oversight

Los Coyotes Band of Mission Indians, Warner Springs, California

Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-09-25.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                    U.S. Department of Housing and Urban Development
                                                                   Office of Inspector General
                                                                                    Pacific/Hawaii District
                                                                     450 Golden Gate Avenue, Box 36003
                                                                    San Francisco, California 94102-3448




                                                                                 Audit Memorandum
                                                                                     2001-SF-1805


September 25, 2001


MEMORANDUM TO:               C. Rafael Mecham, Administrator
                             Southwest Office of Native American Programs, 9EPI


                             //SIGNED//
FROM                         Mimi Y. Lee
                             District Inspector General for Audit, 9AGA

SUBJECT:                     Los Coyotes Band of Mission Indians
                             Warner Springs, California


                                      INTRODUCTION

We conducted a limited review of Los Coyotes Band of Mission Indians’ (Tribe) Indian
Community Development Block Grant (ICDBG) and Indian Housing Block Grant (IHBG)
funded housing activities. The review was initiated in response to a citizen complaint alleging
overall grant fund mismanagement; ineligible housing recipients; inadequate pre-construction
planning; and false information in the Tribe’s grant applications. Although the majority of the
complainant’s allegations were determined not to be valid, we did note various matters that
warrant your review and action as discussed herein.

                                         SUMMARY

Our review primarily focused on the Tribe’s procurement and contract management as well as its
overall grant administration. The Tribe did not effectively manage its procurement and contract
administration process. We noted problems in almost every area of the procurement process.
There was no documentation evidencing that the Tribe obtained contractors through fair and
open competition and that the contracts were obtained at the most reasonable and economical
prices. Additionally, we noted payments totaling $20,230 for services which were not necessary
or not provided. The Tribe also had serious problems with its overall grant administration.
Specifically, the Tribe’s record keeping was almost non-existent. There were numerous missing
documents related to the procurement process such as proposals, bids, price quotes, cost
estimates, and executed contracts making it impossible to accurately determine what occurred
during the contracting process. Financial records were also in disarray. There were missing
invoices, receipts, bank statements, and cancelled checks and up to date financial data was not
Audit Memorandum                                                   Los Coyotes Band of Mission Indians

available. Additionally, we could not locate documents supporting the process used to rank and
select housing recipients.

We attribute the problems to the Tribe’s inexperienced management staff and a failure to
establish policies and procedures necessary for proper grant administration. No written policies
and procedures had been adopted relative to procurement, travel, financial transactions, record
keeping and the application and selection process for housing recipients.

                                                  BACKGROUND

The Los Coyotes Tribe is a small tribe with a population of 275. The Tribal reservation
comprises a land base of approximately 25,000 acres and is located near Warner Springs,
California, approximately 50 miles northwest of San Diego. The Tribe operates under tribal
customs and traditions and is not formally organized with a charter or by-laws. The General
Council, the governing body of the Tribe, consists of all voting Tribal members.

The Tribe was awarded three Indian Community Development Block Grants (ICDBG) to
construct new housing. The Indian Housing Block Grant (IHBG) was used to rehabilitate
existing housing units. The following is a list of active ICDBG and IHBG grants:

Year                     Grant Program           Grant            Grant Agreement        Grant
                                                 Number           Date                   Amount
1998                     ICDBG                   B98SR062126      2/17/99                $550,000
1999                     ICDBG                   B99SR062126      9/22/99                $550,000
2000                     ICDBG                   B00SR062126      11/9/00                $550,000
1998                     IHBG                    98IT0621260      10/6/98                $ 72,271

The Tribe is currently in the process of constructing 10 single-family residences using 1998 and
1999 ICDBG funds. The homes are in various stages of completion. The Tribe has not started its
2000 ICDBG new housing project but is currently in the process of completing the required
environmental reviews. The Tribe has completed its project to rehabilitate four homes using
IHBG funds.

