Issue Date November 19, 2004 Audit Case Number 2005-FW-1002 TO: Elva Castillo Director, Multifamily Program Center, 6JHMLAX Margarita Maisonet Director, Enforcement Center, CV FROM: D Michael Beard Regional Inspector General for Audit, 6AGA SUBJECT: Domicile Property Management, Inc. Multifamily Management Agent San Antonio, Texas INTRODUCTION As part of the Office of Inspector General’s initiative to combat equity skimming in the multifamily housing programs, we have completed an audit of Domicile Property Management, Inc. (Domicile). The Office of Investigation requested us to do the audit. Our objectives were to determine whether Domicile used HUD assisted property funds in compliance with the regulatory agreements and applicable HUD requirements. To accomplish our objectives, we interviewed Domicile’s owner, his employees as necessary, his attorneys, and HUD staff. We reviewed Domicile’s records and HUD assisted property records including general ledgers, bank statements, cancelled checks and supporting documentation, and audited financial statements. Our review started on September 21, 2000, and concluded July 25, 2003. We performed the review at Domicile’s office and the San Antonio HUD office. We discussed our initial findings with the United States Attorney’s office on September 17, 2001. Based on the interest of the assigned Assistant United States Attorney, we expanded the review and examined 100 percent of the HUD assisted property disbursements between January 1, 1997, and December 31, 2000. Because Domicile was slow to produce records, we issued a subpoena on December 13, 2001. We took custody of the records on March 6, 2002. We conducted our audit in accordance with generally accepted government auditing standards. 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 your staff have any questions, please contact me at (817) 978-9309. SUMMARY In violation of the properties’ regulatory agreements, Domicile diverted property income totaling $771,103 to pay its own expenses and paid $1,469,926 from property accounts without documentation to show the payments were for necessary and reasonable operating costs. Further, Domicile did not abide by the 1995 settlement agreement for a previous HUD claim, involving project overcharges during 1992 and 1993. Under that agreement, Domicile paid $272,113 but did not report and pay an additional $49,262 for self-funded health insurance. Because of Domicile’s current diversions and failure to pay the previous settlement obligation, they deprived the properties of operating funds reducing HUD’s security interests and increasing HUD’s risks. We discussed each of the matters presented with Domicile’s owner during the audit and requested his written responses. We are providing his responses in the finding and our evaluation of his responses. We did not receive responses on the excess management agent fees, ineligible telephone charges, and unsupported costs. His full response is attached in Appendix C. BACKGROUND Mr. John Condit owns Domicile Property Management Inc. Domicile’s office was located at 601 Howard Street, San Antonio, Texas 78212. Domicile managed 35 HUD assisted properties; 27 with HUD insured mortgages and 8 with HUD direct loans. The properties are located in Texas, Oklahoma, and Kansas. A list of the properties as of July 31, 2003, showing the property name, Housing Act section, whether the mortgagor is a nonprofit, fiscal yearend (FYE), and the loan status is shown in Appendix B. As of March 25, 2003, Domicile stopped managing three of the properties, Alexandra, Kings Cove and Knightbridge. One property, Mulberry Court, is in foreclosure, two, Kings Cove and Silverwood, are in default and nine, Alexandra, Alice Village, Aurora, Clinton Parkway, Kings Cove, Knightsbridge, Mercedes Palms, Mission Village, and Mulberry Court, were in a nonsurplus cash positions as of fiscal yearend 2001. The remaining properties were current. 