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 December 17, 2001 Audit Memorandum 2002-AT-1804 MEMORANDUM FOR: Arthur L. Wasson, Director, Public Housing Division, 4IPH FROM: Nancy H. Cooper District Inspector General for Audit-Southeast/Caribbean, 4AGA SUBJECT: Waverly Housing Authority Waverly, Tennessee At your request, we completed a limited review of the Waverly Housing Authority (Authority). Our primary objective was to determine the extent of funds diverted by the former Executive Director (ED) and identify any other potential fraud. METHODOLOGY AND SCOPE To accomplish the objectives, we: • Reviewed Department of Housing and Urban Development (HUD) records; • Reviewed Authority records; • Interviewed HUD and Authority staff; and, • Inspected 13 of the Authority’s 70 public housing units. We limited our review primarily to cash receipts and disbursements, procurement, tenant accounts, and property conditions. Our review generally covered the period October 1, 1999, through June 30, 2001. We conducted our review from June 22, 2001, through August 31, 2001. We conducted the review in accordance with generally accepted government auditing standards. BACKGROUND The Authority administers 70 low rent public housing units. A five member Board of Commissioners (Board), appointed by the Mayor, administers the Authority. Its office is located at 35 West Brookside Drive, Waverly, Tennessee. Exit The Independent Public Accountant’s audit report for fiscal year ended September 30, 2000, questioned “bonuses” the former ED paid to himself, his wife, and Authority staff. The bonuses totaled $49,750 for the fiscal year. The Authority’s Board Chairman notified HUD’s Public Housing Director in Nashville, Tennessee, of the diversions. Following an on-site review, the Director issued a report on June 11, 2001, stating the former ED diverted over $165,000 during fiscal years 2000 and 2001. The report also concluded there was “…a general lack of proper management oversight in all program areas….” Because of the problems, you requested OIG audit the Authority. The former ED and the bookkeeper resigned in March 2001. The only remaining office staff was the Occupancy Clerk. Thus, the Board contracted with the Dickson Housing Authority, Dickson, Tennessee, for management. On July 11, 2001, HUD’s Nashville office issued Limited Denials of Participation restricting participation by the former ED and bookkeeper in HUD’s programs. SUMMARY Because of mismanagement, abuse, and a lack of internal controls, the Authority is financially troubled and tenants are living in housing that is not decent, safe and sanitary. As discussed in Finding 1, between May 2000 and December 2000, the former ED diverted $165,630. He diverted the funds to himself, his wife, and Authority staff. In a possible attempt to conceal or justify the diversions, the ED submitted a budget revision requesting an additional $14,138, including funds for employee bonuses. When the Board and HUD approved the revision, they were unaware the ED had already paid bonuses totaling $49,750. Our review also confirmed HUD’s finding that the Authority had a general lack of proper management oversight in all program areas. We found: • Insufficient Board oversight; • Poor financial conditions; • Poor property conditions; • Inadequate management controls; • Inappropriate, inefficient, and undocumented expenditures; and, • Missing, incomplete, and falsified records. Because of the poor condition of the records, we could not fully assess operations. For example, because tenant records were in such disarray, we could not determine tenant eligibility or verify their rents were properly calculated. We recommend you require the Authority to collect $165,630 through its fidelity insurance policy or from the persons that received the inappropriate payments. Also, you should take appropriate actions, including administrative sanctions and employment terminations, to protect the interest of the Secretary of HUD and the Authority. Additionally, you should ensure the Board is properly trained to oversee the Authority and ensure the Authority is provided acceptable long-term management. You should also consult with the Memphis Troubled Agency 2 Exit Recovery Center (TARC) and develop a plan to provide much needed financial and technical assistance to the Authority. Details of the findings and recommendations are in Attachment A. Please furnish to this office a reply within 60 days for each recommendation describing: (1) the corrective action taken; (2) the proposed corrective action and a planned implementation date; or (3) why action is not considered necessary. Also, please furnish us copies of any correspondence or directives issued because of the review. Note that Handbook 2000.06 REV-3 requires management decisions to be reached on all recommendations within 6 months of report issuance. It also provides guidance regarding interim actions and the format and content of your reply. We provided a copy of this memorandum to the Authority. If you have any questions, please contact me at (404) 331-3369 or Jerry Kirkland, Assistant District Inspector General for Audit, at (865) 545-4368. Attachments: A – Findings and Recommendations B – Schedule of Bonus Payments C – Schedule of Ineligible Expenditures D – Auditee Comments E – HUD Comments F - Distribution 3 Exit Attachment A FINDINGS AND RECOMMENDATIONS