In order to use ICDBG funds for new housing construction, the Tribe organized a tribally based
organization, the Los Coyotes Housing Committee (TBDO). Supposedly, the TBDO and the
Tribe are separate entities, but in reality they are not.    For example, the General Council1 ,
including the Tribal Spokesperson, makes all final decisions related to housing and related
expenditures. In addition, the Tribe, not the TBDO, receives, maintains, and disburses the
ICDBG and IHBG funds. The TBDO only makes recommendations to the General Council
related to housing expenditures and selection of applicants for housing. In effect, the TBDO is
simply an advisory committee to the Tribe and there is no real distinct delineation between the
Tribe and the TBDO. The memorandum of understanding between the Tribe and Los Coyotes
Housing Committee/TBDO states “All TBDO determinations are subject to approval by the Los



1
    This could include any or all of the voting Tribal members.


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Audit Memorandum                                          Los Coyotes Band of Mission Indians

Coyotes General Council.” Key officials of the Tribe include the Tribal Spokesperson and the
ICDBG/ IHBG project administrator.

                       OBJECTIVE, SCOPE, AND METHODOLOGY

Our overall objective was to determine whether the Tribe managed its Indian Community
Development Block Grants and Indian Housing Block Grants in a cost efficient and effective
manner and in accordance with HUD requirements.              To accomplish our objective, we
interviewed HUD officials, current Tribal staff, and the Tribe’s grant consultant. We reviewed
the procurement and contract administration process as related to the construction of ten single
family residences, the rehabilitation of four homes, and the acquisition of consulting services.
These processes were reviewed to determine if the contracts were obtained through a fair and
open competition and at the most reasonable and economical price. In addition, we reviewed the
Tribe’s grant administration and internal controls related to procurement, travel, financial
transactions, and recipient eligibility. We selectively tested disbursements to ensure that the
costs were fully supported and eligible; that they went through a full internal control review
process; and that funds were expended in a timely manner. We attempted to review housing
recipient files but none were available.

Our review covered the period from February 1999 to March 2001 and was conducted during the
period March 2001 through May 2001. The audit was conducted in accordance with generally
accepted government auditing standards.

                                     REVIEW RESULTS

Finding 1 The Tribe did not effectively manage its procurement and contract
administration process

The Tribe had not established policies and procedures necessary to effectively manage
procurement and contract administration.          Specifically, contractors were obtained without
competition, procurement actions were not adequately planned, and effective payment controls
were not adopted resulting in over billing and cost overruns. We attributed these problems to the
Tribe’s inexperienced management staff and lack of written procurement policies and
procedures. As a result, there was no assurance that services were obtained fairly and impartially
and at the most reasonable and economical price. Additionally, it resulted in the payment of at
least $20,230 for services not provided or not needed.

The IHBG and CDBG regulations in 24 CFR 1000.26 and 24 CFR 1003.501 require grantees to
comply with 24 CFR Part 85, Uniform Administrative Requirements for Grants and Cooperative
Agreements. Specifically, 24 CFR 85.36 requires Tribal governments to adopt and implement
procurement and contract management policies and procedures that ensure:

            •   All procurement transactions are conducted in a manner providing full and open
                competition.




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Audit Memorandum                                         Los Coyotes Band of Mission Indians

           •   Awards are made to the firm whose contract or proposal is most advantageous to
               the program.

           •   A cost or price analysis is performed in every procurement action, including
               contract modifications.

           •   Sufficient records are maintained to detail the history of procurement actions to
               include the rationale for the method of procurement, selection of contract type,
               contractor selection or rejection, and the basis for the contract price.

The IHBG and ICDBG regulations also require grantees to comply with Office of Management
and Budget (OMB) Circular A-87, Principles for Determining Costs Applicable to Grants and
Contracts with State, Local, and Federally recognized Indian Tribal Governments. Attachment
A, paragraph C of this circular requires, that for costs to be allowable, they must be necessary,
reasonable, and adequately documented. Tribal governments must use these principles to
promote and ensure effective and efficient use of grant funds.