2 The HUD Office of Inspector General’s initiative to combat equity skimming consists of audits such as this one where auditors consult with the appropriate United States Attorney’s office and HUD Assistant General Counsel to recover project funds used in violation of the regulatory agreement. Under Title 12, United States Code (USC), Section 1715z-4a, HUD may recover double the amount of project assets used for purposes other than those permitted by the regulatory agreement, plus the cost of any audit, litigation, and attorney’s fees. We provided a prosecution/litigation package to the HUD Assistant General Counsel on July 25, 2003, and to the United States Attorney’s office, Western District of Texas, on August 27, 2003. On August 10, 2004, we received approval from the United States Attorney’s office to release this audit report. On August 28, 2003, we learned that United States Marshals enforced a seizure order issued by the Lubbock Division of the United States District Court of the Northern District of Texas against Domicile’s owner in an unrelated matter. A receiver has been appointed by the United States District Court to take over his assets. The receiver has taken steps to freeze his assets, including appointing McDougal Properties to take over Domicile Property Management, Inc. FINDING Domicile Diverted Property Income to Pay Management Agent and Unsupported Property Expenses Domicile Property Management, Inc., diverted $771,103 of property income to pay management agent expenses in excess of what federal requirements allowed and paid $1,469,926 in unsupported expenses. Further, Domicile did not fully abide by the 1995 agreement with the United States Attorney’s office. Domicile paid part of the settlement but has not fulfilled all of the agreement. Domicile has recognized a liability on its books in the amount of $49,262 but has not remitted the funds to the government. The government’s current claim includes $771,103 in diverted funds, $1,469,926 of unsupported costs, $49,262 due from the 1995 settlement, and $352,053 in audit costs. The claim is detailed below. Title 12, USC, Section 1715z-4a, provides for the government to recover double damages for violating the regulatory agreements. 3 Diversions: Front-Line Costs: Per Unit Bookkeeping Fee $ 481,173 Postage 43,884 Payroll Processing Fee 119,721 Management Fees 43,868 Training 66,730 Telephone 15,727 $ 771,103 * Other Unsupported 1,469,926 * 1995 Settlement, Self-Funded Ins. 49,262 Audit costs 352,053 Total $2,642,344 * Subject to double damages Federal Requirements The property owner signs and agrees to the regulatory agreement to obtain a non-recourse loan and either HUD FHA mortgage insurance (federal guarantee for mortgage repayment to the lender), a HUD direct loan or HUD financial assistance. The regulatory agreement pledges all income from the property to HUD and spells out the only proper uses of property funds such as: • Payment of the mortgage; • Deposits to the reserve for replacements and other required reserves; • Payment of reasonable expenses necessary for proper operation and maintenance of the project;1 • Distributions of surplus cash when permitted; and • Repayment of mortgagor advances authorized by the commissioner’s administrative procedures. The Section 202 and 811 regulatory agreements prohibit the owner or any owner representative from having any financial interest in any contractual arrangement entered into by the owner in connection with rendition of services, the provision of goods or supplies, management of the project, procurement of furnishings and equipment, construction of the property, procurement of the site, or other matters whatsoever. In addition, the regulatory agreement requires the owner to: 1 Payments for services, supplies, or materials shall not exceed the amount ordinarily paid for such in the same area. 4 • Maintain the property’s books and accounts according to HUD requirements (Handbook 4370.2 REV-1 Financial Operations and Accounting Procedures for Insured Multifamily Projects) and in reasonable condition for audit; • Retain all copies of written contracts or other instruments, which affect the property; • Provide access to those records by authorized agents; • Maintain the premises in substantial repair and condition; and • Provide property management satisfactory to HUD. In providing property management, HUD requires the owner and agent to provide a management certification. The owner and agent certify and agree to: • The fee (as a percentage of revenue); • Any special fee; • Comply with the regulatory agreement; • Comply with HUD Handbooks, notices, and other policy directives relating to management of the property; • Ensure all expenses are reasonable and necessary; • Obtain cost estimates and document the reasons for accepting other than the lowest bid; • Maintain copies of documentation; • Refrain from purchasing from identity-of-interest entities; • The types of insurance policies and coverage; • Respond to HUD inquiries; and • All the records belonging to the property. The owner and agent sign the certification under false statement, criminal, and civil equity skimming and civil money penalty warnings. HUD Handbook 4381.5 REV-2, The