oversight

The Puerto Rico Department of Housing, San Juan, PR, Did Not Adequately Enforce HUD's Housing Quality Standards

Published by the Department of Housing and Urban Development, Office of Inspector General on 2016-03-14.

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

    Puerto Rico Department of Housing,
               San Juan, PR
     Housing Choice Voucher Program Housing Quality
                       Standards




Office of Audit, Region 4     Audit Report Number: 2016-AT-1004
Atlanta, GA                                       March 14, 2016
To:            Antonio Cordova, Director, Public and Indian Housing, San Juan Field Office,
               4NPH


               //signed//
From:          Nikita N. Irons, Regional Inspector General for Audit, 4AGA
Subject:       The Puerto Rico Department of Housing, San Juan, PR, Did Not Adequately
               Enforce HUD’s Housing Quality Standards




Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of the Puerto Rico Department of Housing’s Section
8 Housing Choice Voucher program’s housing quality standards.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG Web site. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
404-331-3369.
                    Audit Report Number: 2016-AT-1004
                    Date: March 14, 2016
                    The Puerto Rico Department of Housing, San Juan, PR, Did Not
                    Adequately Enforce HUD’s Housing Quality Standards



Highlights

What We Audited and Why
We audited the Puerto Rico Department of Housing’s Section 8 Housing Choice Voucher
program’s housing quality standards as part of the activities in our fiscal year 2014 audit plan.
We selected the Department because it had a large program receiving more than $54 million in
2014. Our main audit objective was to determine whether the Department’s inspection process
adequately ensured that its units complied with the U.S. Department of Housing and Urban
Development’s (HUD) housing quality standards.

What We Found
The Department’s inspections were not adequate for enforcing HUD’s housing quality standards.
Of 94 program units inspected, 64 failed to comply with HUD’s minimum housing quality
standards, and 35 of those were in material noncompliance with the standards. For the 35 units
in material noncompliance, the Department’s inspectors failed to observe or report 166 violations
that existed when they conducted their last inspections. In addition, 44 inspections were not
performed in a timely manner. As a result, some tenants lived in inadequately maintained units,
and the Department disbursed $101,152 in housing assistance payments and received $11,063 in
administrative fees for the 35 units in material noncompliance with HUD standards. Unless the
Department improves its inspection program and ensures that all of its units materially meet
minimum housing quality standards, we estimate that over the next year, HUD will pay about
$19.3 million in housing assistance for units in material noncompliance with the standards.

What We Recommend
We recommend that the Director of HUD’s San Juan Office of Public and Indian Housing
require the Department to (1) reimburse its program more than $112,000 from non-Federal
funds for the 35 units that materially failed to meet HUD’s requirements, (2) ensure that all
violations cited for the units failing to meet housing quality standards have been corrected and
certify that the units meet the standards, and (3) improve its quality control inspection
program to ensure that all units meet HUD’s housing quality standards and prevent more than
$19.3 million in program funds from being spent on units that do not comply with HUD’s
requirements over the next year.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................4
         Finding: The Department Did Not Always Ensure That Program Units Met
         HUD’s Housing Quality Standards ................................................................................. 4

Scope and Methodology .........................................................................................11

Internal Controls ....................................................................................................13

Appendixes ..............................................................................................................14
         A. Schedule of Questioned Costs and Funds To Be Put to Better Use ...................... 14
         B. Auditee Comments and OIG’s Evaluation ............................................................. 15
         C. Schedule of Units in Material Noncompliance With Housing Quality
            Standards ................................................................................................................... 18
         D. Schedule of Late Inspections .................................................................................... 19




                                                                    2
Background and Objective
The Puerto Rico Department of Housing was created by Act No. 97 of June 10, 1972. Through a
secretary appointed by the governor, the Department is engaged in implementing the
government’s policy related to public housing. This process includes, among other things, the
acquisition, sale, lease, and operation of public housing projects and land development to provide
housing for the benefit of low-income and moderate-income families. The primary source of
funds to carry out the government’s public housing program is Federal Government subsidies
and grants.