Finding 1: Former ED Diverted $165,630 of Authority Funds The Authority’s former ED diverted $165,630 of Authority funds. This occurred because the Authority did not have adequate management controls and the ED did not apprise the Board of transactions or the Authority’s financial condition. Also, the Board was not fully aware of its duties and responsibilities for overseeing the Authority. As a result, the Authority is financially troubled and the funds are not available to ensure tenants are provided decent, safe, and sanitary housing. We recommend you require the Authority to collect $165,630 through its fidelity insurance policy or from the persons that received the inappropriate payments. Also, you should take appropriate actions, including administrative sanctions and employment terminations, to protect the interest of the Secretary of HUD and the Authority. Additionally, you should ensure the Board of Commissioners is properly trained to oversee the Authority and ensure the Authority is provided acceptable long-term management. You should also consult with the Memphis TARC and develop a plan to provide much needed financial and technical assistance to the Authority. The ED diverted $165,630 In violation of requirements, the ED diverted $165,630 of Authority funds to himself, his wife, and Authority staff. In a possible attempt to conceal or justify the diversions, the ED submitted a budget revision dated August 31, 2000, to the Board and HUD requesting an additional $14,138. Among other items, the budget revision included bonuses of $5,176 to the ED, $3,500 each for the part-time bookkeeper and occupancy clerk, and $2,500 for the maintenance mechanic. The Board approved the budget revision even though it conflicted with the Authority’s personnel policy. When the Board and HUD approved the revision, they were unaware the ED had already paid bonuses totaling $49,750. The bookkeeper recorded all of the payments as bonuses or salary payments in the accounting records. The diversions occurred between May 25, 2000, and December 15, 2000. Appendix B is a detailed schedule of the payments. Below is the gross amount paid to each recipient and their annual salaries: Recipient Bonus Salary Part-time Bookkeeper $ 40,950 $10,754 Occupancy Clerk 40,950 12,792 Former Executive Director 39,115 16,718 Maintenance Mechanic 38,3651 22,963 Executive Director’s wife 5,000 0 Part-time maintenance 1,250 11,375 Total $165,630 $74,602 1 The Maintenance Mechanic and the Occupancy Clerk are married. 4 Exit The Authority’s personnel policy permits “incentive payments” when an employee’s efforts result in direct cost savings. However, the payments are limited to the lower of 5 percent of an employee’s salary or $1,000 annually. The employees knew, or should have known the payments violated the personnel policy. Thus, they had a responsibility to report the matter to the Board. Further, the Board did not approve the payments as required by the personnel policy. The ED was required to provide an account of transactions and a report on the Authority’s financial condition to the Board. We reviewed the minutes from 16 Board meetings and did not find any evidence the ED provided the required financial reports. Further, the Authority’s bylaws required the Board Chairperson to sign all checks. However, we found the ED and the Occupancy Clerk signed checks, including the bonus checks, without review or approval by a Board member. While the ED may have concealed the payments from the Board, the Board was not fully aware of its duties and responsibilities for overseeing the Authority. We recommend you ensure the Board is properly trained to oversee the Authority. Public housing units were not decent, safe, and sanitary The diversions had a significant impact on the Authority’s ability to provide quality housing. The Authority is required to provide decent, safe, and sanitary housing for its tenants. Further, HUD provided $274,531 of modernization funds to the Authority to assist it in ensuring its housing was adequate. Of the $274,531 ($140,239 + $134,292) of modernization funds received, the Authority only used about $52,000 for property improvements. The Authority’s developments were built during the 1950s and 1960s. We inspected 13 of the Authority’s 70 public housing units. We found the units to be in a general state of disrepair and in dire need of systems upgrades. The units had outdated heating/cooling systems and electrical systems. Most, if not all, windows and doors need to be replaced. The units also need routine maintenance, such as painting and repair/replacement of attic vents, gutters and downspouts. HUD’s fiscal year 2000 physical assessment classified the Authority as “near troubled” because of the “Substandard Physical” condition of its units. The heating/cooling systems and electrical systems need to be upgraded immediately. The Authority has not installed air conditioners in any of its units even though many of its residents are elderly. The only source of heat in the one and two bedroom units is a gas heater in the front room. The heater is not vented to the rest of the unit. According to the tenants, the heater does not adequately heat the units. The units appear to have the originally installed 60 amp electrical system. The system is not adequate to support usage of many modern appliances, such as clothes dryers and window air conditioners. The Authority permitted residents to modify their units to accommodate such appliances. Many tenants modified their electrical systems, which resulted in numerous hazards. We found holes in concrete block walls to accommodate supplemental wiring, wires not in protective conduit, and wires strung on the outside of interior walls rather than within the walls. It appeared that the tenants made the modifications rather than a professional electrician. This could increase the risk of electrical shock or fires. 