oversight

The Housing Authority of the City of Durham, NC, Did Not Adequately Enforce HUD's and Its Own Housing Quality Control Standards

Published by the Department of Housing and Urban Development, Office of Inspector General on 2016-05-10.

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

        Housing Authority of the City of
                Durham, NC
          Section 8 Housing Choice Voucher Program
                   Housing Quality Standards




Office of Audit, Region 4       Audit Report Number: 2016-AT-1005
Atlanta, GA                                           May 10, 2016
To:            Michael A. Williams, Director of Public and Indian Housing, Greensboro, NC,
               4FPH


               //signed//
From:          Nikita N. Irons, Regional Inspector General for Audit, 4AGA
Subject:       The Housing Authority of the City of Durham, NC, Did Not Adequately Enforce
               HUD’s and Its Own Housing Quality Control 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 Housing Authority of the City of Durham’s
Section 8 Housing Choice Voucher program 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-1005
                          Date: May 10, 2016

                          The Housing Authority of the City of Durham, NC, Did Not Adequately
                          Enforce HUD’s and Its Own Housing Quality Standards




Highlights

What We Audited and Why
We audited the Housing Authority of the City of Durham’s Section 8 Housing Choice Voucher
program’s housing quality standards based on our recent audit 1 of the Authority’s program,
during which potential issues with the Authority’s inspections were noted, and as part of our
annual audit plan. Our audit objective was to determine whether the Authority ensured that
program units met the U.S. Department of Housing and Urban Development’s (HUD) and its
own housing quality standards.

What We Found
The Authority did not always ensure that program units met HUD’s and its own housing quality
standards. Of 75 program units inspected, 69 failed to comply with HUD’s minimum housing
quality standards and the Authority’s own requirements, and 40 of those were in material
noncompliance with the standards. For the 40 units in material noncompliance, the Authority’s
inspectors failed to observe or report 352 violations that existed when they conducted their last
inspections. As a result, some tenants lived in inadequately maintained units, and the Authority
disbursed more than $100,000 in housing assistance payments and received more than $8,000 in
administrative fees for the 40 units in material noncompliance. Unless the Authority 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 $7.5 million in housing
assistance for units in material noncompliance with the standards.

What We Recommend
We recommend that the Director of HUD’s Greensboro Office of Public and Indian Housing
require the Authority to (1) reimburse its program more than $108,000 from non-Federal funds
for the 40 units that materially failed to meet HUD’s and its own housing quality standards, (2)
ensure that all violations cited for the units failing to meet housing quality standards have been
corrected, and (3) implement adequate procedures and controls to ensure that all units meet
HUD’s and its own housing quality standards to prevent more than $7.5 million in program
funds from being spent on units that do not comply with HUD’s requirements over the next year.




1
    Audit report 2015-AT-1011, issued on September 30, 2015, focused on tenant eligibility.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................4
         Finding: The Authority Did Not Always Ensure That Program Units Met HUD’s
         and Its Own 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 OIG Housing Quality Standards Inspection Results ........................ 18




                                                            2
Background and Objective
The Housing Authority of the City of Durham, NC, was established under chapter 456 of the State
of North Carolina public laws of 1935 as amended. The Authority’s mission is to be a leader for
affordable housing in Durham County by serving as a housing safety net, promoting individual
self-sufficiency, leveraging core housing competency to support the Authority’s mission,
managing real estate, and facilitating and participating in mixed-income housing development.
The Authority is a nonprofit municipal corporation governed by a seven-member board of
commissioners. The board is composed of active public servants who are appointed by the
Durham City Council. The board’s responsibilities include setting policies and appointing the
Authority’s chief operating officer, who is in charge of the Authority’s day-to-day operations.
The Authority administers public housing and Section 8 Housing Choice Voucher programs
funded by the U.S. Department of Housing and Urban Development (HUD). The Section 8
Housing Choice Voucher program provides assistance to low- and moderate-income individuals
seeking decent, safe, and sanitary housing by subsidizing rents with owners of private housing.
The Authority administers more than 2,300 tenant-based housing choice vouchers and received
more than $87 million in program funding for fiscal years 2011 through 2015.
The goal of the Housing Choice Voucher program is to provide decent, safe, and sanitary
housing at an affordable cost to low-income families. To accomplish this goal, program
regulations include basic housing quality standards, which all units must meet before assistance
can be paid on behalf of a family and at least annually throughout the term of the assisted
tenancy. Housing quality standards define “standard housing” and establish the minimum
criteria necessary for the health and safety of program participants. In addition to complying
with HUD’s housing quality standards, section 8-IB of the Authority’s program administrative
plan requires the Authority to comply with its own requirements, including the City of Durham’s
housing code.
Our objective was to determine whether the Authority ensured that program units met HUD’s
and its own housing quality standards.




