U. S. Department of Housing and Urban Development Washington, D.C. 20410-4500 Office of the Inspector General for Audit Northwest/Alaska 909 First Avenue, Suite 125 Seattle, WA 98104-1000 Phone 206-220-5360 Fax 206-220-5159 Audit-Related Memorandum 2000-SE-209-1801 January 19, 2000 MEMORANDUM FOR: Lynn Martin, Director, Office of Public Housing, OAPH FROM: Frank E. Baca, District Inspector General for Audit, 0AGA SUBJECT: Seattle Housing Authority Holly Park Hope VI Revitalization Complaint Alleging Conflict Of Interest In response to a citizen’s complaint, we conducted a limited review of the Holly Park HOPE VI project. The complaint alleged that the Seattle Housing Authority (Authority) violated HUD conflict of interest requirements when it awarded contracts for the Holly Park implementation. Our review found that the Authority did not comply with HUD conflict of interest requirements in awarding two of these contracts, and another contract not included in the complaint. Specifically, the Authority awarded these three contracts to firms whose principals had inside knowledge of the project. This occurred because the Authority either ignored or was unaware of the conflict of interest provisions included in the HOPE VI planning and implementation Grant Agreements. These provisions prohibited the Authority from awarding contracts to individuals in a position to gain inside information. Conflicts of interest may jeopardize public trust in government and affect the impartiality of contract awards. Attachment A discusses in detail the results of our review. We submitted the draft memorandum to the Seattle Housing Authority for comments on October 19, 1999. We received written comments from the Authority on November 4, 1999, and discussed the draft report with Authority officials at an exit conference on December 15, 1999. We reviewed and evaluated the auditee’s comments. Attachment A includes a summary of the Authority’s comments and our evaluation. The Authority’s written comments are included in their entirety in Attachment B. Within 60 days please furnish us, for the recommendation in this report, a status report on: (1) the corrective action taken; (2) the proposed corrective action and the date to be completed; or (3) why action is considered unnecessary. Also, please furnish us copies of any correspondence or directives issued because of the review. If you have any questions, please call me or Robert Woodard, Assistant District Inspector General for Audit, at 206-220-5360. Attachments Attachment A Results of Review In response to a citizen’s complaint, we conducted a limited review of the Holly Park HOPE VI project. The complaint alleged that the Seattle Housing Authority (Authority) violated HUD conflict of interest requirements when it awarded contracts for Program Management, Financial Management Consultant, and Property Management services for the Holly Park implementation. Our review found the complaint to be partially valid. The Authority did not comply with HUD conflict of interest requirements in awarding two of these contracts: Program Management Services and Financial Consulting Services. In addition, our review disclosed that another contract not included in the complaint, for Property Management Consulting Services, was not awarded in compliance with HUD conflict of interest requirements. Specifically, the Authority awarded these three contracts to firms whose principals had inside knowledge of the project. The principals had obtained inside knowledge by having been members of a panel that had evaluated a developer’s proposal for implementing the redevelopment. This occurred because the Authority either ignored or was unaware of the conflict of interest provisions included in the HOPE VI planning and implementation Grant Agreements. These provisions prohibited the Authority from awarding contracts to individuals in a position to gain inside information. Conflicts of interest may jeopardize public trust in government and affect the impartiality of contract awards. Background The HOPE VI HUD’s Urban Revitalization Demonstration program, known as program HOPE VI, was created to revitalize severely distressed or obsolete public housing developments. Funding for HOPE VI grants is authorized by each Fiscal Year’s Notice of Funding Availability (NOFA), as published in the Federal Register. In August 1994 HUD awarded the Seattle Housing Authority The Holly Park (Authority) $500,000 to plan the revitalization of the Holly Park Redevelopment public housing community. In February 1995 HUD awarded the Project Authority $47,116,503 to carry out the the Holly Park Redevelopment Project. Holly Park is a low-income public housing community located in Southeast Seattle. The South Seattle area is beset with high unemployment, high crime rates, and gang activity. The revitalization plan is to replace the existing 893 old public housing units with 1,200 units of new, mixed income housing. August 4, 1994 and February 2, 1995. HUD awards the Authority Chronology of HOPE VI planning and implementation grants, respectively. HOPE VI contract awards February 15, 1995. The Authority issues a nationwide Request for Proposal for an overall developer to implement the Holly Park 2 2000-SE-209-1801 Attachment A redevelopment. Only one firm, McCormack Baron and Associates of St. Louis, Missouri, responded to the Request for Proposal. Sept-Oct 1995. The Authority convened a Panel of Experts to study McCormack Baron’s proposal and recommend alternatives. The pro bono Panel of Experts consisted of 14 consultants, including designers and developers, tax credit equity financing experts, bond counselors and underwriters, property managers, real estate appraisers, and home buyer marketers. November 27, 1995. In line with the Panel of Experts’ recommendations, the Authority rejected McCormack Baron’s proposal. Instead the Authority assumed the role of overall developer. 