Audit Memorandum - Congressionally Requested Audit of the Outreach and Training Assistance Grant awarded to the Legal Aid Society of Hawaii, Honolulu, HI, Grant Number FFOT98006HI

Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-09-30.

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

                                              Issue Date: September 30, 2002
                                              Audit Case Number: 2002-SF-1006

TO:           Charles H. Williams, Director HUD’s Office of Multifamily Housing Assistance
              Restructuring, HY


FROM:         Mimi Y. Lee, Regional Inspector General for Audit, 9AGA

SUBJECT:      Audit Memorandum - Congressionally Requested Audit of the Outreach and
              Training Assistance Grant awarded to the Legal Aid Society of Hawaii, Honolulu,
              HI, Grant Number FFOT98006HI.


We completed an audit of the Legal Aid Society of Hawaii’s (LASH) Outreach and Training
Assistance Grant (OTAG). The LASH performed OTAG activities and also distributed funds to
the Affordable Housing and Homeless Alliance (AHHA) to perform OTAG activities on behalf
of the LASH. The audit identified the grantee participated in questionable activity, and did not
sufficiently confirm costs in compliance with the 1998 Notice of Funds Availability (NOFA),
Office of Management and Budget’s (OMB) Circulars, the applicable Codes of Federal
Regulations (CFR), and the grant agreement. Our report contains four recommendations to
address the issues identified in the report.

Section 1303 of the 2002 Defense Appropriation Act (Public Law 107-117) requires the HUD
Office of Inspector General to audit all activities funded by Section 514 of the Multifamily
Assisted Housing Reform and Affordability Act of 1997 (MAHRA). The directive would
include the Outreach and Training Assistance Grants (OTAG) and Intermediary Technical
Assistance Grants (ITAG) administered by the Office of Multifamily Housing Assistance
Restructuring (OMHAR). Consistent with the Congressional directive, we reviewed the
eligibility of costs with particular emphasis on identifying ineligible lobbying activities.

In conducting the audit, we reviewed the grantee’s accounting records and interviewed
responsible staff. We also reviewed the requirements in MAHRA, the OTAG Notice of Fund
Availability, the OTAG grant agreement, HUD’s requirements for grant agreements for
nonprofit entities, and OMB Circular A-122’s guidance on the allowability of cost for nonprofit
The audit covered the period of October 1998 through June 2002 for the OTAG grant. We
performed the fieldwork at the LASH office located in Honolulu, Hawaii, during July 2002. In
addition, we obtained information from other OIG auditors, who performed a concurrent review
at the AHHA office, located in Honolulu, Hawaii. We conducted the audit in accordance with
Generally Accepted Government Auditing Standards.

We appreciate the courtesies and assistance extended by the personnel of the LASH during our

In accordance with HUD Handbook 2000.06 REV-3, within 60 days please provide us, for each
recommendation without a management decision, a status report on: (1) the corrective action
taken; (2) the proposed corrective action and the date to be completed; or (3) why action is
considered unnecessary. Additional status reports are required at 90 days and 120 days after
report issuance for any recommendation without a management decision. Also, please furnish us
copies of any correspondence or directives issued because of the audit.

Should you or you staff have any questions please contact me at (415) 436-8101.


The LASH submitted an application to HUD for OTAG funding and was awarded grant
FFOT98006HI in February 1999. LASH planned to perform eligible tenant outreach,
organizing, and training under the OTAG in coordination with the AHHA. Grant funds of
$22,157 were subsequently provided to the AHHA. Our audit identified the LASH charged the
grant $6,408 for tenant legal representation not allowed by the 1998 NOFA, OMB Circular A-
122, or the grant agreement. In addition, the LASH did not sufficiently confirm $10,904 in
questionable sub grantee payroll expenses in accordance with the grant agreement; OMB
Circular A-110; and 24 CFR Part 84, Uniform Administrative Requirements for Grants and
Agreements with Nonprofit Organizations. Our report contains recommendations to address the
issues identified in the report.


The Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA) established
the Office of Multifamily Housing Assistance Restructuring (OMHAR) within HUD. Utilizing
the authority and guidelines under MAHRA, OMHAR’s responsibility included the
administration of the Mark-to-Market Program, which included the awarding, and oversight of
the Section 514 Outreach and Training Assistance and Intermediary Technical Assistance
Grants. The objective of the Mark-to-Market Program was to reduce rents to market levels and
restructure existing debt to levels supportable by these reduced rents for thousands of privately
owned multifamily properties with federally insured mortgages and rent subsidies. OMHAR
worked with property owners, Participating Administrative Entities, tenants, lenders, and others
to further the objectives of MAHRA.

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Congress recognized, in Section 514 of MAHRA, that tenants of the project, residents of the
neighborhood, the local government, and other parties would be affected by the Mark-to-Market
Program. Accordingly, Section 514 of MAHRA authorized the Secretary to provide up to $10
million annually ($40 million total) for resident participation, for the period 1998 through 2001.
The Secretary authorized $40 million and HUD staff awarded about $26.6 million to 38 grantees
(a total for 81 grants awarded). Section 514 of MAHRA required that the Secretary establish
procedures to provide an opportunity for tenants of the project and other affected parties to
participate effectively and on a timely basis in the restructuring process established by MAHRA.
Section 514 required the procedures to take into account the need to provide tenants of the
project and other affected parties timely notice of proposed restructuring actions and appropriate
access to relevant information about restructuring activities. Eligible projects are generally
defined as HUD insured or held multifamily projects receiving project based rental assistance.
Congress specifically prohibited using Section 514 grant funds for lobbying members of

HUD issued a Notice of Fund Availability in fiscal year 1998 and a second notice in fiscal year
2000 to provide opportunities for nonprofit organizations to participate in the Section 514
programs. HUD provided two types of grants: (1) the Intermediary Technical Assistance Grant
(ITAG), and (2) the Outreach and Training Assistance Grants (OTAG). The Notice of Fund
Availability for the ITAG states that the program provides technical assistance grants through
Intermediaries to sub-recipients consisting of: (1) resident groups or tenant affiliated community-
based nonprofit organizations in properties that are eligible under the Mark-to-Market program
to help tenants participate meaningfully in the Mark-to-Market process, and have input into and
set priorities for project repairs; or (2) public entities to carry out Mark-to-Market related
activities for Mark-to-Market-eligible projects throughout its jurisdiction. The OTAG Notices of
Fund Availability state that the purpose of the OTAG program is to provide technical assistance
to tenants of eligible Mark-to-Market properties so that the tenants can (1) participate
meaningfully in the Mark-to-Market program, and (2) affect decisions about the future of their

OMHAR also issued a December 3, 1999 memorandum authorizing the use of OTAG and ITAG
funds to assist at-risk projects. OMHAR identified these as non-Mark-to-Market projects where
the owners were opting out of the HUD assistance or prepaying the mortgages.

HUD’s regulations at 24 CFR Part 84 contain the uniform administrative requirements for grants
between HUD and nonprofit organizations. The regulations (24 CFR 84.27) require that
nonprofit grantees utilize OMB Circular A-122, Cost Principles for Non-Profit Organization, in
determining the allowability of cots incurred to the grant. OMB Circular A-122 outlines specific
guidelines for allowability of charging salaries and related benefits to the grants and the records
needed to support those salaries. For indirect costs charged to the grant, the Circular establishes
restrictions for indirect costs, and specific methods and record keeping to support the allocation
of costs.

The Circular also establishes the unallowability of costs associated with Federal and state
lobbying activities. Simply stated, the use of federal funds for any lobbing activity is
unallowable. OMB Circular A-122 identifies some examples of unallowable lobbying activities.

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These include any attempt to influence an elected official or any Government official or
employee (Direct Lobbying) or any attempt to influence the enactment or modification of any
actual or pending legislation by propaganda, demonstrations, fundraising drives, letter writing, or
urging members of the general public either for or against the legislation (Grassroots Lobbying).