Management Agent Handbook, applies to management agents of HUD-insured and HUD-assisted properties. HUD designed the handbook to serve as a reference for owners and their management agents. The Director of Housing may waive directives specified in this handbook only if they are not formally required by statute or regulation. According to the Director of the Multifamily Program Center, HUD has not issued a wavier to Domicile. The project owner is responsible for selecting a management agent, subject to HUD approval. The management agent is paid a management fee for their services. The agent must cover the costs of supervising and overseeing project operations out of their fee. Management Costs Paid from Management Fee The agent pays expenses for services that are not front-line activities (see paragraph below explaining front-line activities) from the management fee, except centralized accounting and computer services. Other costs paid from the agent’s fee include overhead expenses (e.g. supplies and equipment, transportation and phone calls to the projects, regularly scheduled long distance calls from project to agent, office space, data 5 processing, etc). Additional costs paid from the agent’s fee include salaries, fringe benefits, office supplies, fees, contract costs, and designing procedures/systems to keep the project running smoothly and in conformity with HUD requirements. Contracting Guidelines The agent solicits written cost estimates from at least three contractors or suppliers for any contract, ongoing supply or services expected to exceed $10,000 per year. For contracts estimated to cost less than $5,000 per year, the agent should solicit verbal or written estimates. The agent should retain the documentation as part of the project’s records for 3 years following the completion of the work. Front-Line Activities HUD allows reasonable expenses for front-line activities including when a management agent elects the single office approach as Domicile has. Front-line activities include: taking applications; screening, certifying, and recertifying Section 8 residents (residents with subsidized rent); maintaining the project; and accounting for project income and expense. When front-line activities are performed out of a single office, HUD requires the agent to prorate the total associated costs based on actual use. Agents may not impose surcharges or administrative fees in addition to actual costs. Bookkeeping The costs of bookkeeping services for a project performed as part of a centralized system are treated as a project cost and should not be treated as a special fee. Such expenses are paid from project funds based on actual costs. A project can reimburse the agent for prorated cost of personnel providing property-specific accounting and computer services to the project. The cost to the project for such services provided by the agent may not exceed the cost of procuring comparable services from an independent vendor. Each year, the agent must determine that these costs are at or below the market and maintain such evidence on-site. The agent pays the agent’s bookkeeping expenses from the management fee. Training for Front-Line Staff Owners and agents may use property funds to obtain project related (emphasis added) training. Telephone Charges From the management agent’s fee the management agent pays for telephone charges originating from his office to the project and any regularly scheduled calls from the project to the agent’s office. The project pays for other calls originating from the project to the agent’s office. 6 HUD Handbook 4370.2 REV-1, Financial Operations and Accounting Procedures for Insured Multifamily Projects, is the principal guide for financial and accounting operations for HUD insured properties. The Handbook applies to multifamily rental properties under charter or regulatory agreement permitting HUD to exercise control over property administration and operation. The general objectives include: • Executing all transactions in accordance with property management and where required, HUD’s authorization; • Reporting on all financial transactions using HUD guidelines and generally accepted accounting principles; • Safeguarding property assets; and • Providing timely, accurate, and complete information for management decision- making and assisting with compliance with HUD specified accounting procedures. Further, all disbursements (including checks, wire transfers, and computer generated disbursements) must be supported by approved invoices/bills or other supporting documentation. Disputed