oversight

Housing Choice Voucher Subsidy Standards, Housing Authority of the City of Houston, Houston, TX

Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-09-29.

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

  AUDIT REPORT




HOUSING CHOICE VOUCHER
  SUBSIDY STANDARDS

HOUSING AUTHORITY OF THE
    CITY OF HOUSTON

     HOUSTON, TEXAS

        2004-FW-1010

     September 29, 2004
   OFFICE OF AUDIT, REGION 6
      FORT WORTH, TEXAS
                                                                   Issue Date
                                                                           September 29, 2004
                                                                   Audit Case Number
                                                                           2004-FW-1010




TO:             Dan Rodriguez
                Program Center Coordinator, Office of Public Housing, 6EPH




FROM:           D. Michael Beard
                Regional Inspector General for Audit, 6AGA

SUBJECT:       Housing Choice Voucher Subsidy Standards
               Housing Authority of the City of Houston
               Houston, Texas


We audited the Housing Authority of the City of Houston (the Authority). This audit reviewed the
administration of the Section 8 Program concerning assistance payments to families housed in
larger units than the Authority’s policy allowed. Additional audits concerning the Authority’s
Section 8 Program including: (1) housing quality standards; (2) calculation of housing assistance
payments; and (3) assistance payment databases are underway or planned.

Our report contains one finding with recommendations requiring action by your office. The audit
objective was to determine whether the Authority used its Section 8 funds to pay housing assistance
for tenants who are housed in a larger unit than the Authority’s policy allows.

In accordance with U.S. Department of Housing and Urban Development Handbook 2000.06,
REV-3, within 60 days, please provide us for each recommendation without management decisions,
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 the report is issued 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 your staff have any questions, please contact Theresa Carroll, Assistant Regional
Inspector General for Audit, at (817) 978-9309.
Management Memorandum




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2004-FW-1010                Page ii
Executive Summary
As part of the Office of Inspector General’s Annual Audit Plan, we audited the Housing Authority
of the City of Houston (the Authority). The objective of this audit was to determine whether the
Authority used its Section 8 funds to pay housing assistance for tenants who are housed in larger
units than the Authority’s policy allows. Additional audits of the Authority’s Section 8 Program are
underway.



                                           The Authority paid Section 8 Housing Choice Voucher
    The Authority paid                     funds for tenants to live in larger units than the Authority’s
    excessive Section 8                    policy allowed. Testing showed the Authority overpaid at
    assistance.                            least $797,280 to improperly house at least 352 Section 8
                                           tenants between January 2002 and May 2004. Statistical
                                           testing identified $172,193 in actual ineligible
                                           overpayments and a minimum of $625,087 in projected
                                           overpayments. In addition, the Authority could overpay
                                           more than $3.2 million over the next 3.71 years if it does
                                           not implement controls to stop the overpayments. The
                                           Authority made the overpayments because its Contractor
                                           chose not to follow the Authority’s policy to avoid
                                           increasing its already backlogged workload. The
                                           Authority’s monitoring, which should have detected and
                                           prevented the improper payments, was not sufficient to do
                                           so.

                                           We recommend that the U.S. Department of Housing and
    Recommendations.
                                           Urban Development (HUD) require the Authority to comply
                                           with the unit size limitations in its Administrative Plan. We
                                           also recommend that HUD require the Authority to:

                                           • Repay $172,193 in identified Section 8 overpayments;
                                           • Review other identified tenants potentially living in units
                                             larger than the Authority’s policy allows and repay any
                                             ineligible Section 8 assistance, which we project to be at
                                             least $625,087; and
                                           • Implement controls to avoid future estimated
                                             overpayments of $3.2 million over the next 3.7 years.




1
     According to a HUD Office of Policy Development and Research report, dated January 2003, the average
     Section 8 tenant in Houston resides in an assisted unit for 3.7 years.

