oversight

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)

                               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




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                                                                       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.”


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                                                                  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



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                                                                          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.




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                                                                   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


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                                                                    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


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                                                                         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

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                                                                                 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.



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                                                                           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.




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                            Attachment B

AUDITEE COMMENTS




                   13
                        2000-SE-209-1801
         Attachment B




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     2000-SE-209-1801
         Attachment B




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     2000-SE-209-1801
         Attachment B




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     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
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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.




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                                                                                 2000-SE-209-1801