Issue Date
June 27, 1996
Audit Case Number
96-PH-212-1017
TO: Charlie Famuliner, Director, Multifamily Division,
Virginia State Office, 3FHM
FROM: Edward F. Momorella, District Inspector General for
Audit, Mid-Atlantic, 3AGA
SUBJECT: Dorchester Square Apartments
Multifamily Mortgagor Operations
Franklin, Virginia
As you requested we have audited the operations of Dorchester Square Apartments (project) to
determine whether the Owner operated the project according to the terms and conditions of the
Regulatory Agreement and HUD requirements.
The report identifies that improper cash distributions were paid to the Owner. Additionally, the
identity-of-interest Agent and the Owner incurred ineligible and unsupported expenses, did not
properly verify income of tenants reporting little or no income on recertification and failed to
maintain the financial records of the project as required.
Within 60 days, please give us, for each recommendation in this report, a status report on: (1)
the corrective action taken; (2) the proposed corrective action and the date to be completed; or
(3) why action is considered unnecessary. Also, please furnish us copies of any correspondence
or directives issued because of the audit.
If you have any questions, please contact Irving I. Guss, Assistant District Inspector General for
Audit, at (215) 656-3401.
Management Memorandum
96-PH-212-1017 Page ii
Executive Summary
We audited Dorchester Square Apartments to determine whether the Owner operated the project
according to the terms and conditions of the Regulatory Agreement and HUD requirements.
Issues identified in the report indicate that the Owner/Agent's oversight of financial and certain
program areas requires improvement. From a monetary standpoint these conditions resulted in
ineligible and unsupported costs of $113,463 and $104,604 respectively.
The Owner was paid $16,856 in excess cash distributions
Improper distributions
and did not deposit an additional $17,076 in the residual
paid Owner
receipts fund as required. Based on surplus cash
computations for the period 1989 through 1995, there was
not a cash surplus to support the excess distributions. The
Owner's actions represent a disregard for HUD
requirements and mismanagement of project funds.
The Agent increased management fees and paid their
Agent received and paid
employee from project funds contrary to HUD
improper project
requirements. The improper payments totaled $79,531.
expenses
The Agent's actions were to their benefit and detrimental to
project operations. As a result the project has lost needed
revenue.
Review of the projects' books and accounts identified
Unsupported project costs
numerous instances of non-compliance. The Owner/Agent:
and questionable
1) Disbursed $96,108 from the operating account without
accounting transactions
proper supporting documentation. When documentation
was available it did not fully identify the items purchased or
the services performed. 2) Used an accounting system that
produced unreliable information. These actions by the
Owner/Agent demonstrate a disregard for HUD
requirements, and have resulted in questionable financial
operation of the project.
Our review disclosed that five project tenants are reporting
Management has failed to
no income on recertification, and other tenants are reporting
adequately justify tenants
income as low as $100 per month. In all cases the files did
non-income status
not contain documentation that indicated all efforts were
exhausted by management to verify possible income as
required. As a result the potential exists that HUD has
overpaid Housing Assistance Payments (HAP) for these
tenants.
Page iii 96-PH-212-1017
Executive Summary
We recommend the Owner/Agent: (1) repay ineligible
costs to the project; (2) justify the eligibility of unsupported
costs; and (3) implement accounting and income
verification requirements.
We discussed the finding issues with the Owner/Agent and
staff during the audit and their comments are summarized
in the findings. The draft findings were provided the
Owner and responses received were considered in our
report. The Owner's written response, exclusive of exhibits,
is included as Appendix B. Copies of exhibits supporting
the questioned costs in the findings were provided to the
Owner and your staff.
An exit conference was held with the Owner on June 17,
1996.
96-PH-212-1017 Page iv
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 Improper Cash Distributions Paid The Owner 3
2 Project Paid Ineligible Agent Costs 5
3 The Projects' Records Are Improperly Maintained 9
4 Questionable Tenant Income Verification
By Management 13
Internal Controls 17
Follow Up On Prior Audits 19
Appendices
A Schedule of Ineligible and
Unsupported Costs 21
B Auditee Comments 23
C Distribution 27
Page v 96-PH-212-1017
Table of Contents
Abbreviations
HAP Housing Assistance Payments
HUD Department of Housing and Urban Development
OIG Office of Inspector General
96-PH-212-1017 Page vi
Introduction
Dorchester Square Apartments is a HUD-insured multifamily housing project in Franklin,
Virginia with 125 Section 8 units. The mortgage was initially endorsed for insurance under
Section 221(d)(3) of the National Housing Act on December 27, 1972.
