Loading...
141-2000 LTC , , ~ Po.~ CITY OF MIAMI BEACH CITY HALL 1700 CONVENTION CENTER DRIVE MIAMI BEACH, FLORIDA 33139 http:\\ci,miam~beach,fl.us ~. 141 -- 2000 L.T.C. No. LETTER TO COMMISSION TO: Mayor Neisen O. Kasdin and Members of the City co~ Lawrence A. Levy O. City Manag~ Housing AU~; of the City of Miami Beach S'6~ ..L, '0 f\1 C-" 1:::1 r" r0 1'\\ ~~ cP '__ r_ L "7': :P.: . (fJ :::- r\\ co '-P. '0 -n, ~~. t'V "f> r-..J rn July 24, 2000 FROM: SUBJECT: On June 7, 2000, the City Commission referred to the Community Affairs Committee (CAC) a discussion regarding the Housing Authority of the City of Miami Beach (Housing Authority). This discussion item has been deferred to the Committee's next meeting on July 28, 2000. The Housing Authority has agreed to conduct a presentation during the meeting of the CAC. In anticipation of said presentation, the Administration is providing pertinent information regarding the Housing Authority. The Housing Authority hired Casterline Associates, P.C., as consultants, to conduct a review of their operations and determine if adequate internal controls were in place. A summary of the reports prepared by Casterline Associates is attached. U.S. HUD and the HUD Office of the Inspector General have been conducting an audit of all operations of the Housing Authority. HUD issued an in-depth Consolidated Management Review (CMR) which is also attached hereto. HUD has placed the Housing Authority, Section 8 Department under probation. Since 1992, the City and the Housing Authority have entered into a Joint Program for Housing- Related Community Development Enhancement (Interlocal Agreement). Under the terms of the Interlocal Agreement, the Housing Authority has funded services provided by the City for the Housing Authority. These services historically have included four components: Code Compliance, Recreation Program, Enhanced Police Protection, and Subsidized Child Care. As part of the ongoing audit, HUD has preliminarily indicated that the Housing Authority may have erred in determining that the components of the Interlocal Agreement were eligible activities and/or that the Housing Authority may have used incorrect accounts to pay for said services. Therefore, pending the official report from HUD, the Housing Authority has not renewed the Interlocal Agreement for FY 1999/2000. As a consequence, the City has canceled the services under the Interlocal Agreement, effective July 1,2000. Under the terms of the Interlocal Agreement, payments are processed through the City of Miami Beach / Miami Beach Housing Authority Benefit Fund Goint account) between i the City and the Housing Authority. Therefore, HUD's Office of the Inspector General is auditing the records of the joint account kept by the Finance Department of the City. In 1994, the City also entered into a HOME Program Agreement with the Housing Authority for the Single Parent Family Housing and Resource Center, 1231-1251 17th Street, Miami Beach. Under the terms of the HOME Program Agreement, the City committed $760,000 in fiscal years 1993/94 and 1994/95 HOME Program funds toward the construction of the Center. The HOME funds have not been spent. The Housing Authority has designed the Center and construction permits have been obtained. However, the Housing Authority has not decided if it will proceed with construction. U.S. HUD has requested that the City provide a time frame for the expenditure of the HOME funds committed to this project. The City has notified the Housing Authority, and at their July 11,2000 meeting, Commissioner Gutierrez was asked to meet with the City and to report back to the Board with a recommended action plan. Concurrently, and as referred by the City's Land Use and Development Committee, Joseph Johnson, Transportation/Concurrency Management Director, conducted a presentation to the Board of Commissioners on July 11, 2000 regarding the West Avenue Connector Study. The proposed Connector is to run through the lot located at 1231-1251 17th Street, which the Housing Authority acquired intending to build the Single Parent Center. On June 12, the Land Use and Development Committee postponed any action on the Connector until September in order to allow time for the Housing Authority to determine whether they will proceed with the construction of the Single Parent Center. If the Housing Authority does not proceed with construction of the Center, the City may consider acquiring the land from the Housing Authority. On July 12,2000, the City Commission appointed Steve E. Chaykin to the vacancy in the Board of Commissioners of the Housing Authority. Amy Turkel recently resigned from the Board. The Office of the City Clerk has obtained a copy of her resignation letter from the Housing Authority (attached). The Housing Authority has conducted a nationwide search for a new Executive Director. As a result, Larry Shoeman from Brevard County has been recruited and started as Executive Director on July 17,2000. Attached is also a copy of the Florida Statutes, Chapter 421 Public Housing. Sections 421.001 through 421.54 refer to Housing Authorities. LAL/CMC/RM/MDC Attachments c: Christina M. Cuervo, Assistance City Manager Patricia D. Walker, Director, Finance Department Randolph Marks, Assistant Director, CommunitylEconomic Development Miguell Del Campillo, Director, Housing Division Steven K. Cumbo, Housing Specialist . HIGHLIGHTS OF REPORTS PREPARED BY CASTERLINE ASSOCIATES, P.C. FOR THE MIAMI BEACH HOUSING AUTHORITY Report: Phase I - Observations & Recommendations Regarding the Internal Control Structure of Section 8 Department The report states that: . The purpose of this review was to determine if adequate internal controls are in place for the Section 8 Program at MBHA. . The review was, to some extent, prompted by allegations of impropriety being leveled by a MBHA housing inspector. These allegations include the overstatement of contract rents in return for kick-backs, in the form of cash and gifts, to key members of the MBHA staff, threats on the life of this inspector from landlords intended to discourage investigating into improprieties, steering of residents to certain landlords and falsification ofHQS inspection results in return for bribes. . The most significant discovery made involves the lack of adequate written procedures in virtually every area of the Section 8 program examined. . Due to the absence of adequate internal controls in the setting of contract rents to owners, it is very difficult to effectively refute the charges of impropriety being made. Compounding the problem is thefact that these controls have been absent for a significant but undetermined period of time. The report recommends that: . For the next audit MBHA engage a well-known form with solid national reputation. In addition, the firm chosen to conduct the audit should be advised that they would be conducting a particularly high-risk audit. . MBHA implement a policy that will ensure that an audit firm will not be retained for more than three consecutive years. . The chief recommendation arising from this review involves advising the Office of the Inspector General (HUD) of the allegations and the long-standing internal control issues. Since the allegations being made cannot be refuted, due to the substantial internal control flaws, an outside entity should be brought in to conduct an in-depth review. . If it can be established by an outside group, such as the Inspector General's Office, that the allegations are not true, steps should be taken to repair the damage that has been done. Report: Phase II - Observations & Recommendations Regarding the Internal Control Structure of the Accounting Department The report states that: . The MBHA has very significant flaws in its internal control structure. This is the case in every area of the Authority evaluated. This combined with projected operating deficits, a new comptroller, new computer system, a significant development project and a HUD mandate to convert to Generally, Accepted Accounting Principles has brought the Authority's leadership to a significant crossroad. The repercussions of actions taken now will, without a doubt, be felt for many years to come. Budgetine Public Housing . The budgets prepared by MBHA are not very meaningful. Technical / mathematical errors and omissions were found. . Budgets should be, if possible, based on actual expenditures. Therefore, it is vital that transactions be recorded in an accurate and detailed manner. Budget forms in a Lotus 123 Spreadsheet have been provided. Section 8 . Budget forms in a Lotus 123 Spreadsheet have been provided. This forms will perform mathematical calculations automatically. Budget Monitoring . The Authority has not been developing meaningful budgets for the expenditures being made with Section 8 and Public Housing funds. No formal procedures exist that facilitate any degree of budget monitoring. . The Authority should develop budgets for all programs in addition to a consolidated budget. Once produced, budgets should be monitored. Cost Allocation . The Authority has no written allocation plan that provides an equitable basis for allocating the costs incurred by the Authority's central administrative offices to the various programs it administers. . As the Authority's accounting system develops and can afford greater sophistication, the adoption of a mixed basis allocation system is advised. Cash & Check Stocks . The MBHA has significant internal control deficiencies. . Many of the cash control problems could be corrected by constructing a lockable closet in the comptroller's .office and purchasing a cash register and secure drop-box. When not in use, all signature plates should be kept in the safe and the safe should be locked at all times. Blank check stocks should be moved to the secure closet. . It should be mentioned that, if the MBHA wishes to have the best internal controls possible, cash payments for rent should be forbidden and the Authority should cash no resident checks. Purchasinf: and Accounts Payable . The MBHA has significant internal control deficiencies. . Once approved, a copy of all purchase orders should be sent to the vendor, accounting and the acquiring department. The accounting department should maintain a file of all purchase orders. The receiving function should be centralized. A receiving log should be maintained at the central receiving point. Fixed Assets . The inventory of fixed assets is being maintained using a somewhat antiquated index card system. . It is recommended that the MBHA immediately begin to implement conversion steps to move Fixed Assets toward Generally Accepted Accounting Principles in accordance with new requirements for PHAs. Materials Inventory . In the past, obsolete or otherwise unusable materials were sold in bulk. 1bis transaction was not properly accounted for. . Whenever materials are sold or disposed of in any way, this activity should be thoroughly documented. It has been some time since obsolete or otherwise unusable materials have been disposed of. These items have been steadily piling up in Authority storage space. It should be noted that storage space is at a premium at the Authority. Standard O'perating Procedures . The MBHA must develop updated Standard Operating Procedures for all Finance functions including Tenant Accounting, Fixed Assets, Accounts Payable, Materials Inventory, Payroll, General Ledger, Budgeting, and Financial Reporting. This task is particularly important now that the MBHA has purchased a new computer system. . The MBHA should develop a policies and standard operating procedures manual accessible to all Finance Department personnel. Report: Inspection Report - Summary of Findings . The are significant flaws in the practices of the MBHA inspection staff. The MBHA inspectors are passing units that do not meet HQS standards. However, no patterns were found in the inspection data that indicate anything other than training and procedural deficiencies. . Immediate and decisive correction action should be taken by the MBHA to improve the quality ofHQS inspections. Report: Rent Comparability Study - Summary of Findings . One significant deficiency noted in the Section 8 Department is the absence of adequate rent comparability procedures and documentation. Some rents exceeded the comparability restrictions set by HUD's comparability guidelines, and overpayments have been incurred. . The MBHA faces',significant compliance issues in the area of rent comparability. The Authority should begin to address these issues by ensuring that rent rolls are collected when processing new tenants and whenever tenants are re-certified. These rent rolls must be examined to ensure that comparability guidelines are met. The HUD field office and the Office of the Inspector General are aware of the study that has been conducted and the results produced. It is recommended that additional guidance be sought from these offices, as to the most appropiate way to reach full compliance. . . .