LASH is a corporation organized under the laws of the State of Hawaii. On January 25, 1972,
the IRS determined that LASH was exempt from Federal income tax under section 501(c)(3) of
the Internal Revenue Code. The objective and purpose of LASH is to equip, maintain, and
operate offices and to employ attorneys to render legal assistance to worthy persons who are in
need of such help but who are unable to pay for it, and by reason thereof might be denied equal
protection under the laws; to solicit, receive, and provide funds to engage in such activities as are
usual and legal and proper for legal aid societies; and to secure justice for and to protect the
rights of the needy and to promote measures for their assistance in such connection. The mission
of LASH is to achieve fairness and justice for Hawaii's people through quality representation,
advocacy, community partnerships, education, and outreach. Under the Community Education
Outreach program, LASH provides outreach and training to Section 8 tenants who live in
buildings with expiring Section 8 subsidies by informing them of the process and assisting tenant
associations. There are over 40 other programs that LASH is involved in that are funded through
various Federal and non-Federal sources. For fiscal years ending June 30, 2000 and 2001, this
included other HUD funding of $121,020, and Maui Community Development Block Grant
funds of $37,500.

LASH applied for OTAG funding on June 26, 1998. HUD awarded $50,000 to the LASH under
grant agreement FFOT98006HI in February 1999. LASH began drawing down funds from the
grant starting in June 1999, which included expenses back to October 1998. As of July 2002, the
LASH had drawn down $48,090 of the grant funds. Between 1999 and 2000, LASH provided
$22,157 of grant funds to the AHHA, which had not yet applied for its own OTAG grant. The
AHHA subsequently applied for and received its own OTAG funding [Note: OTAG funds
awarded directly to the AHHA were reviewed under a separate concurrent audit, the results of
which will be reported under a separate cover]. The LASH received annual financial audits of
their activities for the years ending June 30, 1999, 2000, and 2001. The auditor provided an
unqualified opinion for each of the three years.

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            The Grantees Did Not Comply With HUD and OMB Requirements

The LASH charged the grant $6,408 for questionable legal representation activities. In
addition, the LASH did not adequately confirm $10,904 of questionable sub grantee
payroll. As a result, less funding was available for eligible tenant outreach, organizing, and
training under the Mark-to-Market program. This occurred because LASH placed a low
priority over the confirmation of sub grantee activity, and LASH was not sufficiently
familiar with program requirements.

Questionable Legal Representation

The 1998 NOFA defined the purpose of the OTAG program as to provide funds to conduct
outreach and training development for HUD tenants in properties eligible to participate in the
Mark-to-Market (M2M) program, so the tenants can participate in the M2M program and affect
decisions about the future of their housing. Eligible activities include:
       1. Identifying residents and resident groups living in eligible properties;
       2. Providing outreach and training to tenants to explain the M2M program, the possible
           financial changes, the possible project repairs, access and community resources and
           effective methods for communicating the organization's position;
       3. Organizing residents of eligible low-income housing so the tenants can effectively
           participate in the M2M process;
       4. Performing outreach, training, and counseling, which may include teaching sound
           housing management, maintenance, and financial management, to residents and
           resident groups living in eligible M2M properties;
       5. Delivering training programs on M2M and/or resident homeownership options;
       6. Establishing M2M clearinghouses as a resource to resident organizations, community
           groups and potential purchasers;
       7. Creating informational materials about the M2M process for distribution;
       8. Providing support for HUD approved activities proposed by the grantee that would
           further the M2M program and others considered eligible at HUD's discretion; and
       9. Educating parties outside HUD about the M2M process.

The OTAG grant agreement FFOT98006HI between HUD and LASH incorporated the grant
application, which described LASH’s planned activities under the OTAG grant. Activities
described included outreach, organizing, and training efforts similar to eligible activities
identified in the NOFA. Neither the application nor the agreement proposed using OTAG funds
to provide legal representation concerning tenancy issues.

Federal regulations at 24 CFR 84.25, Revisions of budget and program plans, requires recipients
to report deviations from budget and program plans, and request prior approvals for budget and
program plan revisions, including changes in the scope or the objective of the project or program
and changes in a key person specified in the application or award document.

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OMB Circular A-122, Attachment A, states that for costs to be allowable, the costs must be
reasonable, ordinary and necessary for the performance of the award, and allocable to the grant
in accordance with the benefits received.

HUD issued a letter on December 3, 1999 expanding the types of projects eligible for OTAG
assistance. However, it does not allow OTAG funds to be used to represent tenants in legal
matters relating to civil rights complaints, inappropriate charges, and harassment by owners.