1996-97. The Authority issued Requests for Proposals and subsequently awarded contracts to local firms for Program Management, Financial Management Consultant, Property Management Consultant, and Property Management services. Our office received a citizen’s complaint (March 10, 1999, and an The complaint addendum dated April 9, 1999) alleging that the Authority violated conflict of interest requirements when it awarded contracts for Program Management, Financial Management Consultant, and Property Management services for the Holly Park implementation. Specifically, the complaint alleged that the conflicts of interest occurred because: • Two partners of Lorig Associates, L.L.C., in their roles as boardmember of the Authority and review panelist for the contract proposals, respectively, participated in the award of the developer contract to Popkin Development. The alleged conflict of interest occurred because Weinstein Copeland Architects, named in Popkin’s bid as part of the Development Team, were retained by Lorig Associates between May 1994 and May 1996 to do the design work for a multimillion dollar project. • At least five members of the Panel of Experts wound up with lucrative contracts to do the Holly Park project. The complaint states: “In effect, a group of local developers, contractors, and consultants, in their capacity as SHA appointees - key insiders - recommended to SHA that they hire locally. These same insiders then turned around as local bidders to bid for and obtain these lucrative contracts to do the Holly Park Project.” 3 2000-SE-209-1801 Attachment A In addition, the complaint alleged the Authority’s awarding of the Program Management contract to Popkin Development was irregular in that the Authority only interviewed one of six project applicants. Also, the complaint stated that most of the other companies bidding for the development contract had more experience in low income housing development than either Popkin or Weinstein Copeland. The purpose of our review was to determine if conflict of interests Review objectives occurred in the Authority’s awarding of the HOPE VI contracts. We and methodology also reviewed the contract awards to determine if they complied with HUD procurement requirements. To achieve the review objectives we: 1. Reviewed the complaint and interviewed the complainant. 2. Reviewed the Planning Grant Agreement and the Implementation Grant Agreement. 3. Reviewed HUD procurement requirements, and examined the Authority’s procurement process for compliance with HUD requirements for the major Holly Park contracts. 4. Obtained advice from the Office of Inspector General’s legal counsel regarding conflict of interest requirements. 5. Interviewed appropriate Authority personnel and Panel of Experts members for their understanding of HUD requirements and any attendant circumstances. The Code of Federal Regulations (24 CFR 85.36 (b)(3)) states in Conflict of interest part: requirements “No employee, officer or agent of the grantee or subgrantee shall participate in selection, or in the award or administration of a contract supported by Federal funds if a conflict of interest, real or apparent, would be involved. Such a conflict would arise when: (i) The employee, officer or agent, (ii) Any member of his immediate family, (iii) His or her partner, or 4 2000-SE-209-1801 Attachment A (iv) An organization which employs, or is about to employ, any of the above, has a financial or other interest in the firm selected for award.” Also, the Planning and Implementation Grant Agreements between the Seattle Housing Authority (SHA) and the Department of Housing and Urban Development for the Holly Park project state: “1. In addition to the conflict of interest requirements in 24 CFR part 85, no person who is an employee, agent, consultant, officer, or elected or appointed official of the Grantee and who exercises or has exercised any functions or responsibilities with respect to activities assisted under this HOPE VI grant, or who is in a position to participate in a decision- making process or gain inside information with regard to such activities, may obtain a financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has family or business ties, during his or her tenure or for one year thereafter. 