AUDIT REPORT NEWPORT RESIDENT COUNCIL, INC. NEWPORT, RHODE ISLAND 2002-BO-1003 APRIL 30, 2002 OFFICE OF AUDIT, NEW ENGLAND BOSTON, MASSACHUSETTS Issue Date April 30, 2002 Audit Case Number 2002-BO-1003 TO: Donna Ayala, Director, Office of Public Housing, 1APH FROM: Barry L. Savill, District Inspector General, Office of Audit, 1AGA SUBJECT: Newport Resident Council, Inc. Newport, Rhode Island As requested by your office, we performed an audit of the Newport Resident Council, Inc.,(NRC). The overall objective of our audit was to determine if the NRC was administering its federal funds in an efficient, effective and economical manner and in compliance with the terms of its federal contracts and regulations. The NRC received $195,275 from the Housing Authority of the City of Newport, Rhode Island through the Comprehensive Grant Program and Tenant Services Program between August 1, 1999 and January 31, 2001. The NRC also received $70,000 from the City of Newport, Rhode Island through the Rhode Island Small Cities Community Development Block Grant for the Employment Readiness Program. Our audit disclosed the NRC did not establish accountability over these funds. Specifically, the NRC failed to maintain adequate accounting records and monitoring procedures resulting in $42,887 in questionable costs. These deficiencies occurred because the NRC Board of Directors did not effectively manage and account for its federal funds. Within 60 days, please provide us a status report for each recommendation listing: (1) the 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 because of this audit. If you have any questions, please contact our office at (617) 994-8380. Management Memorandum THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page ii Executive Summary As requested by your office, we performed an audit of the Newport Resident Council, Inc. (NRC). The overall objective of our audit was to determine if the NRC was administering all federal funds it received in an efficient, effective and economical manner and in compliance with the terms of its federal contracts and regulations. The NRC received funds from the Housing Authority of the City of Newport, Rhode Island (Authority) through the Comprehensive Grant Program and Tenant Services Program. The NRC also received funds from the City of Newport, Rhode Island (City) through the Rhode Island Small Cities Community Development Block Grant for the Employment Readiness Program. Our audit disclosed the NRC did not establish Audit Results accountability over all federal funds it received from the Authority and City, including Comprehensive Grant Program (CGP), Tenant Services Program and Employment Readiness Program funds, which as of January 31, 2001 totaled $265,275. Specifically, the NRC failed to maintain adequate accounting and monitoring records over Comprehensive Grant Program, Tenant Services Program and Employment Readiness Program funds provided by the Authority and City. We also noted $42,887 in questionable costs. The deficiencies occurred because the NRC Board of Directors did not effectively manage and account for its federal funds. Since the NRC received CGP and Tenant Services Program funds from the Authority, we recommend that you require the Authority to ensure that the NRC reimburses the Authority for all ineligible expenditures made from federal funds and that appropriate administrative action is taken against NRC individuals who improperly used federal funds. We also recommend that you require the Authority to ensure that the NRC evaluates the reasonableness and eligibility of all expenditures charged to the Comprehensive Grant Program and Tenant Services Program. Lastly, we recommend that you require the Authority to ensure that the NRC establishes fiscal accountability and effective management controls in regards to the use of federal funds. Page iii 2002-BO-1003 Executive Summary We discussed the findings in this report with the Authority Findings and and the NRC staff and Board members during the course of Recommendations the audit. On February 26, 2002, we provided the Discussed Authority and NRC a copy of the draft audit report for comment. We received the NRC’s written response on March 15, 2002 and the Authority’s response on March 25, 2002. We included their pertinent comments in the Finding section of this report. The NRC’s full response is included in Appendix C and the Authority’s full response is included in Appendix D. 2002-BO-1003 Page iv Table of Contents Management Memorandum i Executive Summary iii Introduction 1 Findings 1. Accountability for Federal Funds Not Established 7 Management Controls 13 Appendices A Schedule of Questioned Costs 15 B Questionable Credit Card Charges 17 C Questionable Check Disbursements 19 D Auditee Comments Newport Resident Council, Inc. 21 E Auditee Comments – Newport Housing Authority 24 F Distribution 27 Page v 2002-BO-1003 Table