U.S. Department of Housing and Urban Development District Office of the Inspector General Office of Audit Richard B. Russell Federal Building 75 Spring Street, SW, Room 330 Atlanta, GA 30303-3388 (404) 331-3369 September 24, 2001 2001-AT-1806 MEMORANDUM FOR: Charles E. Gardner Director, Atlanta Homeownership Center, 4AHH SUBJECT: The Rain Foundation Titusville, FL Nonprofit Participation in FHA Single Family Insurance Program As part of a nationwide audit of the Federal Housing Administration’s (FHA) Single Family Insurance Program, we audited The Rain Foundation’s (Rain) purchase of Real Estate Owned (REO) properties. Our objectives were to determine whether Rain was legitimate and independent (not under the influence, control, or direction of other parties) and passed on the benefits of discounts received on the purchase of HUD homes to low and moderate-income homebuyers. We concluded that Rain was not independent and did not pass on benefits of discounts it received from HUD. Rain allowed a consultant and venture partners to influence and control most of the properties purchased from HUD. The arrangement created a conflict of interest and defeated HUD’s objective of increasing opportunities for affordable homeownership to low and moderate-income persons. Rain and/or the venture partners received excessive profits from the resale of the properties. For the 6 properties we reviewed, Rain received discounts of $45,593 from HUD. However, it discounted them a total of only $7,750 below fair market value, while turning a profit for itself and its partners of $65,035. Also, Rain sold two properties to ineligible buyers, was unable to properly account for property repairs, and submitted inaccurate information to HUD during its re-certification process. During our audit, HUD issued a 1-year removal action against Rain with an effective date of November 15, 2000. HUD found similar problems including use of joint venture agreements, conflicts of interest, and failure to pass on discounts to homeowners. We believe HUD’s action was appropriate. Since HUD has removed Rain from the program, we are making no further recommendations for corrective action. Exit We sent a draft of this audit memorandum to Rain on September 7, 2001. Rain provided oral comments on September 18, 2001 and written comments on September 19, 2001. Overall, Rain disagreed with our finding. If you have any questions, please contact James D. McKay, Assistant District Inspector General for Audit, at 404-331-3369. 2 Exit Background The Rain Foundation, Inc. is a nonprofit organization under section 501 (c)(3) of the Internal Revenue Code and was incorporated under Florida State law on November 10, 1997. Its office is located in Titusville, Florida. According to its By-Laws, Rain’s activities are exclusively charitable and educational, directed towards providing needed services, products, and financial assistance to persons in need, and to facilitate community outreach, affordable housing to lower income persons, and community development activities. Rain’s non-profit status allowed it to participate in the purchase of HUD owned properties. HUD’s discount sales program allows nonprofit organizations to purchase HUD owned properties at a discount up to 30 percent in revitalization areas and up to 15 percent in non- revitalization areas. HUD intended that the discounted sales would allow nonprofit agencies to rehabilitate the properties if necessary and then resell them to low and moderate-income homebuyers at a reduced, affordable price. A five-member Board of Directors governed Rain. The Board of Directors was responsible for managing the business and affairs of the organization, establishing policies, making rules and regulations for guidance of the officers and management of the organization, and appointing and supervising the president. The president was responsible for managing and implementing all program activities for Rain. Rain also used two consultants to help manage its affordable housing plan – a management consultant/administrative assistant and a project manager. The management consultant/administrative assistant was the financial analyst and determined the marketability and turnover of the properties. The project manager was responsible for overseeing the rehabilitation work and inspecting the properties. Below is a brief chronology of events pertaining to Rain’s participation in HUD’s FHA Insurance Program: • November 3, 1998, HUD approved Rain as a nonprofit organization to participate in the purchase of REO properties at a discount for a 2-year period. • December 2, 1999, HUD issued a Limited Denial of Participation (LDP) action against Rain and its president. One reason for the sanction was Rain’s use of joint ventures. HUD determined that Rain was not the true purchaser of the properties and that the joint venture entities through which it operated were not qualified to participate in the nonprofit program. • April 6, 2000, Rain and HUD entered into a Settlement Agreement to resolve the administrative sanction. HUD agreed to settle for time served the LDP action issued against Rain and its president. Rain agreed to comply with all HUD program requirements. • April 14, 2000, Rain submitted its re-certification package under Mortgagee Letter 00-08. 