The Tribe did not have written procurement policies and procedures. Instead, they claimed to use
the applicable Code of Federal Regulations (CFR). However, the CFRs provide only general
guidance and overall rules applicable to a grantee’s procurement actions. They do not serve as a
substitute for a grantee’s own policies and procedures which are necessary for the day-to-day
management of procurement actions.           Further, the Tribe failed to even follow Federal
requirements relating to bid solicitation and contract management specified in 24 CFR 85.36 as
discussed below.

Results of Procurement Review

We reviewed the procurement and contract administration process relating to nine contracts
totaling approximately $1.1 million. These procurement actions included obtaining contractors
for the construction of ten single-family residences, the rehabilitation of four homes, and
consulting services. Specific problems noted were as follow:

   §   Eight of the nine contracts lacked documentation showing that a cost analysis was done
       to determine cost reasonableness. The only cost analysis performed was for the general
       construction contract.

   §   For seven of the nine contracts, documentation was not available to substantiate that
       competitive bids were obtained or even solicited prior to awarding the contract and in
       some instances it appeared contractors were pre-selected. For example, there was no
       legitimate solicitation for grant consultant services. The Tribe only pretended to solicit
       for the original grant writing contract for 1998. The contract was executed on July 29,
       1998, prior to even asking other consultants for proposals, i.e. two other proposals were
       solicited and received in August 1998. In addition, the consultant’s contracts were
       renewed for 1999 and 2000 grant writing and technical assistance without additional
       solicitation.



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Audit Memorandum                                         Los Coyotes Band of Mission Indians

   §   In three cases - accounting services, year 2000 ICDBG grant writing services, and
       engineering services - work was paid for without written contracts.

   §   In some instances it appeared contractors were paid prior to work being performed. For
       example, the grading contractor was paid $5,000 three days after contract execution
       (contract dated October 10, 2000) and an additional $6,560 was paid even before the first
       invoice (dated November 30, 2000) was received. The grading contractor quit before he
       fulfilled his contract obligations.

   §   The grant consultant billed and was paid $20,230 for services which were unnecessary,
       not provided or which should have been provided as part of his monthly technical
       assistance contract. These ineligible charges are summarized below:

       Ineligible Charge     Comments

       $17,500.00            The consultant, based on a contract dated June 5, 2000, charged the
                             Tribe $3,500 per month for services necessary to set up and
                             manage a materials supply depot. This was in anticipation of the
                             Tribe’s obtaining a labor only contract for building 10 new houses,
                             with the Tribe purchasing and supplying needed materials to the
                             contractor. This idea was never implemented and the Tribe knew
                             as early as June 28, 2000 that it would not occur. However, even
                             though no supply depot was ever established, the consultant
                             continued to bill, and receive payment, for these non-existent
                             services through November 2000. Once it was determined no
                             supply depot was to be established the consultant should have
                             stopped billing. Payments after June 2000 totaling $17,500 are
                             considered unnecessary, unreasonable, and ineligible in accordance
                             with OMB Circular A-87.

       $   500.00            The consultant charged the tribe $500 for preparing a program
                             amendment (Invoice #440, Check #7325). This service should
                             have been covered as part of the monthly consulting fee and
                             represents a duplicate charge.

       $   500.00            The consultant charged the tribe $500 for preparing another
                             program amendment (Invoice #44, Check #7326). This service
                             should have been covered as part of the monthly consulting fee and
                             represents a duplicate charge.

       $ 1,730.00            This represents a charge for preparation and review of contract
                             bids (Invoice #466, check #7453) which should have been included
                             as part of the monthly consulting fee. Accordingly, it is a duplicate
                             charge and ineligible.

       $20,230.00            Total ineligible costs.



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Audit Memorandum                                             Los Coyotes Band of Mission Indians


   §   There were numerous missing invoices and documents related to the procurement process
       including, proposals, bids, price quotes, cost estimates, and executed contracts making it
       impossible to accurately determine what occurred during the procurement process (also
       see Finding 2).