The Department administers about 9,000 housing choice vouchers. It received more than $54
million in program funding during 2014. The Department is the largest recipient of Section 8
funds in Puerto Rico and is divided into nine regional offices. The Department’s central office is
located at 606 Barbosa Avenue, San Juan, PR.

Our audit objective was to determine whether the Department’s inspection process adequately
ensured that its units complied with the U.S. Department of Housing and Urban Development’s
(HUD) housing quality standards.




                                                 3
Results of Audit

Finding: The Department Did Not Always Ensure That Program
Units Met HUD’s Housing Quality Standards
The Department’s inspections were not adequate for enforcing HUD’s housing quality standards.
Of 94 program units inspected, 64 failed to comply with HUD’s minimum housing quality
standards, and 35 of those were in material noncompliance with HUD standards. For the 35
units in material noncompliance, the Department’s inspectors failed to observe or report 166
violations that existed when they conducted their last inspections. In addition, 44 inspections
were not performed in a timely manner. The excessive violations occurred because the
Department’s quality control inspection program was not effective and the Department missed
opportunities to improve inspectors’ performance. As a result, some tenants lived in
inadequately maintained units, and the Department disbursed $101,152 in housing assistance
payments and received $11,063 in administrative fees for the 35 units in material noncompliance
with HUD standards. Unless the Department improves its inspection program and ensures that
all of its units materially meet minimum housing quality standards, we estimate that over the
next year, HUD will pay about $19.3 million in housing assistance for units in material
noncompliance with the standards.

HUD’s Housing Quality Standards Not Met
We performed housing quality standards inspections on 94 1 statistically selected units from a
universe of 1,499 program units that had passed a Department housing quality standards
inspection between October 31 and December 31, 2014. The 94 units were selected to determine
whether the Department ensured that its program units met minimum housing quality standards.
We inspected the units from February 2 to 6, 2015, and from April 21 to May 18, 2015.

Of the 94 program units inspected, 64 (about 68 percent) failed to meet minimum housing
quality standards (with 264 individual failed items, 200 of which were preexisting conditions).
The following table lists the five most frequently occurring violations for the 64 units.

                 Violation category                              Number of               Number of units
                                                                 violations
    Electrical                                                       72                          37
    Water heater                                                     27                          19
    Bathrooms, sinks, showers, toilets                               27                          18
    Doors and locks                                                  23                          16
    Smoke detector                                                   22                          20



1
    Our methodology for the statistical sample is explained in the Scope and Methodology section of this audit
    report.


                                                          4
Additionally, 35 of the 64 units (about 55 percent) were in material noncompliance with housing
quality standards. We considered these units to be in material noncompliance because they had
at least five health and safety violations or at least one 24-hour violation that predated the
Department’s last inspection. The 35 units had a total of 198 individual failed items, and 166 of
those predated the Department’s last inspection. Of the 198 failed items, 126 were life-
threatening violations. Appendix C provides the number of violations for the 35 units.

Throughout the inspection process, we kept the Department’s staff aware of the life-threatening
health and safety violations. Regulations at 24 CFR (Code of Federal Regulations) 982.404
require that owners correct life-threatening defects within no more than 24 hours.

Types of Deficiencies
The following photographs illustrate some of the violations noted during housing quality
standards inspections of the 64 units that failed to meet HUD’s standards. The most prevalent
deficiencies were electrical violations.

A total of 72 electrical violations were found in 37 units that failed to meet housing quality
standards.




The picture above shows a missing breaker panel cover with exposed wiring,
creating an electrical hazard.

We also found other health and safety hazards, including abandoned vehicles in yards, missing
handrails, hot plates in lieu of stoves, unsafe bathrooms, unsound structural conditions, and
unsafe water heater installations. The following photographs illustrate examples of these types
of violations noted during our inspection of the units.



                                                  5
The picture above shows abandoned vehicles in the front yard of the unit. This
situation does not promote safe and sanitary conditions.