The Owner, Dorchester Associates, a limited partnership, was organized on December 1, 1972.
On January 1, 1983, the current ownership was organized as a Virginia Limited Partnership. The
principals of the partnership are Rocco Lassiter, David Levine and Gale Levine. The project is
operated under the Section 8 Rental Supplement Program of the National Housing Act. David
Levine and Gale Levine have managed the project since 1983 through an identity-of-interest
management agent, Sun Realty Co (Agent). Sun Realty Co. offices are located in Virginia Beach,
Virginia.
Primary tenant records are maintained at the project's office in Franklin, Virginia. Financial
records are kept at Hodges Manor Apartments in Portsmouth, Virginia, another HUD-insured
project managed by the Agent.
During the audit your office engaged a contractor to physically inspect the project. The
contractor reported many physical conditions of the project were unsatisfactory together with the
project's maintenance policies and practices. Ninety-nine percent of the units inspected by the
contractor failed housing quality standards. We inspected ten units which failed housing quality
standards, confirming the contractor's work. The physical condition of the project is not being
reported since your office is handling the problem with the Owner.
The objectives of the audit were to determine whether the
Audit Objectives
Owner complied with the Regulatory Agreement and HUD
requirements. Specific objectives were to determine
whether the project's system of internal control was
adequate and disbursements were reasonable and necessary.
We examined Dorchester Square's accounting and financial
Audit Scope
records, and reports located in the HUD Virginia State
Office. We reviewed the project's independent public
accountant's work papers for Fiscal Year 1993 and 1994.
We interviewed project, Agent, and HUD staff members.
We inspected two vacant and eight occupied units.
Audit work was performed between October 1995 and June
Audit Period
1996 and covered activities between January 1993 through
December 1995. The audit period was expanded when
appropriate.
Page 1 96-PH-212-1017
Introduction
We conducted the audit in accordance with generally
accepted government auditing standards.
96-PH-212-1017 Page 2
Finding 1
Improper Cash Distributions Paid The Owner
The Owner was paid $16,856 in excess cash distributions and did not deposit an additional
$17,076 in the residual receipts fund as required. Based on surplus cash computations for the
period 1989 through 1995, there was not a cash surplus to support the excess distributions. The
Owner's actions represent a disregard for HUD requirements and mismanagement of project
funds.
Paragraph 9G of the Regulatory Agreement provides that
surplus cash is any cash remaining after the current
mortgage payment is made; all required deposits are made
to the reserve fund for replacements; and the payment of
project expenses.
The project is also required to make deposits in a residual
receipts fund. The Regulatory Agreement limits
distributions to six percent annually on the Owners initial
equity investment amounting to $20,034. Any additional
cash surplus must be deposited into the residual receipts
fund. However, the Owners can take more surplus cash
than they earned during the year if they had distributions
accrued and unpaid in prior years.
The Owner contrary to the Regulatory Agreement took
Owner took excess
excess distributions without an available cash surplus and
distributions
did not make the required deposit to the residual receipts
fund. The Owner claims cash surpluses were available to
support the distributions. Further, the Owner stated that
$18,000 in surplus cash is available every year. However,
our computations of surplus cash from 1989 to 1995
disclosed the Owner did not deposit $17,076 in the residual
receipts fund as required, and made excess distributions
totaling $16,856.
The Owner's lack of knowledge of HUD requirements has
contributed to the mismanagement of project finances.
Page 3 96-PH-212-1017
Finding 1
Auditee Comments The Owner disputes the finding that they made excess
distributions of surplus cash and failed to deposit funds in
residual receipts as required. The basis for the dispute is the
OIG Auditor failed to use the proper HUD forms to
compute surplus cash and their accountant did. The
accountant states that in 1994 and 1995 excess distributions
of $14,000 and $14,700 respectively were repaid.
OIG Evaluation of Calculations of surplus cash were made in accordance with
Auditee Comments HUD Handbook 4370.2. The information compiled in the
schedule provided to the Owner came directly from HUD
Form 93486 (Computation of Surplus Cash, Distributions
and Residual Receipts) and the project's accounting records.
Regarding the $28,700 reported as repaid to the project by
the Owner documentation was not provided to support
repayment.
Recommendations We recommend the Owner:
1A. Provide documentation to support repayment of
$28,700 to the project in 1994 and 1995.