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Executive Summary




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2004-FW-1010          Page iv
Table of Contents

Management Memorandum                                                    i



Executive Summary                                                      iii



Introduction                                                            1



Finding

  The Authority Paid for Tenants to Reside in Larger Units              5
  than Allowed


Internal Controls                                                       9



Appendices
   A. Schedule of Questioned Costs and Funds to be Put to             11
      Better Use

   B. Auditee Comments                                                13

   C. Sample Selection, Testing Methodology, and Test Results         19




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2004-FW-1010          Page vi
Introduction
The City of Houston established the Housing Authority of the City of Houston (the Authority) in
1938. The Mayor appoints a five-member Board of Commissioners (Board) to govern the
Authority. The Board hires an Executive Director to manage the Authority’s day-to-day operations.
The Authority keeps its records at its central office at 2640 Fountainview, Houston, Texas.

The Authority has operated its Section 8 Rental Assistance Program since 1975. HUD executed the
Authority’s first Section 8 contract in June 1975 to serve 1,619 families. In June 1985, HUD
executed the Authority’s first Housing Voucher contract to serve an additional 91 families. In 2000,
HUD combined the Section 8 and Housing Voucher Programs to create the Housing Choice
Voucher Program. During the period January 2002 through May 2004, the Authority administered
more than 16,000 Housing Choice Vouchers, including vouchers that it terminated during the
period. From 2002 to 2003, HUD paid the Authority $185 million to fund the Housing Choice
Voucher Program, including $14.5 million for the Authority’s administrative expenses related to the
program.



                                      During 2001, HUD designated the Authority “troubled”
  The Authority hired a               and gave it a very low Section 8 Management Assessment
  contractor to improve its           Program score. The Authority contracted with Quadel
  performance.                        Consulting (Contractor) in December 2001 to manage and
                                      improve its Section 8 Program performance. The
                                      Contractor formed a subsidiary, Houston Housing
                                      Assistance Partnership, to perform the contract work. The
                                      Authority paid the Contractor 85 percent of the
                                      administrative fees that HUD awarded the Authority to
                                      operate the Section 8 program. The Contractor did improve
                                      the Authority’s score out of the “troubled” category.

                                      Even though the Authority hired a contractor to manage
                                      and operate its Section 8 Program, it is ultimately
                                      responsible to HUD for program operations and for any
                                      errors.

                                      Our objective was to determine whether the Authority used
  Audit Objective                     its Section 8 funds to pay housing assistance for tenants who
                                      were housed in larger units than the Authority’s policy
                                      allowed.

                                      To achieve the objective, we:
 Audit Scope and
 Methodology                          •   Reviewed HUD’s and the Authority’s regulations;
                                      •   Reviewed tenant data maintained in HUD’s Public and
                                          Indian Housing Information Center database;


                                           Page 1                                     2004-FW-1010
Introduction


                                            •   Reviewed a statistical sample of inappropriately housed
                                                tenant files maintained by the Contractor at the
                                                Authority’s central office;
                                            •   Interviewed HUD, Authority, and Contractor staff as
                                                necessary; and
                                            •   Recalculated assistance payments to determine how
                                                much the Authority overpaid when it did not use
                                                appropriate unit size or correct payment standards.

                                           Appendix C contains detailed information regarding our
    Sample Selection and
                                           sample selection, testing methodology, and test results.
    Testing Methodology
                                           By comparing Multifamily Tenant Characteristics System
                                           (MTCS)2 data to the subsidy standards in the Authority’s
                                           Administrative Plan, we determined that the Authority paid
                                           assistance for 1,824 out of 16,065 tenants to occupy larger
                                           and smaller units than the Authority’s policy allowed during
                                           the period January 2002 through May 2004. We identified
                                           the 1,824 tenants by comparing their family sizes and unit
                                           sizes to the subsidy limits in the Authority’s Administrative
                                           Plan, below:

                                                                    Minimum #         Maximum #
                                                 Voucher            Persons in        Persons in
                                                 Size               Household         Household
                                                 0 BR                   1                  1
                                                 1 BR                   1                  2
                                                 2 BR                   2                  4
                                                 3 BR                   3                  6
                                                 4 BR                   4                  8
                                                 5 BR                   5                 10
                                                 6 BR                   6                 12

                                           By performing additional analyses on the data in the MTCS
                                           database for these 1,824 families, we determined that the
                                           Authority may have overpaid assistance for 501 of the tenants
                                           because:

                                            •   The tenants possessed a Section 8 Housing Choice
                                                Voucher with more bedrooms than their family size
                                                allowed and



2
     Multifamily Tenant Characteristics System is a HUD database containing demographic data on Section 8
     tenants.