The picture above shows exterior stairs without hand railings, creating a falling
hazard. Handrails are required for stairs with more than three steps.




                                                 6
The picture above shows that a hot plate is used for cooking. Hot plates are not
acceptable substitutes for stoves or ranges.




The picture above shows a damaged and rusted tub drain with a peeling and
chipped finish. The rusted and sharp borders create a cutting hazard.




                                                7
The pictures above show the improper use of metal sheets as improvised retaining walls at the
rear of the unit. The inadequate structure provides no support, and the proximity of the hill
creates a landslide hazard.




The picture above shows an unsecured water heater sitting on the ledge of the
roof and missing a discharge line.

HUD regulations at 24 CFR 982.401(a)(3) require that all program housing meet housing quality
standards performance requirements, both at commencement of assistance and throughout the
assisted tenancy. In accordance with regulations at 24 CFR 982.152(d), HUD is permitted to
reduce or offset program administrative fees paid to a public housing agency if it fails to
correctly or adequately meet its administrative responsibilities, such as enforcing housing quality
standards. The Department disbursed $101,152 in housing assistance payments and received
$11,063 in program administrative fees for the 35 units that materially failed to meet HUD’s


                                                 8
housing quality standards. 2 Based on the results of the 94 statistically selected units, we estimate
that over the next year, HUD will pay about $19.3 million in housing assistance for units in
material noncompliance with the standards unless the Department takes action to improve its
inspection process. 3

Inspections Not Performed in a Timely Manner
The Department’s inspections were not conducted in a timely manner. Of 94 program units
inspected, 65 were reinspections, and 44 (67 percent) of those were not inspected within 12
months of the prior inspection. HUD regulations and the Department’s administrative plan
provide that the Department must inspect units at the time of initial lease-up and at least once
every 12 months to ensure that the properties meet minimum conditions for compliance with
standards. The 44 program units were inspected between 5 and 263 days late, and 12 of those
inspections were more than 90 days late. Appendix D provides details on the late inspections.

The 2013 independent public accountant report included a similar deficiency. However, the
deficiency continued to exist. This deficiency occurred because the Department did not
adequately enforce its own policies and procedures.

Quality Control Inspections
The Department’s quality control program was ineffective in improving inspector performance.
HUD regulations at 24 CFR 982.405(b) require public housing agencies to perform supervisory
quality control inspections. Although the Department performed its supervisory inspections, it
did not provide documentation showing that the results were used to assess performance or
training needs as we requested. For example, one of the Department’s inspectors failed all 12
supervisory inspections performed during fiscal years 2013, 2014, and 2015, but it did not
provide an assessment of the inspectors’ work. In addition, some units that failed our inspections
due to material violations had been passed by Department inspectors. Of the 198 total failed
items for the 35 units that materially failed our inspections, 166 (83 percent) existed at the time
of the Department’s last inspection. Several of these preexisting failed items are shown in the
photographs above.

The Department should use the quality control inspections to verify that each inspector conducts
accurate and complete inspections to ensure consistency among inspectors in applying the
housing quality standards and determine whether individual performance or training issues need
to be addressed. Strengthening its quality control program to ensure that its inspection staff is
aware of all HUD requirements with respect to the conditions that represent housing quality
standards violations should effectively improve inspectors’ performance and better ensure that
units meet housing quality standards during the assisted occupancy.

Conclusion
The housing quality standards deficiencies described above occurred because the Department’s
quality control program was ineffective in improving inspector performance. As a result, some


2
    The housing assistance and administrative fees correspond to the period of October 2014 through May 2015.
3
    The sampling methodology and calculations are shown in the Scope and Methodology section of this report.


                                                        9
of the Department’s households lived in inadequately maintained units and were subjected to
health- and safety-related violations, and the Department did not properly use its program funds
when it failed to ensure that the units complied with HUD’s housing quality standards. The
Department disbursed $101,152 in program housing assistance payments and received $11,063
in program administration fees for the 35 units that materially failed to meet HUD’s standards.

