oversight

St. Croix Chippewa HA, Comprehensive Review Hertel, Wisconsin

Published by the Department of Housing and Urban Development, Office of Inspector General on 1995-11-01.

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

                                                                      Issue Date

                                                                           November 1, 1995
                                                                      Audit Case Number

                                                                           96-CH-202-1006



TO:            Kevin Fitzgibbons, Acting Administrator, Eastern Woodlands Office of Native
                American Programs

FROM:          Dale L. Chouteau, District Inspector General for Audit, Midwest

SUBJECT:       St. Croix Chippewa Housing Authority
               Comprehensive Review
               Hertel, Wisconsin

We completed an audit of the St. Croix Chippewa Housing Authority. We selected the St. Croix
Chippewa Housing Authority for an audit based on input from HUD program staff. Our audit
objectives were to: determine whether the Housing Authority administered its housing programs in
an efficient, effective, and economical manner; identify the causes that contributed to any financial
difficulties; and develop recommendations to correct the deficiencies disclosed.

The Housing Authority needs to improve the administration of its programs and ensure compliance
with the Annual Contributions Contract and other HUD requirements. This report addresses issues
related to: (1) inadequate internal control procedures; (2) the receipt of unauthorized loans; (3)
improperly disbursed program funds; (4) funds not properly accounted for; (5) excessive funds drawn
down from HUD; and (6) uncollateralized deposits exceeding Federal Deposit Insurance Corporation
limits.

Within 60 days, please give us, for each recommendation made in the report, a status report on: (1)
the corrective action taken; (2) proposed corrective action and the date to be completed; or (3) why
action is considered unnecessary. Also, please furnish us copies of any correspondence or directives
issued because of this audit.

Should your staff have any questions, please have them contact me at (312) 353-7832.
Management Memorandum




                 (THIS PAGE LEFT BLANK INTENTIONALLY)




96-CH-202-1006                   Page ii
Executive Summary
We completed an audit of the St. Croix Chippewa Housing Authority. We selected the St. Croix
Chippewa Housing Authority for an audit based on input from HUD program staff. Our objectives
were to determine whether the Housing Authority administered its housing programs in an efficient,
effective, and economical manner; identify the causes that have contributed to any financial
difficulties; and develop recommendations to correct the deficiencies disclosed.

Improvements by the Housing Authority are needed to assure compliance with the Annual
Contribution Contract and HUD requirements and to increase the efficiency and economy of its
operations. To comply with the Annual Contributions Contract, HUD requirements, and improve
operations, the Housing Authority needs to correct the following problems.



                                     The Housing Authority failed to maintain an adequate system
 Internal Control
                                     of internal controls. The Housing Authority did not ensure
 procedures were
                                     that: (1) accounting functions were adequately segregated; (2)
 inadequate
                                     unused checks were adequately safeguarded; (3) adequate
                                     controls were maintained over the disbursement functions; (4)
                                     accounting records were properly maintained; and (5) Housing
                                     Authority resources were effectively used.

                                     The Housing Authority obtained loans from the St. Croix
 The Housing Authority
                                     Chippewa Tribe for assistance in administering the Mutual
 received unauthorized
                                     Help Program without obtaining HUD approval. The loans
 loans
                                     were used to help pay for program expenses and were not
                                     formally recorded on the Housing Authority's books and
                                     records.

                                     The Housing Authority improperly disbursed its development
 The Housing
                                     program funds. The Housing Authority: (1) spent $657,410
 Authorityimproperly
                                     of the development program funds for the construction of an
 disbursed program funds
                                     apartment project when the Authority was not a party to the
                                     construction contract; (2) incurred a $15,100 finance charge
                                     to complete the project; and (3) used $206,333 of
                                     development funds to purchase parcels of land without
                                     obtaining HUD approval.

                                     The Housing Authority failed to maintain adequate controls
 Housing Authority funds
                                     for the accountability of its program accounts. The Housing
 were not properly
                                     Authority: (1) transferred account funds without adequate
 accounted for
                                     documentation, and (2) commingled the Youth Sports
                                     Program funds with other program funds.



                                              Page iii                                 96-CH-202-1006
Executive Summary




                             The Housing Authority drew down $482,340 of development
 The Housing Authority
                             program funds in excess of its actual needs. Top management
 drew down excess funds
                             at the Housing Authority did not implement effective
 from HUD
                             disbursement controls over the development funds.

                             Collateralization was not maintained for Housing Authority's
 The Housing Authority did
                             bank deposits that exceeded the $100,000 Federal Deposit
 not collateralizedeposits
                             Insurance Corporation coverage. The Housing Authority's
 exceeding Federal Deposit
                             Finance Officer said she did not understand the Federal
 Insurance Corporation
                             Deposit Insurance Corporation limitations or the bank
 limits
                             collateralization process and she was unaware the funds were
                             at risk.

                             We recommend that the Acting Administrator, Eastern
                             Woodlands Office of Native American Programs, assures that
                             the Housing Authority takes actions to correct the weaknesses
                             cited in this report.

                             We gave our draft findings to the Executive Director and the
                             Eastern Woodlands Office of Native American Program
                             officials during the audit. We held an exit conference with the
                             Executive Director on August 29, 1995. The Executive
                             Director provided written comments to our findings and
                             recommendations. Excerpts from the comments are included
                             in each finding and Appendix A contains the complete
                             comments.




96-CH-202-1006                        Page iv
Table of Contents

Management Memorandum                                             i


Executive Summary                                                iii


Introduction                                                      1


Findings

    1      The Housing Authority's Internal Control
           Procedures Were Inadequate                             3

    2      The Housing Authority Received Unauthorized
           Loans From The St. Croix Chippewa Tribe              13

    3      The Housing Authority Improperly Used
           Development Program Funds                            17

    4      The Housing Authority Did Not Maintain
           Adequate Accountability Over Its Program
           Funds                                                21

    5      The Housing Authority Drew Down Excess
           Development Funds                                    25

    6      Deposits Exceeding Federal Insurance
           Were Not Collateralized                              27




                               Page v                 96-CH-202-1006
Table of Contents




Internal Controls                               31


Follow Up On Prior Audits                       33


Appendices

         A       Auditee Comments               35

         B       Schedule of Questioned Costs   43

         C       Distribution                   45




96-CH-202-1006                      Page vi
Introduction
The St. Croix Chippewa Housing Authority was formally organized pursuant to the authority of the
Constitution and Bylaws of the St. Croix Chippewa Tribe under Tribal Ordinance number one on July
20, 1967. The Housing Authority received its Annual Contribution Contract in 1972. The Housing
Authority is governed by a Board of Commissioners consisting of five unpaid members who direct
the Housing Authority's policies. The Chairman of the Board is Lewis Taylor. The Executive
Director, Monica Butler, is responsible for the day to day operations.