of Contents THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page vi Introduction The Newport Resident Council, Inc. (NRC) is an organization of and for residents of the public housing developments within the Housing Authority of the City of Newport, Rhode Island (Authority). As of May 17, 2001, the Authority had six developments with 1,096 units and 3,451 residents. The NRC’s mission is to provide programs and services to maximize residents’ dignity, respect, standard of living and quality of life. The Board of Directors is the governing body of the NRC. Any resident of a development managed by the Authority may join the NRC. The residents elect the fourteen members of the Board of Directors, which include the President of the Board and Development Representatives. The minimum number of Board members allowed is seven. The Board is responsible for overseeing the operation of the NRC and appointing an Executive Director who runs the day-to- day operations of the NRC. As of the time of our review, the NRC had no Executive Director and had effectively ceased operations. During the period of our review, NRC received funding from the Housing Authority, the City of Newport, RI and several non-federal sources. Funding for Newport Resident Council Newport Housing Authority Tenant Services Program 1% Newport Housing City of Newport Authority Employment Comprehensive Grant Readiness Program Program 67% 25% Non-Federal sources 7% Page 1 2002-BO-1003 Introduction THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 2 Introduction NRC Contracts with the Authority The Authority used its Comprehensive Grant Program (CGP) to fund a contract with the NRC. Under this contract NRC would provide services to low-income residents for the period of August 1,1999 to July 31, 2000. Tasks under this contract included: Ø outreach and organizing; Ø computer training; Ø job development training; and Ø workshops and seminars on skills training and development. NRC and the Authority entered into a one-year contract for August 1, 1999 and July 31, 2000 for $130,000 with an additional $12,133 for the purchase of laptop computers and $3,942 for other tenant-related services. When this contract expired, on July 31, 2000, the Authority did not enter into another contract because the Authority was not satisfied with the NRC’s performance. Although the contract had expired, the Authority agreed to continue funding NRC if the NRC could: (1) document their expenses and (2) demonstrate their achievement of the specified goals and objectives stated in the initial contract. Using funding from the Comprehensive Grant Program and the Tenant Services Program, the Authority provided another $49,200 to the NRC between August 1, 2000 and January 31, 2001. NRC also contracts with the City The City of Newport used its Small Cities Community Development Block Grant to fund a $70,000 contract with the NRC for job training under the Employment Readiness Program. The Employment Readiness Program exists to fill the gap left by traditional training programs that are not prepared to address many of the social, economic and educational problems impacting disadvantaged individuals and their families. NRC was contractually required to assist forty to fifty residents of the Authority and an additional ten to twenty low-income individuals from subsidized housing developments in the area. During the contract’s term of August 1, 1999 to July 31, 2000, NRC would teach various skills to residents such as: Ø shaking hands in the business world, Ø being responsible and dependable, Ø dressing in appropriate business attire, Ø conducting interviews, Ø writing a resume, Ø utilizing a telephone professionally Ø using a computer Non federal funding. NRC received almost $20,000 from non-HUD sources including national non-profit organizations, state-wide non-profit organizations and local fund raising efforts. Page 3 2002-BO-1003 Introduction Audit discovers problems NRC hired an independent public accountant to conduct an audit of its operations. Dated June 30, 2000, the audit report identified operational problems such as: Ø personal charges made to NRC credit cards, Ø loans to employees and board members, and the Ø absence of NRC credit card and travel policies. In January 2001, a second independent audit was scheduled by the Authority in response to allegations of credit card abuse by NRC personnel published in local newspapers. The NRC refused to provide records to the Authority subsequent to July 31, 2000. The NRC believed that the Authority had no justification for reviewing its records after July 31, 2000 because the contract between the Authority and the NRC had expired. As a result, the Authority has refused to provide additional funds to the NRC until an audit is completed. In February 2001, the Massachusetts Office of Public Housing requested that our office audit the NRC’s books and records. The