=r..,,\~e..'4rQt::" tllll"\ , < I-,oll.! * :: ~ 1111111 l ~Q '? '~-4N :lE\j~'.9 U.S. Department of Housing and Urban Development Florida State Office, Southeast/Caribbean 909 SE First Avenue, Room 500 Miami, FL 33131-3028 June 22, 2000 Mr, Charles W, Burkett, IV Chairperson Board of Commissioners Housing Authority of the City of Miami Beach 801 Alton Road, Suite 2 Miami Beach, FL 33139 Dear Mr, Burkett: An In-Depth Consolidated Management Review (CMR) of the Housing Authority of ,he City of Miami Beach (HACMB) was completed during the month of Februarj 2000. The Revie.v was conducted by staff from the Florida State Office, Office of Public Housing (OPH), The assessment included a Management Operations Review, a Financial Controis Review, a Maintenance Operations Review, a Public Housing Ocoupancy Audit anc a Section 8 Management Re'/Iew The major purposes of the CMR are to ensure that the HAC~IB is fumishing deoent. safe and sanitary housing to lower income families: carrying out statutorj, regulatcr; and contractual obligations; properly managing Federal funds without waste or fraud: and adhering :0 pregram requirements implementing civil rights laws, In addition to the CMR a Public Housing Management Assessment Program (Pi-'MP.P) comfirmatory Review was performed. The purpose of the PHMAP Comfirmatcr; Review was to assess the management performance of tr,e HACMB by verifying data certified by the HACM8 and the accuracy of data derived from HUD files for the fiscal year ending "ere 30,1999. Based on the Confirmatory Review the HACMB's total weighted PHMAP score for tr,e assessment of its fiscai year ending June 30, 1999, is 87,5 percent. A total weighted PhvlA? score of less than 90 percent but not less than 60 percent shall be designated' as a standard performer, As a result of its total weighted PHMAP score, the HACMB was recognized as a stardard performer, A scoring report is attached to explain the score fer each Indicator (and each Component within the Indicator, if applicable) and the total PHMAP score based on the weighted average of the PHMAP Indicator scores, As you know PHMAP is no Icnger used to measere the performance of public housing authorities. Beginnin9 with the HACMB's Fiscal Year Ending (FYE) June 30,1999, the Department assessed the Authority under the Departrlent's new Pubiic Hcusing Assessment System (PHAS), Previously issued scores were considered advisori. Once 'he ='-ijO.,S is fully implemented, the HACMB will be fcrmally assessed under this sJs;em, If ;he i-'AC\18 Talis ,0 adequately address public housing program Findings identified in this Reoort, it will be considered an "at risk" Housing Authority under PHAS and senctions may be impose::. The HACMB shall be required to submit an Improvement Plan (iP\ to correo; the ceficiency for the following Indicator if the deficiency has not already been correctec:, Indicator Grade Indicator 5, Annual Inspection of Units and Systems F ~ ~ 2 The CMR resulted in a total of thirty (30) Findings, A Finding is a deficiency that represents a violation of statutory or regulatory requirements, for which sanctions or other corrective actions are authorized and which, therefore, necessitates immediate remedial action, A summar; of the number of Findings is as follows: Function Number of FindinGS Management Operations Review Financiai Controls Review Maintenance Operations Review Public Housing Occupancy Audit Section 8 Management Review 2 2 2 10 14 In addition, there are ten (10) Observations with Recommendations discuss ad in this Report. An Observation may be a general comment, or may be a deficiency in program performance, which does not result in a vioiation of a statutory or regulator; requirement, but which could, if not addressed, result later in a Finding, The primary purposes of this Report are to furnish the HACMB with a copy of the Findings that resulted from the assessment and to provide Corrective Actions for improvement. Part I - Introduction, is intended to provide a general overview of the type and scope of the assessment. Part II refiects the results of the Management Operations Review, Financial Controls Review, Maintenance Operations Review, Public Housing Occupancy Audit and Section 8 Management Review, Part III refiects Observations, Part VI contains the results of the PHMAP Confirmatory Review, The Findings, Observations and other deficiencies cited in this report were discussed at a close-out meeting with you, the former Executive Director, the Interim Executive Director and HACMB key staff on February 18, 2000, In addition to the response to the failed PHMAP Indicator (Indicator #5 - Improvement Plan) noted above, the HACMB must send a written response to this Office, within thirty (30) days identifying deficiencies that have been addressed since the date of the Review and its plans for addressing any outstanding deficiencies that are identified in the Report. Based on the Review, the HACMB would have failed the Section Eight Management Assessment Program (SEMAP) evaluation and be designated a troubled PHA if the SEMAP had been fully implemented at the time of the Review, The HACMB's overall performance of the administrative duties mandated under the Section 8 program requirements was evaluated to be EXTREMELY POOR (see Section 8 Management Review), In fact, the Findings from the Review are serious enough for the Department to declare the HACMB in breach of its obligations under the Section 8 Annual Contributions Contract (ACC) and remove administration of the program from the control of the HACMB, The Department does not intend to exercise this righI under the ACC at this time, However, effective immediately, the HACMB is hereby advised that it will be under a probationary status for a period of one-year from the date of this letter, As a condition of this status, the HACMB must enter into a third party agreement/contract with a well performing Housing Authority, organization or firm for the administration of its Section 8 programs, If the HACMB fails to improve its administration of the program within the one-year probationar; period, HUD will reconsider its options, The Section 8 Certificate and Voucher programs must be operated in a manner that provides for the well being of assisted tenants including rents that are not excessive priced and units that are safe, decent and sanitar;, We look fOrNard to the resolution of all of the identified deficiencies and offer our assistance. -' ^ 3 This Office acknowledges that in the last few years there have been several changes in the management of the HACMB, However, because of the sericusness of the deficiencies refiected in the enclosed reports we are requesting that the entire Board teke an active part in resolving the noted deficiencies, It is the Board of Commissioners responsibility to ensure resolution of ail Findings and deficiencies contained in tr,is Report. Lastly, the attached Report may contain information such as names, unit numbers and addresses of residents that may be of a personal and conficential nature thet should not be re'/eeled except in the course of official business, This Office would like to thank the HACrv1B's staff for the cooperation and coul1esies extended to the HUD Review Team during the course of the Review. Should you have any questions or comments regarding this Report, please contact Phil Aldridge, Division Director, at (305) 536-4443, extension 2291, or you may contact me at extension 2275, Very sincerely yours, i~)/ .../ '" y .' I ~~\~'C0--L.L'yU7] Karen Cato- Turner Director Office of Public Housing .~. -6-- Enclosures cc: Ail Members of the HACMB Board of Commissioners Rolando Barrios, Interim Executive Director, HACMB Jose Cintron, State Coordinator, Florida State Office Ferdinand Juluke, Director, Multifamily Housing, Jacksonville Area Office , 5 HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH IN-DEPTH CONSOLIDATED MANAGEMENT REVIEW PART 1: INTRODUCTION An assessment of the Housing Authority of the City of Miami Beach (HACMB) was cOn"cieted on February 3, 2000, by staff from the Florida State Office, Office of Public Housing (OPH), The assessment consisted of an analysis and an examination of the HAC~18's ooerations throucn an In- Depth Consolidated Management Review (CMR) which covered 'management.. general maintenance and occupancy operations of the HAC~IB, The major objectives of an assessment such as this are to ensure that a PHA is providing decent. safe and sanitary housing to lower income families: carr;ing out s;atutor;, regulator; and contractual obligations; properly managing Federal funds without waste or fraud; and adhenng to program requirements implementing civil rights laws, The HACMB ownS and manages one site which consists of 200 conventional public housing units (housing elderly tenants), Also, the HACMB administers approximately 2116 Section 8 Certificates, 256 Section 8 Vouchers and 131 Section 8 Moderate Rehabilitation units, Additionally, the HACMB owns and manages a 200 unit Section 8 New Construction project, a 16 unit building housing mostly Seotion 8 tenants and the HA is the Contract Administrator for three Section 8 Substantial Rehabilitation projects with approximately 194 units, This Review does not include the Section 8 New Construction nor the Section 8 Substantial Rehabilitation projects, Those programs are under the jurisdiction of HUD's Office of Multifamily Housing, In monitoring the HACMB's performance, the OPH also identified technical assistance needs of the HACMB and provided assistance where possible, Technical assistance was provided to HACMB staff in the following areas: (1) Proper methods for determining rent reasonableness, (2) Recommendations on improving and maintaining tenant fries, (3) Recommendations for improving occupancy standards, (4) Proper method for calculating the Housing Choice Voucher ret'lt formula under the Section 8 Merger Rule, (5) Technical assistance was given to the Accounting Department and the Section 8 Departments on the entry of correct project data into the new computer system. (6) Technical assistance was given to the HACMB to help it utilize its Section 8 annual funding more efficiently, This included instructions on the use of the reconciled HAP register to determine whether edditional funds are available for leasing additional units, The Review Team furnished worksheets that give future funding and lease-up scenarios based upon current funding data and inflation factors, Each Finding is discussed in detail within Part II of this Repcrt, A Finding is a ceficiency that represents a violation of statutor; or regulator; requiremems, for which sanctions or other corrective actions are authorized, and which, therefore, necessitates Immediate remedial action, Obser/atlcns are discussed in Part III of this Report, An Obser/ation may be a general comment. or may be a deficiency in program performance, which does not result in a violation of a statutor; or regulatcr; requirement, but which could, if not addressed, result leter in a Finding. 