The Housing Authority manages a total of 200 units, of which 168 are Low-Rent with 12 units
designated for the elderly. The Mutual Help Homeownership Program has seven units with an
additional 25 under acquisition. In addition to its Low-Rent and Mutual Help programs, the Housing
Authority operates a: (1) Development Grant Program with funding of $3,917,455 for Fiscal Years
1990-1995; (2) Comprehensive Improvement Assistance Program with funding of $1,745,759 for
Fiscal Years 1990-1995; and (3) Youth Sport Grant Program with funding of $94,781 between May
1, 1992 to July 20, 1994.

The Housing Authority's official books and records are located at 4456 Highway 70, Hertel,
Wisconsin.



                                     The audit objectives were to determine whether the Housing
 Audit Objectives
                                     Authority administered its housing programs in an efficient,
                                     effective, and economical manner; identify the causes that
                                     contributed to any financial difficulties; and develop
                                     recommendations to correct the deficiencies disclosed.

                                     To achieve these objectives, we interviewed HUD and
 Audit Scope and
                                     Housing Authority staff to obtain information relating to the
 Methodology
                                     Housing Authority's operations. We reviewed the following
                                     Housing Authority records: the Development Grant, Low-
                                     Rent, and Mutual Help Programs' general ledgers and cash
                                     disbursements to verify the accuracy of receipts and
                                     disbursements; bank statements, related reconciliations, and
                                     cancelled checks to assure all sources of cash were properly
                                     accounted for; vendors invoices and vouchers for proper
                                     controls and payments; and the Development Grant and
                                     Mutual Help Programs' contracts and expenditures for proper
                                     execution and support for payments. We confirmed the
                                     Housing Authority's bank balances with its depositories to
                                     evaluate cash controls and procedures.

                                     The audit covered the period January 1, 1990 to February 28,
                                     1995. We expanded the coverage as necessary. We


                                              Page 1                                  96-CH-202-1006
Introduction



                 performed the audit between March and July 1995 at the
                 Housing Authority.

                 We conducted our audit in accordance with generally accepted
                 government auditing standards.

                 We provided a copy of our report to the Housing Authority's
                 Executive Director.




96-CH-202-1006            Page 2
                                                                                           Finding 1




       The Housing Authority's Internal Control
            Procedures Were Inadequate
The St. Croix Chippewa Housing Authority failed to maintain an adequate system of internal controls.
The Authority did not ensure that: (1) disbursement functions were adequately segregated; (2) unused
checks were adequately safeguarded; (3) adequate controls were maintained over the disbursement
functions; (4) accounting records were properly maintained; and (5) resources were effectively used.
The Board of Commissioners did not effectively carry out its responsibility to review and verify the
supporting documentation for cash disbursements. As a result, the Authority increased the risk that
cash and other assets could be diverted without prompt detection, and its resources were not
effectively and efficiently used.



                                      Internal controls comprise the plan of organization, methods,
 Internal Control
                                      and procedures adopted by management to ensure that
 Requirements
                                      resource use is consistent with laws, regulations, and policies;
                                      that resources are safeguarded against waste, loss, and misuse;
                                      and that reliable data are obtained, maintained, and fairly
                                      disclosed in reports. Important features of an adequate system
                                      of internal controls include:

                                      •   Control should be established early in a transaction and
                                          carried through to its completion.

                                      •   No person should have complete control over all phases of
                                          any function.

                                      •   Work should flow from one employee to another without
                                          ever returning to an employee.

                                      •   Specific policies and procedures should be in place that
                                          outline departmental goals, plans of organization, and
                                          physical arrangements to provide a high degree of
                                          assurance that the internal control objectives are efficient
                                          and effective.

                                      •   Record keeping should be kept separate from operations
                                          or the handling and custody of assets. For example, the
                                          bookkeeping functions should be separate from the
                                          disbursement function including check preparation and
                                          distribution of checks after signature. Additionally,

                                               Page 3                                    96-CH-202-1006
Finding 1



                               periodic verification and reconciliations of disbursements
                               and bank statements should be made by an employee who
                               does not handle cash, record vouchers and disbursements,
                               or sign checks.

                           •   Accountability for the custody and use of resources should
                               be assigned and maintained.

                           •   Access to resources and records should be limited to
                               authorized individuals.

                           Authority Commissioners have a responsibility to HUD to
 Board of Commissioner's
                           ensure national housing policies are carried out, and to the
 responsibilities
                           Executive Director and staff to provide sound and manageable
                           directives. The Commissioners are accountable to their
                           locality and best serve it by monitoring operations to be
                           certain that housing programs are carried out in an efficient
                           and economical manner.

                           The Authority did not properly segregate employee duties
 The Authority did not
                           related to its cash disbursement function. An Authority
 adequately segregate
                           employee performed various activities without adequate
 employee duties
                           internal checks and balances. Therefore, the Authority
                           unnecessarily increased its susceptibility to program abuses.

                           The Finance Officer was responsible for functions that should
                           have been separated. She prepared the bank deposit slips,
                           made deposits, and obtained the bank validated deposit slips.
                           She also prepared disbursement checks, received the canceled
                           checks and bank statements directly from the bank, and
                           prepared the bank reconciliations before sending them to the
                           fee accountant. She had signatory rights for the Youth Sports
                           Program's checking account and signed several checks she
                           prepared for payment to the vendors. She transferred funds
                           from the Authority's savings account to the various Authority
                           program accounts without the need for any approval. Proper
                           internal controls should preclude the Finance Officer from
                           having access to disbursements, deposits, and bank
                           statements.

                           The Authority lacked adequate safeguards for its blank
 The Authority lacked
                           checks. Blank checks were stored in an unlocked file cabinet
 adequate safeguards for
                           at the Authority. The file cabinet was located in an area at the
                           Authority frequented by non-Authority personnel. Although


96-CH-202-1006                      Page 4
                                                                                          Finding 1



  the Authority required checks to have two signatures by the Authority's Commissioners, the
  Commissioners usually pre-signed the checks before the checks had amounts or payees on them.
  Officials said the pre-signed checks were used because it was difficult to locate the signatory's
  when needed.

