oversight

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)

                                                       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.




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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.




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                                         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.


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   •   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.




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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
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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.
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                                                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.




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                                       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.



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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.



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   *** 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
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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.



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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.




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AUDITEE COMMENTS




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                                        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)




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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




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