In accordance with 24 CFR 982.152(d), HUD is permitted to reduce or offset any program
administrative fees paid to a public housing agency if it fails to enforce HUD’s housing quality
standards.

Unless the Department improves its unit inspection program to ensure compliance with HUD’s
housing quality standards, we estimate that over the next year, HUD will pay more than $19.3
million in housing assistance on units in material noncompliance with the standards.

Recommendations
We recommend that the Director of the San Juan Office of Public and Indian Housing
require the Department to

       1A.     Reimburse the program $112,215 from non-Federal funds for housing
               assistance payments ($101,152) and administrative fees received ($11,063)
               for the 35 units that materially failed to meet HUD’s housing quality
               standards.

       1B.     Ensure that the housing quality standards violations have been corrected for
               the 64 units cited in this finding and certify that the units meet the standards.

       1C.     Implement adequate procedures and controls to ensure that all program units
               meet HUD’s housing quality standards to prevent $19,344,376 in program funds
               from being spent on units that do not comply with HUD’s requirements over the
               next year. The procedures should include but not be limited to ensuring that
               inspectors consistently conduct accurate, complete, and timely inspections.

       1D.     Implement adequate procedures and controls to ensure supervisory inspections
               are used to determine whether individual performance or training issues need to
               be addressed and ensure consistency among the Department’s inspectors when
               applying the housing quality standards.




                                                  10
Scope and Methodology
We performed our onsite audit work between November 2014 and October 2015 at the
Department’s main office located at 606 Barbosa Avenue, San Juan, PR. The audit covered the
period October 1 through December 31, 2014.

To accomplish our audit objective, we interviewed HUD program staff and the Department’s
employees. In addition, we obtained and reviewed the following:

    •    Applicable laws, HUD’s regulations at 24 CFR Part 982, Office of Public and Indian
         Housing notices, HUD’s Guidebook 7420.10G, and HUD’s Housing Inspection Manual.

    •    The Department’s program administrative plan, policies and procedures, tenant files,
         households’ inspection reports, and housing assistance payment register.

We statistically selected a stratified systematic sample of 95 of the Department’s program units
to inspect from 1,499 units that passed the Department’s inspections from October 1 through
December 31, 2014. 4 The use of substitutes decreased the originally selected sample by 1
record, resulting in a final sample of 94 units. The 94 units were inspected to determine whether
the Department ensured that its program units met HUD’s housing quality standards. We used
statistical sampling because each sampling unit was selected without bias from the audit
population, thereby allowing the results to be projected to the population. After our inspections,
we determined whether each unit passed, failed, or materially failed. All units were ranked, and
we used our materiality standards and auditors’ judgment to determine the material cutoff point.
Materially failed units were those that had one or more exigent (24-hour) health and safety
violations that predated the Department’s previous inspections, five or more health and safety
violations that predated the Department’s previous inspections, or a combination of both.

Based on our review of the 94 statistically selected units, we found that 35 of the units had
material failures in housing quality standards, although they had recently passed a Department
inspection. Using a confidence interval of 95 percent, we projected that 29.1 percent of the units
had material violations. Extending this rate to the monthly count of 9,032 occupied units on the
Department’s program, we can say that at least 2,633 units would not have complied with
housing quality standards, despite having passed the Department’s inspection.

Based on the average housing assistance paid for the 94 units, less a deduction to account for a
statistical margin of error, we can say with a confidence interval of 95 percent that the average
amount of monthly housing assistance spent on inadequate units was $178 per unit. Extending



4
    Two units passed inspection in September 2014 and January 2015. However, the Department’s records
    incorrectly reflected that these units passed the inspection during the period October 1 through December 31,
    2014.


                                                          11
this amount to the 9,032 active units on the Department’s program over 12 months yields at least
$19.3 million in housing assistance paid per year for substandard housing units.

The calculation of administrative fees was based on HUD’s administrative fee per household
month for the Department. The fees were considered inappropriately received for each month in
which the housing assistance was incorrectly paid for units that materially failed to meet HUD’s
minimum housing quality standards.