2004-FW-1010                                     Page 2
                                                                                                   Introduction


                                            •    The Authority’s actual assistance payment exceeded its
                                                 subsidy payment standards for the appropriately sized
                                                 unit, based on the tenant’s family size.

                                            We selected a statistical sample3 of 98 of the 501 tenants to
                                            confirm the Authority was overpaying assistance for tenants
                                            housed in larger units than its policy allows. We requested
                                            and reviewed the Authority’s tenant files for any evidence
                                            that these 98 tenants warranted larger units. If we found that
                                            the tenants did not warrant larger units, we recalculated the
                                            assistance payments for those tenants using the correct
                                            bedroom size and compared it with the Authority’s
                                            calculations. When we conducted the testing, we accepted
                                            and did not re-verify the Authority’s housing assistance
                                            calculations for income, deductions, and utility allowances.
                                            If the Authority’s total rental assistance calculations exceeded
                                            our calculations, we considered the excess funds to be
                                            overpayments.

                                            Additional instances of tenants in larger units than allowed by
    Additional instances of                 the Authority’s policy may exist. Our testing may not have
    tenants in larger units than            detected all improperly housed tenants because we only
    allowed may exist.                      tested those family sizes that obviously fell outside the range
                                            created by the maximum and minimum size limits in the
                                            Authority’s Administrative Plan. We did not attempt to test
                                            for tenants that could have fallen inside the maximum and
                                            minimum size limits based on their family composition. For
                                            example, the subsidy standards allow a two-person household
                                            to have a one- or two-bedroom unit. However, if the two-
                                            person household composition is a mother and a child under
                                            5 years old, the Administrative Plan requires the Authority to
                                            issue a one-bedroom voucher.4

                                            We performed audit work from March through July 2004 at
                                            the Authority’s central office at 2640 Fountainview, Houston,
                                            Texas. The audit covered the period January 1, 2002,
                                            through May 24, 2004. We extended the review, when
                                            appropriate, to include other periods. We conducted the audit
                                            in accordance with generally accepted government auditing
                                            standards.




3
     We used EZ Quant statistical sampling software to select a simple random sample with a 90 percent confidence
     level and a 10 percent precision range.
4
     The Authority’s Administrative Plan, January 1, 2004, revision, page 23.

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Introduction




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2004-FW-1010     Page 4
                                                                                                    Finding 1


      The Authority Paid for Tenants to Reside in
             Larger Units Than Allowed
The Authority paid Section 8 Housing Choice Voucher funds for tenants to live in larger units
than its policy allowed. Consequently, the Authority overpaid at least $797,280 to house its
Section 8 tenants between January 2002 and May 2004. Statistical testing identified $172,193 in
actual ineligible overpayments and a minimum of $625,087 in projected overpayments. In
addition, the Authority could overpay more than $3.2 million over the next 3.75 years if it does
not implement controls to stop the overpayments. The Authority made the overpayments
because its Contractor chose not to follow the Authority’s policy to avoid increasing its already
backlogged workload. In addition, the Authority's monitoring, which should have detected and
prevented the improper payments, was not sufficient to do so.