3 Exit • September 22, 2000, HUD issued a proposed removal letter to Rain after its review of the re-certification package and other information. One reason was Rain’s continued use of joint venture partners. • February 15, 2001, HUD issued a 1-year removal action against Rain with an effective date of November 15, 2000. Some of the reasons included use of joint venture agreements, conflicts of interest, and failure to adequately pass on discounts to homeowners. Rain was never approved under Mortgagee Letter 00-08. Rain has filed a motion with the Board of Contract Appeals seeking to enforce the settlement agreement. Rain contends HUD’s February 15, 2001 removal of Rain is a violation of the settlement agreement. During the period of January 1, 1998, through November 30, 2000, Rain purchased a total of 91 properties with total sales of $4,857,606 and total discounts of $577,902. Audit objectives, scope, and methodology Our audit objectives were to determine whether Rain was legitimate and independent (not under the influence, control, or direction of other parties) and passed on the benefits of discounts received on the purchase of HUD homes to low and moderate-income homebuyers. To accomplish our objectives, we conducted interviews with HUD officials, Rain’s management and consultant, profit-motivated entities involved in the purchase, rehabilitation and resale of the properties, and homebuyers. We also conducted public record searches and on-site reviews of the properties. Further, we reviewed HUD files on Rain, REO case files, property files maintained by Rain, records obtained from the profit-motivated entities, loan origination files, closing files, and Rain’s financial data. We selected six properties for review from HUD’s Single Family Asset Management System report. We selected the only 30 percent-discounted property Rain purchased and five 10 percent discounted properties. We focused on those properties Rain resold to homebuyers who obtained FHA insured mortgages. The audit included properties purchased by Rain from January 1, 1998, through November 30, 2000. We performed fieldwork from January 2001 through August 2001. 4 Exit Benefit of Discount Sales Not Provided to Low and Moderate Income Buyers Rain did not properly control and manage its affordable housing program. Rain allowed a consultant and venture partners to influence and control most of the properties purchased from HUD. The arrangement created a conflict of interest and defeated HUD’s objective of increasing opportunities for affordable homeownership to low and moderate-income persons. Rain and/or the venture partners received excessive profits from the resale of the properties. For the 6 properties we reviewed, Rain received discounts of $45,593 from HUD. However, it discounted them a total of only $7,750 below fair market value, while turning a profit for itself and its partners of $65,035. Also, Rain sold two properties to ineligible buyers, was unable to properly account for property repairs, and submitted inaccurate information to HUD during its re- certification process. Rain did not properly control and manage its affordable housing program Rain did not properly manage or oversee the operations of its affordable housing plan to ensure that HUD program objectives were being pursued and met. Rain improperly allowed a consultant and venture partners seeking to derive a profit from the program to influence, control, and manage its affordable housing program. Rain officials told us they used the joint venture arrangement because it did not have the administrative and financial capacity to buy, renovate, and sell the properties. They explained the arrangement placed the financial burden on the joint venture partners. Mortgagee Letter 96-52 requires a nonprofit to act on its own behalf and not be under the influence, control, or direction of any outside party seeking to derive a profit or gain from the proposed project, such as a landowner, real estate broker, contractor, builder, lender, or consultant. A nonprofit must have the administrative capability and financial capacity to develop and carry out its proposed affordable housing plan (Housing Notice 94-74, Attachment 1, Requirements 4 and 5; and Mortgagee Letter 96-52). Furthermore, HUD prohibits any person who is an employee, agent, consultant, officer, or an elected or appointed official or who is in a position to participate in a decision-making process or gain inside information from obtaining a personal or financial interest or benefit from the lease or purchase of the property, 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. (Title 24 of the Code of Federal Regulations (CFR) §291.5 (b)). Rain used a consultant to help it manage its program. Rain did not have a contract that specified the consultant’s