overall objective of our audit was to determine if the Audit Objectives NRC was administering all federal funds it received in an efficient, effective and economical manner and in compliance with the terms of its federal contracts and regulations. To accomplish our audit objective, we: Audit Scope and Methodology Ø Obtained and reviewed the NRC’s contracts with the Housing Authority of the City of Newport, Rhode Island and the City of Newport, Rhode Island, and federal regulations. Ø Obtained and reviewed the independent audit report dated June 30, 2000; Ø Reviewed the NRC’s financial records of cash receipts and disbursements; Ø Selected and reviewed a sample of 119 out of 502 check disbursements made between August 1999 through January 2001 to determine whether items were reasonable and necessary under the contract and were adequately supported. We determined that a non- 2002-BO-1003 Page 4 Introduction representational sample was appropriate for testing the allegations. Ø Reviewed petty cash account transactions between August 1999 and January 2001 to determine the nature and reasonableness of expenditures; Ø Determined whether NRC staff and members of the Board of Directors have repaid all loans from NRC funds identified during our audit period; Ø Reviewed the NRC's credit card policies and procedures to determine if policies and procedures are reasonable, adequate and comply with federal regulations governing the funding; Ø Reviewed all credit card charges between August 1999 and January 2001 to determine if the charges were reasonable and necessary for the operation of the NRC and in compliance with the contracts and federal regulations; Ø Evaluated the reasonableness and eligibility of all out-of-state travel costs charged to HUD programs between August 1999 and January 2001; Ø Inventoried the laptop computer equipment purchased with HUD funds; Ø Held discussions with NRC staff, the President of the Board of Directors, the NRC’s independent auditors, the NRC’s attorney, and the HUD Massachusetts State Office of Public Housing staff. We conducted our audit at the NRC’s office located in Newport, Rhode Island. Our audit covered the period between August 1, 1999 and January 31, 2001. Where appropriate, the review was extended to include other periods. Audit work was performed from February 2001 through March 2001. Our audit was conducted in accordance with generally accepted government auditing standards. Page 5 2002-BO-1003 Introduction THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 6 Finding 1 Accountability for Federal Funds Not Established The Newport Resident Council, Inc. (NRC) did not establish accountability for HUD funds. The NRC failed to maintain adequate accounting records and failed to perform their contractual obligation. As a result, the NRC is unable to assure either the Authority or the City that charges to its programs are reasonable, eligible and effectively utilize limited federal funds. These deficiencies occurred as a result of the NRC’s Board of Directors’ inability to effectively manage and account for its federal funds. Between August 1999 and January 2001, NRC incurred questionable costs of $42,887. The NRC’s contract with the Authority requires NRC to Adequate Financial comply with all applicable federal and state financial audit Management System requirements pertaining to non-profit organizations. The Required NRC’s contract with the City also requires that the NRC comply with federal regulations including OMB Circular A-110 Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations. In Subpart C paragraph 21 (b) 2, 3, and 7, OMB Circular A- 110 states that recipients’ financial management systems shall provide for: (2) Records that identify adequately the source and application of funds for federally sponsored activities. These records shall contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, outlays, income, and interest . . . (3) Effective control over and accountability for all funds, property, and other assets. Recipients shall adequately safeguard all such assets and assure that they are used for authorized purposes . . . (7) Accounting records including cost accounting records that are supported by source documentation. NRC’s accounting records were not accurate because expenses were not accurately posted to the accounting records. The NRC received $265,275 in HUD funds and almost $20,000 from various other non-HUD sources Page 7 2002-BO-1003 Finding 1 including national non-profit organizations, state-wide non- profit organizations and local fund raising efforts. Although the NRC received $285,275 between August 1, 1999 and January 31, 2001, it expensed $292,945 or $7,670 more than it received. Amount Amount Expensed Funding Source Funded on Books Difference Comprehensive Grant Program $191,333 $229,084 ($37,751) Tenant Services $3,942 $4,911 ($969) Employment Readiness Program $70,000 $51,513 $18,487 non-federal sources $20,000 $7,437 $12,563 Total $285,275 $292,945 ($7,670) Between August 1999 and January 2001, NRC charged $41,938 on their credit cards. During this same period, it expensed $20,629, posted $13,882 to their Accounts Payable and did not account for the remaining $7,427. However, when we manually calculated the amount of credit card charges not recorded as Accounts Payable between November 2001 and January 2001, we found that $7,591 was not recorded. NRC personnel were unable to reconcile or explain the difference between the $7,427 and $7,591. Between August 1999 and January 2001, NRC paid Questionable Expenditures $42,887 in questionable expenditures. Of this amount Paid $26,342 represented credit card charges (Appendix B) and $16,545 represented check disbursements (Appendix C). OMB Circular A-122, Cost Principles for Non-Profit Organizations advises that allowable costs must be reasonable for the performance of the award, allocable to the award and adequately documented. To determine the reasonableness of a given cost, consideration shall be given to whether the cost is of a type generally recognized as ordinary and necessary for the operation of the organization or the performance of the award. 2002-BO-1003 Page 8 Finding 1 The $26,342 of questionable credit card charges included Used Credit Cards for personal expenses of the NRC’s former Executive Director Personal Expenses such as meals, hotel lodging, flowers, grocery, alcohol, and jewelry. NRC also made purchases for events such as staff birthdays, going-away parties, Secretary’s Day, Valentine’s Day, and the wedding of a relative of a Board member. There was no supporting documentation available to evidence that any of the $26,342 in credit card charges were necessary for the performance of NRC’s federally funded programs. Attachment A lists these questionable expenditures. The $16,545 of questionable disbursements by check Questionable Check included cash bonuses to the NRC’s former Executive Disbursements Director, NRC staff members, volunteers, and members of the Board of Directors; and loans to NRC staff and Board members. In addition, proper supporting documentation was not available for services such as cleaning, instructor fees, and bookkeeping, as well as, trips made by NRC staff, and meal reimbursements. Attachment B shows a listing of these questionable expenditures. Prior to August 2000, the NRC did not have a credit card Credit Card Policy not in policy. When the NRC promulgated a credit card policy in Accordance with Federal August 2000, it contradicted federal regulations by stating, Regulations in part: Purchases of items for personal use, which are of a non- business nature, is not allowed without direct authorization of the Board of Directors or the Executive Director. OMB Circular A-122, Attachment B, paragraph 18 specifically states that: costs of goods or services for personal use of the organization's employees are unallowable regardless of whether the cost is reported as taxable income to the employees. NRC’s policy should be revised to prohibit this practice under all circumstances. The NRC issued three credit cards: (1) NRC’s former Accrual of Credit Card Executive Director, (2) President of the Board of Directors, Finance Charges and (3) the Office Manager. Between August 1999 and January 2001, $41,938 was charged to these cards. The unpaid balance in January 2001 totaled $8,055. However, the NRC bank account as of February 2001 showed only Page 9 2002-BO-1003 Finding 1 $3,497 in funds available, which is approximately $4,500 less than the credit card balance. With no active funding sources, the NRC will continue to needlessly incur interest expenses on the credit cards. Prior to August 2000, the NRC did not have a travel policy. Travel Policies Not However, subsequent to August 2000 when NRC Enforced developed a policy they did not follow or enforce their policy. Our review disclosed that NRC employees received travel advances, but did not reconcile actual travel costs with the advances. As a result, NRC staff used credit cards to pay travel-related expenditures for which they had previously received an advance. NRC did not maintain adequate documentation to identify the traveler, identify the purpose of the trip, or compute actual expenditures less any travel advances. Supporting documentation typically consisted of either a check requisition form or a memo from the NRC’s former Executive Director regarding the trip. NRC’s Board of Directors was aware that the NRC’s Inadequate Oversight by former Executive Director was using NRC resources for Board personal expenses. In October 2000, the Board of Directors discussed the significant amount of personal charges on the credit cards with the NRC’s former Executive Director and requested that he sign a repayment agreement. According to the President of the Board of Directors, the former Executive Director acknowledged to the Board that he used the credit cards for personal reasons and he refused to sign the repayment agreement. Although the Board was aware of the personal charges and the former Executive Director’s refusal to sign a repayment agreement, the Board did not remove the credit cards from the former Executive Director’s possession until January 2001. Failure to close the credit card accounts allowed the former Executive Director to charge an additional $6,880 in questionable costs after October 2000. 