2. HUD may grant an exception to the exclusion in paragraph 1 of this Article on a case-by-case basis when it determines that such an exception will serve to further the purposes of HOPE VI and its effective and efficient administration.” In February 1995, the Authority issued a nationwide Request for The Panel of Proposal (RFP) for a master developer to implement the Holly Park Experts HOPE VI project. Only McCormack Baron & Associates submitted a response to the RFP. Authority officials stated that, because there was only one proposal received they wanted to take every precaution and get all the expert advice that was available. To obtain advice from local experts in various fields, the Authority’s Director of Development, assembled a pro bono Panel of Experts to evaluate the responding developer’s proposal from all aspects; development, financing, legal, marketing investing, and marketing studies. 5 2000-SE-209-1801 Attachment A According to Authority officials, the Panel of Experts was formed primarily to evaluate the proposal of the developer and then to propose alternatives for the Project. The Authority wanted alternatives because it believed the developer’s proposal did not contain enough information and the developer may not be willing to assume any risk for the Project. The Authority invited local experts from different relevant disciplines to form a panel for the purposes of gathering and evaluating critical market data and strategic input regarding the Project. The Panel of Experts consisted of three designers and developers, three tax credit equity financing experts, a bond counsel and a bond underwriter, three property managers, a real estate appraiser, and a home buyer marketer. The Authority also hired a consultant to facilitate meetings and discussions with the Panel of Experts. On October 26, 1995, the consultant submitted the Panel of Expert’s Development, Financing, and Implementation Report for the Project to the Authority. According to the report, various members of the Panel of Experts attended a series of six meetings dealing with the Project from September 8, 1995 through October 18, 1995. Other attendees at these meetings included Authority Board members, officers and staff, and representatives of Holly Park residents. One of the report’s recommendations was that the Authority itself assume the role of master developer for the Project while relying on third party developers for the development and construction of the Project. Based on this recommendation, the Authority became the master developer for the Holly Park project, and rejected McCormack Baron’s offer. After rejecting McCormack Baron’s offer, the Authority issued four The Authority Requests For Proposals for Program Management, Financial awards HOPE VI Management Consulting, Property Management Consulting, and contracts Property Management services. After review panels appointed by the Authority evaluated and rated the applicant responses to the RFPs, the Authority awarded the following contracts to: • Popkin Development for Program Management services on April 11, 1996 ($337,000), • Devine and Gong, Inc. for Financial Consultant services on 6 2000-SE-209-1801 Attachment A April 11, 1996 ($289,000), • Pinnacle Realty Management for Property Management Consultant services on August 27, 1996 ($25,000), and • Quantum Management for Property Management services on December 8, 1997 ($68,550). The review found the complaint to be partially valid: The complaint was partially valid Regarding the allegation that there was a conflict of interest when two partners of Lorig Associates L.L.C. participated in the award of the developer contract to Popkin Development: In our opinion, there was no evidence that the Authority violated HUD conflict of interest requirements. For there to be a conflict under the HUD regulations at 24 CFR (b)(3), whether real or apparent, the individual would have to have “...a financial or other interest in the firm selected for award.” To have a financial or other interest such as to create a conflict of interest, the individuals would need a reason to be biased in the contract award decision, such as to obtain a financial benefit or some other benefit. The mere fact of awarding the contract to Popkin Development, who in turn sub- contracts with Weinstein Copeland, does not appear to confer any benefit on the individuals. To our knowledge, the partners had no financial, ownership or familial interest in Weinsten Copeland; their only interest is a private, presumably arm’s length contractual relationship. That Weinstein Copeland might at some time give the partners gratuities or other favorable treatment in their private contractual dealings, solely because the partners participated in awarding the Holly Park contract to Popkin Development, who then sub-contracts with Weinsten Copeland, is too speculative for this situation to qualify as a conflict of interest, real or apparent. Regarding the allegation that there was a conflict of interest when at least five members of the Panel of Experts were subsequently awarded three Holly Park contracts: For two of the three contracts named in the complaint, plus a fourth contract not mentioned in the complaint, we concluded that the Authority violated conflict of interest requirements. The Authority awarded contracts for Program Management and Financial Management Consulting services (included in the complaint), and Property Management Consulting services (not included in the 7 2000-SE-209-1801 Attachment A complaint) to three companies. Four principals of these three firms