Documentation shall include bank deposits, bank
statements, wire transfers, canceled checks and
accounting analysis of the net amounts claimed. In
the absence of documentation reducing excess
distributions reimburse the project $16,856 for
excess cash distributions and deposit $17,076 in the
residual receipts fund as required.
1B. Implement accounting controls that conform to
HUD requirements regarding the distribution of
surplus cash.
96-PH-212-1017 Page 4
Finding 2
Project Paid Ineligible Agent Costs
The Agent increased management fees and paid their employee from project funds contrary to
HUD requirements. The improper payments totaled $79,531. The Agent's actions were to their
benefit and detrimental to project operations. As a result the project has lost needed revenue.
A. Excess management fees taken by the Agent
The Agent increased its management fee without HUD's
approval and took excess management fees totaling
$35,968.
The Management Agreement signed by the Agent, Owner
and HUD on January 1, 1983, stated that each monthly fee
will be equal to six percent of gross collections during the
preceding month. Further, the percentage fee may be
increased by 1/4 of one percent on the anniversary date of
the agreement, if HUD approves the Owner's written
request.
HUD Handbook 4381.5 REV-2, Chapter 3, Section 3.10,
states to request a change in the management fee
percentage, the Owner and Agent are required to submit a
new management certification with the revised management
fee. Further, Section 3.11B states that rent increases do not
trigger management fee reviews.
The Agent contrary to HUD requirements increased the
Agent improperly
percentage for the management fee without HUD's written
increased management
approval. Additionally, the Owner never sought to obtain
fee
a new management agreement with HUD when it expired
in 1985. The Owner claims that HUD approved the
increased percentage for the management fee when it
approved the rent increase in 1990.
In a memo dated October 31, 1995, HUD's Virginia State
Office directed the Agent to reduce the fee to the amount
agreed upon in the Management Agreement signed in 1983.
Page 5 96-PH-212-1017
Finding 2
However, the Agent has not complied and continues to
collect excess management fees.
B. Ineligible payments made to an employee of the
Agent
The Agent paid an employee $28,563 classified as
bookkeeping fees from January 1, 1993 to December 31,
1995. However, the bookkeeper for Hodges Manor
Apartments, is the bookkeeper of Dorchester Square
Apartments.
The Agent also paid the same employee $15,000 which was
Project improperly paid
classified as partners' distributions. The employee is not
Agent costs
listed as a general or limited partner of the partnership
entity therefore not entitled to distributions from surplus
cash. The owner claims that HUD approved the payments
to the employee when they approved the rent increase in
1990.
According to HUD Handbook 4381.5 REV-2, salaries of
the Agent's personnel are paid from the management fee.
Further, as stated above, rent increases do not trigger
management fee reviews. As a result, the $15,000 and
$28,563 are Agent costs not project costs and ineligible.
Auditee Comments The Owner/Agent disputes that the Management Agreement
has expired. A memo to HUD in 1985, Virginia contract
law and the management review report that stated the
contract was indefinite are cited as supporting their
position.
The Owner/Agent contends that a HUD Asset Manager
authorized the management fee increases prior to the
issuance of the 1994 HUD Handbook 4381.5 REV-2.
The Owner/Agent states that the employee was paid
additional fees for bookkeeping services performed beyond
her normal duties. They also claim that the $15,000 was a
bonus permitted by HUD Handbook 4381.5 REV-2 under
extraordinary circumstances. Additionally, the bonus was
disclosed to HUD in 1990, and not questioned.
96-PH-212-1017 Page 6
Finding 2
The Management Agreement between the Owner/Agent
OIG Evaluation of and HUD clearly states that the percentage fee may be
Auditee Comments increased by 1/4 of one percent on the anniversary date of
the agreement, if HUD approves the Owner's written
request. No documentation was provided that HUD
approved such a request or the 1985 memorandum
allegedly sent to HUD. The Management Review Report
representation of indefinite by the reviewer indicates the
management term was not definite and unclear. In our
opinion the indefinite citation was made because the
agreement had expired.
HUD Handbook 4381.5 and all subsequent revisions state
to request a change in the management fee percentage, both
the Owner and the Agent are required to submit a new
management certification with the revised management fee.
Further, there is no documentation that a HUD Asset
Manager authorized any increase in the management fee.
Bookkeeping fees are allowable expense from operations.