2002-BO-1003 Page 10 Finding 1 As a result of the lack of accountability, the NRC is unable to Improvements Needed assure the Authority and HUD that its expenditures are reasonable, eligible, and an effective use of limited Federal funds. The NRC Board of Directors needs to ensure: Ø accountability over all Federal funds, Ø policies and procedures are appropriate, implemented, and comply with Federal regulations. Auditee Comments Authority and NRC Comments As the NRC is funded by HUD through the Authority, both the Authority and the NRC were given the opportunity to comment on the report. A complete text of the Authority’s response is available in Appendix B and a complete text of the NRC’s response is available in Appendix C. Both the Authority and the NRC advise that they have implemented a system to avoid re-occurrence of the questionable expenditures. Both the NRC and the Authority believe that individuals should be held accountable for their actions. Both the Authority and the NRC contend that they will be unable to determine the eligibility of expenditures with the available records when professional auditors are unable to determine eligibility. Both the Authority and NRC contend that the NRC has no substantial source of funds other than HUD funds therefore reimbursement from non- federal funds is not practical. Additional Comment by the Authority The Authority noted that it made the request to HUD for an audit to assist with dealing with stone-walling of the former Executive Director and it continues to request HUD’s assistance to impose appropriate sanctions as recommended. Additional Comment by the NRC The NRC contends that the Board instructed the employees to no longer use the credit cards when it learned of questionable expenditures. The NRC’s response also Page 11 2002-BO-1003 Finding 1 contends that the Board had no reason to believe its instructions would not be followed. OIG Evaluation of The new system to avoid re-occurrence of questionable Auditee Comments expenditures needs to be evaluated by HUD to ensure recurrence is avoided. Individuals should be held accountable for their actions. Expenditures whose eligibility cannot be proven should be reimbursed to the program. NHA and NRC should pursue their plan to obtain reimbursement from individuals. Repayment of remaining funds should be discussed with HUD. NRC contends that it did not know that its instructions would not be followed. The existence of questionable expenditures gives reason to believe that instructions would not be followed. Recommendations We recommend that you require the Authority to: 1A. Require the NRC to reimburse the Authority for all ineligible costs. 1B. Impose appropriate administrative sanctions against individuals who improperly used federal funds. 1C. Require the NRC to provide your staff documentation of the amount, the eligibility and the reasonableness of all expenditures 1D. Require the Authority to ensure that NRC establishes fiscal accountability and effective management controls to assure that Federal funds are used effectively and efficiently. 1E. Require the NHA to monitor the performance of its contractors to ensure that all expenditures are reasonable for the performance of the contract and accurately reflect expenditures necessary to the contract. 2002-BO-1003 Page 12 Management Controls In planning and performing our audit, we considered management controls of the Newport Resident Council, Inc. (NRC) as specifically related to funding provided by the Housing Authority of the City of Newport, Rhode Island (Authority) and by the City of Newport, Rhode Island (City). We evaluated management controls to determine our auditing procedures to be used, and not to provide assurance on management controls. Management controls consist of a plan or organization and methods and procedures adopted by management to ensure that resource use is consistent with laws, regulations, and policies; that resources are safeguarded against waste, loss, and misuse; and that reliable data is obtained, maintained, and fairly disclosed in reports. We determined the following management controls were Relevant Management relevant to our audit objectives: Controls Ø Financial controls over program funding Ø Management controls over program expenditures Ø Policies and procedures over travel and credit card usage A