had acted as consultants on the Panel of Expert less than one year prior to the contract awards and were in a position to gain inside information about the Holly Park project. This violated the conflict of interest provisions under the Grant Agreements. For one contract (Property Management services), the Authority awarded the contract more than one year after the one of the firm’s principals served as a Panel of Experts member, and therefore the Authority did not violate conflict of interest requirements in that instance. Regarding the allegation that the Authority’s awarding of the Program Management contract to Popkin Development was irregular in that the Authority only interviewed one of six project applicants, and most of the other companies bidding for the development contract had more experience in low income housing development than either Popkin or Weinstein Copeland: The Authority complied with HUD procurement requirements in awarding the HOPE VI contracts. For the program management contract, the Authority, in accordance with its policies and procedures and consistent with federal procurement requirements, evaluated and rated the six applicants and selected the highest rated applicant, which was Popkin Development. The Authority interviewed Popkin subsequent to the evaluation and rating process. Authority officials told audit staff that some members of the Panel of The Authority Experts asked if service on the Panel would preclude the members’ states it was not firms from later participating in the Holly Park project. The aware of the Grant Authority’s General Counsel said she told the Panel members they Agreements’ could serve on the Panel of Experts and still participate in the conflict of interest project. According to the Authority’s General Counsel, she did not provisions believe the conflict of interest existed because: 1. None of the Panel members was involved in awarding any contracts, 2. The Panel members were not paid for their services, and 3. The report issued by the Panel was made available to the general public. The Authority’s Counsel said she based her opinion on the conflict of interest requirement per the Code of Federal Regulations (24 CFR 85.36 (b)(3)). However the Authority’s Counsel did not refer to, and was apparently unaware of the more stringent conflict of interest requirements included in the HOPE VI Grant Agreements, which preclude individuals who are in a position to gain inside information from participating in the HOPE VI project for a one 8 2000-SE-209-1801 Attachment A year period. There is no excuse for the Authority not being familiar with, and following the Grant Agreement provisions, especially for grants of this magnitude. Conflicts of interest can lead the public to infer unethical behavior in both the private and public sectors. This jeopardizes the trust that citizens place in their government and adversely affects the credibility of the government agencies which manage public funds. Also, the conflicts of interest may have affected the outcome of the Holly Park contract awards, marring what should have been an impartial process. Auditee Comments The Authority responded in writing to the draft report in a and OIG Evaluation November 4, 1999 letter (Appendix B). Authority response: The Authority disagreed that it violated the conflict of interest Conflict of interest provisions contained in the HOPE VI Implementation Grant Agreement. The Authority indicated it correctly interpreted the conflict of interest provision which HUD clarified in HUD’s subsequent HOPE VI Grant Agreements. The Executive Director quoted the Roxbury HOPE VI Grant Agreement conflict of interest provision, which states: “In addition to the conflict of interest requirements in 24 CFR part 85, no person who is an employee, agent, consultant, (but excluding an independent contractor) officer, or elected or appointed official of the Grantee...(A person who is, or was, an independent contractor to the Grantee is not covered by this conflict of interest provision and, therefore, is not barred by this provision from competing for further contracts) (emphasis added) Article XIV, FY 1998 Revitalization Grant Agreement” The Authority claimed that this is “a clear indication that HUD’s intent in the Holly Park Agreement was not to exclude independent contractors like the Panel of Experts from bidding on future redevelopment -related projects.” OIG evaluation: We disagree. As stated in the report, during the audit the Conflict of interest Authority’s Legal Counsel indicated she was unaware of the Holly Park conflict of interest provision, and never mentioned the Roxbury provision. For the Authority to, after the fact, claim that they correctly interpreted the Holly Park provision based on the Roxbury “clarification” is unacceptable. 