                                                3
Results of Audit

Finding: The Authority Did Not Always Ensure That Program
Units Met HUD’s and Its Own Housing Quality Standards
The Authority did not always ensure that program units met HUD’s and its own housing quality
standards. Of the 75 program units inspected, 69 did not meet minimum housing quality
standards, and 40 of those were in material noncompliance with HUD standards. The violations
occurred because the Authority’s inspectors were not properly trained and lacked sufficient
knowledge of HUD’s and its own housing quality standards. As a result, some tenants lived in
inadequately maintained units, and the Authority disbursed more than $100,000 in housing
assistance payments and received more than $8,000 in administrative fees for the 40 units in
material noncompliance with the standards. Unless the Authority improves its inspection
program and ensures that all program units materially meet minimum housing quality standards,
we estimate that over the next year, HUD will pay about $7.5 million in housing assistance for
units in material noncompliance with the standards.

Housing Quality Standards Not Met
We statistically selected 75 2 units from a universe of 498 program units that had passed an
inspection by the Authority between June 1 and August 31, 2015. The 75 units were selected to
determine whether the Authority ensured that its program units complied with HUD’s and its
own housing quality standards. We inspected the 75 units from October 14 through December 2,
2015. The Authority’s staff accompanied us during our inspections and was made aware of the
results of each inspection.

Of the 75 units inspected, 69 (92 percent) had a total of 616 housing quality standards violations,
408 of which predated the Authority’s last inspection. In addition, 40 units containing 493
violations were in material noncompliance with housing quality standards, of which 352
violations predated the Authority’s last inspection. Of the 40 units that materially failed the
inspection, 25 were found to have a total of 30 life-threatening fail items requiring correction
within 24 hours, which existed at the time of the Authority’s latest inspection. 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 Authority’s last inspection or a
combination of both conditions. Appendix C categorizes the results of all 75 units inspected.
The Authority disbursed $100,214 in program housing assistance payments for the 40 units that
materially failed to meet HUD’s and its own housing quality standards and received $8,176 in
program administrative fees. The following table lists the 7 most frequently occurring violations
for the 40 units that materially failed to meet HUD’s housing quality standards.




2
    Our methodology for the statistical sample is explained in the Scope and Methodology section of this audit report.



                                                            4
             Violation category                 Number of violations       Number of units

 Windows                                                 123                       33
 Doors                                                    66                       27
 Electrical                                               62                       30
 Exterior, foundations, site conditions,                  49                       22
 exterior debris, etc.
 Baths, sinks, showers, toilets, and vents               42                        22
 Floors                                                  39                        25
 Walls                                                   23                        14

Types of Deficiencies
The following photographs illustrate some of the violations noted during our housing quality
standards inspections of the 40 units that materially failed to meet HUD’s standards. The most
common deficiencies were windows, doors, and electrical contacts.

Windows
A total of 148 window violations were found in 48 units that failed to meet housing quality
standards.




The picture above shows a kitchen window being kept closed with screws, not
allowing exit in case of an emergency and not allowing for ventilation.




                                                5
Doors
A total of 82 door violations were found in 40 units that failed to meet housing quality standards.




The picture above shows a keyed deadbolt lock on the kitchen exit door. If the
tenant cannot find the key, exit would be blocked in case of emergency.