6 The Review Team acknowledges that in the last few years tr,ere have been several changes in the management of the HACMB. However, it is the Board of Commissioners responsibility to ensure resolution of all Findings and deficiencies contained in this Report. 1 '.. 7 HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH IN-DEPTH CONSOLIDATED MANAGEMENT REVIEW PART II: MANAGEMENT OPERATIONS REVIEW FINANCIAL CONTROLS REVIEW MAINTENANCE OPERATIONS REVIEW PUBLIC HOUSING OCCUPANCY AUDIT SECTION 8 MANAGMENT REVIEW The deficiencies that follow were found during the assessment and require corrective actions. These deficiencies are deviations from various Federal regulations, Handbooks, the Consolidated Annual Contribution Contract (CACC) and other requirements as indicated. A. MANAGEMENT OPERATIONS REVIEW FindinQ # 1: The HACMB Incorrectly Certified To Several PHMAP Indicators and Did Not Have Adequate Records To Support Data For Other Indicators. The HACMB incorrectly certified or did not have adequate records to support the data submitted for the following PHMAP Indicators; (1) Indicator #1: Vacancy Rate and Unit Turnaround For Component #1, the HACMB certified that the total number of actual vacancy days was 991, The HUD Review Team verified and confirmed that the correct total number of actual vacancy days was 963, When calculating vacancy days, in some instances, the HACMB had miscalculated the total number of vacancy days by including the actual day that the tenant moved out. Based on the HACMB's Certification, its actual vacancy rate and its adjusted vacancy rate were the same, 1,38 percent. However, based on data confirmed by the Review Team, the Actual Vacancy Rate and the adjusted vacancy rate were 1,32 percent. Since both percentages were less than 3 percent, the grade of "A" was confirmed. For Component #2, the HACMB certified that it had an adequatg system to track unit tum around time, The Review Team found that the HACMB did not have a tracking system in place to determine the unit turnaround time, Since the HACMB received a grade of 'A" for Component #1, vacancy rate, the HA,CMB was not scored for this Component. Consequently, this situation would not have resulted in a change in the grade, (2) Indicator #3: Rents Uncollected The HACMB certified that it had no dweiling rent owed by residents in possession at the beginning of the assessed fiscal year (FY), carried forward from the previous FY: dwelling rents billed during the FY being assessed was $428,080: and dwelling rents collected during the FY being assessed was $428,080, Based on the reported data, the percentage of dwelling rents uncollected was 0,0 percent of total dwelling rents to be collected, The Review Team's confirmation of Indicator #3 included the verification of rent registers, the general ledger, financial statements, the TAR reports and the HACMB's working papers, In addition, these numbers were discussed with key members of the HACMB's staff, Based on the assessment, the Review Team confirmed that the dwelling rent owed by residents in possession at the beginning of the assessed fiscal year, carried forward from the previous FY was $0: dwelling rents billed during the FY being assessed were $429,915: and dwelling . 8 rents collected during the FY being assessed were 5428,226, The amounts cf ,:;weliing rent billed during the FY being assessed certified by the HAC);IB were incorrectly stated. Based an the confirmed data, the correct percentage of dwelling rents uncollected was 0,39 cercem of total dwelling rents to be collected and the 'NPBI-A received a ccnfirmed grade of "A." The discrepancy had no effect on the overall Grade for the indicator, (3) Indicator #4: Work Orders Under Component #2, a PHA is entitled to receive a grade of "A" if all non-emergenc, work orders are completed within an average of 25 calencar days, The HACMB certifiec that it had a total of 961 non-emergency work orders and that the total number of calencar days that it took to complete them was 1300, This averages to 1,35 days for the HAC);IB to complete non-emergency work orders, However, the Review Team found that the HACMB had a total of 1221 non-emergenc, work orders and that the total number of calendar days that it took to complete them was 1300, This averages to 1,06 days for the HACMB to complete non-emergency work orders, The discrepancy had no effect on the overall Grade for the Indicator and a Grade of ",:',' was confirmed, (4) Indicator #5: Annuallnsoection of Units and Svstems For Component #1, the HA,CMB certified that it had inspected 100 percent of its un,:s; that 133 of its 200 units, which it inspected, met local ccdes or HQS: and it completed all repairs on units where necessary for local code or HQS comeliance during the inspection, issued work orders for the repairs, or referred the deficiencies to the current year's or the fcllowing year's modernization program. The Review Team confirmed the grade of an 'OF" based on the following: The inspection form utilized by the HACMB for unit inspections is not equivalent to HUD's Housing Quality (HQS) Inspection form, The inspection form used by the HACMB only identified general repairs, It did not designate whether the repairs are HQS violations, life threatening or non-HQS deficiencies, The present inspection form is limited to only 3 lines for each unit the HACMB inspects. The HACMB could not show evidence that HQS inspections had been performed on all units, and On the units which it inspected, the HACMB could not provide evidence that repairs had been completed during the inspections, work orders were issued or that the repairs were referred to modernization, For Component #2, the HACMB certified that it had inspected 100 percent of its bUilcings and sites, according to its ,vlaintenance Plan, Also, the hACMB certified that its inspec:ions included performing the required maintenance on structures and systems, The Review Team found that the HACMB did not have a written Maintenance Plan :cr Its FYE June 30, 1999. Additionally, the HACMB could not provide the Review Team with any documentation showing that an annual inspection of systems had been performed, Consequently, the Review Team confirmed a grade of "F." 9 (5) Indicator #6: Financial Manaqement A PHA is entitled to receive a Grade of "A" if it has cash reser/es a'/allable fcr operations which are greater than or equal to 15 percent cf tetai actual routine ~x~encitur-=s ~r the ?~A has cash reser/es of 33 million or more. The HACMB certified that its cash reserves were 3624,176, The Re'/iew Tea~ foune :~at this amount was actually the operating reser/e enoing balaroe, The cash reser/es reccrted for PHMAP should have been adjusted for short-term accounts receivable and payaele. Based on the HACMB's books and records, the Re'/iew Teem computed the cash rese"/e figure for PHMAP purposes to be 3143,212, The routine exeene:iture figure was foune: :c be $775,178, Consequently, the cash reser/es were 18,5 percent IS143,2'2 e:ivie:ec: 'oy $775,178), Based on the results of the Review, the HACf'vIB's books and records. operer:ng reserves were 18,5 percent which resultee: in a grae:e of ",;, , The effect of the error cic ~ct change the overall Grade for this Indicator, However, the Review Team has serious concerns about the emounts shown cr, the HACMB's low income Public Housing books and records, The cash reser/e amc~nt included inter-fund acoounts receivable and payable amounts ~f 3'..15.351 arc 323.3:-' respectively, The acoounts payable amount was a plugged figure to balance wit,: the Balance Sheet. In addition, the Accounts Payable Revolving LJan amount showec a balance of $456,098,39, ,;Iso, approximately S251 ,465 in amounts payable tc three c:her funds were written off during the year, While reviewing the worksheets utilized by the HACMB to reconcile the revolving loan, it appeared to the Review Team that the cash accounts for the HACMB's funds were reconciled but the offsetting entries for the inter-fund and revolving loan acoounts were not, thus distorting these general ledger accounts, The issue of using a plugged number to balance the balance sheet indicates serious acoounting problems which are exacerbatec 'oy the fact that the HACMB does not have a self-balancing set of accounts for each of its program fund groups, It appears that the HACMB is subsidizing its low income Public Housing operations frem other sources, This may indicate that this program is not ooerating efficiently, To ens~re future financial solvency, the low income Public Housing program should operate on its cwn Corrective Actions Required for Indicators Number 1, 3, 4. 5 and 6. Federal Regulations at 24 CFR Section 901,100(b)(2\, rec:uired PCiAs to malr,:air documentation for three years verifying all certified Indicators fcr riUD on-site review. In addition, the Executive Director and the Chairperson certlfiee that the information reporrec is true and accurate, The Regulations at 24 CFR Secticn 901.1 GC(J)(5) s:,:::ec as :CI:C'}.S: "A PCiA that cannot provide justifying documentation tc HUD :unng tr,e ccrduct:: " Confirmator; Review. or other verification review(s), for any ir.dicawr(s) or Component(s), certified to, shall receive a failing grade in that Indicator(s) or Component(s), and its overall PHMAP score shall be lowered.' The HACf'v1B must maintain complete and accurate books and recores to support thec;:;:a submitted to HUD. While the June 30, 1999, PHMAP gr;:;de is the last ~nder PCif'vIAP 're HACMB is now required to submit a certification fcr the new P~blic Housing Assessccent System (PHAS). The failure to maintain and submit correct data may result In the HAC,\tB receiving incorrect PHAS grades. The H)l.,C"-IB must provlce trairlrg to its emolcyees ard install ae:equate systems to collect and repcrt correct c~ata to riUD, ,. 