                                           HUD requires the Authority to establish subsidy standards to
    HUD and Authority
                                           set how much rental assistance it will pay for each unit size
    Requirements.
                                           based on the number of bedrooms in the unit.6 HUD also
                                           requires the Authority to apply the subsidy standards
                                           consistently for all tenant families of like size and
                                           composition.7. The Authority established its subsidy
                                           standards in its Administrative Plan. The Administrative
                                           Plan requires the Authority to:

                                               Issue the minimum subsidy standard available to
                                               adequately serve a family8 and
                                               Upgrade or downgrade a family’s voucher as
                                               appropriate.9

    The Authority’s                        The Authority’s Contractor determines the number of
    Contractor issues                      persons in a tenant’s family applying for a voucher. It
    vouchers to tenants.                   consults the Authority’s subsidy standard table in its
                                           Administrative Plan to determine the appropriate unit size.
                                           Once the Contractor makes the determination, it issues a
                                           Housing Choice Voucher to the tenant for the appropriate
                                           unit size. The voucher allows the tenant to rent any size
                                           unit. However, the Authority’s subsidy standards limit



5
     According to a HUD Office of Policy Development and Research report, dated January 2003, the average
     Section 8 tenant in Houston resides in an assisted unit for 3.7 years.
6
     Section 8 Program 24 Code of Federal Regulations 982.402, paragraph (a).
7
     Section 8 Program 24 Code of Federal Regulations 982.402, paragraph (b)(3).
8
     Administrative Plan, January 1, 2004, revision, page 23.
9
     Administrative Plan, January 1, 2004, revision, page 37.

                                                Page 5                                          2004-FW-1010
Finding 1

                             rental assistance to the number of bedrooms on the
                             voucher.

                             Testing showed the Authority improperly housed 76 of the 98
                             statistically sampled tenants in larger units than its policy
                             allowed. Further, the Authority overpaid $172,193 in Section
                             8 Housing Choice Voucher assistance for these 76 tenants.
                             When projected to the population of 501 tenants, statistical
                             theory shows that the Authority has overpaid at least
                             $625,087 on other tenants improperly housed in units that are
                             larger than allowed. Further, if the Authority continues to
                             pay for tenants to lease larger units than they are allowed, it
                             could overpay more than $3.2 million in assistance over the
                             next 3.7 years.

                             Although the Authority initially issued the correct voucher
 The Authority overpaid      size for most of the tenants tested, its Contractor failed to
 because the Contractor      downgrade the vouchers as the tenant’s family sizes changed.
 did not downgrade           In some cases (22%), the Contractor justifiably issued larger
 vouchers.                   units to tenants with exceptional medical circumstances.
                             According to one of the Contractor’s managers, the
                             Contractor did not downgrade the vouchers because it
                             chose not to follow the Authority’s policy to avoid
                             increasing its already backlogged workload. The
                             Authority’s monitoring of the Contractor’s performance did
                             not detect the Contractor’s decision to violate the
                             Authority’s policy.

                             The Authority’s Director of Regulatory Compliance and
  The Authority agreed and   Intergovernmental Affairs agreed that the Authority housed
  expects to complete        the identified tenants in units larger than policy allowed. He
  corrections by October     stated that the Authority has taken steps to correct the 76
  2004.                      erroneous files and anticipates completion by the end of
                             October 2004.



Auditee Comments             The Authority agreed the problems discussed in the finding
                             existed and are in immediate need of correction. The
                             Authority concurred that it overpaid $172,193 and stated it
                             is having its Contractor review and take corrective action
                             on the 76 participants. The Authority indicated it
                             developed a plan to review all of its participant files to
                             identify any that are over-housed. Further, the Authority
                             indicated it is performing a comprehensive review of the
                             remaining 403 files out of the 501 identified as potentially

2004-FW-1010                      Page 6
                                                                        Finding 1

                    over-housed by OIG. The Authority expects this review to
                    be completed in 30 days. In addition, the Authority agreed
                    to relocate or take other administrative action to ensure that
                    housing is appropriately based on the number of persons in
                    a household. The Authority also stated that it will take
                    operational and administrative control of its Section 8
                    Programs from its Contractor, effective October 20, 2004.
                    Finally, the Authority indicated it would not incur future
                    estimated overpayments of $3.2 million because it is taking
                    corrective actions to prevent such a problem.