Costs Domicile diverted $771,103, and did not adequately document $1,469,926 in costs charged to insured properties. Also, Domicile did not pay $49,262 due from the prior agreement with the United States Attorney’s office. Domicile used the following diversion methods: 1. Front-Line Costs: a. Charging bookkeeping fees instead of actual cost; b. Charging management agent costs as postage; i. Charging each property $32 to $34 per month to refill Domicile’s postage meter instead of the actual property’s cost and ii. Collecting a fee for postage to pay management agent cost; and c. Charging payroll-processing costs payable from the management fee. 2. Collecting excess management fees; 3. Charging a training fee instead of actual cost and then using the fees to pay management agent costs; 4. Charging management agent telephone calls; and 5. Charging unsupported expenses. Domicile used property income and rents to pay management agent expenses in excess of what federal requirements allow. Further, Domicile did not establish the use of property income and rents for reasonable operating expenses and necessary repairs or adequately document disbursements. 7 Front-Line Costs Domicile charged bookkeeping and postage fees (special fees) in excess or instead of the actual cost. Further, Domicile improperly paid management agent expenses including postage meter refills and payroll-processing fees from insured property funds. Total disputed front-line costs are $644,778. Bookkeeping Fee Domicile charged the properties $481,173 in bookkeeping fees instead of actual cost. From Domicile’s books and records we could not determine an individual property’s actual bookkeeping cost, a method to prorate those costs in proportion to actual use, or whether the bookkeeping costs were reasonable. HUD requires the cost of bookkeeping services for a property, performed as part of a centralized system, to be treated as a property cost and not as a special fee. Properties pay bookkeeping expenses based on actual costs.2 Further, Domicile never provided any documentation as to whether an outside vendor could perform the same services for less, as required by HUD.3 We found no cost comparisons, studies, solicitations, or any other means for determining the reasonableness of bookkeeping costs. AUDITEE RESPONSE Domicile’s owner provided the breakdown of the monthly per unit bookkeeping reimbursement of $6.01. Domicile’s owner said he based the fee calculation on costs including salaries, hardware/software, office rent, property taxes, overhead, and supplies divided by total units under management. OIG’S EVALUATION OF AUDITEE RESPONSE Domicile’s response addresses a fee that HUD does not allow. The management agent is required to charge actual bookkeeping costs. The bookkeeping salaries appeared to be for only 1 month and Domicile provided no supporting documentation. In addition, according to HUD Handbook 4381.5 REV-2, The Management Agent Handbook, Figure 6-2, office rent, property taxes, and overhead are payable from the agent’s fee not from the property. Postage Domicile charged the properties $43,884 for postage. Domicile collected $32 to $34 per month in fees from the properties, deposited them in a separate Domicile bank account and used the fees to pay management agent costs. The fees amounted to $34,035. Domicile used these funds for management agent expenses including payroll, lease of a postage meter at the agent’s central office, and postage for that meter. However, Domicile charged the 2 HUD Handbook 4381.5 REV-2, The Management Agent Handbook, 3.6 c. 3 HUD Handbook 4381.5 REV-2, The Management Agent Handbook, Figure 6-2. 8 properties another $9,849 to refill Domicile’s postage meter. Initially, Domicile made checks payable to the Postmaster and used $9,849 to refill Domicile’s postage meter. Starting in 1998, Domicile made the checks payable to itself. Domicile charged insured properties $34,035 for postage, when the property purchased no postage. On the check vouchers, Domicile noted the checks as “postage,” “monthly postage,” or “office supplies” claiming these as property expenses. However, they were not property expenses. AUDITEE RESPONSE Domicile’s owner said he uses the $34 per month to offset allowable direct property expenses incurred in the daily management of the properties. He said these expenses include the cost of check stock, check printer, envelopes, postage, and copies. These expenses are allowed by HUD Handbook 4381.5 REV-2, The Management Agent Handbook, Figure 6-2. He said he chose the per month fee to avoid the cost of