As discussed above, the Tribe has serious problems with its procurement process and contract
administration. We believe these problems primarily resulted from the inexperience of the
Tribe’s management staff. Because the Tribe relies heavily on an outside consultant for
technical advice related to the planning and procurement process, the Tribal management staff is
not fully aware of their responsibilities.       Additionally, the Tribe’s failure to establish
procurement policies and procedures made it even more difficult for management staff to
effectively manage the procurement process. As a result of these factors, there is no assurance
that services were obtained through open and fair competition and at the most reasonable and
economical prices.

Auditee Comments

The Tribe provided a written response to our draft report (see Attachment A), but decided that a
formal exit conference to discuss the results of our review was not necessary. In its written
response, the Tribe provided a copy of a plan it has developed to ensure that, in the future,
products and services are obtained through open and fair competition and at the most reasonable
and economical prices. Additionally, the tribe contended that the $500, $500, and $1,730
payments to its consultant, which OIG considered ineligible, were in fact eligible charges as they
represented charges for services which were outside the scope of the consultant’s original
contract(s). In relation to the $17,500 of questionable payments to its consultant, which were
charged under the June 5, 2000 contract to establish and maintain a supply depot, the Tribe also
contented that these were eligible payments. They claimed that during the month of July 2000,
the consultant did in fact expend efforts in trying to establish a supply depot. Further, they stated
that under a verbal agreement effective during the period August through November 2000 the
consultant provided additional services which were outside the scope of his existing contracts.
Such additional services supposedly included facilitating meetings with various parties,
consultations with the civil engineer, staff training, identification of reputable contractors, setting
up vendor accounts, and provision of other services above and beyond the original contract
requirements.

OIG Evaluation of Auditee Comments

The “plan” provided by the Tribe was just a very bare outline of the different phases of the
procurement process. In order to be useful, this plan must be fully developed, adopted as official
policy, and procedures established and implemented to ensure compliance.

We disagree with the Tribe’s contention that the ineligible consultant payments identified in our
finding represent additional services provided by the consultant over and above those to be
provided under existing contracts. We could identify no additional services provided, and in fact
the type of “extra services” claimed to have been provided were typical services previously made



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Audit Memorandum                                             Los Coyotes Band of Mission Indians

available through the existing contracts. Further, when the consultant was asked what services
he provided for the additional $3,500 per month received from June through November 2000, he
did not claim that the additional payments were related to these additional services identified by
the Tribe. Instead, he maintained they were related to the establishment of the supply depot. As
discussed in the finding, the supply depot was never established and the Tribe knew it would not
be implemented as early as June 28, 2000. Accordingly, we continue to assert that the $20,230
of consultant payments identified in the finding are ineligible program costs.

                                       RECOMMENDATIONS

We recommend that you require the Tribe to:

1A.        Establish and implement appropriate policies and procedures which will provide for proper
          procurement management, including obtaining cost analysis for each procurement action;
          obtaining competitive proposals or bids as required; establishment of payment controls to
          ensure that duplicate payments are not made, that payments are made only after the work is
          done or services performed; and retention of documents supporting the procurement and
          payment process.

1B. Refund to the ICDBG program, from non-federal sources, the $20,230 of ineligible
    payments made to its consultant and seek reimbursement for these charges from the
    consultant.

Finding 2 The Tribe did not plan, manage, and administer its Indian Community Block
Grant and Indian Housing Block Grant in a cost effective and efficient manner or in
compliance with HUD requirements

The Tribe had not adopted policies and procedures necessary to properly administer its grant
programs. Specifically:

      §    The Tribe’s record keeping was extremely deficient. There were numerous missing
           documents related to the procurement process such as proposals, bids, price quotes, cost
           estimates, executed contracts and payments to contractors making it impossible to
           accurately determine what occurred. In addition, financial records were in disarray.
           There were missing invoices, receipts, bank statements, and cancelled checks and up to
           date financial data was not available.