Electrical
A total of 80 electrical violations were found in 41 units that failed to meet housing quality
standards. HUD regulations at 24 CFR (Code of Federal Regulations) 982.404 provide that if a
life-threatening violation is noted, it must be corrected within 24 hours of the inspection. Among
other items, the Authority defined any electrical problem or condition that could result in shock
or fire as a life-threatening violation requiring correction within 24 hours of discovery. Of the 80
electrical violations, 30 were emergency (life-threatening) violations causing electric hazard such
as shock or fire.




                                                 6
The picture above shows that the cover on an electric meter box is missing the
seal and can be easily opened, exposing electrical contacts and creating an electrical
hazard such as shock.

We also found other health and safety hazards violations, including unsafe water heater
conditions, cracked foundations, and ceiling deficiencies such as large holes. The following
photographs show examples of these types of violations noted during our inspections of the
units.




The picture above shows a water heater with an unsteady foundation, allowing
it to be easily knocked over, causing injury to tenants or damage to the unit.




                                                 7
The picture above shows a large crack in the unit’s foundation. allowing water,
air, and insect infiltration.




The picture above shows a large hole in a closet ceiling through which pipes
are passing. The large hole allows for vermin, dust, and air infiltration.

Lack of Adequate Training
The Authority is required by HUD and its administrative plan to inspect Section 8 units at least
once a year to ensure that the properties meet minimum conditions for compliance with housing
quality standards. HUD requires and the Authority’s administrative plan provides minimum
conditions that must exist for a unit to be considered decent, safe, and sanitary. Each unit must
meet minimum housing quality standards for the entire period of tenancy.

We found 408 deficiencies that existed at the time of the Authority’s most recent inspections, but
the inspectors did not identify or report them. Keyed deadbolt locks, electrical hazards
(unsecured meter boxes, missing outlet covers, etc.), missing or damaged window screens,



                                                 8
ceiling damage from water leaks, an improper smoke detector installation, and improper spacing
on handrail spindles were some of the deficiencies not reported by inspectors.

Although the Authority’s inspection staff had received some housing quality standards
inspection training, the training vendor was not always the same, the training was at least 3 years
old, and none of the staff members had been trained on the City of Durham’s local housing code,
which was included in the Authority’s administrative plan. All three of the Authority’s
inspectors stated that they had not had formal training on the local housing codes. The lack of
adequate training resulted in the inspectors failing to perform complete and accurate inspections
in accordance with HUD’s and the Authority’s own requirements. Of the 75 units inspected, 69
(92 percent) failed the inspection. In addition, 40 of the units inspected materially failed, with a
total of 352 fail items that existed at the time of the Authority’s latest inspection. Of greater
concern, of the 40 units that materially failed the inspection, 25 were found to have a total of 30
life-threatening fail items requiring correction within 24 hours, which existed at the time of the
Authority’s latest inspection. 3

Conclusion
HUD regulations at 24 CFR 982.401(a)(3) require that all program housing meet housing quality
standards, both at commencement of assistance and throughout the assisted tenancy. In addition,
in accordance with 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. Based on our
review, the Authority did not always ensure that its program units complied with HUD’s and its
own housing quality standards. The violations occurred because the Authority’s inspectors were
not adequately trained and lacked sufficient knowledge of HUD’s and the Authority’s own
housing quality standards. As a result, some tenants lived in inadequately maintained units, and
the Authority disbursed $100,214 in housing assistance payments and received $8,176 in
administrative fees for the 40 units in material noncompliance. Unless the Authority 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 more than $7.5 million in housing
assistance for units in material noncompliance with its standards.
Recommendations
We recommend that the Director of HUD’s Greensboro Office of Public and Indian Housing
require the Authority to




3
  Regulations at 24 CFR 982.404(a)(1)(3)-(4) provide that the Authority must not make any housing assistance
payments for a dwelling unit that fails to meet HUD’s housing quality standards unless the owner or family,
whichever is responsible, corrects the defect within the period specified by the Authority and the Authority verifies
the correction. If a defect is life threatening, it must be corrected within no more than 24 hours.