                                    The Low-Rent Housing Accounting Guide, Handbook
                                    7511.1, Chapter 3, Section 2, Part 5(c) states that the signing
                                    or countersigning of checks in advance is prohibited.

                                    The Authority did not maintain adequate controls over its cash
The Authority had
                                    disbursements. The Board of Commissioners did not
inadequate controls
                                    effectively carry out its responsibility to review and verify the
overdisbursements
                                    supporting documentation for cash disbursements.

                                    The Low-rent Housing Accounting Guide, Handbook 7511.1,
                                    Chapter 3, Section 2, Part 2 (c) states that voucher checks in
                                    payment of services rendered or materials furnished should not
                                    be issued until all supporting documentation has been verified
                                    and approved for payment.

                                    The Authority disbursed $31,405 for services without
                                    appropriate documentation. The services included $24,711
                                    for construction expenses and $6,694 for purchases at a local
                                    general store for groceries, gasoline, and miscellaneous
                                    sundries.

                                    The Authority did not have invoices that supported $24,711
                                    of construction expenses paid. The construction expenses
                                    included payments to two contractors as well as payments
                                    made directly to the owners of one of the construction
                                    companies. The Authority did not have executed contracts
                                    with the construction companies. The Special Project
                                    Coordinator said the work paid for was often not completed.
                                    The invoices did not detail the services provided or the project
                                    the payments were billed to.

                                    The Authority was billed monthly for groceries, gasoline, and
                                    miscellaneous sundries from a local general store. Most of the
                                    items purchased would not be allowable Authority related
                                    expenses. The Authority did not have documentation to show
                                    the purchases were reasonable and necessary to its operations.
                                    The store owner said that general grocery items such as soda
                                    pop, donuts, rolls, and coffee were purchased on a regular
                                    basis by the Authority staff. He also stated that the gasoline


                                             Page 5                                     96-CH-202-1006
Finding 1



                 purchases were normally made by the maintenance staff of the
                 Authority.
                 There was not adequate documentation to determine which
                 expenditures were for gasoline and which were for general
                 grocery items. The gasoline for Authority maintenance
                 vehicles would be considered an eligible program expense, but
                 there was no documentation showing that the expenses were
                 in fact for Authority maintenance vehicles.

                 The Authority disbursed program funds totalling $6,993 for
                 ineligible expenses. Section 406 of the Annual Contributions
                 Contract states in part that in an Authority's "Operating
                 Expenditures" with respect to each Project shall mean all costs
                 incurred by the Local Authority for administration and
                 maintenance which are necessary for the operation of each
                 Project.

                 The following is a breakdown of the ineligible expenses:

                 •   $2,947 in home mortgage payments for an applicant
                     whose residence was not approved for the Authority's
                     Acquisition Program.

                 •   $3,100 for holiday bonuses and gift certificates given to
                     Authority employees and board members.

                 •   $281 for meals at local restaurants.

                 •   $665 for repairs to non-Authority vehicles.

                 These were not program related expenses. The expenditures
                 were not necessary for the daily operations of the Authority.


                 The Authority's top management did not review and verify the
                 supporting documentation before authorizing the disbursement
                 of funds. The former Executive Director had control over the
                 disbursements made by the Authority.

                 The Authority continuously prepaid a vendor credit card in
                 excess of the total balance owed. The Authority made a
                 standard monthly payment to a gas/convenience store
                 regardless of the balance owed on the account. As a result,
                 the account would have a credit balance in some months and


96-CH-202-1006            Page 6
                                                                          Finding 1



                      a past due balance in other months. For example, the
                      Authority made a March, 1994 payment for $400 when only
                      $241 was owed, resulting in a $159 credit balance.

                      The Finance Officer said she made standard payments because
                      the previous Finance Officer made the same payment amount
                      every month to the convenience store regardless of the balance
                      owed. Therefore, she simply continued the practice.

                      The Finance Officer paid the former Executive Director and
                      former Resident Service Coordinator for their accrued
                      vacation time without proper approval. The Finance Officer
                      utilized the pre-signed checks to make the disbursements. She
                      said the former Executive Director asked her to make the
                      disbursements because the former Authority employees were
                      entitled to be paid for their accrued vacation time. She took
                      it upon herself to pay the individuals without the consent or
                      knowledge of the Acting Executive Director. The Authority's
                      personnel policy does not provide for payment of accrued
                      vacation time. As a result, the Authority failed to adequately
                      protect funds from misuse.

                      The Authority made an ineligible loan that was not adequately
The Authority used
                      supported. The loan has not been repaid in full. Section 401
program funds for a
                      of the Annual Contributions Contract states in part that the
personal loan
                      Authority may withdraw monies from the general fund only
                      for (1) the payments of development costs, (2) the payment of
                      operating expenditures, (3) the purchase of investment
                      securities as approved by HUD, (4) other purposes specified
                      in this contract, and (5) other proposes specifically approved
                      by HUD.

                      The Authority improperly used $2,000 of its development
                      funds to make an interest free loan to a St. Croix Chippewa
                      Tribal Center employee. The Authority's former Executive
                      Director authorized the loan in May 1994 and the Chairman of
                      the Board signed the loan check payable to the Tribal
                      employee. The loan transaction was not recorded on the
                      Authority's books. The Authority maintained a ledger sheet
                      showing the loan amount and two $300 loan payments made
                      in June and July 1994. Both loan payments were reflected in
                      the Authority's bank deposits.




                               Page 7                                   96-CH-202-1006
Finding 1



                           The Authority's Board Chairman said he signed the check
                           without reviewing any supporting documentation and did not
                           realize that the funds were development funds. He thought
                           the funds were from a State account.

                           The Tribal employee acknowledged he received the funds and
                           made two payments during 1994 totalling $600. He said he
                           did not make further payments because he forgot about the
                           money owed to the Authority. He did not specify the purpose
                           of the loan, but said he would start repayments immediately.


                           The Authority failed to properly safeguard access to, or
 The Authority failed to
                           maintain its financial records. Section 309 of the Annual
 adequately safeguard or
                           Contribution Contract states in part, that the Authority will
 maintain its accounting
                           maintain complete and accurate books of account and records,
 records
                           as may be prescribed by HUD, in connection with the
                           development and operation of the projects, including records
                           which permits a speedy and effective audit.

