section 8 Funds “Due HUD”                                                    $262,925

1B Low Rent (Due from UHDC)                                                          4,702

1C Low Rent (Ineligible Transfers)                                                  58,799

1D Low Rent (Unsupported Costs)                                                                          $13,082

        Totals                                                                  $326,426                 $13,082




1
  Ineligible costs are costs charged to a HUD-financed or insured program or activity that the auditor believes are not allowable
  by law, contract, or federal, state, or local policies or regulations.
2
  Unsupported costs are costs questioned by the auditor because the eligibility cannot be determined at the time of audit. The
  costs are not supported by adequate documentation or there is a need for a legal or administrative determination on the
  eligibility of the costs. Unsupported costs require a future decision by HUD program officials. This decision, in addition to
  obtaining supporting documentation, might involve a legal interpretation or clarification of Departmental policies and
  procedures.




                                                         Page 23                                              01-FW-203-1003
Appendix A




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                     BLANK
                 INTENTIONALLY




01-FW-203-1003        Page 24
                               Appendix B

Auditee Comments




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            Appendix B




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            Appendix B




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            Appendix B




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01-FW-203-1003   Page 32
            Appendix B




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01-FW-203-1003   Page 34
            Appendix B




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01-FW-203-1003   Page 36
                                                                                     Appendix C

Distribution
Secretary's Representative, 6AS
Comptroller, 6AF
Director, Accounting, 6AAF
Director, Office of Public Housing, 6JPH
Secretary, S (Room 10000)
Deputy Secretary, SD (Room 10100)
Assistant Deputy Secretary for Field Policy & Mgmt, SDF (Room 7108)
Acting Assistant Secretary for Administration, A (Room 10110)
Deputy Chief of Staff for Programs & Policy, S (Room 10226)
Deputy Asst. Secretary for Public Affairs, S (Room 10222)
Special Asst. for Inter-Faith Community Outreach, S (Room 10222)
Executive Officer for Admin Operations & Management, S (Room 10220)
General Counsel, C (Room 10214)
Director, Office of Federal Housing Enterprise Oversight, O, 9th Floor Mailroom
Assistant Secretary for Housing/FHA, H (Room 9100)
Office of Policy Development & Research, R (Room 8100)
Assistant Secretary for CPD, D (Room 7100)
Government National Mtg. Assoc., T (Room 6100)
Assistant Secretary for Fair Housing & Equal Opportunity, E (Room 5100)
Chief Procurement Officer, N (Room 5184)
Assistant Secretary for Public & Indian Housing, P (Room 4100)
Chief Information Officer, Q (Room 3152)
Director, Office of Departmental Operations & Coordination, I (Room 2124)
Chief Financial Officer, F (Room 2202)
Director, Enforcement Center, V, 200 Portals Bldg., D.C. 20024
Director, REAC, X, 1280 Maryland Ave., SW (Ste.800), D.C. 20024
Director, Office of MF Assistance Restructuring, Y, 4000 Portals Bldg., D.C. 20024
Deputy Chief Financial Officer for Operations, FF (Room 2202)
David Gibbons, Director, Office of Budget, FO (Room 3270)
FTW ALO, 6AF (2)
Public Housing ALO, PF (Room P8202) (2)
Dept. ALO, FM (Room 2206) (2)
Acquisitions Librarian, Library, AS (Room 8141)




                                         Page 37                                01-FW-203-1003
Appendix C


                                DISTRIBUTION (Cont’d)

Director, Hsg. & Comm. Devel. Issues, US GAO, 441 G St. NW, Room 2474
     Washington, DC 20548 Attn: Judy England-Joseph
Henry A. Waxman, Ranking Member, Committee on Govt Reform,
     House of Rep., Washington, D.C. 20515
The Honorable Fred Thompson, Chairman, Committee on Govt Affairs,
     U.S. Senate, Washington, D.C. 20510
The Honorable Joseph Lieberman, Ranking Member, Committee on Govt Affairs,
     U.S. Senate, Washington, D.C. 20510
Cindy Fogleman, Subcomm. on Gen. Oversight & Invest., Room 212,
     O'Neill House Ofc. Bldg., Washington, D.C. 20515
The Honorable Dan Burton, Chairman, Committee on Govt Reform,
     House of Representatives, Washington, D.C. 20515
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human
     Resources, B373 Rayburn House Ofc. Bldg., Washington, D.C. 20515
Steve Redburn, Chief, Housing Branch, Office of Management and Budget
     725 17th Street, NW, Room 9226, New Exec. Ofc. Bldg., Washington, D.C. 20503
Inspector General, G
Uvalde Housing Authority
Texas State Auditor
Texas Department of Housing and Community Affairs
Mayor, Uvalde, Texas
Board Chairman of Authority
Board Chairman of Uvalde Housing Development Corporation




01-FW-203-1003                              Page 38