      §    There was no evidence that contractor and other billing invoices were reviewed and
           approved by management prior to payment. This is a serious breach of the internal
           control process that could result in overpayments and malfeasance.

      §    Documents supporting the process used to select housing recipients and determine their
           eligibility could not be located making it impossible to determine what process the Tribe
           used when selecting housing recipients.




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Audit Memorandum                                           Los Coyotes Band of Mission Indians

We attributed these problems to the Tribe’s inexperienced management staff and the lack of
written policies and procedures relative to procurement, travel, financial transactions, record
retention, and recipient eligibility. As a result, there was no reasonable assurance that the Tribe
managed and administered its grants in an effective and efficient manner and in compliance with
HUD requirements.

The IHBG and ICDBG regulations in 24 CFR 1000.26 and 24 CFR 1003.501 require Tribal
governments receiving federal grant funds to comply with Office of Management and Budget
(OMB) Circular A-87, Principles for determining Costs applicable to Grants and Contracts with
State, Local, and Federally recognized Indian Tribal Governments. Additionally, IHBG and
ICDBG regulations require Tribal governments to comply with specified sections of 24 CFR Part
85, Administrative Requirements for Grants and Cooperative Agreements to State, Local, and
Federally Recognized Indian Tribal Governments. Specifically, grantees are required to adopt
and implement policies and procedures relative to financial administration which provide for
maintenance of records to adequately identify expenditures, or outlays; effective control and
accountability for all grant cash; adherence to OMB cost principles (set out in OMB circular
number A-87); and maintenance of accounting records supported by source documentation such
as cancelled checks, paid bills, and contract documents. In addition, grantees are required to
maintain all financial and programmatic records, supporting documents, statistical records, and
other records pertinent to their grant programs for three years from the day the grantee submits
its final expenditure report for the period to HUD.

On non-statistical basis, we selected and tested a representative sample of disbursements to
determine whether the applicable costs were fully supported and eligible; disbursements went
through a complete internal control review process; and funds drawndown from the treasury
were expended in a timely manner. We also attempted to review housing recipient files but none
were available. We noted the following:

   §   The Tribe had not set up policies and procedures necessary to properly administer its
       ICDBG and IHBG grants. Specifically, the Tribe had not established policies and
       procedures for procurement (see Finding 1), travel, financial transactions, recipient
       eligibility, and record retention. We were advised that rather than adopting their own
       policies and procedures the Tribe used the applicable policies and procedures contained
       in the Code of Federal Regulations (CFR). Although the CFRs contain minimum
       requirements related to grant administration, they are not sufficiently detailed to properly
       manage a grant program on a day-to-day basis.

   §   The Tribe had poor record retention. They could not readily provide financial documents
       and cost data i.e. invoices, cancelled checks, bank statements, and current financial data
       including programmatic documents such as original recipient applications and supporting
       documents.     There was no current financial data available.        The latest available
       information was from June 2000 and the Tribe’s accountant had to fax us pertinent up-to-
       date financial records. It took over a week to collect all the contract agreements we
       requested for review and in some instances the contractors had to fax us their contracts
       because they were not available at the Tribal office.




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Audit Memorandum                                            Los Coyotes Band of Mission Indians

   §   The Tribe charged $1,390 to its ICDBG for meals served at Tribal meetings. Meal costs
       related to Tribal meetings are considered entertainment costs, which, in accordance with
       OMB Circular A-87, cannot be charged to a Federal grant program.

   §   Payments to various contractors were made without prior management approval and
       payments were made to contractors prior to the contractors performing work or providing
       any services. None of the transactions reviewed went through the proper administrative
       internal control process, i.e. there was no evidence that the billing invoices were reviewed
       and approved by management prior to payment. The billing invoices were not referenced
       back to applicable payment documents (checks) and in some instances the invoices and
       checks did not show the program activity to be charged. For example, the consultant’s
       billing invoices could not be readily traced to his contracts because his contracts did not
       have sufficient information to enable referencing to his billing invoices.