                           The Authority maintained cancelled checks, contracts, bank
                           statements, and personnel records in banker boxes in a spare
                           unlocked room. Access to the room was not restricted to
                           non-authorized personnel. The Authority maintained other
                           accounting records in banker boxes throughout the Authority.


                           The safeguarding of the Authority's records and documents
                           was the responsibility of the Financial Officer based on the
                           position descriptions. The Financial Officer said she was not
                           aware that it was her responsibility.

                           In addition, the Authority lacked a systematic filing system or
                           the ability to develop an audit trail for reviewing the records.
                           For example, the Authority did not always file the voided
                           checks with the bank statements. As a result, locating
                           canceled checks was a difficult task.

                           Public and Indian Housing Notice 95-27, requires the
                           Authority to execute General Depository Agreement with the
                           depository institutions.

                           The Authority did not maintain a General Depository
                           Agreement with its financial institution. The Executive


96-CH-202-1006                      Page 8
                                                                                  Finding 1



                             Director said the Authority had not executed a General
                             Depository Agreement with its bank. The Depository
                             Agreement is an effective control for adequate cash
                             management to protect against unauthorized use.

                             The Authority did not have written policies and procedures in
 Written policies were not
                             place for tenant rent collections or evictions to assure
 established for tenant
                             delinquent accounts were pursued and the risk of collection
 collections
                             losses were decreased.

                             24 CFR Section 905.335 states in part that each Indian
                             Housing Authority shall establish, adopt, and use its best
                             efforts to obtain compliance with written policies sufficient to
                             assure the prompt payment and collection of rent payments.

                             The Authority's records showed that many residents have gone
                             one year or more without making rent payments. An
                             Authority board member has gone two years without making
                             rent payments. As of February 1995, 88 of the Authority's
                             161 tenants, or 54 percent, were delinquent in making rent
                             payments for over one month, representing an account balance
                             of $51,394. As of July 1995, the delinquency rate had
                             increased to 124 of the 164 tenants, or 75 percent,
                             representing an account balance totalling $103,412.

                             HUD performed a management review of the Authority in
                             March 1993 and instructed the Authority to reduce its
                             accounts receivables balance through payroll deductions,
                             payback agreements, and evictions. However, the Authority
                             has not taken the recommended corrective actions. The
                             employees responsible for responding to the HUD review
                             were no longer employed at the Authority; thus, it could not
                             be determined why the recommended corrective actions were
                             not taken.



Auditee Comments             Excerpts from the Executive Director's comments on our draft
                             findings follows. The complete text of her comments is
                             included in Appendix A.

                             The Authority agrees with this finding. The Authority will
                             make changes that are necessary to adequately safeguard all
                             funds and to make sure a good paper trail is prepared,
                             including back-up for any payments to anyone or transactions


                                      Page 9                                    96-CH-202-1006
Finding 1



                    of funds with the banks. With the staffing as it is, the
                    Executive Director should have the responsibility of handling
                    all money transactions and then take the needed document to
                    the bookkeeper for proper recording.

                    The Authority had unsupported expenses that it realizes must
                    be paid back.

                    The Authority intends to get a plan with the Holiday Gas
                    Company for its housing vehicles that will give it a better
                    accountability of gas used and better control its fuel costs and
                    track expenditures.

                    The Authority is implementing purchase orders with various
                    businesses in the area so that it pays for nothing that does not
                    have a purchase order.

                    The check signers will always see supporting documentation
                    for each check they sign.

                    The Authority submitted a letter to the Tribal Center
                    employee to repay per payment plan and will accept a payroll
                    deduction plan. The Authority gave the employee one week
                    to make arrangements and if he does not, the Authority will
                    pursue tribal court garnishment of wages.

                    Also, there will be changes in the way rent collections are
                    handled. Eviction and collection policies will be established
                    immediately.


OIG Evaluation of   The Authority indicated it will take action to adequately
Auditee Comments    safeguard all funds and to correct the issue regarding the loan
                    reimbursement by the Tribal employee. However, the duties
                    of handling the money transactions should be segregated to
                    the extent practical. The Authority did not address the
                    implementation of procedures for the Board to maintain an
                    adequate oversight of the Authority's disbursements and
                    procedures requiring the Board to establish formal repayment
                    agreements with all delinquent tenants.




96-CH-202-1006               Page 10
                                                                       Finding 1




Recommendations   We recommend that the Acting Administrator, Eastern
                  Woodlands Office of Native American Programs, assure that
                  the St. Croix Chippewa Housing Authority:

                  1A.    Segregates the duties of its employees to the extent
                         practical. No employee should have complete control
                         over a program area. The duties should be segregated
                         to provide checks and balances on all work.

                  1B.    Restricts access to blank checks to those employees
                         involved in check preparation.

                  1C.    Establishes and implements procedures and controls
                         for the Board to maintain adequate oversight of the
                         Authority's disbursements. At a minimum, the
                         procedures and controls should assure (1)
                         disbursement checks are not pre-signed by anyone, (2)
                         disbursements are supported by invoices, and (3)
                         supporting documentation are reviewed and
                         disbursements are approved by two members of the
                         Board of Commissioners prior to payment.

                  1D.    Provides documentation to support the $31,405 of
                         expenditures or reimburses HUD for the amounts that
                         cannot be substantiated.

                  1E.    Reimburses HUD        $6,993    for   the     ineligible
                         expenditures.

                  1F.    Requires the St. Croix Chippewa Tribal Center
                         employee to reimburse the Authority $1,400 for the
                         loan balance owed plus interest.

                  1G.    Establishes and implements procedures to safeguard,
                         control, and maintain all accounting records to allow
                         efficient access to them.

                  1H.    Establishes and implements written collection and
                         eviction policies and procedures.

                  1I. Establishes and implements policies and controls to
                      maintain Depository Agreements.



                          Page 11                                    96-CH-202-1006
Finding 1



                 1J. Develops procedures that require the execution of formal
                     repayment agreements with all delinquent tenants, or
                     documents the reasons for not executing repayment
                     agreements on a case by case basis.




96-CH-202-1006           Page 12
                                                                                           Finding 2




 The Housing Authority Received Unauthorized
  Loans From The St. Croix Chippewa Tribe
The St. Croix Chippewa Housing Authority received unauthorized loans from the St. Croix Chippewa
Tribe for assistance in administering its Mutual Help Program. The Authority used the loans to pay
its expenses and did not formally record the loans on its books and records. The former Executive
Director had extensive control over the administration of the Authority and was able to receive loans
as needed from the Tribe during periods of cash flow problems. As a result, the Authority was
encumbered with outside loans contrary to Annual Contributions Contract requirements.