However, the employee in question does not perform any
bookkeeping duties as stated in the finding.
HUD Handbook 4381.5 all revisions do not permit bonuses
to the Agent's employees to be paid from the operating
account. Salaries of agent's employees are paid from the
management fee. HUD Handbook 4381.5 REV-2 will only
allow the cost of supervisory personnel providing oversight
of computer and accounting services to be paid from the
operating account. However, they must be prorated and
approved by HUD.
Recommendations We recommend the Agent:
2A. Repay the project $79,531 for ineligible
management fees and improper payments made to
the employee. Repay the project additional fees
taken from January 1, 1996 to date, and discontinue
the improper practices.
2B. Submit to HUD for approval a new management
certification and proposal for the management fee.
Page 7 96-PH-212-1017
Finding 2
96-PH-212-1017 Page 8
Finding 2
Page 9 96-PH-212-1017
Finding 3
The Projects' Records Are Improperly
Maintained
Review of the projects' books and accounts disclosed numerous instances of non-compliance.
The Owner/Agent: 1) Disbursed $96,108 from the operating account without proper supporting
documentation. When documentation was available it did not fully identify the items purchased
or the services performed. 2) Used an accounting system that produced unreliable information.
These actions by the Owner/Agent demonstrate a disregard for HUD requirements, and have
resulted in questionable financial operation of the project.
A. Unsupported costs
The Regulatory Agreement, paragraph 9d, states that the
books and accounts of the property must be maintained in
accordance with the requirements of the Commissioner.
HUD Handbook 4370.2 REV-1, Chapter 2, paragraph 2B,
states that the books and accounts must be complete and
accurate. Further, paragraph 2-6B states that all
disbursements must be supported by approved invoices and
other supporting documentation.
During our review, we presented the Owner/Agent a list of
Documentation not
questionable disbursements. We were told documentation
provided to support costs
would be provided to support the questioned disbursements.
The documentation provided by the Owner/Agent
supported some of the disbursements questioned. The
following list represents the remaining $96,108 in
questionable and unsupported disbursements.
A contractor was paid $58,942 from January 1, 1993 to
December 31, 1995 for work identified as contract
maintenance. The invoices provided by the contractor
consist of envelopes filled with invoices from local
hardware stores and convenience stores. Handwritten on
the envelopes are the words wages and gas followed by
dollar amounts. No contract was provided identifying the
cost of labor or any other services requiring reimbursement.
Page 9 96-PH-212-1017
Finding 3
A contractor was paid $6,800 for work identified as siding;
however, no invoice was provided that identifies the cost of
the labor or the materials used.
Two contractors were paid $9,220 for labor and materials;
however, no invoices were provided to support the cost of
the labor and materials.
The Agent paid a hardware store $12,784 and an office
supplies store $1,906; however, in both instances the
invoices provided only identified the amount owed on
account. Supporting invoices identifying the items
purchased on account was not provided.
Miscellaneous disbursements totalling $6,456 either did not
have invoices available or if an invoice was available it
lacked adequate detail to support the disbursement as a
project expense.
The Owner/Agent was provided a detailed schedule of the
above costs to assist them in gathering documentation to
support the costs. To date we have not received any
additional documentation, and the costs remain questioned.
B. Accounting system deficiencies
HUD Handbook 4370.2 REV-1, Chapter 2 states that the
projects' accounting system should meet certain general
objectives, two of which are, provide timely, accurate and
complete information for management decision making;
and safeguard the projects' assets. Contrary to HUD
requirements the Owner/Agent accounting system does not
meet these objectives. Examples of system deficiencies
identified during our review follow:
• Amounts posted to tenants accounts receivable were
based on the rent roll and did not agree with the tenant
ledgers. Beginning in July 1995, the project used the
tenant ledgers to calculate tenants' accounts receivable.
However, our testing of July tenants' accounts
receivable disclosed that those figures were incorrect.
96-PH-212-1017 Page 10
Finding 3
• A bad debt account did not appear on any of the trial
balances we reviewed, through December 1995. In the
Fiscal Year 1994 Financial Statements, $8,496 was
reported as bad debts. We requested postings to the
account, but none were provided, and the write off is
questioned.
• Postings made to the Housing Assistance Payment
account were higher than those posted to the bank
statements and the cash account for the two months we
reviewed.
• The Owner/Agent allowed contractors, performing work
at the project, to purchase materials at a local hardware
store and charge the purchases to the project's account.