duties, but Rain officials told us the consultant helped determine the marketability and turnover of the properties and located and obtained joint venture partners. Of the 91 properties Rain purchased during the audit period, 69 (or 76 percent) involved the use of joint venture partnerships. Five of the six properties we reviewed involved joint venture partnerships. Generally, the agreements specified that the partners were responsible for handling all phases of the purchase, rehabilitation, and resale of the properties. Furthermore, the agreements allowed the partners to set the resale prices. The agreements contained no requirement that the discounts be passed on to low and moderate-income homebuyers. In fact, the agreements stated the purpose of the venture was to purchase real property from HUD for the benefit of the venture, and to rehabilitate and sell the property at or below its fair market 5 Exit appraised value. The agreements specified the partners were entitled to all the profits from the sale of the property. Rain and the consultant shared fees derived from the HUD discount. Essentially, Rain had a limited role in the program and used its nonprofit status as a means to obtain the property from HUD at a discount. The consultant received over $275,000 for helping Rain administer the program and obtaining joint venture partners. The following chart shows they received $65,035 in fees and profits from the 6 properties we reviewed. Consultant Rain’s Rain’s Fees and Purchase Resale Rain’s Partner Property Address Price Price Fee Profit 7800 Pine Hawk Lane $40,800 $71,600 $ 936 $11,904 2103 Hartwell Avenue 32,900 67,000 1,000 9,725 5501 Elizabeth Rose Sq. 57,240 94,900 1,000 11,368 10449 Mayflower Road 36,900 55,000 6,500 4,262 1024 Galsworthy Ave 45,239 90,750 3,410 6,821 810 Arlington Street 33,150 75,500 5,950 2,159 Total $18,796 $46,239 Rain did not incur any risk in the purchase, rehabilitation, or resale of the joint venture properties, because Rain invested no monies in them. The partners financed the purchase by finding the lender and/or investing their own monies. Rain was the owner of title, and signed the mortgage note to obtain financing for the purchase while its partners guaranteed the loan. Several venture partners told us that Rain was not involved in overseeing the rehabilitation work on their properties or setting the resale price. Thus, the partners were allowed to determine the extent of repairs and set the sales price. One partner (involved in the 30 percent discounted property) stated that, had Rain dictated what he could charge, he would not have done business with them. He also stated Rain did not advise him the resale price could not exceed 110 percent of the net development cost. We interviewed the four homeowners who purchased homes controlled by venture partners. None of them knew that Rain was the seller, and all dealt with their realtor or the venture partner. Rain made no contact with them, and did not assist them in filling out paper work, in explaining the process, or with financial assistance. We identified other conflicts of interest in three of the six properties we reviewed. The director of Rain was also the Director of Rain Realty. Rain Realty collected a $2,722.50 commission on the sale of a property located on Galsworthy Avenue. The wife of a venture partner was a sales agent for the Arlington Street property. The sales commission was $2,642.50. A company owned by a venture partner received a $2,000 payment at closing from the purchaser on a property located at Mayflower Road. Discounts not passed on Although Rain received discounts of $45,593 from HUD, it sold the 6 properties at or near their appraised fair market value, passing along little, if any discount. 6 Exit Resale Rain’s Discount to Appraised Resale Discount to Property Address Rain Value Price Homeowner 7800 Pine Hawk Lane $ 7,200 $74,500 $71,600 $2,900 2103 Hartwell Avenue 14,100 67,000 67,000 5501 Elizabeth Rose Sq. 6,360 95,000 94,900 100 10449 Mayflower Road 4,100 55,000 55,000 1024 Galsworthy Ave 7,983 93,000 90,750 2,250 810 Arlington Street 5,850 78,000 75,500 2,500 Total $45,593 $7,750 Mortgagee Letter 97-5 states that for properties discounted in excess of 15 percent, the resale price cannot exceed 110 percent of the net development cost. If the sale price exceeds 110 percent of net development cost, the excess profit must be used to pay down the existing mortgage. Currently, HUD has no specific written restrictions on the resale of properties purchased at a discount of 15 percent or less. We compared Rain’s resale prices of the 6 properties to 110 percent of net development cost. Rain improperly sold the one 30 percent discount property for more than 110 percent of net development cost. Rain (or its partner) received an excess amount of $12,413 for the Hartwell property. While HUD does not limit the resale prices for properties purchased at a 10 percent discount, the comparison shows Rain (or its partners) sold the other 5 properties significantly higher than 110 percent of their net development costs. 