                                      Section 422 of the Annual Contributions Contract states that
 HUD Requirements
                                      the Local Authority cannot, without the approval of HUD,
                                      obtain, from any source whatsoever, any loan in connection
                                      with the Projects other than those specifically provided for
                                      under this Contract.

                                      Section 12.3 of the Mutual Help Homeownership Program
                                      Annual Contributions Contract states in part that the
                                      Authority must maintain complete and adequate books and
                                      records which outline the operations of the Authority.

                                      The Authority received several loans from the St. Croix
 The Authority obtained
                                      Chippewa Tribe to assist in the purchase of homes and to pay
 loans from the Tribe
                                      operating costs prior to HUD funds becoming available. The
                                      Authority did not obtain HUD's approval to receive the loans.

                                      Neither the Authority nor the Tribe had an accurate record of
                                      the outstanding loan amount. For example, the minutes from
                                      the Authority's May 3, 1995 board meeting, reported that the
                                      Authority owed the Tribe $637,822. The Authority's books
                                      did not document the amounts owed to the Tribe; but the
                                      Finance Officer maintained informal ledger sheets which
                                      documented the Tribe loan payable amount as $452,407. The
                                      Tribe's Accounting Office staff said that they did not know the
                                      exact amount owed by the Authority, but were in the process
                                      of determining the amount.

                                      The Authority's Board's meeting minutes stated that the
                                      Authority used funds from the Mutual Help Acquisition Grant
                                      to purchase 620 acres of land and several homes. It appears

                                               Page 13                                   96-CH-202-1006
Finding 2



                   that the Tribal loans were used to fund the Acquisition
                   Program prior to the drawdown of HUD funds as well as pay
                   for past due vendor invoices.

                   The Authority also used $151,280 of the funds borrowed from
                   the Tribe in April 1995 to pay for past due vendor invoices.
                   The Authority suspended several employees and terminated
                   the Executive Director in March 1995 which caused the
                   vendor payments to be late.

                   The former Executive Director was responsible for obtaining
                   the majority of the Tribal loans during 1994; thus, the reasons
                   for the loans could not be determined. While there are no
                   formal documents outlining the amount owed by the
                   Authority, Authority and Tribal Officials acknowledged that
                   funds were borrowed from the Tribe to fund the Authority's
                   daily activities.



Auditee Comments   Excerpts from the Executive Director's comments on our draft
                   findings follows. The complete text of her comments is
                   included in Appendix A.

                   The loans we received from the Tribe will be discussed with
                   the Tribal Council to see if the loans can be given to the
                   Authority as other income which will not effect our subsidy.
                   We can work with HUD on monies owed or whatever we
                   need to get projects in order as they should be.


Recommendations    We recommend that the Acting Administrator, Eastern
                   Woodlands Office of Native American Programs, assure that
                   the St. Croix Chippewa Housing Authority:

                   2A.    Provides documentation supporting the amount owed
                          to the St. Croix Chippewa Tribe as well as other non-
                          HUD sources.

                   2B.    Maintains an adequate subsidiary record for all monies
                          borrowed, loaned, and repaid.




96-CH-202-1006              Page 14
                                               Finding 2



2C.   Obtains prior HUD approval for the repayment of
      amounts owed to the St. Croix Chippewa Tribe or any
      other outside entities.

2D.   Discontinues the practice of receiving loans from
      outside sources without prior HUD approval.

2E.   Works with the Authority to encourage the St. Croix
      Chippewa Tribe to donate the loaned amount.




       Page 15                               96-CH-202-1006
Finding 2




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96-CH-202-1006                   Page 16
                                                                                            Finding 3




        The Housing Authority Improperly Used
             Development Program Funds
The St. Croix Chippewa Housing Authority improperly used $878,843 of its development program
funds to: (1) construct an apartment project in which it was not a party to the construction contract;
and (2) purchase land without obtaining HUD's approval. The Authority wanted the apartments
completed prior to the winter of 1994. The Authority used development funds from another project
to construct the apartment complex. The land was purchased for speculative purposes. As a result,
HUD funds were not available to achieve the development grant objectives.



                                       The August 10, 1993, Mutual Help Annual Contributions
 HUD Requirements
                                       Contract Amendment for development projects 62-13 and 62-
                                       14, states in part that the grant funds for the projects were to
                                       be used for force labor and for the acquisition of 25 housing
                                       units. The Housing Authority agreed to carry out the
                                       development activities in accordance with the approved
                                       proposal and at the lowest possible development cost.

                                       The Authority's Annual Contributions Contract, Section 101
                                       states in part that the Authority will administer and develop
                                       each project to promote efficiency and economy. Section 102
                                       states that each project will be developed in accordance with
                                       the applicable Development Program. Section 103 states in
                                       part that the Authority will not undertake to acquire real
                                       property unless HUD has approved that acquisition.

                                       The Authority disbursed $672,510 of program funds
 The Authority used
                                       designated for the acquisition of 25 single family homes for
 program funds for
                                       unauthorized development activities.
 unauthorized activities
                                       The Authority spent the funds between August 1994 and May
                                       1995 for the construction of three apartment buildings. The
                                       Authority was not a party to the construction contract and
                                       HUD had not granted them authorization to build the three
                                       apartment buildings. During that period, the Authority was
                                       authorized a planning grant for the costs associated with the
                                       planning of the apartment project, but it did not receive HUD's
                                       approval for any construction until March 1995. The
                                       construction of the apartments was completed in January
                                       1995.

                                                Page 17                                   96-CH-202-1006
Finding 3



                             The Authority wanted the apartment project completed prior
                             to the winter of 1994 because tribal members had expressed
                             a desire to live in the apartments. However, the Authority had
                             not completed the necessary HUD requirements which would
                             have authorized the construction and funding for the project.


                             In order to facilitate the construction of the project for the
                             Authority, the St. Croix Chippewa Tribe entered into a
                             contract with a builder to begin construction of the
                             apartments. The contract was signed by the Tribe and the
                             builder in August, 1994 for $657,410. In August, 1994 the
                             Authority paid $65,000 for the initial deposit to the builder.
                             The Authority made four additional payments for the
                             remaining $592,410 in December 1994, January 1995, and
                             February 1995. Since the Authority could not be a party to
                             the contract without an approved Annual Contributions
                             Contract from HUD and a secure funding source, the builder
                             initially required an additional 16 percent finance charge or
                             $20,107. The Authority re-negotiated the finance charge from
                             the original $20,107 down to $15,100 and paid the $15,100 in
                             May, 1995.