   §   No files supporting new housing recipients’ income, eligibility and selection were
       available. The Tribe could only direct us to their 1998, 1999, and 2000 ICDBG grant
       applications that contained skeletal copies of recipient records. The accuracy of this
       partial information relative to the true condition of family size, income and living
       conditions could not be determined. For example, two housing applicants who lived in
       Indiana did not verify their true living condition i.e., over-crowded, substandard or
       homeless - one simply stated, she wanted a new home. The Tribe also did not verify
       income of all adult household members in nine of fifteen instances. In addition, the
       selection process of housing recipients was not clear. Although the Tribe set criteria to
       select the “neediest” household, it is subject to multiple interpretations. In fact, based
       upon the limited information available, it appears families selected for new housing did
       not meet the Tribe’s “neediest” criteria. In this regard, a comparison of summary
       (undocumented) demographic survey data to selected applicants revealed that only six of
       the fifteen families selected to receive a new home appeared to meet the “neediest”
       criteria. However, because of the lack of supporting documentation, we could not
       determine what basis was actually used to select these recipients.

   §   The Tribe used tribal funds to pay for ICDBG activities and subsequently reimbursed
       these costs with ICDBG funds. This is a poor financial management practice which
       should be discouraged.

As discussed above, the Tribe had significant problems with its grant administration resulting
from inexperienced staff, and the failure to establish administrative policies and procedures
relative to procurement, travel, financial transactions, recipient eligibility, and record retention.
Even though the Tribe relies heavily on its consultant for guidance, adequate policies and
procedures are necessary to ensure that grant funds are used in accordance with program
requirements. This is especially true when staff have very limited experience in managing grant
programs. As a result of poor management and administration of its grant, there was no
reasonable assurance that the Tribe managed and administered HUD grants in an effective and
efficient manner and in compliance with program requirements.




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Audit Memorandum                                           Los Coyotes Band of Mission Indians


Auditee Comments

The Tribe provided a written response to our draft report (see Attachment A), but decided that a
formal exit conference to discuss the results of our review was not necessary. In its written
response, the Tribe contented that, although not documented and not in the correct format,
procedures for administering its grants were developed and followed. However, it agreed that
improvements are needed in its grant management and administration and provided a copy of a
plan to be used for making these improvements. Additionally, the Tribe agreed to reimburse the
ICDBG program for the $1,390 of ineligible meal costs identified in the finding and to establish
procedures to avoid incurring such costs in the future.

OIG Evaluation of Auditee Comments

As set out in the finding, the Tribe had no record of having adopted and implemented
administration and management procedures necessary for effective grant administration.
Further, in many instances documentation supporting actions taken in administering its grant
could not be located. The plan provided in its response for improving grant administration is just
a general outline of broad administrative areas where improvements are needed. In order to be
useful, this plan must be fully developed, adopted as official policy, and procedures established
and implemented to ensure compliance.

                                   RECOMMENDATIONS

We recommend that you require the Tribe to:

2A.     Establish and implement appropriate policies and procedures which set out responsibility
      for accounting and record keeping including appropriate internal controls, maintenance of
      contract files, financial records, and other required program documents and which provide
      for management review of fee accountant prepared journal entries, bank reconciliations,
      and financial reports.

2B.     Refund to the ICDBG program, from non-federal sources, the $1,390 of ineligible meal
      costs charged to the program.

                                              ****

Within 60 days, please give us a status report on the recommendations stating (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
related to this review.

If you have any questions concerning this report, please call Ruben Velasco, Assistant District
Inspector General for Audit, at (213) 894-8016.