Of 94 program units in our sample, 65 were reinspections by the Department’s inspectors. We
reviewed the 65 tenant files to determine whether the Department inspected the units in a timely
manner. The results of the review apply only to the units selected for review and cannot be
projected to the portion of the population that was not tested.

We relied in part on data maintained by the Department. Although we did not perform a detailed
assessment of the reliability of the data, we performed a minimal level of testing and found the
data to be adequately reliable for our purposes. We provided our review results and supporting
inspection reports to the Department’s officials during the audit.

We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.




                                                12
Internal Controls
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to

•   Effectiveness and efficiency of operations,
•   Reliability of financial reporting, and
•   Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls include the processes and
procedures for planning, organizing, directing, and controlling program operations as well as the
systems for measuring, reporting, and monitoring program performance.

Relevant Internal Controls
We determined that the following internal controls were relevant to our audit objective:

•   Effectiveness and efficiency of operations – Policies and procedures that management has
    implemented to reasonably ensure that a program meets its objectives.

•   Reliability of financial reporting – Policies and procedures that management has
    implemented to reasonably ensure that valid and reliable data are obtained, maintained, and
    fairly disclosed in reports.

•   Compliance with applicable laws and regulations – Policies and procedures that management
    has implemented to reasonably ensure that resource use is consistent with laws and
    regulations.

We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.
Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:

•   The Department’s inspection process was not adequate to ensure that program units complied
    with HUD’s housing quality standards (finding).




                                                  13
Appendixes

Appendix A


            Schedule of Questioned Costs and Funds To Be Put to Better Use

                  Recommendation                            Funds to be put
                                          Ineligible 1/
                      number                                to better use 2/
                        1A                 $112,215
                        1C                                   $19,344,376
                         Totals            $112,215          $19,344,376


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/   Recommendations that funds be put to better use are estimates of amounts that could be
     used more efficiently if an Office of Inspector General (OIG) recommendation is
     implemented. These amounts include reductions in outlays, deobligation of funds,
     withdrawal of interest, costs not incurred by implementing recommended improvements,
     avoidance of unnecessary expenditures noted in preaward reviews, and any other savings
     that are specifically identified. In this instance, if the Department implements our
     recommendations, it will stop incurring program costs for units that are not decent, safe,
     and sanitary and, instead, will spend those funds in accordance with HUD’s requirements
     and the Department’s program administrative plan. Once the Department improves its
     controls, this will be a recurring benefit. Our estimate reflects only the initial year of this
     benefit.




                                                14
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




                               15
Ref to OIG   Auditee Comments
Evaluation




Comment 1


Comment 1



Comment 1




                            16
                        OIG Evaluation of Auditee Comments


Comment 1   The Department’s management agreed with the OIG finding and
            recommendations. The Department stated that it will reimburse from non-Federal
            funds the ineligible housing assistance and administrative fees related to
            recommendation 1A, and certified that all cited violations were corrected. In
            addition, the Department stated that it will design and implement procedures to
            ensure compliance with program requirements and that its inspectors will receive
            in-house training by March 31, 2016. We commend the Department for its
            proposed actions to address the findings cited in this report. The Department
            should work with HUD to ensure violations were corrected and properly certified,
            and that its procedures and controls are fully implemented.