                             Authority officials said the former Executive Director had
                             control over all of the internal control functions at the
                             Authority. This control gave the former Executive Director
                             the ability to use project monies of one project to finance
                             another project, as well as, allowing payments to a builder that
                             the Authority did not have a contract with.
                             The Authority improperly purchased $206,333 of vacant land
 The Authority improperly
                             between March 1994 and February 1995 without obtaining
 used development funds to
                             HUD's approval. The Authority used project development
                             funds that HUD awarded for the acquisition of 25 housing
                             units to purchase the vacant land.

                             During an Authority board meeting, the former Executive
                             Director said the Authority could purchase the land if homes
                             were eventually built on it. However, HUD's Eastern
                             Woodland Office of Native American Program officials said
                             the project development funds were program specific,
                             indicating the funds drawn from the development project
                             account were to be used for the acquisition of houses only.




96-CH-202-1006                        Page 18
                                                                        Finding 3



                   At a May 3, 1995 meeting between HUD's Eastern Woodland
                   Office of Native American Programs, the Authority, and the
                   St. Croix Chippewa Tribal Council, HUD informed the
                   Authority that it can not own vacant land; therefore, it should
                   not have purchased the land parcels. It was suggested that the
                   Tribe reimburse the Authority for the land purchases. The
                   Tribal Council Chairman said the vacant land was purchased
                   for the development of future housing for tribal members. It
                   was agreed that the Tribe would reimburse the Authority for
                   the land purchases and lease the land back to the Authority
                   when housing needs arose. At the time of our audit, the Tribe
                   had not reimbursed the Authority for the land purchases.

                   As a result of the Authority using the development funds to
                   purchase vacant land, sufficient funds were not available to
                   close on approximately three of the 25 homes under contract
                   to purchase.



Auditee Comments   Excerpts from the Executive Director's comments on our draft
                   findings follows. The complete text of her comments is
                   included in Appendix A.

                   The Authority agrees with this finding. Improperly disbursed
                   funds totalling $672,510 will be put into the correct project
                   and if necessary any balances owed the Government will be
                   taken up with the St. Croix Chippewa Tribal Government for
                   pay back. The Authority understands that it can not purchase
                   land and the Tribe will pay the Authority back funds for the
                   land purchase but then will lease the land when needed for
                   future housing.


Recommendations    We recommend that the Acting Administrator, Eastern
                   Woodlands Office of Native American Programs, assure that
                   the St. Croix Chippewa Housing Authority:

                   3A.    Establishes and implements proper controls to
                          segregate the duties over the development program
                          fund activities and expenditures. At a minimum, the
                          procedures and controls should assure that: (1) no
                          employee has complete control over the program, and



                            Page 19                                  96-CH-202-1006
Finding 3



                       (2) the duties provide checks and balances of the
                       work.

                 3B.   Reimburses the development project account $15,100
                       for the unauthorized construction contract finance
                       charges.

                 3C.   Reimburses the development project account for
                       $657,410, unless: (1) HUD approves a request for a
                       waiver to apply the funds against the March 1995
                       approved construction contract and (2) the property
                       title is transferred to the Authority's name.

                 3D.   Reimburses the development project account for the
                       $206,333 used to purchase vacant land.




96-CH-202-1006          Page 20
                                                                                        Finding 4




     The Housing Authority Did Not Maintain
     Adequate Accountability Over Its Program
                     Funds
The St. Croix Chippewa Housing Authority did not maintain an adequate accountability for its
program accounts. The Authority: (1) transferred account funds without adequate documentation,
and (2) commingled the Youth Sports Program funds with other program funds. The Authority's top
management did not implement effective accounting controls over its funds. As a result, HUD
program funds were used for purposes other than intended and balances are outstanding between the
program accounts.



                                     Section 309 of the Annual Contributions Contract states in
 HUD Requirements
                                     part that the Authority shall maintain complete and accurate
                                     books of account and records. This includes records which
                                     permit a speedy and effective audit.

                                     24 CFR Section 960.229 paragraph (3) states in part that use
                                     of development funds of projects under the Annual
                                     Contribution Contract to covers costs for another project are
                                     strictly prohibited.

                                     24 CFR Section 950.635 states in part that the Housing
                                     Authority shall undertake the modernization activities and
                                     expenditures set forth in its approved Comprehensive
                                     Improvement Assistance Program budget in a timely, efficient,
                                     and economical manner subject to the following requirement.
                                     The Housing Authority shall ensure that there is no
                                     duplication between the activities carried out with
                                     Comprehensive Improvement Assistance Program funds and
                                     the activities carried out with other funds.

                                     The Authority's Public and Indian Housing Youth Sports
                                     Program Grant Agreement, Article I, paragraph H states in
                                     part that the accounting systems of the grantee must ensure
                                     that HUD funds are not commingled with funds from other
                                     Federal agencies or other HUD program funds. Funds
                                     specifically budgeted and/or received for one program may not
                                     be used to support another.



                                             Page 21                                  96-CH-202-1006
Finding 4



                          The Authority wire transferred its HUD program funds for the
 Account funds were
                          Operating Program, Development Program, Youth Sports
 improperly transferred
                          Program, and Comprehensive Improvement Assistant Program
                          accounts into one savings account. The Finance Officer
                          transferred funds from the savings account into the respective
                          programs' checking account as the Authority needed funds to
                          pay the program expenses. The Authority did not reconcile
                          the account balances when the transfers were made in order to
                          account for the money owed between the accounts.

                          The Authority also made interfund transfers between the four
                          program accounts and it did not maintain the wire transfer
                          authorization slips or record the transactions to its general
                          ledger and cash journal to support the wire transfers between
                          the accounts. As a result of interfund transfers made between
                          May 1992 and March 1995, the following balances were
                          outstanding between the different accounts:

                          •   The Development Program owes Comprehensive Program
                              $17,000.

                          •   The Development Program owes Operations Program
                              $78.

                          •   The Development Program owes the Youth Sports
                              Program $60,000.

                          •   The Operating Program owes the Youth Sports Program
                              $15,375.