significant weakness exists if management controls do Assessment Results 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 is obtained, maintained, and fairly disclosed in financial statements and reports. Our review identified significant weaknesses at the NRC Significant Weaknesses including their lack of accountability over HUD funds received from the Authority and the City. Specific weaknesses were identified in all of the management control areas discussed above. These weaknesses are described in the Finding section of this report. Page 13 2002-BO-1003 Management Controls THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 14 Appendix A Questioned Costs Finding 1 Amount Questionable Disbursements via check, Details in Appendix B $26,342 Questionable Disbursements via credit card, Details in Appendix C $16,545 Total $42,887 Page 15 2001-BO-1003 Appendix A THIS PAGE LEFT BLANK INTENTIONALLY 2001-BO-1003 Page 16 Appendix B Questionable Credit Card Charges Category Amounts Cash Advances $ 9,093 Local Meals 3,925 Local Hotels 1,975 Hotel charges for out-of-state travel (includes movies, phone, parking) 1,689 Department Store Purchases 1,542 Other Purchases 1,158 Meals for out-of-state travel 1,078 Finance Charges/Late Payment Charges/Cash Advance Fees 974 Cash Advances for out-of-state travel (including ATM fees) 921 Jewelry Store Purchases 842 Grocery Store Purchases 701 Transportation costs for out-of-state travel 501 Video Store Purchases 392 Pharmacy Purchases 344 Liquor Store Purchases 303 Merchandise/Department Store Purchases for out-of-state travel 243 Other Purchases for out-of-state travel 207 Music Store Purchases 189 Flower Shop Purchases 81 Toy Purchases 75 Alcoholic Beverages for out-of-state travel 45 Convenience Stores/Gas Station Purchases 34 Gas for out-of-state travel 30 Totals $26,342 Page 17 2002-BO-1003 Appendix B THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 18 Appendix C Questionable Check Disbursements Description Amount 1999 Bonus to Executive Director $ 5,000 Loans to NRC staff and Board Members 2,500 Payments for Services (bookkeeping, cleaning, instructors, landscaping) 2,480 Trips made by NRC staff and food reimbursements 2,070 2000 Christmas bonus to Board Members ($675)and volunteers ($400) 1,075 Payments for volunteer services 760 1999 Christmas bonus to Board Members ($500) and volunteers ($250) 750 1999 Christmas bonus to NRC staff members 700 Flowers 609 2000 Christmas bonus to NRC staff members 450 Charitable contribution 100 Pantyhose 26 NRC staff member parking ticket 25 Total $16,545 Page 19 2002-BO-1003 Appendix C THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 20 Appendix D Auditee Comments Newport Resident Council, Inc. Page 21 2002-BO-1003 Appendix D 2002-BO-1003 Page 22 Appendix D Page 23 2002-BO-1003 Appendix E Auditee Comments Newport Housing Authority Page 24 2002-BO-1003 Appendix E Page 25 2002-BO-1003 Appendix E THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 26 Appendix F Distribution Outside of HUD Chairman, Committee on Governmental Affairs, 340 Dirksen Senate Office Building, United States, Senate, Washington, DC 20510 Ranking Member, Committee on Governmental Affairs, 706 Hart Senate Office Building, United States Senate, Washington, DC 20510 Chairman, Committee on Government Reform, 2185 Rayburn Building, House of Representatives, Washington, DC 20515 Ranking Member, Committee on Government Reform, 2204 Rayburn Building, House of Representatives, Washington, DC 20515 Subcommittee on Oversights and Investigations, Room 212 O’Neil House Office Building, Washington, DC 20515 Director, Housing and Community Development Issue Area, United States General Accounting Office, 441 G Street NW, Room 2474, Washington, DC 20548 Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human Resources, B373 Rayburn House Office Building, Washington, DC 20515 Chief, Housing Branch, Office of Management & Budget, 725 17th Street, NW, Room 9226, New Executive Office Building, Washington, DC 20503 Page 27 2002-BO-1003 Appendix F THIS PAGE LEFT BLANK INTENTIONALLY 2002-BO-1003 Page 28 Filename: ig211003.pdf Directory: D:\backup\REPORTS Template: C:\WINNT\Profiles\caroliv\Application Data\Microsoft\Templates\Normal.dot Title: The following audit report content requirements are presented herein to better illustrate the required audit report format Subject: Author: HUDware IIa Test User Keywords: Comments: Creation Date: 4/30/02 4:49 PM Change Number: 3 Last Saved On: 4/30/02 4:53 PM Last Saved By: Vincenta Carolina Total Editing Time: 4 Minutes Last Printed On: 4/30/02 5:01 PM As of Last Complete Printing Number of Pages: 36 Number of Words: 4,072 (approx.) Number of Characters: 23,214 (approx.)
Newport Resident Council, Inc. Newport, Rhode Island
Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-04-30.
Below is a raw (and likely hideous) rendition of the original report. (PDF)