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Audit Memorandum        Los Coyotes Band of Mission Indians

                                             ATTACHMENT A




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Audit Memorandum        Los Coyotes Band of Mission Indians




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Audit Memorandum        Los Coyotes Band of Mission Indians




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Audit Memorandum        Los Coyotes Band of Mission Indians




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Audit Memorandum        Los Coyotes Band of Mission Indians




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Audit Memorandum                                             Los Coyotes Band of Mission Indians

                                                                                  ATTACHMENT B

                                         DISTRIBUTION

Secretary, S, Room 10000
Deputy Secretary, SD, Room 10100
Chief of Staff, S, Room 10000
Acting Associate General Deputy Assistant Secretary for Administration, HR, Room 9138
Acting Assistant Secretary for Congressional and Intergovernmental Relations, J, Room 10120
Deputy Assistant Secretary, Office of Public Affairs, W, Room 10132
Deputy Assistant Secretary for Administrative Services, Office of the Executive Secretariat, AX,
      Room 10139
Deputy Assistant Secretary for Congressional and Intergovernmental Relations, JI, Room 10234
Deputy to the Chief of Staff for Policy & Programs, S, Room 10000
Deputy to the Chief of Staff for Operations and Intergovernmental Relations, S, Room 10000
Special Counsel to the Secretary, C, Room 10110
Senior Advisor to the Secretary, C, Room 10110
Director, Center for Faith-Based and Community Initiatives, K, Room 10184
Chief Executive Officer for Administrative Operations and Management, S, Room 10220
Assistant Secretary for Housing/Federal Housing Commissioner, H, Room 9100
General Counsel, C, Room 10110
Deputy General Counsel for Housing Finance and Operations, CA, Room 10240
General Deputy Assistant Secretary for Housing, 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
President, 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, Room 2134
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 P8206
Acting Director, Enforcement Center, V, Suite 200, Portal Building
Acting Director, Real Estate Assessment Center, X, Suite 800, Portal Building
Director, Office of Multifamily Assistance Restructuring, Y, Suite 4000, Portal Building
Assistant to the Secretary and White House Liaison, S, Room 10000
Press Secretary/Senior Communications Advisor to the Secretary, S, Room 10000
Director, Office of Healthy Homes and Lead Hazard Control, L, P3202
Director, National Office of Labor Relations, I, Room 7118
Secretary’s Representative, 9ES, 16th Floor
Departmental Audit Liaison Officer, FM, Room 2206 (2)
ONAP Audit Liaison Officer, PNPE, Room 3390
Western District Audit Liaison Officer, Bettye C. Adams, 6AF
Deputy Assistant Secretary, Office of Native American Programs, PI, Room 4126



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Audit Memorandum                                         Los Coyotes Band of Mission Indians

C. Raphael Mecham, Administrator, Southwest Office of Native American Programs, 9EPI
Acquisitions Librarian, Library, AS, Room 8141
Mr. Armando Falcon, Director, Office of Federal Housing Enterprise Oversight, 1700 G Street,
     NW, Room 4011, Washington, DC 20552
Ms. Sharon Pinkerton, Senior Advisor, Subcommittee on Criminal Justice, Drug Policy &
     Human
     Resources, B373 Rayburn House Office Building, Washington, DC 20515
Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O’Neil House
     Office Building, Washington, DC 20515
Mr. Stanley Czerwinski, Associate Director, Housing and Telecommunications Issues, United
     States General Accounting Office, 441 G Street, NW, Room 2T23, Washington, DC 20548
Mr. Steve Redburn, Chief Housing Branch, Office of Management and Budget, 725 17th Street,
     NW, Room 9226, New Executive Office Building, Washington, DC 20503
Mr. Andy Cochran, Senior Counsel, House Committee on Financial Services, 2129 Rayburn
     House
     Office Building, Washington, DC 20515
The Honorable Fred Thompson, Ranking Member, Committee on Governmental Affairs, 340
     Dirksen Senate Office Building, United States Senate, Washington, DC 20510
The Honorable Joseph Lieberman, Chairman, Committee on Government Affairs, 706 Hart
     Senate
     Office Building, United States Senate, Washington, DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Raybur
     Building, House of Representatives, Washington, DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204
     Rayburn Building, House of Representatives, Washington, DC 20515
Evelyn Duro, Tribal Administrator, P.O. box 189, Warner Springs, CA 92086




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