                          The Authority transferred funds to pay the expenses from one
                          program with the funds of another program. This was
                          especially true for Youth Sports Program funds. Generally,
                          HUD regulations do not prohibit the transfer and commingling
                          of program funds. They only require that the Authority
                          maintain accurate records supporting the transfer of funds.
                          However, HUD's Youth Sports Program Grant Agreement
                          specifically requires that Youth Sports Program funds cannot
                          be commingled with any other program funds. The Authority
                          transferred Youth Sports Program funds into other program
                          accounts where they were commingled. It appears the
                          Authority used Youth Sports Program funds to pay
                          Development Program expenses and its daily operating
                          expenses. Due to inadequate recordkeeping, an exact


96-CH-202-1006                    Page 22
                                                                     Finding 4



                   accounting of the funds could not be performed in order to
                   determine how the funds were spent. It could only be
                   determined which program account the funds were transferred
                   into and what expenses were paid from that account.

                   The Chief Financial Officer said she relied on the former
                   Executive Director to monitor the transactions. We did not
                   locate any Authority records which documented the transfer
                   of the program funds. Due to inadequate record keeping
                   regarding the transfer of funds, the balances of the program
                   accounts were not adequately determinable.

                   As a result, HUD is not assured that the Authority used the
                   program funds for the purposes awarded.



Auditee Comments   Excerpts from the Executive Director's comments on our draft
                   findings follows. The complete text of her comments is
                   included in Appendix A.

                   The Authority was scheduled for a HUD review August 29,
                   1995 at which time new procedures would be set forth to
                   properly handle and maintain control over program funds.
                   Any payments made will have all necessary documentation for
                   back-up of payments made with program funds.


Recommendations    We recommend that the Acting Administrator, Eastern
                   Woodlands Office of Native American Programs, assure that
                   the St. Croix Chippewa Housing Authority:

                   4A.    Maintains adequate documentation to support the wire
                          transfers from HUD in the program accounts.

                   4B.    Establishes policies and procedures to properly
                          account for and document interfund transactions.

                   4C.    Reimburses the program accounts the amounts owed
                          based on the interfund transfers.

                   4D.    Establishes procedures and controls which will assure
                          compliance with the grant agreements.



                           Page 23                                 96-CH-202-1006
Finding 4



                 4E.   Establishes procedures to discontinue the commingling
                       of the Youth Sports funds.




96-CH-202-1006          Page 24
                                                                                        Finding 5




           The Housing Authority Drew Down
               Excess Development Funds
The St. Croix Chippewa Housing Authority drew down $482,340 of development program funds in
excess of actual needs for acquisition costs and development payments. The Authority's top
management did not implement effective disbursement controls over the development funds. As a
result, HUD funds were not efficiently used.



                                   Public and Indian Housing Notice Number 94-73 issued
 HUD Requirements
                                   October 5, 1994, Line of Credit Control System - Voice
                                   Response System for Traditional Indian Housing
                                   Development, paragraph 3-5, C, states the Indian Housing
                                   Authority may requisition funds only when payment is due and
                                   after inspection and acceptance of the work. It also must
                                   distribute the funds within three working days of receipt of the
                                   funds.

                                   The Authority drew down $482,340 in excess funds from its
 The Authority drew down
                                   development account. In May 1995, the Authority drew
 excess funds
                                   down $756,548 of development funds for acquisition costs
                                   and development payments, but it only disbursed $274,208 of
                                   the funds for development activities. The excess funds were
                                   maintained in a non-interest bearing account.

                                   The Resident Services Coordinator said the majority of the
                                   funds were drawn to acquire houses for the Authority's
                                   development program. The Authority had not yet acquired
                                   the houses at the time the draw was made. As a result, the
                                   Authority drew down $482,340 in excess funds from its
                                   development account.


Auditee Comments                   Excerpts from the Executive Director's comments on our draft
                                   findings follows. The complete text of her comments is
                                   included in Appendix A.

                                   The Authority understands that this cannot happen in the
                                   future and will follow the procedures that it set to draw down
                                   on funds only as needed.


                                            Page 25                                   96-CH-202-1006
Finding 5




OIG Evaluation of   The Authority's comments indicate action will be taken to
Auditee Comments    improve the controls over funds being drawn, but did not
                    address remitting the excessive funds to HUD.


Recommendations     We recommend that the Acting Administrator, Eastern
                    Woodlands Office of Native American Programs, assure that
                    the St. Croix Chippewa Housing Authority:

                    5A.    Establishes and implements procedures and controls to
                           assure funds are drawn only when payments are due.

                    5B.    Remits $482,340 to HUD.




96-CH-202-1006              Page 26
                                                                                             Finding 6




Deposits Exceeding Federal Insurance Were Not
                Collateralized
The St. Croix Chippewa Housing Authority failed to obtain collateralization for its bank deposits that
exceeded the $100,000 Federal Deposit Insurance Corporation coverage. The Authority's Finance
Officer said she did not understand the Federal Deposit Insurance Corporation limitations or the bank
collateralization process, and was unaware the funds were at risk.



                                       Public and Indian Housing Notice 95-27 states the Housing
 HUD Requirements
                                       Authority shall require its depositories to continuously and
                                       fully (100 percent) secure all deposits in excess of the
                                       $100,000 (Federal Deposit Insurance Corporation) insured
                                       amount. This may be accomplished by the pledging or setting
                                       aside collateral of identifiable U.S. Government securities as
                                       prescribed by HUD. Such securities shall be owned by the
                                       depository and the manner of collateralization shall provide
                                       the Authority with a continuing perfected security interest for
                                       the full term of the deposit in the collateral in accordance with
                                       applicable laws and Federal regulations. Such collateral shall,
                                       at all times, have a market value at least equal to the amount
                                       of the secured deposits.

                                       The Federal Deposit Insurance Corporation coverage rules
                                       states that all single ownership accounts are subject to a
                                       $100,000 standard limit for deposit insurance. Joint accounts
                                       cannot be insured for over $100,000 and multiple joint
                                       accounts with identical ownership cannot be insured for over
                                       $100,000 in the aggregate.

                                       The Authority did not obtain any type of collateralization for
 The Authority failed to
                                       its bank deposits when they exceeded the $100,000 Federal
 obtain collateralization for
                                       Insurance coverage. As of May 31, 1995, the Authority had
                                       the following funds on deposit at its depository:




                                                Page 27                                    96-CH-202-1006
Finding 6




                         Account Number                  Balance
                            32600                        $633,360
                            28732                           3,354
                            1201728                         3,477
                            35430                           4,180
                            39754                           9,381
                            9265523                           100
                                                         $653,852

                   According to the Branch Manager at the Depository, the
                   Authority is the common account holder for the six accounts
                   listed above and no collateralization agreement existed
                   between the Authority and the bank. All six accounts are
                   viewed as a single account according to the $100,000 Federal
                   Deposit Insurance Corporation coverage.