In 2001, the LASH began charging staff time to represent tenants in their pursuit of legal and
management issues relating to their tenancy. The progress reports submitted to OMHAR showed
these cases related to retribution by management when tenants began organizing under the
OTAG program. The LASH pursued the following cases on behalf of the tenants:

       ·   Case 00-10-03009607 involved tenant(s) of the Kulana Nani housing development
           being harassed by the manager,
       ·   Case 00-10-02007350 involved a tenant's uncorrected maintenance problems at the
           Kulana Nani housing development. Respondents to the matter were the City and
           County of Honolulu, the management agent, and HUD,
       ·   Case 01-10-02002301 involved a tenant's challenge of the management's Section 8
           and Section 236 rent calculations, and
       ·   Case 01-10-02002589 involved a tenant's eviction from the Kulana Nani housing
           development for nonpayment of rent.

LASH charged its attorney’s payroll costs associated with time spent on these cases. Overall,
this included 267 hours at $20 per hour, with 20 percent fringe benefits, which totaled $6,408.
The following table summarizes the hours spent on the cases and attributed to the OTAG

                 Month       00-10-   00-10-   01-10-   01-10-              Total
                            03009607 02007350 02002301 02002589
                Jan-01         47                                           47
                Feb-01        15.5         1.5                              17
                Mar-01          2           2         1.5                   5.5
                Apr-01         46          12        4.25         8.5      70.75
                May-01        11.25       10.5        5.5         1.5      28.75
                Jun-01         10                      3         6.75      19.75
                Jul-01         63         0.75                             63.75
                Aug-01          4                                            4
                Sep-01         6.5          4                              10.5
                 Total:      205.25      30.75       14.25      16.75       267

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LASH interpreted HUD’s December 3, 1999 letter as allowing OTAG funds to be used for other
purposes related to HUD projects. LASH claimed it consulted with an OMHAR representative
concerning its conclusion that working with the tenants included representing them in their effort
to settle tenancy issues with the property management or, failing that, represent the tenants in the
court of law. However, LASH could not produce documented approval from HUD, showing the
activity was eligible. Nothing in the grant agreement, NOFA, CFR or OMB criteria state this
activity was an appropriate under the OTAG program. As a result, there was less funding
available for eligible tenant outreach, organizing, and training for tenant groups under the Mark-
to-Market program.

Inadequate Monitoring of AHHA Results in Questionable Payroll Expenses

As part of the OTAG agreement, FFOT98006HI, LASH agreed to accept responsibility for
compliance by any other entities to which it makes grant funds available, with the NOFA and
any other applicable laws, regulations and requirements (including record keeping requirements),
and with the activities listed in the grantee's application.

OMB Circular A-110, Section 51, states recipients are responsible for managing and monitoring
each program, activity, and sub award.

Federal regulations at 24 CFR 84.21 requires grantees to maintain records adequately identifying
the source and application of funds, and maintain accounting records that are supported by
source documentation. Section 84.85, Reports and records, makes grantees responsible for
managing and monitoring each project, program, subaward, function or activity supported by the
award. In addition, financial records, supporting documents, statistical records, and all other
records pertinent to an award shall be retained for a period of three years from the date of
submission of the final expenditure report.

OMB Circular A-122, Attachment A, prescribes cost allocation methods including direct and
indirect. Allowable indirect cost allocation methods include the simplified allocation method
and the multiple allocation base method. Attachment B, Paragraph 7, Compensation for Personal
Services, states that reasonable compensation and fringe benefits to employees are grant
fundable costs. The Circular also places specific salary record keeping requirements on the
grantee. The grantee must maintain reports that account for the total activity an employee is
compensated for in fulfillment of their obligations to the organization. The reports must reflect
an after the fact determination of actual activity for each employee. Budget estimates do not
qualify as support for charges to the grant. Grantees must also maintain reports reflecting the
distribution of activity of each employee (professionals and nonprofessionals) whose
compensation is charged, in whole or in part, directly to awards. In addition, in order to support
the allocation of indirect costs, such reports must also be maintained for other employees whose
work involves two or more functions or activities if a distribution of their compensation between
such functions or activities is needed in the determination of the organization's indirect cost rate.