5 Exit The units also still had the original aluminum-framed, non-insulated windows. The windows were severely deteriorated and in need of replacement. Similarly, the light duty aluminum storm doors were deteriorated. Most doors had missing closers, latches, or other deficiencies. Units did not appear to have been painted for several years. The metal porch posts and handrails were rusted and had flaking paint. Likewise, most units had peeling/flaking paint on the interior walls and doors. The developments also lacked suitable playground equipment for the children. The Authority had three developments, but the only play equipment was a rusted swing at the Authority office. We noted that children regularly used the swing. They should be entitled to proper playground equipment. However, rather than providing adequate playground equipment for the children, the Authority personnel diverted funds for their personnel benefit. Modernization grant funds were diverted The Authority relies on its operating subsidy from HUD and tenant rent receipts to pay its routine operating expenses. The Authority also received modernization grants from HUD, $140,239 of Comprehensive Improvement Assistance Program (CIAP) funds for fiscal year 2000, and Capital Funds of $134,292 for fiscal year 2001. These modernization grants were for non-routine expenditures such as building improvements. This includes major renovations, such as replacing worn electrical, plumbing and other major systems, or renovating dilapidated or outdated units. HUD places restrictions on Authority funds through an Annual Contributions Contract (ACC), the Code of Federal Regulations, and grant agreements. The ACC required the Authority to operate the projects, at all times, in a manner that promotes serviceability, economy, efficiency, and stability. It also required the Authority to only incur operating expenses pursuant to an approved operating budget. Because HUD designated the Authority as “near troubled”, HUD required it to submit its annual budget for approval. The grant agreements require the Authority to use the funds for capital and management activities designed to ensure its developments are available to serve low-income families. Because the Authority commingled its funds into one bank account, we could not specifically identify the source of the diverted funds. However, of the $274,531 ($140,239 + $134,292) of modernization funds received, the Authority only used about $52,000 for property improvements. Because the operating subsidy and tenant rent receipts are intended to pay the operating expenses, it appears the remaining modernization funds were either diverted or used for other inappropriate expenses. In one instance, modernization funds were clearly diverted. On November 6, 2000, the Authority prepared “bonus” checks totaling $43,472. On the same day, the bookkeeper requested, through HUD’s electronic funds transfer system, $140,239 from the Authority’s fiscal year 2000 modernization grant. HUD transferred the funds into the Authority’s bank account on November 8, 2000. Prior to the deposit, the Authority’s bank account was overdrawn by more than $4,000. By November 9, 2000, all the “bonus” checks had cleared the account. 6 Exit The authority was financially troubled The diversions had a significant impact on the Authority’s financial condition. Because of the diversions and poor management, the Authority was financially troubled. The Authority’s bank account was often overdrawn which required the Authority to pay penalties to the bank. For example, in July 2000, the account was overdrawn four times and the Authority incurred $88 in penalties. This likely occurred because the Authority paid $39,000 in “bonuses” in June 2000. Again in November 2000, the Authority incurred $66 in penalties, shortly after paying bonuses of $38,830 in October and $56,800 in November. Although the penalties are not large, given the Authority’s small operating budget and the physical condition of units, the penalties demonstrate the poor management. Also, because the Authority did not have adequate funds, it liquidated its investments to pay operating expenses. On October 1, 1999, the Authority had investments of $51,600. As of March 31, 2001, the Authority only had $33,000 of its investment funds remaining. Because of inadequate operating fund, in April 2001 the Board Chairman had to use another $3,000 of the investment funds to pay past due utility bills Authority comments In its November 26, 2001, response to the draft report, the Authority agreed with the finding, but did not agree with some of the draft recommendations. Primarily, it did not agree that the City of Waverly should be liable for any funds not recovered through insurance and did not feel the Authority should be turned over to HUD or the TARC. While there is a lot of work needed at the Authority, the ED