accounting for each actual item. He said this would add almost $18 per month per property to the cost. He said this is a reasonable reimbursement, they are holding down the cost of small items. OIG’S EVALUATION OF AUDITEE RESPONSE Again, Domicile’s response addresses a fee that HUD does not allow. Although, HUD Handbook 4381.5 REV-2, The Management Agent Handbook, Figure 6-2, allows these expenses, Domicile must account for these expenses and charge them on an actual basis. In fact, Domicile does charge some of these expenses directly and continues to collect the monthly fee. Finally, the auditee states the fee is reasonable but provides nothing to support the statement. Payroll-Processing Fee Domicile contracted with a payroll-processing firm in June 1993 and presently uses an employee leasing arrangement. Domicile charges its processing fee to the properties. Thus, Domicile has transferred its management agent cost and payroll function to the insured properties. So far, Domicile has charged $119,721 in payroll-processing costs payable from the management agent fee to insured properties. In February 1994, Domicile asked HUD to confirm the fee as an eligible project expense. HUD’s Chief of Loan Management told Domicile in a letter that the payroll-processing cost “must be paid from the management fee.” Domicile disregarded HUD instructions and passed on the payroll-processing costs anyway. Further, Domicile did not provide any documentation as to the reasonableness or cost effectiveness of using a payroll-processing service or an employee leasing arrangement. As a result, property funds totaling $119,721 are ineligible. AUDITEE RESPONSE Domicile’s owner said, “The payroll processing fees incurred for payroll management have varied based on the level of service for which an outside service was contracted. Prior to 1999, DPMI (Domicile [added by OIG]) kept the Human Resource function in-house and engaged an outside service that only issued payroll checks and processed the payroll tax 9 requirements. Employee benefits, non-participant or worker’s compensation insurance and the employee medical insurance were placed using in-house staff.’ ‘The rising cost of, and difficulty of obtaining, health and worker’s compensation insurance and employee benefits, as well as the increasing complexity of the Human Resource function dictated either addition of internal staff or contracting for a higher level of service. The determination was made to shift the personnel function to a staff leasing arrangement. The staff leasing engagement encompasses far more than just payroll processing, being all inclusive of the Human Resource function.’ ‘In June 2000 DPMI entered into a contract with Premier Consulting, Inc. for full employee leasing services under a co-employment agreement. The fee paid to Premier for this service was 4% of the base payroll. During the year the service was evaluated and found not to be of the overall quality expected. Further, we did not consider the cost of their service formula to be the most appropriate for the wide range of property types and salary ranges. At the end of the first year of the contract DPMI, in an effort to obtain better service to cost performance, re-bid the employee leasing contract.’ ‘After review of a number of bids and interviews with four firms, AdminiStaff was selected as the service provider. In negotiations with AdminiStaff, a basic bundle rate of approximately 20.25% of base payroll was agreed. This bundle rate includes payroll taxes, worker’s compensation insurance, health insurance, benefits and the service fee. Because AdminiStaff quotes only a “bundle” rate, the exact percentage of payroll that comprises the AdminiStaff service fee cannot be broken out as a specific percentage of payroll that is common across all properties. However, when we looked at all competing bids the total “cost of service” and range of service provided showed the AdminiStaff bid to be in line with competing proposals but with a superior service package.’ ‘The fee(s) paid to AdminiStaff are assessed directly to each property and are paid by that property. DPMI corporate payroll is administered and charged under the same formula as each property. There is no add-on fee from DPMI and DPMI receives no rate break or extensive resources providing AdminiStaff with payroll and employee documentation and information.” OIG EVALUATION OF AUDITEE RESPONSE Although Domicile’s owner provided additional information about the payroll-processing fee charged to the projects, he did not respond to the issue of paying management agent costs from property income. Further, he did not address why he did not stop the practice when HUD’s Chief of Loan Management specifically told him in writing the payroll processing cost must be paid from his management fee. Excessive Management Fees Domicile collected $43,868 in excess management fees from Mt. Carmel, an insured property. According to Mt. Carmel’s 2000 audited financial statements, Domicile’s 10 owner stated that Domicile discovered a management contract with a fee rate of 8.6 percent instead of 7 percent. Domicile retroactively charged and collected the difference in fees. Domicile has not produced the management contract supporting the increase in management fees or paid back the excess fee. Training/Seminar Domicile collected $66,730 in training fees instead of charging actual training cost. Then, Domicile’s owner used these funds to finance his “annual seminar.” HUD allows training, but it must be project related.4 Domicile showed these charges in the properties’ books and accounts as training expenses with no support. Domicile noted “training expense” on the project check vouchers. We reviewed Domicile’s annual seminar records and found that Domicile did not spend all the funds collected for project related training. As of December 31, 2000, Domicile had accumulated $22,106 in excess of actual cost. Domicile provided the agenda for seminars in 1999 and 2000. The seminar expenses appear about half project related. To illustrate, the 2000 seminar ended at noon on May 26. The hotel bill shows everyone stayed over until the next day. In 1999, Domicile purchased shirts for participants and paid for a trip to Disney World. In 1998, Domicile paid for the printing of its Operating Manual, a management agent expense. In 1999 and 2000, Domicile passed out cash awards. AUDITEE RESPONSE Domicile’s owner said he holds an annual training seminar lasting 3-1/2 to 4 days for property managers. They cover project related subjects including break out sessions for HUD and conventional properties. He said HUD approved the training. He assesses a monthly reimbursement in order to offset the training cost. He charges $40 for properties in the metro area, $50 within driving distance and $70 if air travel is required. OIG EVALUATION OF AUDITEE RESPONSE HUD does approve project related training. However, our review showed only about half of the training was project related and that Domicile has accumulated $22,106 (as of December 31, 2000) in excess of actual costs. Domicile needs to return the training fees and charge the projects only actual costs for project related training as approved by HUD. Telephone Costs Domicile charged $15,727 in long distance telephone costs to the insured properties when it should have been payable from the management agent fee. HUD requires the agent to pay the cost of telephone calls to the project and regularly scheduled long distance calls from the project to the agent.5 We did not solicit comments from Domicile’s owner since 4 HUD Handbook 4381.5 REV-2, The Management Agent Handbook, 6.38 c. (1). 5 HUD Handbook 4381.5 REV-2, The Management Agent Handbook, Figure 6-2. 11 the calls were placed from his office to the project and according to HUD Handbook 4381.5 these type of costs are clearly ineligible. Unsupported Costs Domicile did not document $1,469,926 in costs paid to Domicile and charged to insured projects as required by HUD handbooks and the Civil Equity Skimming Statute. We could not find bills, invoices, payroll records, or computations to support these costs as either reasonable or necessary. Settlement of 1995 Domicile did not abide by the 1995 agreement with the United States Attorney’s office. The agreement with the United States Attorney’s office settled a HUD equity-skimming claim of $272,113 covering the years 1992 and 1993. The agreement involved violations for overcharging payroll costs, ineligible telephone charges, and overcharges for Section 8 subsidies. Domicile paid $272,113. Domicile agreed to terminate the health insurance no later than July 30, 1996, and produce an accounting to HUD no later than120 days after termination. As of the current date, Domicile has not provided the information but has recognized a $49,262 liability on its books for self-funded health insurance. Audit Costs In addition, the government may claim $352,053 in reasonable audit costs allowed by the Civil Equity Skimming Statute. We started the audit in September 2000. Domicile has stalled and attempted to block our audit at every turn. We issued a letter on October 17, 2001, demanding