110 Percent HUD of Net Discount Development Resale Excess Property Address Percentage Cost Price Amount 7800 Pine Hawk Lane 10 $57,312 $71,600 $14,288 2103 Hartwell Avenue 30 54,587 67,000 12,413 5501 Elizabeth Rose Sq 10 83,733 94,900 11,167 10449 Mayflower Road 10 42,200 55,000 12,800 1024 Galsworthy Ave 10 77,372 90,750 13,378 810 Arlington Street 10 67,835 75,500 7,165 As a further test, we also compared Rain’s resale prices to HUD’s as-repaired value from the REO appraisals. Our comparisons showed the resale price of the 6 properties ranged from 118 to 168 percent of HUD’s as-repaired value. 7 Exit HUD’s As- Rain’s Resale Price as a Repaired Resale Percentage of Property Address Value Price HUD’s Value 7800 Pine Hawk Lane $54,915 $71,600 130 2103 Hartwell Avenue 53,448 67,000 125 5501 Elizabeth Rose Sq. 77,725 94,900 122 10449 Mayflower Road 42,000 55,000 130 1024 Galsworthy Avenue 76,760 90,750 118 810 Arlington Street 45,000 75,500 168 As shown by these analyses, the discounts to Rain were not used to reduce the price of properties for the benefit of low and moderate-income homebuyers. The higher resale prices resulted in higher mortgages to the homebuyer leading to a higher monthly mortgage payment. This caused an undue financial burden on the low to moderate-income homebuyer. Ineligible purchasers Rain sold two properties to ineligible buyers. Rain purchased a property at 7800 Pine Hawk and received a $7,200 discount. Six months later Rain sold the property to another nonprofit and split the discount with consultants. HUD Handbook 4310.5 REV-2 §10-20 E (2) prohibits properties from being resold to an investor within 1 year of HUD’s closing. An investor is defined as a purchaser who does not intend to use the property as his or her principal residence (CFR §291.5 (b)). In another situation, Rain purchased a property at 5501 Elizabeth Rose Square and received a $6,360 discount. Rain sold the property to a purchaser whose income exceeded 115 percent of median area income. Mortgagee Letter 96-52 states the affordable housing program must serve the housing needs of low and moderate-income individuals and families. Title 24 CFR 203.41(a)(1) defines low or moderate-income housing as housing that is designed to be affordable to individuals or families whose household income does not exceed 115 percent of the median income for the area. Inadequate system to account for property repairs Mortgagee Letter 00-08 requires nonprofits to maintain an acceptable accounting system to report on property purchases, rehabilitation, rental, and resale. However, we found Rain did not have information concerning property repairs for its joint venture activities. For example, Rain did not maintain invoices, work orders, and contracts for the cost of repairs for four of the six properties we reviewed. To obtain the support, we contacted the venture partners and requested the information. However, we only obtained information from two partners. We were unable to locate one partner, and one partner did not provide all the needed documents to support the repair cost, despite numerous requests. As a result, Rain could not support the net development cost of the properties or the net proceeds from the resale. 8 Exit Inaccurate information reported to HUD Rain provided inaccurate information on the Status Report submitted to HUD and on the closing statements (HUD 1). Inaccurate status report As part of the recertification process, Attachment 3 of Mortgagee Letter 00-08 required nonprofits to submit a report on prior program accomplishments. Non-profits also had to submit HUD 1 Settlement Statements and addenda supporting the sales. Rain submitted a Status Report as part of its re-certification package, dated April 2000. The Status Report detailed properties purchased and resold by Rain, net development costs, date of purchase and resale, sales price, owner-occupant, etc. Five of our six properties were included in the Status Report (one was purchased June 22, 2000, and thus was not included in the report). On four of the five properties, Rain did not accurately report amounts paid. Property Status Address Description Report Actual Cost Difference Pine Hawk Rehabilitation Cost $4,800 Unknown * Unknown Holding Cost 2,535 $3,822 ($1,287) Sales Cost 4,296 2,000 2,296 Buyer Assistance 500 0 500 Hartwell Holding Cost 4,308 5,654 (1,346) Closing Cost 3,162 2,100 1,062 Sales Cost 4,020 0 4,020 Buyer Assistance 4,020 0 ** 4,020 Elizabeth Rose Rehabilitation Cost 8,173 6,797 1,376 Holding Cost 3,426 1,873 1,553 Closing Cost 3,730 3,464 266 Buyer Assistance 500 0 500 Mayflower Holding Cost 2,345 0 2,345 Sales Cost 3,300 0 3,300 Buyer Assistance 3,000 0 *** 3,000 NOTES: * Amount reported by the venture partner. We were unable to locate the partner to obtain the partner’s actual cost. ** The buyer received down payment assistance of $3,350, but it was provided by Individual Freedom Ministries Church, not Rain. 9 Exit *** The venture partner increased the sales price by $3,000 to allow for