10 The actions required to correct these deficiencies are set out in the PHMAP Confirmatory Review Report which is attached as Part IV. For brevity, the corrective actions were not repeated in this document. Findino # 2: Certain Services Were Not Properly Procured, The HACMB improperly procured certain professional services, The Review Team examined documentation for a sample of the HACMB's procurement actions for the follcwing services: auditing, consulting and other professional services to determine whether these ser/ices were obtained competitively and in compliance with HUD requirements, Regulations at 24 CFR Section 85,36 (c) provide that all "procurement transactions will be conducted in a manner providing full and open competition, Also, in accordance with 24 CFR Section 85,36(d)(3) procurement by competitive proposals is the method to be used when conditions are not appropriate for the use of sealed bids, Paragraph 4-18, HUD Handbook 7460,8 REV-1, Procurement Handbook for Public Housing Agencies and Indian Housing Authorities, states that "Professional services_ are generally not appropriate for the sealed bidding methcd, but should be handled using competitive proposals _," The Review Team identified the following weaknesses in the procurement of the ser/ices identified below: Computer Software In March of 1999, the HACMB issued an RFP for Accounting and Program Software (Software), The HACMB selected a vendor as the most responsive bidder for the new software package, The initial bid was for approximately $149,000, The price was adjusted upward to $160,000 to include an amendment for the property account for the New Construction project, Rebecca Towers North, The HACMB selectec a lis. of the three most responsive bidders. However, the reasons for the selection of the vendors for this list was not apparent. At least one other possible responsive bid was found that did not make the list. The Review Team found that t:-No bids for $35,000 and $70,800 were submitted. The vendor that bid $35,000 was selected as number one of the three most responsive and the other vendor was selected as number three of the most responsive bidders, ,. The vendors on the most responsive bidders list were rated based on the selection criteria outlined in the RFP, The selection committee included the Operations and Administrative Officers. Both reviewers on the selection committee gave very low totals and Component scores to t:-No of the three bidders. One bidder received a total of 0 points from one member of the selection committee and only 13 out of a total of 130 points from another member, In addition, the other bidder also received very low point totals, The winning proposal received over 100 points from each membe'. The reasons for the great disparity in the scores were not apparent to the Review Team. Although the selection criteria in the RFP offered mucn detail, no notes, other than the actual scores were found to support the selection, The t:-No non-winning bidders received zero points for the "Cost Effectiveness" factor when one bid was over $100,000 less than the winning bid. One factor contributing to the great difference in cost was the fact thar the HACMB had already purchased a General Ledger and Accounts Payable module from the low bidder, and therefore, these modules were not part of their bid. Because these were responsive bidders and this was not an Architectural or Engineering procurement, Regulations at 24 CFR Section 85,36(d)(3)(v) require the cost of the proposal to be considered as a selection factor. "rice was evidently not considered, 1 1 , Legal Services Subsequent to the completion of the Field Office Review, HUD's Office of Insoectcr Generel called to our attention a situation invoivlng the solicitetion end selec:ion of tr,ree legal serllces vendors, The HACMB advertisec for legel sen/lces, Three venccrs res;:cncec by sencing proposals for different types of legal services, The HACMB proposeC that contracts be awarced to all three vendors The solicitation was non-competitive sinca contracts were being awarcec to each vendor who responded to the solic:tation, Since the solicitation was non competitl'/e, thiS Offica decided to perform a pre-award review In accordance with Regulations at 24 CF? Section 85,36(d)(4)(iii), This Office directed the HACMB to not execute any of the three ccntracts, unless and until, a pre award review had been performed and written apcroval was receivec from this Office, The HACMB's Board of Commissioners passed resclutions aocrovlng awards to two cf the three vendors, By a letter dated May 24, 2000, this Office advisee the HACMB that no Federal funds could be used to finance the services provided under the contract awerds The immediate need for these seNices did not appear to be an urgent matter anc It was the understanding of this Office that the two firms were already representing the HACMB under previous arrangements, Also, the HAC~1B's present General Counsel, Is not expected to leave his pcsltion until September 1, 2000. This Office re'/Iewed the material subrr,iI:ed by the HAC,\18 and was unable to approve the award of any of these three contracts, The advertisement published In the "Miami Daily Business Review" cid not fully advise prospective vendors of the seNlces solicited, The edvertisament statec that the :HAC\IB'is seeking litigation and occasional general legal services," The advertisement should have been mcre explicit as to the types of seNlces required, Additionally, Request for Proposals No, 4-2000 (RFP) is equally vague, Section I of the RFP mereiy provides for "legal seNices Including litigation in state and federal court." Section IV of the RFP provided that "The seNlces to be providec shall require the firm to: Represent the Agency in all actions brought in state or federal court involving the Authority, Provide legal seNices to the Housing Authority as recuested by the Commissioners, Executive Director and General Counsel." The Fee Proposai Page provides for fees for "General Legal SeNices" and "General Litigation Ser/ices." It should be noted, however, that the ,~rcposed contracts with the three vendors give a much more explicit statement of the ser/ices to be performed, The advertisement published in the "Miami Daily Business Review" appeared to be unduly restrictive, The advertisement required that "Applicants must have performed seNlces for governmental sectors, including housing authority experience for at .~east 20 years, or have substantial litigation experience representing the disabled or elderly regarding housing Issues," Section II of the Request for Proposals No, 4-2000 is even mere restnctive, It requires the ser/ices to have been "continuous," The rec;uirement for 20 years of continuous experience representing governmental sectors appears to be very restrictive and may unccly restrict other,'/Ise qualified vendors, Regulations at 24 CFR Section 85.36(c) provide that "All prccurement transacticns will be conducted In a manner providing full and open competition consistent ','/ith the stancards cf Section 85.36, Some of the situations considered to be restrictive of competition include but are "ct limitee to:" "(Ii) Requinng unnecessar/ exserience _." Addlticnally, the alternative provision recuiring advocacy experience In representing the disabled or elderly appears :c be irrelevent. The HAC,\tIB may be currently or In the future required to defend against these types of actions, Consequently, experience In defending against these cases may be e relevant factor. Additionally, while senior members of the three firms submitting proposels apparently met the experience requirements, other members of the firms that are proposed to perform legal work apparently did not. In a major market such as Miami with many thousands cf lawyers, It is believec that adequate solicitation would have produced more then one proposel for each type of legal service, Regulations at 24 CFR Section 85,36(d)(3)(1) provice that "Reeuest for proccsals Will be publicized and identify all evaluaticn factors and their relative importance, "Section VII of the R,cP does not Icentlfy any evaluation factors or their relative importance. 12 The Proposal submitted by one vendor does not appear to be reseonsive. "7"he P,ceosal does not "Give the lecation of the office from which work is to be perfcrmed.' Additionaily. the =ee Proposal does not address "Expenses such as pre-approved tra'lel, and incidentals and other :csts associated with performing services," Also, the Proposal submitted by another vendor does not appear to be respcnsive, The Proposal does not address the Insurance Requirement. Additionally, the Fee Proposal dces not address "Expenses such as pre-approved travel, and incidentals and other ccsts asscciated 'Nith performing services," Based on information reported in the Proposals submitted by the three Rrms, each represents the City of North Miami. It is the understanding of this Office that the HAC,'vIB's Geneml Counsel is the City Attorney for the City of North Miami. Therefore, to avoid an appearanoe of conflict the HACMB's Contracting Officer should conduct any new solicitations for legal ser/ices, When the non-competitive proposal method of prccurement is used Regulation at 2~ CFR Section 85(d)(4)(ii) provide a "Cost analysis, i,e" verifying the proposed cost data, the projecticns of the data, and the evaluation of the specific elements of costs and profits, is required," The material received from the HACMB did not contain a cost analysis. Subsequent to a meeting between staff from this Office and HACMB Officials, the HAC~,IB is in the process of re-advertising for these legal services, Based on bur review of the advertise!':',ent in the June 18, 2000, edition of the Miami Herald we have concerns regarding the sccpe cfNork. The advertisement in our opinion is very general and does not advise prospective vendors of the types of litigation and other legal services needed, The advertisement is for "litigation and occasional general legal services," As we understand the prior proposed contracts, the ser/ices were Labor Law and other specific areas, Audit Services Prior to June 30, 1999, the HACMB had utilized the same Independent Auditor (!PA) for several years. Engagement letters were executed annually for the audit services, There was no solicitation from other qualified vendors, As indicated above, all procurement actions are required by the Regulations to be competitively procured, For its June 30, 1999 audit the HACMB did competitively procu.,e its audit services, The Review Team found that the HACMB had followed proper procedures for securing the June 30, 1999, audit and that the file contained appropriate documentation suPPOr:in9 the Request for Proposals (RFP) and solicitation in compliance with 24 CFR Secticn 85,36, The HACMB prepared and advertised an RFP for supplemental audit services in AuguSl of 1999, The advertisement was run in a local newspaper. Additionally, a direct solicitation was apparently sent to one vendor, Only one acceptable proposal was received by the HACMB. This proposal was from the vendor which was directly solicited, This vendor's original propcsal was for $138,000 which was negotiated down to about $98,000, Since only one proposal was receives, ,r,e non competitive proposal method at 24 CFR Section 85,36(d)(4) applies to this situmion, The Review Team has concerns regarding the advertising media, It believes that additional advertising in a media targeted to the industry would likely have produced more proposals and, therefore, 'Nould have made this RFP competitive, Consultant The Review Team found a one page RfP for a fixed-price proposel for the faoilitation ,~f a goal setting workshop, The only evidenca whicr, was found of the aotuai soiicitetion was a procosal by one vendor (Vendor A) and several invoices from anothe, vendor (Ven'jcr 3) totaling more :~,an $30,000, In addition, a contract for this ~jpe of service was located with a fixed price of $8,3~O, However, the contract was signed and dated Maroh 22, 1999, but the in'/oices were pale prior to 13 1999. The one page RFP denoted September 01 1998 as the target date, Many of the invoices for Vendor B were for consulting serJices, however, the ac:ual delivered prcduct could net always be determined as the invoices did not have appropriate detail, nor did they agree with the fixec-Grice contract. Air Conditioning Units Please refer to Finding Number 5, which found Imprcoer procuremec,t of air conditicning units under the Comprehensive Improvement ,""ssistance Program (ClAP), Corrective Action Required: All of the HACMB's procurement acticns must be in compliance with the Regulations at 24 CFR Section 85,36 and its own procurement policy and procedures, Addilional, guidanca may be obtained by referring to HUO Handbook 7460,8 REV-1, Prccurement Handbcok for Public Hc~sing Agencies and Indian Housing Authorities, This Handbock provides a great deal of informaticn on properly handling procurement actions, The HACMB must obtain copies cf 2J. CF" Section 8536 and HL;O :-'andbook 7J.60.8 ='::V- 1. The HACivtB's Contracting Officer and other appropriate staff mUSl read them and become familiar with their contents, Additionally, as soon as possitle, the HACivl6 m~st send its Contrac:ing Officer and other appropriate staff to procurement training, In compliance with regulations at 24 CFR Section 85,36(b)(9), the HACMB must maintain records that adequately detail the significant history of a procurement. These records must indude, but are not necessarily limited to the following: rationale