                                                           9
1A.   Reimburse the program $108,390 from non-Federal funds for housing assistance
      payments ($100,214) and administrative fees received ($8,176) for the 40 units
      that materially failed to meet HUD’s and its own housing quality standards.
1B.   Ensure that the housing quality standards violations have been corrected for the
      69 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 and Authority’s own housing quality standards to prevent $7,560,158 in
      program funds from being spent on units that do not comply with requirements
      over the next year. The procedures should include but not be limited to ensuring
      that inspectors are properly trained and familiar with HUD’s and the Authority’s
      requirements to ensure that they conduct complete and accurate inspections.




                                       10
Scope and Methodology
We performed our onsite audit work between October and December 2015 at the Authority’s
central office located at 330 East Main Street, Durham, NC. The audit covered the period
January 1 through August 31, 2015, but was expanded as necessary.
To accomplish our audit objective, we interviewed the Authority’s employees. In addition, we
obtained and reviewed the following:

   •   Applicable laws, HUD’s regulations at 24 CFR Parts 5 and 982, Office of Public and
       Indian Housing notices, HUD’s Guidebook 7420.10G, and HUD’s Housing Inspection
       Manual.

   •   The Authority’s 2014 program administrative plan; policies and procedures; chart of
       accounts; bank statements; general ledger; annual audited financial statements for fiscal
       years 2012, 2013, and 2014; board meeting minutes for January through August 31,
       2015; and housing assistance payments register.

We statistically selected a stratified systematic sample of 75 of the Authority’s program units to
inspect from the 498 units that passed the Authority’s inspections from June 1 through August
31, 2015. The 75 units were inspected to determine whether the Authority ensured that its
program units met HUD’s and its own 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 Authority’s previous inspections, five or more health and safety violations that
predated the Authority’s previous inspections, or a combination of both.
Based on our review of the 75 statistically selected units, we found that 40 of the units had
material failures in housing quality standards, although they had recently passed an Authority
inspection. Using a one-sided confidence interval of 95 percent, we projected that at least 43.7
percent of the units had material violations. Extending this rate to the monthly count of 2,324
occupied units on the Authority’s program, we can say that at least 1,017 units would not have
complied with housing quality standards or the requirements in the Authority’s program
administrative plan, despite having passed the Authority’s inspection.
Based on the average housing assistance paid for the 75 units, less a deduction to account for a
statistical margin of error, we can say with a one-sided confidence interval of 95 percent that the




                                                 11
average amount of monthly housing assistance spent on inadequate units was $271 4 per unit.
Extending this amount to the 2,324 5 active units on the Authority’s program over 12 months
yields at least $7.5 million in monthly housing assistance paid per year for substandard units.
The calculation of administrative fees was based on HUD’s administrative fee per household
month for the Authority. 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 and its own housing quality standards. If the questioned period was less than a full
month, we limited the questioned administrative fee to a daily rate, based on the number of days
during which the unit did not materially comply with HUD’s requirements.
We relied in part on computer-processed data contained in the Authority’s systems to achieve
our audit objective. 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 (inspection reports and pictures) to HUD’s
Greensboro Office of Public Housing and the Authority’s management 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.




4
 This amount was rounded for reporting purposes.
5
 The dollar valuation projection estimation is independent of the unit count projection estimation; to be statistically
correct each was calculated using a different method.



                                                           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 Authority’s inspectors were not properly trained and lacked sufficient knowledge of
    HUD’s and its own housing quality standards (finding).




                                                  13
Appendixes

Appendix A


            Schedule of Questioned Costs and Funds To Be Put to Better Use
                Recommendation                      Funds to be to
                                    Ineligible 1/
                     number                          better use 2/
                          1A               $108,390

                          1C                                   $7,560,158

                        Totals             $108,390            $7,560,158


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 used 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 Authority 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 Authority’s program administrative plan. Once the Authority 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