The contractor simply signs the invoice. As stated in
Part A, the Agent pays the hardware store from invoices
that only identify the amount owed on account.
Supporting invoices identifying the items purchased on
account were not provided.
• Owner/Agent maintains two bank accounts for the
project. Copies of cancelled checks show that the
management fee and the bookkeeping fee were
disbursed from both accounts. Maintaining two
operating accounts confuses rather than simplifies
accountability of financial operations.
• An Agent employee claims that bids are solicited when
selecting contractors to perform work at the project.
However, a review of the project's files did not disclose
any bids or a bid selection process.
The Owner/Agent did not seem aware that there were any
problems with their accounting system. However, other
employees were aware of the problems but were concerned
with job security and believed the best policy was to follow
the Owner/Agent's direction.
Auditee Comments Owner/Agent claim they are unable to provide supporting
documentation to support the questioned costs, because the
OIG Auditor, removed records from the files. Further, the
Page 11 96-PH-212-1017
Finding 3
findings did not identify the questionable costs and
disbursements by contract and amount.
Owner/Agent does not believe items identified are really
deficiencies that need to be corrected, and requested a more
detailed explanation before they will make the corrections.
OIG Evaluation of No records were removed from the project or
Auditee Comments Owner/Agent's office by the auditor.
The disbursements in question were specifically identified
in December to the Owner/Agent. The items identified in
the report were those items that were not supported by
documentation provided.
The HUD Handbook citation clearly identifies the basic
requirements that the project's accounting system shall meet
and the Owner is required to maintain. The accounting
deficiencies cited identifies that the project's system does
not meet HUD requirements.
Recommendations We recommend the Owner/Agent:
3A. Provide supporting documentation for the
disbursements questioned or reimburse the operating
account for $96,108.
3B. Install an accounting system that will provide timely
and accurate information to conform with HUD
requirements. Establish an Internal Control System that
adequately safeguards the project's assets. Use only one
bank account to disburse funds for project operations.
Provide documentation to support the $8,496 reported as a
bad debt in Fiscal Year 1994.
96-PH-212-1017 Page 12
Finding 4
Questionable Tenant Income Verification By
Management
Our review disclosed that five project tenants are reporting no income on recertification. We
also reviewed the files of tenants reporting income as low a $100 per month. In all cases the files
did not contain documentation that indicated all efforts were exhausted by management to verify
possible income as required. As a result the potential exists that HUD has overpaid HAP for
these tenants.
HUD Handbook 4350.3 CHG-27, Chapter 3, Paragraph 3-
30, requires Owners of Section 8 projects to verify all
sources of income, expenses, assets, household
characteristics and circumstances that effect tenant
eligibility or rent.
During November 1995, we identified nine tenants not
Tenant income
reporting any income on recertification. In April 1996, we
verification not effective
found only five tenants not reporting income on
recertification, four from the list in November and one new
tenant. In both November and April, contrary to HUD
requirements, management did not perform an extensive
search to verify all sources of income. Additionally, an
inspection of the units occupied by the aforementioned
tenants in April 1996 disclosed three telephones in one
apartment, new furniture, stereo equipment and televisions.
To afford such amenities some source of income exists.
Further, the question arises how do these tenants subsist?
Reports received from the Virginia Employment
Commission indicated that four of the tenants not reporting
income in 1995 and 1996 are also not reporting income
earned by the their adult children or unemployment
benefits.
The resident manager claims that the Virginia Employment
Commission will not allow access to certain information
that might disclose unreported income. Further, she stated
that HUD does not have any specific guidelines describing
Page 13 96-PH-212-1017
Finding 4
the necessary steps to take when a tenant reports no income.
We point out that a thorough interview with the tenant,
asking simple common sense questions might disclose
unreported income. There was no evidence that such an
approach was taken by management.
Auditee Comments Owner/Agent nonconcurs that management did not
adequately verify tenant income, and claims the following
to support their contention: 1) Resident Manager verifies
with social services to determine eligibility of benefits; 2)
former HUD employee stated that there were no definitive
guidelines to determine lack of income; and 3) tenants who
lose their jobs provide verification of job loss and
termination of unemployment benefits. Various documents
were provided as support for income verification. Further,
recommendation 4A has been accomplished, and need
definition for extensive search, under recommendation 4B.