9 2000-SE-209-1801 Attachment A The Holly Park Grant Agreement clearly prohibits certain persons, including agents and consultants, from participating in Grant activities when those individuals had exercised some function or participated in a decision making process or gained some inside information with regard to such Grant activities. The OIG, as a separate matter, will evaluate the HOPE VI conflict of interest changes: however, the Holly Park agreement provisions are clear and straightforward. It should be noted that both HOPE VI agreements provided the Authority with the opportunity to obtain a waiver from HUD regarding the conflict of interest provision when a case is made that to do so will further the purposes of HOPE VI and its effective and efficient administration. Authority response: The Authority stated that the OIG’s misinterpretation of the Grant Adverse impact of Agreement language “...may very likely cause unfair and totally the OIG’s report undeserved damage to the agency and the Holly Park Redevelopment project...” As an example the Authority cited the OIG’s treatment of the “baseless allegations against Bruce Lorig and Associates.” The Authority states that the OIG’s report, if not corrected, “...will make it virtually impossible for any person or firm which may want to do business with the agency in the future to ever volunteer time and advice to the agency.” OIG evaluation: We disagree. Any adverse impact would be the result of the Adverse impact of Authority’s non-adherence to conflict of interest requirements. The the OIG report OIG has an obligation to make public disclosure of significant findings. Regarding Lorig and Associates, the draft report clearly stated there was no conflict of interest. Authority response: The Authority stated it had never undertaken a project of such Gaining business magnitude and complexity, and that one of the most valuable support and products of the Panel of Experts was to publicize and gain support expertise for the for the project. Further, the Authority indicated the participants Holly Park could not be considered as having a vested interest in who the redevelopment overall developer was since they could have performed work in connection with the redevelopment regardless of who the developer was. OIG evaluation: The OIG recognizes the difficulties and challenges the Authority has Gaining business in such a large undertaking, and believes the Authority is wise in support and trying to obtain local support for the project. Whether or not the expertise for the firms that obtained the contracts would have fared as well if Holly Park redevelopment 10 2000-SE-209-1801 Attachment A McCormack Baron had been the developer is speculative. This report simply points out that the Authority needs to be more aware of conflict of interest situations, whether real or apparent. Authority response: The Authority disagreed that the Panel of Experts were consultants Procurement or that participated in the Authority’s procurement process or any decision making decision making process for the Holly Park project. Instead, the Authority indicated members of the Panel of Experts were volunteers consisting of active professionals and businesspersons who agreed to participate in discussions with one another and share their expertise with the Authority as it tried to sort out its alternatives. OIG evaluation: We disagree. The Authority solicited the Panel of Experts to Procurement or augment the Authority’s staff capacity in evaluating a single decision making developer’s proposal, and to consider and recommend alternative Processes development options/strategies for the Authority so it could decide how to proceed with the Holly Park redevelopment. We believe that these actions represent a procurement function (i.e. evaluating the proposal from a technical and price standpoint). The Authority lacked experience in administering such a large project and used the Panel of Experts as a unique evaluation tool. The Authority then relied on the Panel of Experts’ recommendation when it decided to reject the single proposal and develop the project itself. Authority response: The Authority disagreed that the panel of experts members were Inside information privy to “insider information” which presumably gave them an advantage over their competitors when bids for work were later solicited. The Authority’s response states that inside information is information which is only known by persons inside an organization or with some sort of special relationship to the organization and unavailable to those on the outside. Their report was made available to all parties who submitted bids or proposals for work at Holly Park. Also, “...there is no evidence cited by the I.G. report nor does any exist that Panel members were shown favoritism in the procurement process which followed.” OIG evaluation: Whether the Panel of Experts members had access to inside Inside information information is something difficult to either prove or disprove. However, again, when dealing with conflict of interest issues appearances are a major concern. It is likely that people will assume that experts called upon to review highly complex and 11 2000-SE-209-1801 Attachment A technical issues, and develop alternatives and make recommendations, will be privy to insider information and have the opportunity to develop close relationships with the organization they are assisting. When panel members who serve as Authority advisors are subsequently awarded contracts for the same work for which they served as advisors, it is likely that people will assume there was favoritism involved. Whether or not the members in fact had insider information or were shown favoritism will not erase appearances to the contrary. It is unreasonable for the Authority to expect the OIG or HUD to prove the panel members had insider information. The Authority can avoid controversy by being aware of and following HUD conflict of interest requirements. Recommendation We recommend that the Office of Public Housing: 1A. Require the Authority to implement a policy to ensure that any decisions made by the Authority regarding conflict of interest issues are documented and retained with the related documents. 