records. We issued a subpoena for property and management agent records on December 13, 2001. The United States Attorney’s office was required to enforce the subpoena and still Domicile did not provide the records until March 6, 2002. Further, due to the nature of the diversions and the huge number of disputed transactions of a relatively small dollar amount, considerable audit effort was required to review each property on a transaction-by-transaction basis. RECOMMENDATIONS We recommend the HUD Director of Multifamily Housing, through the Office of Regional Counsel and the United States Attorney’s Office, as appropriate, require Domicile and its owner: 1A. To repay the properties $771,103 diversions identified in the current audit. 1B. To repay the properties or provide adequate support for the $1,469,926 in unsupported costs. 1C. To repay the properties $49,262 owed from the 1995 settlement. 12 1D. To pay the government reasonable audit costs of $352,053, as permitted by Title 12, United States Code, Section 1715z-4a. Also, we recommend the Director, Enforcement Center to: 1E. Take administrative sanctions against the owner and Domicile. 13 MANAGEMENT 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 objectives: Methods and procedures to ensure disbursements are in compliance with the regulatory agreements. 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. We gained an understanding of the management controls but did not rely on them during our review. Based on our review, the owner of the Domicile Property Management, Inc. was able to override any method or procedure used to ensure disbursements were in compliance with the Regulatory Agreement (see Finding). 14 Appendix A SCHEDULE OF QUESTIONED COSTS AND FUNDS PUT TO BETTER USE Recommendation Funds Put to 1 2 Number Ineligible Unsupported Better Use 3 1A $771,103 1B $1,469,926 1C 49,262 1D $352,053 Totals $820,365 $1,469,926 $352,053 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 polices or regulations. 2 Unsupported costs are those costs charged to a HUD-financed or HUD-insured program or activity where we cannot determine eligibility at the time of audit. 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. 3 Funds Put to Better Use are quantifiable savings that are anticipated to occur if an OIG recommendation is implemented resulting in reduced expenditures in subsequent period for the activities in question. Specifically, this includes 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. 15 Appendix B Domicile Property Management Inc. Schedule of HUD Insured and Assisted Properties Managed by Domicile As of July 31, 2003 Act Non- Property Section Loan/FHA # Profit FYE Loan Status 1 AGI-1 236 115-44046 Yes Current 2 AGI-2 221d3 115-35102 Yes Current 3 Alexandra Place 221d4 112-35325 Dec 31 Current 4 Alice Village 221d4 115-35238 Dec 31 Current 5 Antioch Village 221d3 115-35012 Yes Current 6 Aurora 221d4 115-35234 Dec 31 Current 7 Chisolm Trace 221d4 115-35183 Dec 31 Current 8 Cliff Maus Village 221d3 115-35015 Yes Current 9 Clinton Parkway 221d4 102-35131 Dec 31 Current 10 Dove Valley Ranch 221d3 still in development 11 Fairhaven - 1 202 118-EH002 Yes not applicable 12 Fairhaven - 2 202 118-EH023 Yes not applicable 13 Fairhaven - 3 202 117-EH069 Yes not applicable 14 Fairhaven - 4 202 118-EH030 Yes not applicable 15 Golden Terrace 202 113-EE013 Yes not applicable 16 Houston House 236 115-44038 Yes Current 17 Kings Cove 221d4 08435253 Dec 31 Current 18 Knightsbridge Manor 221d4 102-35159 Dec 31 Current 19 La Luz 221d3 115-35113 Yes Current 20 Las Puertas 221d3 still in development 21 La Quinta 221d3 115-35131 Yes Current 22 Lulac Amistad 221d3 115-35039 Yes Current 23 Lulac West Park 236 115-44013 Yes Current 24 Mercedes Palms 221d4 115-35217 Dec 31 Current 25 Mission Village 221d4 115-35200 Dec 31 Current 26 Monarch Place 202 115-HH005 Yes not applicable 27 Mt. Carmel 236 115-44199 Yes Current 28 Mulberry Court 221d4 102-35139 Dec 31 default 9/1/01 29 New Lake Village 236 118-44032 Yes Current 30 Pan American 221d3 115-35004 Yes Current 31 Regal Village 811 115-HD014 Yes not applicable 32 Silverwood 221d4 102-35153 Dec 31 Current 33 Stockton Village 221d3 133-35032 Yes Current 34 Tomball Pines 811 114-HD006 Yes not applicable 35 West End Baptist 221d3 115-35032 Yes Current 16 Appendix C AUDITEE COMMENTS 17 18 19 20 21 22 23
Domicile Property Management, Inc. Multifamily Management Agent San Antonio, TX
Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-11-19.
Below is a raw (and likely hideous) rendition of the original report. (PDF)