OIG Evaluation of   We appreciate the Authority agrees a problem exists and
Auditee Comments    has detailed actions to correct the problems. The Authority
                    has outlined corrective actions including a comprehensive
                    review of all potentially over-housed tenant files within the
                    next 30 days. Then, the Authority will review all of its
                    remaining Section 8 files. Further, the Authority indicated
                    it would assume responsibility for the Section 8 Program
                    from its Contractor. If followed, these steps should be
                    sufficient to correct and prevent the Authority from paying
                    assistance to tenants who are living in a larger unit than the
                    Authority’s policy allows.



                    We recommend HUD require the Authority to:
Recommendations
                    1A. Comply with the unit size limitations in the
                        Administrative Plan.

                    1B. Repay $172,193 in identified Section 8 overpayments.

                    1C. Review other identified tenants potentially living in
                        units larger than the Authority’s policy allows and
                        repay any ineligible Section 8 assistance, which we
                        project to be at least $625,087.

                    1D. Implement controls to avoid future estimated
                        overpayments of $3,232,953 over the next 4 years.




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Finding 1




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2004-FW-1010     Page 8
Internal 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 Internal Controls           relevant to our audit objectives:

                                      •   Management’s assurance that the Contractor complies
                                          with the terms of the Administrative Plan and
                                      •   Contractor’s quality control system, through which it
                                          self-assesses its performance and provides feedback via
                                          training to its employees.

                                      We assessed the relevant controls identified above.

                                      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 identified two significant
  Significant Weaknesses              weaknesses:

                                      1. The Authority did not monitor the Contractor sufficiently
                                         to ensure that it followed the Authority’s policy.

                                      2. The Authority’s Contractor intentionally circumvented
                                         the controls established to prevent the Authority from
                                         overpaying Section 8 Housing Choice Vouchers.




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2004-FW-1010         Page 10
                                                                                                       Appendix A

Schedule of Questioned Costs and Funds to be
Put to Better Use

          Recommendation                 Ineligible 1           Unsupported 2             Funds Put to
                                                                                           Better Use3
                   1B                           $172,193
                   1C                                                    $625,087
                   1D                                                                           $3,232,953




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 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
    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.
3
    “Funds put to better use” are costs that will not be expended in the future if our recommendations are
    implemented, including costs not incurred, de-obligation of funds, withdrawal of interest, reductions in outlays,
    avoidance of unnecessary expenditures, loans and guarantees not made, and other savings.




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2004-FW-1010    Page 12
                             Appendix B

Auditee Comments




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Appendix B




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          Appendix B




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Appendix B




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          Appendix B




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2004-FW-1010    Page 18
                                                                                          Appendix C

Sample Selection, Testing Methodology, and
Test Results
SAMPLE SELECTION:

We found records for 16,065 tenants in the MTCS database for the period January 2002 through
May 2004. The records included those tenants that the Housing Authority terminated from the
program during the period. We performed several sorts on the data in the records to determine
which units the Authority may have over-subsidized based on tenant family sizes.

We sorted the listing by voucher size and number of persons in the household. We compared the
voucher size and number of household members to the unit size limits in the Authority’s
Administrative Plan and found 1,824 tenants whose voucher sizes were greater than or less than the
size limits.

We sorted the 1,824 tenants by number of household members and compared the number of
household members to the number of bedrooms on the 1,824 tenants’ vouchers. We identified
1,088 of the 1,824 tenants whose voucher sizes exceeded the number of family members.

We then compared the number of family members in each household to the actual number of
bedrooms in the tenant’s home and identified 891 tenants who had excessive voucher sizes and
lived in larger units than their number of family members warranted.

We then compared each tenant’s rent to the appropriate payment standard for the tenant’s family
size and determined that the rent exceeded the payment standard for 501 of the 891 tenants. These
are the tenants for whom the Authority may have overpaid housing assistance because the Authority
subsidized the tenants’ residence in larger units than the Authority’s policy allows. However, there
are some allowable exceptions according to the Administrative Plan. Therefore, we selected a
representative statistical sample of the 501 tenants and tested them.