12 2000-SE-209-1801 Attachment B AUDITEE COMMENTS 13 2000-SE-209-1801 Attachment B 14 2000-SE-209-1801 Attachment B 15 2000-SE-209-1801 Attachment B 16 2000-SE-209-1801 Attachment C DISTRIBUTION Secretary’s Representative, 0S Director, Office of Public Housing, 0AHP (2 - 1 ea. Email and Hard Copy) Assistant Deputy Secretary for Field Policy and Management, SDF, (Rm 7108) (2 - 1 ea. Email and Hard Copy) Deputy Chief Financial Officer for Finance, FF, (Room 2202) Director, Office of Budget, FO, (Room 3270) Bettye Adams, Field Audit Liaison Officer, 6AF (Ft. Worth) (2 - 1 ea. Email and Hard Copy) Peter Schmiedel, Headquarters Audit Liaison Officer, PF, (Room P8202) (2 - 1 ea. Email and Hard Copy) Departmental Audit Liaison Officer, FM (Room 2206) (2 - 1 ea. Email and Hard Copy) Acquisitions Librarian, Library, AS (Room 8141) Principal Staff (list attached) The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, United States Senate, Washington, DC, 20510-6250 (Hard Copy) The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, United States Senate, Washington, DC 20510-6250 (Hard Copy) Honorable Dan Burton, Chairman, Committee on Government Reform, House of Representatives, Washington, DC, 20515-6143 (Hard Copy) Henry A. Waxman, Ranking Member, Committee on Government Reform, House of Representatives, Washington, DC, 20515-4305 (Hard Copy) Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O’Neil House Office Building, Washington, DC, 20515-6143 (Hard Copy) Director, Housing and Community Development Issue Area, United States General Accounting Office,441 G Street, NW, Room 2474, Washington, DC, 20548 (Attention: Judy England-Joseph) (Hard Copy) Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human Resources, B 373 Rayburn House Office Building, Washington, DC 20515 (Hard Copy) Mr. Harry Thomas The Seattle Housing Authority 120 Sixth Avenue North Seattle, WA 98109 PRINCIPAL STAFF LISTING Saul N. Ramirez, Jr., Deputy Secretary, SD, Room 10100 Jon J. Cowan, Chief of Staff, S, Room 10000 B.J. Thornberry, Special Assistant to the Deputy Secretary for Project Management, SD, Room 10100 Joseph Smith, Acting Assistant Secretary for Administration, S, Room 10110 Hal DeCell, Assistant Secretary for Congressional and Intergovernmental Relations, J, Room 10120 Ginny Terzano, Senior Advisor to the Secretary, Office of Public Affairs, S, Room 10132 Roger Chiang, Director of Scheduling and Advance, AL, 10158 Nancy-Kirshner-Rodriquez, Office of Intergovernmental Relations, JI, Rm. 10234 Rhonda Glickman, Deputy Chief of Staff, S, Room 10226 Todd Howe, Deputy Chief of Staff for Operations, S, 10226 Jackie Lawing, Deputy Chief of Staff for Programs and Policy, S, Room 10226 Patricia Enright, Deputy Assistant Secretary for Public Affairs, W, Room10226 Joseph Hacala, Special Assistant for Inter-Faith Community Outreach, S, 10222 Marcella Belt, Executive Officer for Administrative Operations and Management, S, Room 10220 Karen Hinton, Senior Advisor to the Secretary for Pine Ridge Project, W, 10216 Gail Laster, General Counsel, C, Room 10214 Armando Falcon, Office of Federal Housing Enterprise Oversight, O, 9th Floor Mailroom William Apgar, Assistant Secretary for Housing/Federal Housing Commissioner, H, Room 9100 Susan Wachter, Office of Policy Development and Research, R, Room 8100 Susan Gaffney, Inspector General, G, Room 8256 Cardell Cooper, Assistant Secretary for Community Planning and Development, D, Room 7100 Mary Madden, Assistant Deputy Secretary for Field Policy and Management, SDF, Room 7108 George S. Anderson, Government National Mortgage Association, T, Room 6100 Eva Plaza, Assistant Secretary for Fair Housing and Equal Opportunity, E, Room 5100 V. Stephen Carberry, Chief Procurement Officer, N, Room 5184 Harold Lucas, Assistant Secretary for Public and Indian Housing, P, Room 4100 Frank Davis, Director, Office of Departmental Operations and Coordination, I, Room 212 Gloria R. Parker, Chief Information Officer, Q, Room 3152 Office of the Chief Financial Officer, Rm. 2202 Richard Keevey, Chief Financial Officer, F, Room 2202 Edward Kraus, Director, Enforcement Center, V, 200 Portals Building Donald J. LaVoy, Acting Director, X, Real Estate Assessment Center, X, 1280 Maryland Avenue, SW, Suite 800 Ira Peppercorn, Director, Office of Multifamily Assistance Restructuring, Y, 4000 Portals Building All Principal Staff will receive this report via Email. The Deputy Secretary and the Chief of Staff will also received printed copies. 18 2000-SE-209-1801
Seattle Housing Authority, Holly Park Hope VI Revitalization, Complaint Alleging Conflict of Interest
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-01-19.
Below is a raw (and likely hideous) rendition of the original report. (PDF)