lor tr,e method 01 orocuremem, selecticn of contract type, contractor selection or rejection and the basis for the contract price, Contract or crice analysis must be performed for all procurement actions as required by Regulations et 24 CFR Section 85,36(1), The HACMB should maintain records for all contracts which cleerly cutline the services and goods purchased, Invoices must clearly relete to the terms of the ccntracts end be in sufficient detail to determine reasonableness of cost. B. FINANCIAL CONTROLS REVIEW As a part of the Re'/iew, the Review Team conducted en examinition to determine whether the HACMB's financial controis met the requirements of 24 CFR Section 85,20, Standards for Financial ivlanagement Systems, The Re'/Iew Team reviewed the following documents and intemal controls: the general ledger; the trial balance and subsidiery backup analyses: bank statements and deposits records; record keeping; records 01 collateral, including third party custodial agreements; internal controls, including segregation 01 duties and collection procedures fcr cash end accounts receivable: procurement of services; budget and year-end statement reviews fer the low income Public Housing progrem and the Section 8 Certificate end Voucher programs: allocaticns 01 ccsts; Section 8 rents and file reviews for HAP Ceterminations and financ'al dccumentation; and Performance Funding System procedures and reviews. The P,eview Team examined the HACMB's financial statements end procedures for tr,e Section 8 program, Tr,e Team compared a sample 01 Housing Assistance Payments (HAP) amounts with the most recent HAP regis;er. No discrepar.cies were found, The Review Team has serious concerns regarding a depletion cf :he HACivlB's Sectien 8 administrative fee reserves, The Bank statements and financial records ir.dicate that the Section 8 administrative fee reserves dedined by more ,han 52 million doilars from ,",,~gust 1997 to June 1999, The Review Team conducted an anaiysis to determine the cause of tr,e declining reserves, 'ee Team found that the current HACivlB administrative salaries sharged to the Section 8 prcgram exceed the current administrative fees earned, This is partiaily caused by the hiring 01 additional i4 personnel. Also, it may be largely the result of the lack of a procer cest allccaticn met~cc as discussed in Finding number 3 below. At the current rate of expencirure, the admiristrat:'/s 'ee reserves will be depleted in a few years, While reviewing Acoounts Payabie, the Re'Jiew Team fcund thaI the i-",.lCe.IBs oay'rg fcr several grants, special prcgrams and expense items from the acmimstra:ive fee reser/es, Sc~e cf these expenses are shawn below: (1) The HACMB has paid a total of about S935,569,72 for the [anc designated fer the site cf a Single Parent Resource Center, (2) The HACMB contracts with the City through annual Inter-local Agreemerts, The an-,cur,t of the latest contract was in excess of 5200,000, (3) The HACMB pays for insurance ard maintenance in'Jol\T.g the JOKeeO of ss'/srai vacant lots owned by the HACMB. This includes the 17'" Street acouisi!icn fcrNnicr. it also has paid large costs for architectural fees, although these costs accear tcca'/e been paid mainly from Section 8 New Construction funds, (4) The costs of several lots owned by the HAC~IB ha'/e, a, least aarliaiiy. !::een '~ndec frcm the Section 8 administrative fee reser/e. This includes payment in Septem!::er 1998 for a cashier's check in the amount of 8199,473,23 for the 3" Strse, site scouisition. (5) The HACMB has approved five grants to Not-for-Profits in the amcunt of S3G,CCC sach, It is questionable as to whether the HACMB oan document thaI the grants were pro'Jiced for housing related purposes, (6) The HACMB has made payment of questicnable se'/eranoe ar,d unemaioyn-en: :sce;1ts to a farmer employee, who was dischargec and, afterNards, paid aporoximareiy S8C,CCO far these benefits. Circumstances surrounding this pay~em are questicnabie, (7) The HACMB provides funding far a rental supplement program (RS;:O;, it is our understanding that is a program administered by the City of rvliami Beach, (8) The HACMB pays far a Family Self Sufficiency program (FSS), (9) The HACMB has miscellaneous expenses including a bus tCKen program which cast as much as 8500 a month, The Review Team found no formal budgets and cast controls far the FSS, ,RSP or the vacant lots, including the 17'" Street land targeted far the Single Parent Rescurce Center The HACMB was carrying the Single Parent Resource Center on its Section 3 books for S935,56~,72, The books showed a reoeivable in the amount of 8334,589,59 due from the Sec:ion 3 ~jew Construction program. However, at the time of the Review, the reimburseinent had not taken ,aiace, In the past, the Acoounting Department prepared the Section 8 budgets, However, the HACMB was under-leasing its Seotion 8 Certifioates and Vouchers and therefore rct utilizi~g its authorized funding efficiently Beoause of its failure to use the funds, HUD recaotured some of the funding that oould have been utilized to house mare families and, in turn, creete adcirional administrative fees. The reasons for the under-leasing appeared to be the lack of commurica;ic~ between the Aooounting and Seotion 8 Departments and a general ncisunderstandi~g of ;cew '0 maximize the utilization of Section 8 funds, This wes compounded by the fact tt',at :he '-,.1," regis:er did not tie-back to the accounting reoords in the computer sys:em, Onoe imclen-encee, the -ew oomputer system will have an integration between the Section 8 HAP and accounting moouies, Findinq #3 The HACMB's Accounting and Internal Control Procedures Are Not Adequate to Safeguard Federal Funds. At the time of the Review, the HACMB was ourrently in the precess of installing its ~ew Memory Lane oomputer accounting and program software package, However, ,n2 irs:ai[at'o~ ~ad not yet been oompleted, ,~ 15 For the HACMB's Fiscal Year Ended (FYE) June 30, 1999, the Review Team examined a sample ot deposits and other cash transactions, oasn and general ledger aocounts, iMal :alances, reoord keeping and collateral for funds on deoosit. Ti1e following weaknesses were founo: The Accounting System and Internal Controls Need Improvement The acoounting system utilized by the hACc/IS did not group eaoh fund into sesarate selt- balanoing cost oenters in the general ledger, Inter-fund balanoes in the general ledger had not teen reoonoiled, This created a problem with interpreting the finandal statements, For example, the Low Inoome Balance Sheet presented to hUD for June 30, 1999, Inoluded an inter-fund payaole jalanoe that was a "plugged" amount used to balanoe the debits and credits within that fund, however, it appeared, through a review of the aooountant's worksheets, that the revolving fund operating cash aooount was reconoiled timely, The Review Team has serious concerns about the amounts shown on the h,.l.,C\IS's low inoome Publio Housing books and records, The cash reserve amount included inter-func accounts reoeivable and payable amounts of $146,851 and 5238,511, respeotively, The Finanoe Director at the time indicated that the aooounts payable amount was a plugged figure to balance the Salenoe Sheet. In addition, the Acoounts Payable Revolving Loan amount showed a :aianoe of $456,098,39, Also, approximately $251,465 in amo~nts payable to three other funds were written off during the year, While reviewing the worksheets utilized by the HACMB to reconcile the revolving loan, it appeared to the Review Team that the cash accounts for the HACMB's :~nds were reconciled but the offsetting entries for the inter-fund and revolving loan accounts were ~et. thus distorting these general ledger accounts, Ihe issue ot using a plugged number to calance the balance sheet indicates serious accounting problems whioh are exacerbated by the fact thet the HACMB did not have a self-balancing set of acoounts for each of its program fund groups, Regulations at 24 CFR Seotion 85,20 (b )(2) provide that "Grantees and subgrantees must maintains records which adequately identify the source and application of funds provieed for financially assisted activities, These records must oontain information pertaining to grant or subgrant awards and authorizations, obligations, unocligated balances, assets, liabilitles~ cutlays or expenditures, and inoome." Regulations at 24 CFR Seotion 85,20(b)(3) provide that "Effeotive oontrol and aocountability must be maintained for all grant and subgrant cash, real and personal property, and Olh,er assets, Grantee and subgrantees must adequately safeguard all suoh property and must ass~re that it is used solely for authorized purposes,'" General Ledger Accounts Were Not Consistently Maintained Some ot the general ledger aocounts were not consistently maintained, For exan1ole, during the analysis of Accounts Payable registers, several exoenses were found trat '.vere crage: cirest!y against the operating reserve andlor sundry aooounts that should have teen charged :c a::ropr:a:e expense aooounts, The HACMB's Accounting Records Were Not Current Trial Balanoes, cash reoonoiliation and General Ledger postings were se'Jerai menths behind, Posting from subsidiary cash reoeipts and eisbursement leegers to the general ledger should be oompleted monthly, However, the Review Team could looate a fuil set ef reccr:1s only through the FYE June 30, 1999, The HACMB had recently implemented a new compu:er software paokage, The oonversion prooess including establishing proper balances within the sys:en1's new ohart of aocounts appears to be the main reason for the incomplete reoords, A conmcLt'ng :actor was the reoent termination of the Finance Direotor, Also, the HAC NIB was utilizing :emporari employees to enter baianoes and perform reoonoiliations The aocounting staff did not accear tc have suffioient training on the new system and their responsibilities were not cleany eefkec, '- 16 Budget Controls A system of cost encumbrances ar,c :~dget controls were not always utilized, T~e Review Team found several expenditures within a se:arate fune: chat were nCI b~dge(ed. This inciudec payments for the FSS, RSP and lhe '!acarlcts, The HACNIB was carrying the Single Parent Resource Center (Center) in its Section 3 ;;cccunts, Nics: oi the Centers costs had been directly charged against the Section a adminls,r;;::'. e fee reser/e, Also, exoenditures relating tc the development and upkeeo of the '\llichigan ,~.e.,ue lot. the Jefferson Street iot and the Third street site acquisition had been charged cirectly tc :ta Secticn a administrative fee account. In addition, a complete Section a Budget for HUD was -C' develooed since only Ihe ",UD estimate cf total required contributions was used, A stend;;': :udget is completed for the Low Ir,come prcgram, however, cost control measures were nct_::iized for this or any bueget. A proper cest Central Method includes a system to determine enc~c.orances ;;gainst budget iine items and an adequaIe system for distributing direct and indireet CCStS to the various funes. The HAC NIB hae:: not developed a proper cost allocation pi;;n 'cr indirect costs, Without a praper ane:: consistem allocation of expenses to appropriate cos, :eccers, it is nct possible to properly bueget ;;nd track oosts within funds, Regulations at 24 CFR Section as.2C (b)(4) provide that "Actual exoenditures or outlays must be compared with budgeted amounts ':r each grant or subgrant. Financl;;i inform;;tion must be related to performance or productivity C;;t;;, including the development of unit cost informaticn whenever appropriate or specifically require: To :he grant or subgrant agreement. " The HACMB Has Not Established a Written Cost Allocation Plan A consistent method for allocating ineirect costs was not being usee::, Also, a written Cost Allooation plan had not been estabiished as