The LASH did not inspect AHHA records to confirm disbursements, which resulted in
questionable payroll costs of $10,904. LASH provided grant funding to the AHHA between
October 1998 and December 2000 to perform OTAG related activity. The LASH only required

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the AHHA to submit time sheets, which was inadequate to ensure payroll costs were appropriate.
This occurred because the LASH did not place sufficient priority over substantiating costs, and
lacked established procedures for reviewing sub grantee costs.

The total amount charged to the grant for AHHA activities during this period was $22,157. This
amount was for payroll expenses, of which $18,464 was for salary and $3,693 was for the
benefits of the Executive Director. Although the AHHA did submit reports to the LASH
showing 900.25 hours worked on the OTAG program, there is no information to show the LASH
confirmed the AHHA’s actual payroll costs.

The LASH established an hourly salary rate of $20.51 and a benefits allocation of 20 percent for
the AHHA’s Executive Director. However, the LASH did not substantiate the AHHA incurred
these costs. There was also inadequate payroll and accounting documentation available at the
AHHA in July 2002 to establish whether the Executive Director was actually paid the rate
charged, or establish whether the benefits costs were reasonable.

However, based on discussions with the AHHA Executive Director, the AHHA Board approved
full-time annual salary of the Executive Director was $24,000 between 1998 and 2000. As a
result, the appropriate hourly salary rate should have been $12.50, and the total salary
reimbursement should have been $11,253. The questionable difference of $7,211 represents
OTAG funds that could have been used to fund other OTAG related tenant outreach and training.


We provided our draft report to the grantee for its comments on August 30, 2002. The grantee
provided their comments on September 16, 2002. We included the LASH’s comments in
Appendix B of the report. We also obtained further clarification during an exit conference
discussion with a LASH official on September 25, 2002.

The LASH disagreed with our conclusions. Its interpretation of the December 3, 1999 letter
from OMHAR allowed for the use of OTAG funds for legal services. The legal representation in
question related to management retribution against tenants in their attempt to organize under the
OTAG program. LASH also stated these activities were fully identified on progress reports
submitted to OMHAR. Since OMHAR approved the associated withdrawal of grant funds, it
also effectively approved the activity.

We acknowledge the legal representations related to management retribution against tenants’
efforts to organize, and this information was disclosed on the progress reports submitted to HUD.
We have adjusted the report to reflect this information. However, no criteria state such legal
representations were appropriate under the OTAG program. The activity was not included in the
LASH’s grant agreement, and no specific HUD approval was available. However, based on
LASH’s response, we adjusted the issue from an ineligible cost to an unsupported/questioned
cost. We conclude there is a need for HUD to make a determination on the eligibility of the

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The LASH also disagreed with our conclusions over the AHHA’s payroll costs, including salary
and benefits. The LASH listed the AHHA Executive Director’s annual salary as $36,000. The
$24,000 figure represented the Executive Director working only two-thirds of full time. In
addition, 10 percent was added to the pay rate to compensate for other unidentified costs. The
LASH also listed its determination of what the AHHA’s Executive Director should have been
paid for benefits. The LASH stated it had an understanding with the AHHA that the amounts
would be paid, and the LASH should therefore not be held liable for what the AHHA did.

The OTAG grant was awarded to the LASH, and the LASH chose to provide funds to the
AHHA. The OTAG grant agreement, OMB, and CFR criteria require the grantee to ensure the
costs of sub grantees are appropriate. The LASH did not take adequate steps to ensure the
accuracy of the sub grantee’s costs, or ensure the sub grantee properly accounted for and
documented these costs. The auditee has provided no information to demonstrate the amounts
disbursed to the AHHA were appropriate. In addition, no support has been provided to
demonstrate the 10 percent allocation of other costs was appropriate within the guidelines of
OMB Circular A-122. However, based on the LASH’s response, we have adjusted the
questioned salary costs from ineligible to unsupported.


We recommended you:

       1A. Obtain a legal determination as to whether the use of OTAG funding for tenant legal
           representation is appropriate under the OTAG program. If not, require the LASH to
           return the $6,408 of OTAG funds used for legal representation.