                                            17
Appendix C
   Schedule of Units in Material Noncompliance With Housing Quality Standards
                            Type of violation                      Total
    Identification                                    Total
                                Health and                      preexisting
       number         24 hour                 Other violations
                                  safety                         violations
         1611             1          0          0        1            1
        79645            10          4          3       17           15
       153259             5          2          1        8            5
        24225             2          0          0        2            2
        36092             2          0          1        3            2
        87129             2          0          0        2            2
        34153             9         11          0       20           16
      AG203261            2          0          0        2            2
        90455             3          2          0        5            3
        26034             1          0          0        1            1
        86048             1          1          2        4            4
        89287             1          3          0        4            4
        66264             5          2          1        8            6
      AG208662            4          0          0        4            4
        39972             1          1          0        2            2
       154862             3          3          0        6            4
        90286             1          0          0        1            1
       155450             1          1          0        2            2
       152191             5          5          0       10            9
        38499             5          2          0        7            7
        27343             2          0          0        2            1
        90268             2          1          0        3            2
        82269             3          1          0        4            3
       149863             9          6          1       16           14
        33807             5          0          0        5            5
        88255             5          1          0        6            3
        26447             3          0          0        3            3
      AG203938            1          1          0        2            2
        23995             3          3          0        6            6
        30652             6          2          1        9            7
        76124             1          4          1        6            6
        24372             7          3          0       10           10
        77829             5          0          0        5            2
        89029             4          1          0        5            4
        88148             6          1          0        7            6
        Totals          126         61         11      198          166




                                       18
Appendix D
                            Schedule of Late Inspections
                                  Department inspection date
    Identification number                                         Days late
                                 Initial           Succeeding
           24225              Apr. 4, 2013        Dec. 23, 2014     263
           33923             Mar. 21, 2013        Oct. 09, 2014     202
           89336             May 29, 2013         Dec. 10, 2014     195
           12780              May 9, 2013         Nov. 17, 2014     192
           90119             June 11, 2013        Nov. 25, 2014     167
           88148             June 21, 2013        Dec. 5, 2014      167
           86248              June 8, 2013        Nov. 12, 2014     157
           34153             May 18, 2013         Oct. 09, 2014     144
           39972             May 24, 2013         Oct. 09, 2014     138
           67749             July 29, 2013        Nov. 25, 2014     119
           77399             June 20, 2013        Oct. 01, 2014     103
           79049              Aug. 7, 2013        Nov. 13, 2014     98
           43156             Aug. 19, 2013        Nov. 5, 2014      78
           68179              Aug. 8, 2013        Oct. 22, 2014     75
            7918             Sept. 25, 2013       Dec. 4, 2014      70
           86048             Sept. 11, 2013       Nov. 20, 2014     70
           89287             Oct. 10, 2013        Dec. 18, 2014     69
           155273            Aug. 21, 2013        Oct. 29, 2014     69
           146568            Aug. 22, 2013        Oct. 28, 2014     67
           76534             Sept. 23, 2013       Nov. 25, 2014     63
           77626             Sept. 17, 2013       Nov. 18, 2014     62
           80602             Sept. 24, 2013       Nov. 24, 2014     61
           64043              Nov. 6, 2013        Dec. 22, 2014     46
           37269             Aug. 29, 2013         Oct. 8, 2014     40
           145729            Oct. 15, 2013        Nov. 24, 2014     40
           88255              Nov. 5, 2013        Dec. 15, 2014     40
           87164              Nov. 4, 2013        Dec. 11, 2014     37
           88669              Nov. 4, 2013        Dec. 11, 2014     37
           27343             Nov. 26, 2013        Dec. 22, 2014     26
           41160             Oct. 30, 2013        Nov. 25, 2014     26
           75120              Nov. 4, 2013        Nov. 24, 2014     20
           23995             Nov. 14, 2013        Dec. 1, 2014      17
           152375            Sept. 23, 2013        Oct. 9, 2014     16
           79332              Dec. 3, 2013        Dec. 19, 2014     16
           78036             Dec. 23, 2013         Jan. 8, 2015     16
           76124             Nov. 20, 2013        Dec. 4, 2014      14
           146907            Oct. 16, 2013        Oct. 29, 2014     13
           149863            Sept. 26, 2013        Oct. 8, 2014     12
           90268              Oct. 3, 2013        Oct. 14, 2014     11
           82269             Oct. 10, 2013        Oct. 20, 2014     10
           30652              Dec. 3, 2013        Dec. 12, 2014      9
           87129             Nov. 25, 2013        Dec. 2, 2014       7
           153259             Dec. 3, 2013        Dec. 8, 2014       5
           26447             Oct. 16, 2013        Oct. 21, 2014      5



                                          19