We used EZ QUANT statistical software to select our sample. We defined the unit to be sampled as
a tenant file in which the Authority paid to house a tenant in a unit larger than the Authority’s
Administrative Plan allowed. We determined that there were 501 such tenants in the universe. We
desired a 90 percent confidence level that the results of the statistical testing would be within a 10
percent precision range.

Based on the size of the universe (501), a presumed error rate of 10 percent, a precision rate of 10
percent, and a desired confidence level of 90 percent, the EZ Quant software selected 98 random
samples for testing.

TESTING METHODOLOGY:

We defined an error as any tenant file in which the Authority housed a tenant in a unit and paid
more than the maximum payment allowed by the Authority’s Administrative Plan for a correct unit
size.


                                            Page 19                                      2004-FW-1010
Appendix C

In order to test the samples, we reviewed the 98 tenant files to determine whether the tenant
warranted a larger unit due to medical needs or some other exception listed in the Administrative
Plan. If there was no documented exception in the tenant file, we recalculated the assistance
payments using the correct payment standards in the Administrative Plan. For purposes of the
recalculations, we accepted and did not re-verify the Authority’s housing assistance calculations for
income, deductions, and utility allowances.

We used the EZ Quant software to project the test results onto the population.

TEST RESULTS:

We found that the Contractor had incorrectly calculated the assistance payments for 76 of the 98
tenants because it used incorrect payment standards. As a result, the Authority overpaid $172,193
to over house the 76 tenants.

When we used EZ Quant to project the results to the population, we found that the Authority over
housed between 352 and 419 of the 501 tenant families, and that the Authority overpaid between
$797,280 and $949,035 to over house them.

We determined that the Authority overpaid $14,244 for the 98 sample tenants during May 2004.
Each of the 98 tenants will be in a single assisted unit in the City of Houston for an average of 3.7
years, therefore, the Authority would overpay $632,433 for the 98 tenants over their average stay in
their current units ($14,244 overpaid/month X 12 months/year X 3.7 years = $632,433). That
equates to $6,453 per tenant over 3.7 years ($632,433/98 tenants = $6,453/tenant). Therefore, if the
Authority does not correct the over housing, we project that it could overpay $3,232,953 over the
next 3.7 years ($6,453/tenant X 501 tenants = $3,232,953).

We included the test results of the 98 samples below:



             Family
             Members           Bedrooms
     Voucher in       Bedrooms on       Overpayment Overpayment Overpaid
#    Number Household in unit  Voucher Start Date   End Date    Amount
1    13812   2        3        3        Oct-02      May-04      $ 5,468
2    19755   1        2        2        May-02      May-04        2,849
3    50271   1        2        2        Mar-04      May-04          168
4    23582   3        4        4        Feb-03      May-04        2,174
5    79735   1        2        3        Apr-04      May-04          344
6    06293   2        3        4        Aug-03      May-04          180
7    03019   1        2        2        Nov-02      May-04        3,046
8    18749   2        4        3        Feb-02      May-04        8,368
9    18913   2        3        3        Aug-02      May-04        3,740
10   19304     1          2           2                                              0
11   22220     2          3           3          Mar-04        May-04              648
12   79868     1          2           2          Aug-03        May-04              170
2004-FW-1010                               Page 20
                                                         Appendix C