the assistance. The funds came from the venture partner’s proceeds and were not seller’s (Rain’s) contributions. Rain did not have the actual cost amounts because these four properties were financed, rehabilitated, and resold by the venture partners. Rain did accurately report the amounts incurred for the Galsworthy property because it did not involve a venture partner. Inaccurate closing statements Two of the closing statements did not accurately reflect the transactions. For 10449 Mayflower Road, Rain closed with HUD on the same day it closed with the homebuyer. The closing statement showed the venture partner received $1,032 for Rehabilitation Cost, and $1,329 for Holding and Finance Charges, indicating financing and rehabilitation efforts took place. In fact, they did not. The venture partner confirmed no rehabilitation work took place and no financing occurred. For the sale of 5501 Elizabeth Rose Square, the closing statement indicated Cash to Seller of $24,025. This would indicate Rain, as the seller, received this amount. However, the disbursement report from the closing agent showed the proceeds actually went to the venture partner. * * * Our audit work indicated that Rain did not meet the objective of HUD’s Single Family Insurance Program – to provide homeownership opportunities for the low and moderate-income persons and to pass along adequate savings to the homebuyer. In most instances, Rain allowed profit- motivated entities to use its name to purchase, rehabilitation, and resell HUD homes and failed to manage the operations of its affordable housing plan. Rain’s Comments: Rain generally disagreed with the finding. Rain’s comments or disagreements were as follows: Joint Venture relationship: Rain said 5 of our 6 sample properties were the subject of a prior litigation involving Rain and HUD, a Board of Contract Appeal’s litigation, and eventual settlement. Rain contends the joint venture relationship was resolved by the April 6, 2000, settlement agreement, and that we should not raise that issue again. Rain said it provided HUD copies of the closing files, in accordance with the settlement agreement, concerning the purchase, rehabilitation, and resale of over 30 properties. Rains also said HUD did not provide guidance and counseling or notify Rain of any deficiencies so that Rain could correct such deficiencies. It was not aware of any problems until November 15, 2000, when HUD elected to terminate Rain from the program. Rain explained it used joint venture agreements to acquire the maximum number of REO properties from HUD at the least risk. Rain said the creative financing arrangement allows the joint venture partner to provide all funds necessary for the acquisition, rehabilitation, and resale of the REO properties. Rain believed the venture arrangement was justified because it does not pass fee simple title to the venture partner. The agreement grants the partner an equitable 10 Exit interest in the proceeds generated from the sale. Rain believed the use of the joint venture does not violate any REO program requirements. Discounts not passed on: Rain said it does not sell the properties at a price greater than 120 percent of net development cost, and does not allow the partner to earn more than 10 percent established by its own internal guidelines. Rain contended that we ignored interest carrying costs, rehabilitation costs and closing costs to the end buyer, in our calculation of net development costs. In addition, Rain noted that we did not consider gifts (down payment or closing costs) made to the buyer. Further, Rain objected to our use of HUD appraisal reports because HUD does not provide them to the non-profit. Ineligible purchasers and inadequate system Rain acknowledged that it sold one property to an ineligible non-profit company, and one property to an owner-occupant whose income exceeded HUD’s guidelines. Rain also acknowledged it did not maintain accurate records of rehabilitation costs for 4 of the 6 properties. But Rain contends these matters were settled as part of the settlement agreement. Inaccurate information Rain contended the information submitted to HUD was accurate. Rain contended that we ignored the actual costs of rehabilitation and carrying costs. OIG Evaluation: We believe the venture arrangement is improper because it allows partners seeking to derive a profit from the program to influence, control, and manage the program. Rain improperly relinquished most of its control over the rehabilitation and calculation of the resale price to the venture partners. Rain did not have the receipts to support the rehabilitation costs. Furthermore, the agreements indicated the resale prices were determined by appraisals, not actual net development costs. Accordingly, Rain relinquished its control and authority over the program. Ultimately, homebuyers paid higher prices than necessary, which defeated the purpose of the program. We computed the allowable net development costs based on HUD’s criteria. In accordance with HUD’s instructions, we did not allow costs for: (1) excessive interest payments, but limited the interest to 10 percent for up to three months; (2) loan origination fees in excess of 1 percent of the loan amount; and (3) seller’s contributions or gifts to the buyer. For example on 810 Arlington Street, Rain included all closing costs or $5,957. Following HUD guidelines, we included only allowable net development costs or $3,132. We reviewed one property (810 Arlington Street), which was purchased and sold after the April 6, 2000, settlement agreement. Rain’s files did not contain supporting documentation for the rehabilitation costs. 