Comment 1




Comment 1




                               15
Ref to OIG   Auditee Comments
Evaluation




Comment 1




Comment 1




                                16
                         OIG Evaluation of Auditee Comments


Comment 1   The Authority did not concur with our assessment that the lack of adequate
            training resulted in inspectors failing to perform accurate and complete
            inspections. The Authority stated each inspector had extensive working
            knowledge of the City of Durham (City) housing code. However, as stated in the
            finding, although the Authority’s inspection staff received some housing quality
            standards inspection training, none of the staff members received formal training
            on the City’s local housing code. In addition, the Authority did not provide any
            documentation to support that its inspectors had extensive working knowledge of
            the City’s housing code. Nonetheless, the Authority concurred with the audit
            finding and all recommendations. Specifically, the Authority stated that it has
            already begun to implement specific audit recommendations to improve its
            housing quality standards inspections process. We commend the Authority for its
            proposed actions to address the recommendations. The Authority 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 OIG Housing Quality Standards Inspection Results
Identification Materially Failed Passed unit         Total         Total        Total
   number       failed unit   unit                 violations number of number of
                                                      for        housing     preexisting
                                                   materially     quality    violations6
                                                     failed     standards
                                                     units6     violations 6
      1                        X                                     6            4
      2              X                                  7            7            7
      3                        X                                     6            4
      4                        X                                     3            2
      5                                  X                           0            0
      6                                  X                           0            0
      7                        X                                     3            1
      8              X                                  8            8            6
      9              X                                  8            8            5
     10              X                                 24           24           23
     11              X                                 12           12           11
     12                                  X                           0            0
     13                                  X                           0            0
     14                        X                                     1            1
     15              X                                  2            2            2
     16              X                                  9            9            4
     17              X                                 25           25           20
     18                        X                                     1            0
     19                        X                                     7            2
     20                        X                                     2            0
     21                        X                                     4            4
     22              X                                  3            3            3
     23                        X                                     3            0
     24                        X                                     5            1
     25                        X                                     5            5
     26              X                                  8            8            6
     27                        X                                     2            1




6
  The total violations for materially failed units, the total number of housing quality standards violations, and the
total number of preexisting violations include violations according to HUD’s housing quality standards and the
Authority’s own requirements.



                                                            18
Identification   Materially    Failed   Passed unit     Total         Total          Total
   number        failed unit    unit                  violations   number of      number of
                                                         for        housing       preexisting
                                                      materially     quality      violations6
                                                        failed     standards
                                                        units6     violations 6
     28                          X                                      5              0
     29              X                                    8             8              7
     30              X                                   23            23             18
     31              X                                   23            23             17
     32              X                                    8             8              7
     33              X                                    7             7              6
     34                          X                                      4              3
     35                          X                                      6              3
     36              X                                    6             6              4
     37              X                                   11            11              7
     38              X                                   20            20             12
     39              X                                    7             7              6
     40              X                                   10            10              5
     41              X                                   10            10              9
     42              X                                   28            28             21
     43              X                                   24            24             19
     44                                     X                           0              0
     45              X                                    6             6              6
     46                          X                                      7              4
     47              X                                   15            15             10
     48                          X                                      5              2
     49              X                                   12            12              9
     50              X                                    4             4              3
     51                          X                                      3              0
     52              X                                    8             8              6
     53              X                                    9             9              3
     54                          X                                      1              0
     55                          X                                      1              1
     56                          X                                      5              4
     57              X                                   29            29             15
     58                          X                                      3              1
     59              X                                   15            15              3
     60              X                                    4             4              3
     61              X                                   15            15              9
     62              X                                    6             6              6
     63                          X                                      9              0
     64                          X                                      5              2
     65                          X                                      3              1


                                             19
Identification   Materially    Failed   Passed unit     Total         Total          Total
   number        failed unit    unit                  violations   number of      number of
                                                         for        housing       preexisting
                                                      materially     quality      violations6
                                                        failed     standards
                                                        units6     violations 6
     66              X                                    9              9             8
     67              X                                    9              9             5
     68                          X                                      13             3
     69                                     X                            0             0
     70              X                                   14             14             8
     71                          X                                       3             3
     72                          X                                       2             2
     73              X                                    19            19            14
     74              X                                    15            15            14
     75              X                                    13            13             7
    Total            40         29          6            493           616           408




                                             20