13   00542   2   3   3      May-03    May-04   2,156
14   17191   1   2   2      Jun-03    May-04   1,068
15   03941   1   3   3      Oct-02    May-04   4,700
16   45419   1   2   2                             0
17   52275   1   2   3                             0
18   75092   1   2   2                             0
19   52546   2   4   3                             0
20   16482   2   3   3                             0
21   52744   1   2   2                             0
22   36589   2   3   3      Dec-03    May-04     762
23   00410   1   3   3                             0
24   35624   1   2   2                             0
25   05970   2   4   3      Dec-02    May-04    4,302
26   53351   1   2   2      Jan-04    May-04      595
27   22170   2   3   3      Aug-02    May-04    3,726
28   54465   2   4   3      Aug-03    May-04    2,070
29   47099   1   2   2      Nov-03    May-04   1,204
30   29341   1   2   2      Sep-02    May-04    2,417
31   02202   1   3   3      Jan-03    May-04    6,500
32   14356   1   2   2                              0
33   86508   1   2   2      Jun-03    Dec-03    1,183
34   56029   1   3   3      Apr-03    May-04    5,754
35   17966   2   3   3      Sep-03    May-04    1,179
36   51699   2   3   3                               0
37   89112   2   3   3      Nov-03    May-04      567
38   20683   1   2   2                               0
39   58869   2   3   3                              0
40   08394   2   3   3      Sep-02    May-04    2,844
41   45406   2   3   3      Mar-04    May-04      396
42   37029   2   3   3      Feb-04    May-04      632
43   79919   1   2   3                              0
44   18247   2   3   3      Oct-03    May-04    1,968
45   04929   1   3   2      Oct-02    May-04    3,014
46   18189   1   2   3      Jan-04    May-04      360
47   25812   2   3   3      Dec-03    May-04    1,394
48   40648   1   2   2                               0
49   20521   1   2   2      Feb-04    May-04      680
50   27559   1   3   3      Jun-03    May-04    2,640
51   15122   1   3   2                              0
52   00017   1   2   2       Jun-03   May-04      924
53   01308   1   3   3       Jan-03   May-04    2,228
54   04005   1   2   2       Feb-03   May-04    1,032
55   26245   2   3   3       Dec-02   May-04    1,992
56   43139   1   2   2       Aug-02   May-04    2,058
57   23585   2   4   3       Dec-02   May-04   4,602
                         Page 21                         2004-FW-1010
Appendix C


58   48987     2   4   3        Apr-03   May-04         4,140
59   19225     2   3   3        Feb-04   May-04           496
60   16991     1   2   2        Dec-02   May-04         2,224
61   71766     1   3   3                                    0
62   17395     1   2   2                                    0
63   32521     1   3   2        Jun-02   May-04         2,633
64   18038     2   3   3        Nov-02   Apr-03         1,056
65   56730     2   4   3        Aug-02   May-04         6,074
66   36799     1   3   3        Jun-03   May-04         4,470
67   03515     1   2   2        Sep-02   Aug-03         1,932
68   20669     2   3   3        May-03   May-04         2,291
69   37158     1   2   2        Aug-03   May-04           490
70   02067     2   3   3        Sep-02   May-04         3,788
71   40368     1   2   2        Sep-02   May-04         1,421
72   22296     2   3   3        Jul-02   Jan-04         3,033
73   00175     1   3   3        Jan-04   May-04           775
74   36862     1   2   2                                    0
75   04953     2   3   3        Dec-02   May-04         3,582
76   07007     1   3   3        Aug-02   May-04         2,048
77   69948     1   2   2                                    0
78   21999     1   3   3        Dec-02   Apr-03          1,250
79   17124     1   2   2        Jul-03   May-04            759
80   43762     2   3   3        May-04   May-04             243
81   21874     2   3   3        Dec-03   May-04            936
82   25983     2   3   3        Mar-03   May-04            459
83   06850     1   2   2        Oct-02   May-04          2,948
84   38526     1   2   2        May-04   May-04            159
85   34987     2   3   3        Feb-03   May-04          3,036
86   37509     1   2   2                                     0
87   75153     1   2   2        Jul-03   Jun-03            936
88   38837     1   2   2        Jul-02   May-04          2,632
89   09895     2   3   3        Oct-02   May-04          3,261
90   23882     2   3   3        Aug-03   May-04          2,938
91   68401     1   2   2        Sep-03   May-04            126
92   68655     1   4   4        Nov-02   May-04         7,045
93   17486     1   3   3        Jan-03   May-04         3,809
94   39308     1   3   3        Jan-04   May-04          2,305
95   73410     2   3   3        Mar-04   May-04            729
96   18563     1   3   3        Nov-03   May-04          3,059
97   89491     1   2   2                                     0
98   76212     1   2   2        May-02   Apr-04          3,008
                                         Total
                                         Overpayments $172,193



2004-FW-1010               Page 22