                   The former Executive Director responsible for ensuring the
                   proper administration of the project funds was not available
                   for comment. The Finance Officer said she was not aware of
                   the Federal Deposit Insurance Corporation limitations, the
                   need for collateralization of funds, or that HUD required the
                   funds to be safeguarded beyond ordinary Federal Deposit
                   Insurance Corporation coverage.

                   As a result, if the depository failed, the Authority risked losing
                   the $553,852 of funds on deposit which were in excess of the
                   insurance limitations.



Auditee Comments   Excerpts from the Executive Director's comments on our draft
                   findings follows. The complete text of her comment is
                   included in Appendix A.

                   The Authority agrees with this finding. The Authority
                   contacted HUD and is in the process of obtaining the
                   necessary form that is needed and correcting the issue.




96-CH-202-1006              Page 28
                                                                  Finding 6




Recommendations   We recommend that the Acting Administrator, Eastern
                  Woodlands Office of Native American Programs, assure that
                  the St. Croix Chippewa Housing Authority:

                  6A.    Obtains adequate collateral for its aggregate bank
                         deposits at one bank that exceeds the $100,000
                         Federal Deposit Insurance coverage.




                          Page 29                               96-CH-202-1006
Finding 6




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96-CH-202-1006                   Page 30
Internal Controls
In planning and performing our audit, we considered the internal controls of the St. Croix Chippewa
Housing Authority to determine our auditing procedures and not to provide assurance on internal
controls. Internal controls consist of the plan of organization, methods, and procedures adopted by
management to ensure that resource use is consistent with laws, regulations, and policies; that
resources are safeguarded against waste, loss, and misuse; and that reliable data are obtained,
maintained, and fairly disclosed in reports.



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

                                      •   Management philosophy and operating style

                                          •   Oversight body

                                          •   Methods of assigning authority

                                          •   Management monitoring methods

                                          •   Proper authorizations

                                          •   Completeness of accounting system

                                          •   Segregation of duties

                                          •   Safeguards over access to and use of assets and
                                              records

                                          •   Policies and procedures

                                          •   Independent verifications and reconciliations

                                      We assessed all relevant controls identified above.

                                      It is a significant weakness if the internal controls do not give
 Significant Weaknesses
                                      reasonable assurance that resource use is consistent with laws,
                                      regulations, and policies; that resources are safeguarded
                                      against waste, loss, and misuse; and that reliable data are
                                      obtained, maintained, and fairly disclosed in reports.

                                      Based on our review, the following are significant weaknesses:



                                               Page 31                                    96-CH-202-1006
Internal Controls



                    •   Management monitoring methods. Taken as a whole, the
                        six findings in this report show that the Authority needs to
                        increase its managerial oversight to assure HUD's
                        requirements are met, and supervisory control to assure
                        compliance with its own policies and procedures.

                    •   Policies and procedures. The Authority did not establish
                        clear concise policies and procedures to ensure Federal
                        programs were effectively managed and costs controlled
                        (see Findings 1, 2, 3, 4, 5, and 6).

                    •   Completeness of accounting system. The Housing
                        Authority did not properly account for development funds
                        on its books and properly report program funds (see
                        Finding 4).

                    •   Segregation of duties. The Housing Authority did not
                        adequately segregate staff duties over its cash
                        disbursements function (see Findings 1 and 3).

                    •   Safeguards over access to and use of assets. The Housing
                        Authority did not maintain effective controls over its
                        assets or disbursements and it did not restrict access to
                        blank checks and financial records (see Findings 1, 2, 3, 4,
                        and 5).




96-CH-202-1006               Page 32
Follow Up On Prior Audits
This is the first OIG audit of the St. Croix Chippewa Housing Authority. The Authority's last Single
Audit Report was for Fiscal Year ending March 31, 1994, dated June 23, 1994, contained two
findings that were unrelated to this report.




                                               Page 33                                  96-CH-202-1006
Follow Up On Prior Audits




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96-CH-202-1006                       Page 34
                             Appendix A

Auditee Comments




                   Page 35   96-CH-202-1006
Appendix A




96-CH-202-1006   Page 36
          Appendix A




Page 37   96-CH-202-1006
Appendix A




96-CH-202-1006   Page 38
          Appendix A




Page 39   96-CH-202-1006
Appendix A




96-CH-202-1006   Page 40
          Appendix A




Page 41   96-CH-202-1006
Appendix A




96-CH-202-1006   Page 42
                                                                                         Appendix B

Schedule of Questioned Costs

                                                      Type of Questioned Costs
                Recommendation Number           Ineligible 1/     Unsupported 2/


                       1D                                         $ 31,405
                       1E                         $ 6,993
                       1F                           1,400
                       3B                          15,100
                       3C                                           657,410
                       3D                         206,333
                       5B                         482,340
                    Total                         $712,166         $688,815


1/ Ineligible costs are costs are amounts that are questioned because of an alleged violation of a
provision of a law, regulation, contract, grant, cooperative agreement, or other agreement or
document governing the expenditure of funds.

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




                                                Page 43                                  96-CH-202-1006
Appendix B




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96-CH-202-1006                   Page 44
                                                                                   Appendix C

Distribution
Secretary's Representative, Midwest
Acting Director, Eastern Woodlands Region, Native American Programs
Assistant General Counsel for the Midwest
Field Controller, Midwest
Public Affairs Officer, Midwest
Director, Accounting Division, Midwest
Assistant to the Deputy Secretary for Field Management, SC (7106)
Acquisition Librarian, Library, AS (Room 8141)
Chief Financial Officer, F (Room 10166)(2)
Deputy Chief Financial Officer for Operations, FO (Room 10166)(2)
Comptroller/Audit Liaison Officer, PF (Room 4122)
Office of the Special Assistant to the Secretary for Indian and Alaska Native Programs,
 SV (Room 10222)
Assistant Director in Charge, U.S. GAO, 820 1st NE, Union Plaza Bldg. 2, Suite 150,
Washington D.C. 20002




                                            Page 45                                96-CH-202-1006