required by Office of Management and Budget (OMB) Circular A-a7, revised May 4, 1995, further amended August 29, 1997, The HACMB did not have a formal c:st allocation plan for allocating indirect costs to the proper funds, Also, in praotice, indirect sa;;;-'2S and costs were not being fainy ailocated to the appropriate cost centers, In addition, a bre;;kcown performed by a Consultant employed by the HACMB disclosed that oertain direct OOStS, s~c~ as direot benefits, may have been also improper:y olassified. This indicated a need for a struc:'_ce,j system for coding eireci costs as well as indiree: costs, Whiie reviewing Acoounts Payable, :~e Review Team noted that several costs that affeot Rebeooa Towers North and Rebecca Towers South such as indirect m;;intenance ch;;rges were: usually equally distributed between the rNo ccc;ects, Since they are of equal size, thiS ineicates that some consistency for the coding of charges :0 :r,e various cost centers, More recently the HACMB has startee :.'1e implementation of a simpie ",ethcd of:harging indirect salaries and costs using an alloca::cr l1ethod based upon direc: salaries, A Ccns~lt;;nl helped develop this allocation pian ,hat is 2 :2": of a ~ew agency-wice bucge:, T'1e new buoge' utilizes the allocation plan on a department ar ::Jrojec~ basis. However, the conversion of baiar.cas for the current software and new set of aCCCLr:s was not complete. Ccnsec;uently, a new general ledger had not been completed, The Re',e','; team found no app;;rent ineication, that the new allocation method was currently being praoery ~Ii[ized for ac:ual expentitures The HACMB Obtained Full Administrative Fees for Owned units. The HACrvlB owns a 16 unit aparcr:e-: buiieinc located at 211 Collins Avenue, Fifteen Section 8 tenants who are assisted by the "',:'::,v1B live Tn the 211 Collins ,;1,venue facilirj, Feeerai law at 42 USCA Section 1437f(g)(E) provioes :nat "The Secretary l1ay e::ecraasa the fee for units owned by a public housing agenc,! to re,'e:: reasonable costs of administration. ",UD h;;d determined that PHAs that rent their ownee _rits to Section a tenants are emitled to a reoucec .. 17 administrative fee of 3 percent. The Review Team found no indication that the HACiltlB used the reduced administrative fees, Corrective Action ReQuired: The first step the HACMS must take in properly implement bucget controls is to develop a written cost allocation plan and develop appropriate coeing within the parameters of the new accounting system, This is imperative for proper budget!ng, the impiementation of cost controls, encumbrances for each department and/or fund group. The current methodology for using direct payroll costs may be adequate inter-departmentally, however, the HACivlB must adopt a multioie allocation base method to properly allocate costs for the various feeerally funded projects, Complete budgets must be developed for all federally funded projects, A tentati'le current entity-wide budget with departmental cost centers and funded projects has been established, Building upon this budget. the HACMS must implement the new budget with the proper controls and cost allocations in the accounting records and the new software, At the time the Review Team completed its Review the Finance Directors position was vacant. However, it is understood that this position has now been filled. The HAG.'AB should expeditiously fill all other vacant accounting positions, if any, with qualified permanent employees, While it is sometimes necessary to use temporary personnel, the HACMB should hire a competent fully trained professional accounting staff, The accounting staff should be immediately thoroughly trained on the new software, A new set of Standard Operating Procedures (SOP) should be developed for accounting anc management staff to follow. These steps should help the HACMB develop a complete set of reconciled and up to cate records after ell relevant Information is entered into the accounting system. The HACMS must properiy show Its owned units In Column C of the calculation of administrative fees so that excessive Section 8 acministrative fees will not be collected, I ne HACMS must adjust Its acministrative fee calculation for the prior three years and reimburse the government for all overpayments for Its owned units. FindinQ #4: Excessive Salaries. Based on a Report of a wage and benefit comparability study performed by Parilla & Assooiates (Parilla) Issued In June 1999, salaries paid by the HACMB for some employees are excessive, Parilla surveyed the salaries and benefits of the City of COral Gables and PHAs In Miami-Dade, Sroward and Palm Beach Counties, Parilla also obtained data In a private sector survey of South Florida salaries and benefits, Not all positions were Inciuded In both sur/eys, Parllla concluded that of the HACMB's 47 employees the salaries of twenty-five employees exceeded the maximums of their salary ranges, OMB Circular A-87 Revised rvlay 4, 1995, as further amendee p.,ugust 28, 1997, establishes principles and standards for determining whether COStS are eiigible under Federal awards, Attachment A to OMB Circular A-87 requires that costs must be necessary and reasonable for proper and efficient performance and administration of Federal awarcs, itam 11(b) of Attachment 8 to OMS Circular A-S7, provides that "",compensation will be considerad reasonable to the extent that It Is comparable to that paid for similar work in the labor market in wt',ich the employing government competes for the kind of employees involved," Corrective action required: Salaries and benefits that exceed comparabie comoensation ~ald for similar work in the labor market in which the HACIV1B competes are not eligible to be paid from Federal grants, The HACMS must determine the salaries and benefits that are excessive and reimburse the HUD programs from non Federal awards. Excessive salaries paie in the future by the HACrvlB may not be paid from Federal awards, 1 8 C. MAINTENANCE OPERATIONS REVIEW Findino # 5: The HACMB Has Not Developed Operating Procedures for Performing Annual Unit and System Inspections, Presently, operating procedures have not been develcpec for the perfcr~ance of anr~ei ~nit and system inspections, Regulations at 24 CFR Sec:icn 902,30 require PHAs :0 report anr~aliv as a part of the PHAS on Management Indicator ;;:5 - ,"YA Annuai inspection of Units and Sys:ems, The HACMB has not developed as a part of the system inspections, a pre'/entive maintenance program, The method by which a PHAs performance .viii be evalualed has changed beginning .vith PHA's with fiscal years ending September 30, 1999, :his change includes a onange in the cr;teha for unit inspections, In prior years, PHA's certified thaI ~ousing I~nits were inscected in acccrcance with local code and/or Housing Ouali~1 Standards (whichever ;s more stringent), Beginnirg wltr, PHA's with fiscal years ending September 30, 1999, all housing units should be inspec:ec in accordance with the Uniform Physical Standards (UPS), At of ire time of tre"'e'Jiew, :he C',.o.C,\16 had not developed inspection procedures or an inscection format that meet :r,e UPS inscec:ion criteria, Also, the HACrv16 could not provide ccc~mentaticn that evider,ces that Sys:ems Inspections were being performed in accordance with an approved preventive maintenance c,an, The HACMB's Public Housing Assessment System (FC'lI,S) certification wiil be due in Augusl2SCO, Corrective Action Reouired: The HACMB must develop policies, procedures, systems and inspec:icn forms will", cr':er!a that is consistent with the requirements of PHAS, Findino #6: The HACMB's Contract Administration of ClAP No, FL29P017904.97 Is Not in Compliance With 24 CFR 85.36. The Review Team examined the HACMB's Contract Administration File for ClAP program No. FL29P017904-97 and could not find a contract fcr tr,e purchase of the thru wall air conditicring units, While the contract file stipulated the air conditicning units were purchased under an ex's:ing contract with TransWorld, Inc., the HACMB could nct produce a contract with TransWcrld Inc, In addition, the HACMB could not provide evidence of bid documents or the type of solicitation Tcr :he purchase of the air conditioning units, Regulations at 24 CFR Section 85,36(b)(9) provides that grantees will maintain reccrds sufficient to detail the significant history of a procurement. These records will include, but are ,1Ct necessarily limited to the following: rational for the method of procurement, selection of cor,:rac: type, contractor selection or rejecticn, and the basis fcr the contract price, Since no contract or bid documents apparently exist. the procurement of :he air ccndilicring units is not in compliance with the federal procurement cegulations. Corrective Action Reouired: The HACMB must establish procedures rcr contract and file adrrdnistra:icn fcc all procurements, Also, the Procurement Officer should ,cerform quarterly reviews cf lhe contrac: ~:es to assure that acceptable and well-documented crocuremem ac:ivities ::eing perfcrmec cy designated staff, Other Results of the Maintenance Operations Review 1. Public Housina Unit Inspections The Review Team performed HOS inspections en a sample of 10 low Income public hc~s,rg units at Rebecca Towers South, Five (5) units passed the inscections, ",,'10 (2) units ::;assed w/ccmment ard three (3) units failed, Examples of :...,as violaticrs in the '~ni:s chat failed ;nc:~cec 19 inoperative smoke detectors and inoperative bathroom exr,aust fans, Detailed results :f the unit inspections are shown in Appendix Number 1, Corrective Action Reauired The HACMB shouid implement actions that will help it maintain its low inc:me public housing stock in an excellent condition so it can attain a high rating under the new PCi,.lS. ,.l, new inspection sheet must be developed which conforms to the Uniform Physical Standarcs fUPS) for the inspeotion of publio housing units whioh HUD's Reai Estate Assessment Center (RE,;,C) has established, Then the HAC"IB shouid inspeot the units in Rebeo:a Towers South usir,g th,e new inspeotion sheet. Any deficiencies should be corrected, These steps will help ensure that the HACMB obtains high scores in future physical inspections by the REAC contractors, anc :herefore, high scores overall in the new PHAS, failing, The HACMB must immediately correct the deficiencies in the units listed in this '<eport as 2. Section 8 Unit Insoections The Review Team inspected a sample of 27 Section 8 units, including (23) existing units and four (4) moderate rehabilitation units, Of the 27 units inspected, two (2) units, 7% per:ent of the total, passed the HQS inspections; ten (10) units, 37% of the total, passed with comments: anc the remaining fifteen (15) units failed the inspection, This constitutes 56 % of the total number:f units inspected, The high peroentage of units failing the HOS inspections may be a reflection :f the high inventory of units that the HACMB has in its program, the lack of systems for notifying landlords about unit deficiencies in a prompt and reliable manner and the laok of communications bert/een the Section 8 Inspection Department and the Section 8 Management Department. This lack cf communication may interfere with the notification, follow-up and implementation of Housing Assistance Payments (HAP) abatements in the case of non-compiiance by iandlorcs, A,:so, tre HACMB has an insufficient number of inspectors, especially when consicering the additicnal task of inspecting the 200 public housing units that are being contemplated by the HACMB's management. There are also some landlords in this program who have been identified as offering substandard housing for the tenants of the Section 8 program at the HACMB, Detaiied resuits of the unit inspections are shown in Appendix Number 2. Corrective Action Reauired The HACMB must address