of the Dickson Housing Authority, management agent, believes progress has already been made and with help from HUD the Authority can become a high performer. HUD comments In your November 13, 2001, response to the draft, you generally agreed with the finding. However, you had concerns with some of the recommendations. Specifically, you stated that HUD has neither the authority to require nor the means to force the City of Waverly to pay amounts not paid by the bonding company. You also did not agree that HUD should take over the Authority or that oversight should be transferred to the TARC. Further, you did not feel that actions should be taken against the Board. OIG response to comments On November 28, 2001, we met with the PIH Directors from the Louisville, KY, and Nashville, TN, HUD offices, and representatives from the Authority to discuss the draft report and reach agreement on the recommendations. We agreed the City of Waverly could not be held liable for the diversions; rather, amounts should be recovered through the Authority’s fidelity insurance policy or from the persons that received the inappropriate payments. We also agreed the Authority should obtain and maintain responsible management by either: (1) combining it with the Dickson Housing Authority, or (2) entering into a long-term management agreement with the Dickson Housing Authority or another acceptable entity. We also agreed that you would consult 7 Exit with the TARC regarding possible financial and technical assistance for the Authority. You will also ensure the Board receives adequate training and provides proper oversight to the Authority. We made changes to the recommendations based on the comments and our discussions. We also made some revisions to the draft finding. Recommendations We recommend you: 1A. Require the Authority to recover the diverted funds of $165,630 through its fidelity insurance policy or from the persons that received the inappropriate payments. 1B. Require the Authority to terminate all staff involved in the diversion of funds. 1C. Ensure the Authority obtains and maintains responsible management and staff either by; (1) combining it with the Dickson Housing Authority, or (2) entering into a long-term management agreement with the Dickson Housing Authority or another acceptable entity. 1D. Consult with the Memphis Troubled Agency Recovery Center and develop a plan to provide much needed financial and technical assistance to the Authority. 1E. Ensure the Board receives adequate training and provides proper oversight to the Authority. 1F. Take appropriate administrative sanctions against the Occupancy Clerk. 1G. Take appropriate administrative sanctions against the Maintenance Mechanic. 8 Exit Finding 2: The Authority Did Not Have Adequate Management Controls Authority expenditures were inappropriate, inefficient, and undocumented. Also, numerous records were missing, incomplete, falsified or in disarray. This occurred because Authority management did not establish effective management controls. As a result, the Authority was financially troubled, tenants were deprived of decent safe and sanitary housing, and we were unable to fully audit Authority operations. We recommend you ensure the Authority establishes policies and procedures necessary for an effective management control system. Inadequate management controls Title 24 of the Code of Federal Regulations, Part 85, requires the Authority to maintain effective control and accountability for all cash, property and other assets. Management is responsible for establishing effective management controls including: • Methods and procedures to ensure its goals are met; • Processes for planning, organizing, directing and controlling program operations; and • Systems for measuring, reporting and monitoring program performance. We found the Authority’s controls were virtually nonexistent. We found little evidence of written policies and procedures. Even when written policies and procedures existed, staff routinely ignored them. For example, except for a part-time maintenance employee, all employees collected tenant rent payments, wrote rent receipts and made the bank deposits. We also found that the ED’s wife, not an Authority employee, signed rent receipts. Other examples of inadequate or missing controls included: • No written job descriptions; • Missing employee personnel files; and, • No periodic inventories of assets and incomplete asset records. We also found: • Inappropriate, inefficient, and undocumented expenditures; • Unreconciled bank statements; and, • Missing, incomplete, and falsified records. Inappropriate, inefficient and undocumented expenditures The Authority was financially troubled before the cash diversions discussed in Finding 1 began. This was due largely to poor management and lack of controls. For example, we found numerous instances of inappropriate, inefficient, and undocumented uses of funds. Also, the Authority frequently incurred costs that were not in its approved budget. As a result, the Authority was often overdrawn on its bank account and did not have funds available to maintain its units. Since the Authority was financially troubled, management should have ensured that 9 Exit funds were used prudently. However, management routinely incurred unreasonable expenses, including: • Numerous video games and other personal computer software; • Cable television