       1B. Require the LASH to submit documentation to confirm the benefits allocation was
           appropriate based on the AHHA’s actual benefits costs, or return the unsupported

       1C. Require the LASH to submit payroll documentation to support salary costs paid to
           the AHHA, or return the $7,211 of questioned salary costs.

       1D. Consider suspending grant funding until the grantee develops and implements
           appropriate management controls to ensure only eligible activities receive funding
           and the documentation for the expenditure complies with OMB Circular A-122.

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                                MANAGEMENT CONTROLS

In planning and performing our audit, we considered the management controls relevant to the
LASH’ Section 514 program to determine our audit procedures, not to provide assurance on the
controls. Management controls include the plan of organization, methods, and procedures
adopted by management to ensure that its goals are met. Management controls include the
processes for planning, organizing, directing, and controlling program operations. They include
the systems for measuring, reporting, and monitoring program performance.

We determined that the following management controls were relevant to our audit objectives:

   ·   Controls and procedures over grant activities and related disbursements,
   ·   Controls and procedures over monitoring activities and costs of sub recipients,
   ·   Controls and procedures over grant receipts, and
   ·   Controls and procedures over the reporting of activities and cost.

It is a significant weakness if management controls do not provide reasonable assurance that the
process for planning, organizing, directing, and controlling program operations will meet an
organization’s objectives.

Based on our review, we believe the following items are significant weaknesses:

   ·   Lack of a procedures to ensure grant activities were eligible under program requirements,
   ·   Lack of polices and procedures over monitoring activities and costs of sub recipients.

                             FOLLOW-UP ON PRIOR AUDITS

The Office of Inspector General performed no previous audit of the LASH.

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                                                                            Appendix A

     Recommendation                      Type of Questioned Costs
         Number                Ineligible 1/      Unsupported/Questioned 2/
           1A                                               $6,408
           1B                                               $3,693
           1C                                               $7,211

1/     Ineligible costs are costs charged to a HUD-financed or HUD-insured program or
       activity that the auditor believes are not allowable by law, contract or Federal,
       State or local policies or regulations.

2/     Unsupported/Questioned costs are costs charged to a HUD-financed or HUD-
       insured program or activity and eligibility cannot be determined at the time of
       audit. The costs are not supported by adequate documentation or there is a need
       for a legal or administrative determination on the eligibility of the costs.
       Unsupported costs require a future decision by HUD program officials. This
       decision, in addition to obtaining supporting documentation, might involve a legal
       interpretation or clarification of Departmental policies and procedures.

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                   Appendix B

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                                                                           Appendix C


The Honorable Christopher S. Bond, Ranking Member, Subcommittee on Veterans Affairs,
    HUD and Independent Agencies, United States Senate, 274 Russell Senate Office
    Building, Washington, DC 20510
The Honorable Barbara A. Mikulski, Chairwoman, Subcommittee on Veterans Affairs, HUD
    and Independent Agencies, United States Senate, 274 Russell Senate Office Building,
    Washington, DC 20510
The Honorable Dan Burton, Chairman Committee on Government Reform, 2185 Rayburn
    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
The Honorable Joseph Lieberman, Chairman, Committee on Government Affairs,
The Honorable Fred Thompson, Ranking Member, Committee on Governmental Affairs,
Sharon Pinkerton, Senior Advisor, Subcommittee on Criminal Justice, Drug Policy & Human
    Resources, (Sharon.Pinkerton@mail.house.gov)
Andy Cochran, House Committee on Financial Services, (Andy.Cochran@mail.house.gov)
Clinton C. Jones, Senior Counsel, Committee on Financial Services,
Kay Gibbs, Committee on Financial Services, (Kay.Gibbs@mail.house.gov)
Stanley Czerwinski, Director, Housing and Telecommunications Issues, U.S. GAO,
Steve Redburn, Chief Housing Branch, Office of Management and Budget,
Linda Halliday, Department of Veterans Affairs, Office of Inspector General,
William Withrow, Department of Veterans Affairs, OIG Audit Operations Division,
George Reeb, Assistant Inspector General for Health Care Financing Audits,
Jennifer Miller, Professional Staff, House Appropriations Committee,
Wayne Keawe, Comptroller, Legal Aid Society of Hawaii, 924 Bethel Street, Honolulu,
    Hawaii 96813

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