the lack of an efficient landlord notification system where prompt correotions of deficiencies found during unit inspections are ensured. Furthermore, tr,e HACMB must establish excellent communioations channels between the Inspection Department and the Section 8 Ivlanagement Department so that it can enforce landlord compiiarce with HQS s,accarcs by means or promptly abating HAP payrr.ents. The HACi'vlB needs more inspec:ors becar.;se cr ~re large numoer of units in the Section 8 program, movement of families who need larger Jnics westward to Miami and the additional workload created by uncertaking the inspectior, duties of Rebecca Towers South, When additional inspectors are addeo, the "AC,vIB shoulc :cnsider inspecting the Section 8 units twice a year, especially units owned by landlords whose units cave a large number of HOS failures, These required aotions, once implemented, will help the HACMB maintain a high percentage of Section 8 units in excellent condition and improve its Section Eight Ivlanagemenr Assassment Score (SEMAP), when implemented, Based on the Review, this Office expects the HA,C~IB to fail the SEMAP score, when implemented, and become a troubled PHA. " 2CJ Extensive follow-up must be done with the landlords whose properties recresent sui::- standard housing, If the necessary repairs are net done timely, the HAC~IB must ai::ate the payment of rental assistance. Additionally, the HACMB must notify all owners of the units lis;ec as failing in this report of the HQS violations noted, ard raouire them to take Immedla,e cor:-eo:ive actions, As required, re-inspections of these units must be performed by the HACi',IB to ensure compliance, This Office is available for assistance If needed, D. PUBLIC HOUSING OCCUPANCY AUDIT The Public Housing Occupancy Audit was completed as a part of an In-Depth Consciicated Management assessment of the HACMB, The deficiencies that foliow were foune during the assessment and require corrective actions, These deficiencies are eeviations from various r=ederai Regulations, Handbook, the Consolidated Annual Ccntribution Contract (CACCI, HUD Haret:coks and other requirements as indicated, All occupancy functions were reviewed. The Review included examina,ions of apciicants' fiies, tenant selection and assignment practices, computation of rents, annuai ane 'r,terim reexamination practices and the HACMB's Dwelling Laase, A total of fifteen (15) low-income "'ut:lic Housing residents' files were audited, Based on information in a June 17, 2000, letter from the Interim Executive Director the HACMB has begun corrective actions on some of the Findings in this Section, Findinq #7: The HACMB Has Not Maintained an Admissions and Continued Occupancy Policy (ACOP). The HACMB is not in compliance with 24 Code of Feeeral Regulations (CFR) Part 960, Admission to and Occupancy of Public Housing, which prescribe standards and criteria for tenam selection and assignment, establishes a preference for elderly families and disabled families fcr admissions to mixed population public housing projects and plans for exemption from eligibility requirements for police officers and other security personnel. The HAC~IB does not have an A,COP, In addition, the Quality Housing and Work Responsibility Act of 1998 (QHWRA) mace significant changes to the low income Public Housing Prcgram. The HA,CMB is not in compliance with the new changes. Corrective Action Required: Within 60 days, the HACMB must develop, implement and maintain an ACOP to reflect tr,e current requirements, inciuding changes required by tr,e QHWRA. Please note that all federai preferences were permanently repeaied in the QHWRA. After, implementation of the ACOP, the HACMB must comply with its ACOP and all federal reguiations that govern the law-income Public Housing program. Findinq #8: The HACMB Does Not Have a Tenant Selection and Assignment Policy and an Acceptable Waiting List. Regulations at 24 CFR Section 960.204 require PHAs to establish and adopt written pclicies for admission of residents, The HACMB could not document that selections and assignments are made in accordance with a Board adopted Tenant Selection and Assignment Plan (iSA.?), According to its staff, the HAC,\1B stopped using Federal preferences months ago ard has established local preferences, However, the staff coule not produce a copy of the TSAP, Additionally, the HACMB does not maintain an acceptable waiting list. The Tenam'Lease Coordinator works from index files, Based on the HACMB's index cards, it appears that appiicants are selected by date: alphabetically, and Federal preferences in that order, Once the appiicants with a Federal preference are offered units then ncn-rederal preference applicants for that cate are ',. 21 offered units, Please note that all Federal preferences were permanently repealed in October 1998 by the QHWRA. They had been suspended for several years before that. Corrective Action ReQuired: Within 60 days, the HACfV1B must prepare and maintain an acceptable waiting list prioritized by date and time of application and Board adopted local preferences, if any. Also within 60 ,jays, the HACfV1B must adopt a written TSAP, Usually the TSAP is a part of the ACOP referred to above. As indicated the ACOP must reflect recent changes in the QHWRA. Any changes in the TSAP relating to local preferences and number of offers must be approved by HUD's Office FH&EO pricr to it becoming effective, After, revision, the HACfV1B must comply with its ACOP and all Federal reguiations that govem the low-income Public Housing program. FindinQ #9: The HACMB Is Currently Using an Outdated Lease. The HACMB was currently using an outdated lease, The lease was outdated and was not in conformance with the requirements at 24 CFR Section 966.4, Corrective Action ReQuired: The HACfV1B's dwelling lease must be structured with, and be in conformance with, its Admissions and Continued Occupancy Policy, when adopted: the Lease procecures outlined in 24 CFR Section 966.4: the Grievance Procedure set out at 24 CFR Section 966, S~boart B: anc state law, Findina #10: Tenant Files Are Incomplete. A total of 15 Public Housing files were reviewed, The new admission files were all missing the lease signed by the tenant and HACMB. The older files have a copy of the original lease but do not have annual lease addendum. Rent generally has been calculated correctly and form HUD 50058s are prepared within the allowed time frames, The Supervisor does not perform quality control reviews on the HACfII1B's low income public housing tenant files Corrective Action ReQuired The HACMB must certify that leases and annual addendum's are included in all tenant files, Immediate action upon receipt of this report is required, For future actions, a sample of tenant files should undergo a quality control review or examination, The HACMB should establish written procedures requiring quality control reviews of tenant files, describing the procedures to be used and assigning responsibilities for accomplishing the quality control reviews, FindinQ #11: Federal Preferences Were Not Confirmed. The HACMB did not obtain information on which it could make a determination as to whether an applicant was entitled to a preference, Based on the files which the Review Team audited, applicants were given Federal preferences, even though there was no proof in the files of the verification of the Federal preferences, As noted above all Federal preferences were permanently repealed in October 1998 by the QHWRA. They had been susoended for several years before that. However, some PHAs have adopted the former Federal preferences as Iccal preferences. 22 Corrective Action Required: The HACMB must adequately document its tenant files to snow that It has 'tenfIed thaI applicants are entitled to a Iccal preference and the ~Jpe cf preference(s; to wnlch the apciicam 's entitled, If the HACMB wishes to continue using the former Federal Preferences, its 3carc must adopt a formal Resolution after notice and a public hearing, Findinq #12 The HACMB Did Not Have a One-Strike Policy, Effective March 28, 1996, the Hcuslng Opportuni~J Extension ,~ct of ,996 required :::::HAs tc develop occupancy standards that allow the PHAs to terminate tenancy or assistance fcr the whcle household that includes a person involved in the proscribed activi~J, Regulaticns at 24 CFR Secticn 960,205(b) provide that a PHA is responsible for screening tenants for cnmlr,al actlvi~J :1",81 wculd adversely affect the health, safety or welfare of other tenants, The eiAC,\,IB has no: Ce'ieloped standards to terminate assistance or that prohibit admission of any hcusahclc with a rT'emcer wnc (1) the PHA has determined has engaged in illegal crug use; or (2) the ,:leiA. r,as reascnacie cause to believe is engaging in illegal crug use or alcohol abuse that in:en'ere 'Nlth :he health. safer: cr right to peacefUl enjoyment of other residents of the developments. Corrective Action Required: The HACMB must develop standards for lease enforcement and adrT'ission In accordance with the Housing Opportunll'f Extension Act of 1996 and 24 CFR Section 960,2G5(b), Findinq #13 The HACMB is Not Admitting Disabled/Non Elderly Into Its low- Income Public Housing Development. Based on a discussion with the Tenant Selection Coordinator II is her understanding that only elderly/elderly disabled are to be housed at the low-income public housing development. It is the understanding of the HACMB's staff that this community is considered designated elderly. For this development to be designated elderly or elderly/disabled, the HAC,'vIB must first fellow the requirements established in 24 CFR Part 945, The HACMB must develop an allocation plan and receive HUD approval for the designation, Corrective Action Required: Until the PHA receives approval of an allocation plan the HACiv18 must admit disacled and non-elderly families into this development. Findina #14 The HACMS Has Failed to Set a Schedule for Annual Re-certifications At the time of the Review, the HACMB was requiring its tenan~s in ~he icw incorT,e puctic housing program to contact the Building Manager for their annual re-car:iflca{ion, Tre ,-,AG.'vIB posted a note on each tenant's deor notifying them that it was time fer :~elr ~2-.:er::iflcatjcr. 