for the office; • Late fees and bank overdraft charges; • IRS tax penalties for failing to make timely employee withholding tax deposits. From November 1999 through March 2001, the penalties totaled $1,543; • Overly generous health insurance benefits for employees including part-time staff. The Authority paid about $13,000 annually for its two part-time employees’ insurance; • About $10,000 annually to the employees Deferred Compensation Plan, for which employees contributed only a token amount; and, • Employees’ medical expenses for some costs that were not covered by employees’ insurance. The Authority also purchased three copiers, including one for over $6,000, a color copier that was seldom used, and a standard copier that was missing from the Authority’s office. It also spent about $1,200 to remodel the conference room. Given the poor financial condition and poor physical condition of units as discussed in Finding 1, these purchases were unreasonable. Further, the Authority routinely ignored its procurement policy designed to ensure fair and open competition. The Authority purchased a copier, refrigerators, furnaces and other items without bids. It did not maintain procurement files documenting the propriety of purchases. Numerous records were missing, incomplete, falsified or in disarray Personnel files for the former ED and Bookkeeper were missing. Tenant files were missing required documentation, such as leases and income information. Many of the leases that were in the files did not include required information, such as the rent amount. Further, in many cases tenant rent amounts on the rent register did not match the rents calculated in the tenant files or the amounts collected from tenants. Routinely, the amounts collected were more than the amounts due according to the rent register. As a result, tenants’ accounts would show the tenants overpaid their rents. In order to remove these overpayments from the books of record, employees created fictitious work orders showing maintenance charges to the tenants. We interviewed some tenants, none of whom had any knowledge of the overpayments or the work orders. Also, the Authority submitted an operating budget to HUD that included the potential tenant rent income. The potential rent was based on the rent register, which was inaccurate. HUD paid the Authority operating subsidy based on the inaccurate potential rent. Thus, it appears that HUD overpaid the subsidy. Because of the poor condition of the records, we were unable to substantiate the amounts overpaid. Given the lack of management controls and the poor condition of the records, there was a significant potential for fraud and abuse. The Authority must implement effective controls. 10 Exit Authority comments The Authority agreed with the finding and the recommendations. The Authority has implemented some new policies and procedures and taken other positive steps to improve operations. HUD comments HUD agreed with the finding and recommendations. OIG response to comments The Authority and HUD are in agreement with the finding and recommendations and have begun taking positive steps toward correcting weaknesses. We did not make any changes to the draft finding or recommendations based on the comments. Recommendation We recommend you: 2A. Ensure the Authority establishes policies and procedures necessary for an effective management control system. 2B Require the Authority to review all tenant files to ensure records are complete and accurate, including reviewing tenant account balances. 2C. Closely monitor the Authority’s operations and provide appropriate technical assistance. 11 Exit Attachment B SCHEDULE OF BONUS PAYMENTS CHECK CHECK EMPLOYEE DATE AMOUNT EMPLOYEE DATE AMOUNT Bookkeeper 05/31/00 $ 2,500 Maintenance Mechanic 05/31/00 $ 2,500 06/06/00 4,750 06/06/00 4,750 06/15/00 4,750 06/15/00 4,750 10/15/00 6,475 10/15/00 6,475 10/17/00 4,525 10/17/00 1,940 11/06/00 12,950 11/06/00 12,950 12/15/00 5,000 12/15/00 5,000 Employee Total $ 40,950 Employee Total $ 38,365 Occupancy Clerk 05/31/00 $ 2,500 Maintenance Aid 05/31/00 $ 250 06/06/00 4,750 06/06/00 250 06/15/00 4,750 11/06/00 500 10/15/00 6,475 12/15/00 250 10/17/00 4,525 11/06/00 12,950 12/15/00 5,000 Employee Total $ 40,950 Employee Total $ 1,250 Executive Director 05/31/00 $ 2,500 Executive Director’s Wife 05/25/00 $ 500 06/06/00 5,500 11/06/00 4,500 06/15/00 4,750 10/15/00 6,475 10/17/00 1,940 11/06/00 12,950 12/15/00 5,000 Employee Total $ 39,115 Employee Total $ 5,000 12 Exit Attachment C SCHEDULE OF INELIGIBLE EXPENDITURES Recommendation Ineligible2 1B $165,630 2 Ineligible amounts obviously violate law, HUD or local agency policies or regulations. 13 Exit Attachment D AUDITEE COMMENTS 14 Exit 15 Exit Attachment E HUD COMMENTS 16 Exit 17 Exit Attachment F DISTRIBUTION Executive Director, Dickson Housing Authority, Dickson, Tennessee 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) 18 Exit Secretary's Representative, 4AS State Coordinator, Tennessee State Office, 4IS Director, Public Housing Division, 4IPH Audit Liaison Officer, 3AFI Audit Liaison Officer, Office of Public and Indian Housing, PF (Room P8202) 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 19 Exit
Waverly Housing Authority, Waverly, Tennessee
Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-12-17.
Below is a raw (and likely hideous) rendition of the original report. (PDF)