11 Exit In February 2001, HUD removed Rain from the program. HUD found similar problems including use of joint venture agreements, conflicts of interest, and failure to adequately pass on discounts to homeowners. We believe HUD’s action was appropriate. Since HUD has removed Rain from the program, we are making no further recommendations for corrective action. 12 Exit AUDITEE COMMENTS 13 Exit 14 Exit 15 Exit 16 Exit 17 Exit 18 Exit 19 Exit 20 Exit 21 Exit 22 Exit 23 Exit 24 Exit DISTRIBUTION Executive Director, The Rain Foundation, Titusville, Florida Secretary, S Deputy Secretary, SD (Room 10100) Chief of Staff, S (Room 10000) Assistant Secretary for Administration, S (Room 10110) Acting Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120) Deputy Assistant Secretary, Office of Public Affairs, S, (Room 10132) Deputy Assistant Secretary for Administrative Services, Office of the Executive Secretariat, AX (Room 10139) Deputy Assistant Secretary for Intergovernmental Relations, Acting Deputy Chief of Staff, S (Room 10226) Deputy Chief of Staff for Policy, S (Room 10226) Deputy Chief of Staff for Programs, S (Room 10226) Special Counsel to the Secretary, S (Room 10234) Senior Advisor to the Secretary, S Special Assistant for Inter-Faith Community Outreach, S (Room 10222) Executive Officer for Administrative Operations and Management, S (Room 10220) General Counsel, C (Room 10214) Assistant Secretary for Housing/Federal Housing Commissioner, H (Room 9100) Assistant Secretary for Policy Development and Research, R (Room 8100) Assistant Secretary for Community Planning and Development, D (Room 7100) Assistant Deputy Secretary for Field Policy and Management, SDF (Room 7108) Office of Government National Mortgage Association, T (Room 6100) Assistant Secretary for Fair Housing and Equal Opportunity, E (Room 5100) Director, Office of Departmental Equal Employment Opportunity, U Chief Procurement Officer, N (Room 5184) Assistant Secretary for Public and Indian Housing, P (Room 4100) Director, Office of Departmental Operations and Coordination, I (Room 2124) Office of the Chief Financial Officer, F (Room 2202) Chief Information Officer, Q (Room 3152) Acting Director, HUD Enforcement Center, V, 1250 Maryland Avenue, SW, Suite 200 Acting Director, Real Estate Assessment Center, X, 1280 Maryland Avenue, SW, Suite 800 Director, Office of Multifamily Assistance Restructuring, Y, 1280 Maryland Avenue, SW, Suite 4000 Inspector General, G (Room 8256) 25 Exit Secretary's Representative, 4AS State Coordinator, Florida State Office, 4D Director, Atlanta Homeownership Center, 4AHH Audit Liaison Officer, 3AFI Audit Liaison Officer, Office of Housing, HF (Room 9116) Departmental Audit Liaison Officer, FM (Room 2206) Acquisitions Librarian, Library, AS (Room 8141) Counsel to the IG, GC (Room 8260) HUD OIG Webmanager-Electronic Format Via Notes Mail (Cliff Jones@hud.gov) Public Affairs Officer, G (Room 8256) Stanley Czerwinski, Associate Director, Resources, Community, and Economic Development Division, U.S. GAO, 441 G Street N.W., Room 2T23, Washington DC 20548 The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, United States Senate, Washington DC 20510-6250 The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, United States Senate, Washington DC 20510-6250 The Honorable Dan Burton, Chairman, Committee on Government Reform, United States House of Representatives, Washington DC 20515-6143 The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform, United States House of Representatives, Washington, DC 20515-4305 Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O'Neil House Office Building, Washington, DC 20515-6143 Steve Redburn, Chief, Housing Branch, Office of Management and Budget, 725 17th Street, NW, Room 9226, New Executive Office Bldg., Washington, DC 20503 Sharon Pinkerton, Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy and Human Resources, B373 Rayburn House Office Bldg., Washington, DC 20515 Armando Falcon, Director, Office of Federal Housing Enterprise Oversight, O, 1700 G Street, NW, Room 4011, Washington, DC 20552 Andrew R. Cochran, Senior Counsel, Committee on Financial Services, 2129 Rayburn House Office Building, Washington, DC 20510 26 Exit
the Rain Foundation, Titusville, FL, Nonprofit Participation in FHA Single Family Insurance Program
Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-09-24.
Below is a raw (and likely hideous) rendition of the original report. (PDF)