OIG Evaluation of The finding identifies nine tenants not reporting income on
Auditee Comments recertification in November 1995 and five tenants in April
1996. The documentation provided with the response is on
three tenants, two who were reporting income on
recertification in April 1996. Our assessment of the
documentation provided disclosed the Owner/Agent did not
verify that the tenant:
• received food stamps or other government assistance;
• was no longer employed;
• was receiving unemployment benefits; and
• identified the source of income to support amenities in
all units cited. Response referred to only one unit.
The documents provided are not sufficient income
verification. Recommendation 4A still requires
implementation.
During the closing conference explanation was provided
covering the type of questions that can be posed to a tenant
during the certification interview. As stated in the finding
96-PH-212-1017 Page 14
Finding 4
asking common sense questions might disclose unreported
income. This approach together with the guidelines
provided in HUD Handbook 4350.3 CHG-27 provides the
basis for adequately verifying tenant income.
Recommendations We recommend the Owner/Agent:
4A. Recertify all tenants reporting no income and
income of $100 or less. For tenants with validated
income restructure the HAP payments. Establish a
workout agreement with the tenants to recapture the
subsidy overpayments due HUD. If there is a
hardship for such a plan consult with HUD for
appropriate action to be taken.
4B. Implement HUD requirements to ensure tenant
interviews are conducted and verification
procedures followed to identify all sources of
income.
Page 15 96-PH-212-1017
Finding 4
96-PH-212-1017 Page 16
Internal Controls
In planning and performing our audit, we considered the internal control systems of the
management of Dorchester Square Apartments in order to determine our auditing procedures and
not to provide assurance on internal controls.
Internal control is the process by which an entity obtains reasonable assurance as to achievement
of specified objectives. Internal control consists of interrelated components, including integrity,
ethical values, competence, and the control environment which includes establishing objectives,
risk assessment, information systems, control procedures, communication, managing change, and
monitoring.
We determined that the following internal control
Internal controls assessed
categories were relevant to our audit objectives:
• Accounting records and reports
• Cash receipts and disbursements
• Occupancy requirements
A significant weakness exists if internal control does not
Significant weaknesses
give reasonable assurance that the entity's goals and
found
objectives are met; 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, we believe the following items are
significant weaknesses:
• Accounting records and reports
• Cash receipts and disbursements
• Occupancy requirements
These weaknesses are detailed in the findings in this report.
Page 17 96-PH-212-1017
Internal Controls
96-PH-212-1017 Page 18
Follow Up On Prior Audits
This was the first OIG audit of Dorchester Square Apartments.
Page 19 96-PH-212-1017
Follow Up On Prior Audits
96-PH-212-1017 Page 20
Appendix A
Schedule of Ineligible and
Unsupported Costs
Finding Number Ineligible 1/ Unsupported 2/
1 $ 33,932
2 79,531
3 $104,604
$113,463 $104,604
1/ Ineligible costs are not allowed by law, contract, or HUD policies or
regulations.
2/ Unsupported costs were not clearly eligible or ineligible but warrant being contested because
of the lack of documentation supporting such costs.
Page 21 96-PH-212-1017
Appendix A
96-PH-212-1017 Page 22
Appendix B
Auditee Comments
Page 23 96-PH-212-1017
Appendix B
96-PH-212-1017 Page 24
Appendix B
Page 25 96-PH-212-1017
Appendix B
96-PH-212-1017 Page 26
Appendix C
Distribution
Director, Multifamily Division Virginia State Office, 3FHM (2)
Internal Control & Audit Resolution Staff, 3AFI
Director, Housing Division, 3AH
Director, Field Accounting Division, 3AFF
State Office Manager, Richmond, 3FS
Assistant to the Secretary for Field Management, SDF
Deputy Assistant Secretary for Field Management, SDF
Audit Liaison Officer, HF (3)
Acquisitions Librarian, Library, AS
Director, Participation & Compliance Division, HSLP
Chief Financial Officer, F (2)
Deputy Chief Financial Officer for Operations, F (2)
Assistant Director in Charge, US GAO, 820 1st St. NE Union Plaza,
Bldg 2, Suite 150, Washington, DC 20002 (2)
General Partner Dorchester Associates, 2100 Marina Shores Drive,
Virginia Beach, VA 23451
Page 27 96-PH-212-1017
Dorchester Square Apartments Multifamily Mortgagor Operations, Franklin, Virginia
Published by the Department of Housing and Urban Development, Office of Inspector General on 1996-06-27.
Below is a raw (and likely hideous) rendition of the original report. (PDF)