3/ '::lr~ this, the HACMB placed this respcnsibiiity upon the tenant to ensure the re-certlflcmion :s ccmcietec annually. Regulations at 24 CF? Section 960.209(a) require PHA,s tc -e-examine tr,e inccme ace composition of all tenant families at least once every 12 months, Corrective Action Required: The HACMB must develop a system for scheduling re-certlflcalicns to assure that tenants are reexamined at least annually, The tenants must be given an ccccrtuni~J to reschecule, if the HACrv1B's scheduled re-certification date conflicts with their schedule, eiowever, the tenants snoulc be advised tenancy may be terminated if the HACrvlB is not permitted :c complete its reexamlnalicn by the anniversary date of the lease. " 23 Findinq #15: The HACMB Has Failed to Update Its Utility Allowance Schedule. The utility allowance schedule currently being used by the HAC"IB was lest revisec and updated in 1996, Pursuent to Regulations at 2d CFR Section 965,507, the HACMB r:-:ust reView its schedule of utility allowences each year, and must rS'/ise its allowance for a utility category if there has been a change of 10 percent or more in tr,e utilir; rate since the last time the utilir; allowance schedule was revised. Corrective Action Required The HACMB must immediately review its schedule of utiiity allowances anc "evise them if needed, Also, the HACMB must maintain information supporting its annual review of utiiity allowances and any re'lisions made in its utili~; allowance schedule, Apprcoriate adjustments and reimbursements must be made to current and past residents. Findinq #16: Utility Allowances Are Improperly Handled. At the time of the Review, the HACMB was directly billed by FPL for electhca[ usage for each public housing unit. The utility allowance is applied to the FPL b[1I and the tenant is billed fer the remaining balance If the utility allowance is greater than the actual FPL biil. nc refund is ;i'/en to the tenant. HACMB officials advised that it is in the process of changing its computer system, When the change is completed, the tenants will be required to put their FPL bill in their own name, Once this is done, the utility allowance will be deducted from their rent. The HACMB plans to utilize revised utility allowance rates effectively with the start of the new system, Also, all units in Rebecca Towers include television cable service, All tenants are required to pay $4 per month for cable regardless whether they use cable or not. This fee is included in their rent. Corrective Action Required The HACMB must refund to tenants any excess of utility allowances over the actual F?L billing, The HACMB must cease charging tenants for television cable service when the tenant cces not receive the service. E. SECTION 8 MANAGEMENT REVIEW The Section 8 Management Review was completed as part of an In-Depth Consolidated Management Review of the HACMB. The deficiencies that follow were found during the assessment and require oorreotive actions, These deficiencies are deviaticns from various Feceral Regulations, Handbooks, the Consolidated Annual Contribution Contract (CACC), Secticn ,3 Housing Assistance Payments contracts (HAPs), HUD Handbooks and cther requiremems as indicated, A total of thirty eight (38) Section 8 resident files were reviewed, The HACMB is edvised that the intent of the Section 8 Review is to ensure PH;', complia~ce with applicable Federal guidelines and regulations, In addition, the HACMB has an opportunity to make any corrections and/or changes to its currant policies and procedures t!",at will ensure hign scores on the Section 8 Management Assessment Pmgram (SE1v1AP) when it is implementec, Based on the Review, if SE,vlAP were currently in effect the HACMB's Section 8 programs would :e considered troubied, Findinq #17: The HACMB Has Failed to Update It's Administrative Plan Regulations at 24 CFR Section 982,54 require PHAs to adopt written acmlnistrative plans that establish local policies for the administraticn of the Section 8 program in ac~ordance with ,,"LD 24 requirements, The HACMB's Administrative Plan has not been re'/ised since 1996, It dces nct reflect the many significant Section 8 prcgram policy revisions required by the QHWRA ar,c: other changes. One significant change was the permanent repeal of the Fec:erai preferences ':y the QHWRA. Additionally, the HA,C:VIB was nct following its cesolete Administrative Plan, Corrective Action Required: Within 60 days, the HACMB must re'/ise its Administrative Plan to reflect the char,ges :0 the Law and Regulations, After revision, the HACMB must comply with its .A.dministrative Plan and all Federal R\lgulations that govern the Section 8 programs, FindinQ #18: The HACMB Is Not Issuing Requests for Lease Approvai (Form HUD 52517) to Certificate or Voucher Holders, Regulations at 24 CFR Section 982,302(c) requires that families submit a Request 'cr Lease Approval, form HUD-52517 (RFLA), to the HACMB during the term of the Certificate cr 'lcucher. When a family finds a unit. and the owner is willing to lease the unit under the program, the :amily must submit a RFLA to the PHA for aperoval to lease the unit. At the time of the Re'/iew, the HACMB was not providing these forms to Certificate or Voucher holders, It appears that the HACMB's procedure is that when a family expresses an interest in renting a unit. the Owner directly contacts the HACMB to schedule an inspection without compieting an RFLA. This is a violation of 24 CFR Section 982,302(c), Consequently, the ciock continues to run on the Certificate or Voucher. [f an inspector fails to inspect the unit timely, the family loses '/aiuable time in shopping for another reasonable unit. This loss of time could result in a loss .cf housing assistance to the applicant. In addition. the HACMB does not track the progress of the requests such as the time it takes to inspect the unit or if it faiis the inspecticn to re-inspect the unit. Corrective Action Reouired: The HACMB must fumish copies of the form for RFLA to families so they may complete them and retum them in a timely menner in accordence with 24 CFR Section 982,302(c), Additionally, the HACMB should develop e system to track the progress of the femily in their search for and processing of their housing assistence, The HACMB must nct permit Certficates or Vouchers to expire through its failure to timely process RFLAs, FindinQ #19: The HACMB Failed to Document Rent Reasonableness in the Proper Manner, Regulations at 24 CFR Section 982.503(b) provides that a PHA must determine whether the rent to owner is reasonable rent in comparison to rent for other comparable unassisted units, To meke this determination, the PHA must consider the location, queiity, size, unit type, anc age cf the contract unit and any amenities, housing sariices, mainterance and utilities to be prc';:c:ec :"1 the owner in accordance with the lease. Tenant files that the Re'/iew Team examined c:rraired a certification regarding rent reasonableness, However, the sUrJey form whlc~ was used cid nOt collect all the necessary data needed for rent reasonableness determinations, The form "sed Cy the HACMB does not take into consideration similar units in the unassisted market such es ur,lt size, including number of bedrooms: bathrooms; and square feet of living space; unit type such es garden apartment: elevator building; townhouse: or single family house; amenities, including air ccnditioning, carpeting, dishwasher, washer/drier connection, garbage diseosal, loceticn cf unit within the building; facilities, including avellebility of storage, parking and etc, 25 Corrective Action Required The HACMB must ensure that an appropriate form is US ad to determine rent reasonableness for each unit with an approved lease so that a proper companson can be mace with urits in the private unassisted mar~et. The HACNlB must submit to this Office a certification, along Wilh a ccpy of the sur/ey form, stating that the required factors are used in its determining of rem reasonableness, FindinQ #20: The HACMB Was Not Using the Rent Reasonableness Data. The HACMB provided the Review Team with data on rent reasonableness a,~c incicated that the data is updated annually, However, the Section 8 inspectors are not utilizing :his cata in determining initial rents, Instead, the Owners are given the requested rents, In addition, it does not appear that other Section 8 staff are utilizing this data for annual rent re-determinations, since rents are in excess of the AAF or manually maintained reascnable rems data. Corrective Action Required: In accordance with 24 CrR Section 982,503(a). the HACMB must begin utilizing its reasonable rent database once it is properly determined (See Finding Number 19 above) to determine that at all times during the assisted tenancy the rent to owners coes not exceed the reasonable rents. The HACMB must submit to this Office a certification that this procedure has been implemented and all Section 8 staff, including Inspectors, have been provided instructicns on when and how rent reasonableness is to be utilized, FindinQ #21: The HACMB Failed to Maintain Complete Tenant Files and Rent Calculations Are Incorrect The Review Team selected a sample of 38 tenant files, Based on an examination of the 38 tenant files 13, or 34 percent of the tenant files, are incomplete, have incorrect rent calculations and are missing documentation, The following deficiencies were found by the Review Team during the file reviews: incorrect payment standards were used to calculate the housing assistance subsidy: incorrect utility allowances were used; the file lacked third party verifications; the verification of earnings did not state how many hours the tenant worked per week: information in the fJle was inadequate for the computation of The contract rent and utility allowance: the owner or tenant's spouse did not sign the lease; medical expenses were not used as a deduction: gross rents were used in the rent calculation instead of the payment standard: the family was issued a certificate instead of a voucher; the file did not contain a lease addendum; and the amount of income was incorrect. Please refer to Appencix Number 3 for a description of the deficiencies b,. tenant or address, The Regulations at 24 CF'R Section 85.42 require PHAs to retain their records Also the Review Team found that the Super/isor did not perform quality contrei re',iews of the HACMB's tenant files for admissions and annual re-certifications, A sample of lenant files shouid undergo a quality control examination by the Super/isor. Corrective Action Reauired: The HACMB must certify that all tenant files have been reviewed and are comcleTe, have correct rent calculations and are not missing documemation. These actions shoule be taken immediately upon receipt of this report, While it is important for the HACMB to :orrect the deficiencies in the flies reviewed by the Review Team, all other files must also be reviewed and all deficiencies corrected, , 26 To assure that the rents are calculated accurately :ond the files are complete and accurate, the HACMB should establish written procedures covering cuality ccntrol reviews of tenant files that describe and assign responsibilities for accomplishing quaiity contrcl exeminations on a same Ie of its tenant flies. The Supervisor shculd then randomly condec: a quality control review of a sample cf initial tenant files and ail re-certifications, The possibility exis:s that some of the documents missing for pre-existing tenants may be found in the initial file opened for the tenant; however, this 'nformation shOL:ld be readily accassible in one file and must be transferred into the tenants' most current file, FindinQ #22:, Improper Rent Increases Were Provided to Owners, The HACMB is using the Fair Market Rent (FMR) instead of the Annua[ Adjustment Fac:cr (AAF) for rent increases, The HACMB is giving FlvlR ir,creases instead of AAF adjustments to owners without obtaining a written notification from the cwners at least 60 days prior to the anniversary date of the HAP Contract. HUD Reguiations ar 24 CFR Section 982.509(b)(5) reouires that the owners must request the increase at least sixty cays before the next annual anniversar; date to receive an increase resulting from the annual adjust:'Clent. The HACi\IB is permitting owners to request rent increases over the telephone instead of writirg a letter documenting the request. In addition, most rent increases are in excess of the AAFs as published in the Federal Register and/or reasonabie rents as most recently determired by the HACvlB, Ail rent increases in excass of thesa ~NO factors must be approved by HUD :os a Spec:al ,~,cjL:stment. Hcwevar, in accordance with 24 CFR Section 982,510, special rent increasas may be permitted, With HUD approvai, based on substantial and general increasas in real property taxes, special governmental assessments, utility ratas, or costs of utilities not coverad !::y regulated rates, In any case, an AAF or Special Rent increase may not excaed re$sonable rents, During the Review, HACMB staff inJicated that higher rents were approved by the Section 8 staff and this was an acceptable practice bV the HACMB, However, this is not consistent with the procedures used to determine approval of r~nt increases, Corrective Action ReQuired: I The HACMB must review all AAF tdiusted rent increases and/or speciai adjustment rent increases compietad during the past two 'Ie rs, The HAC~IB must prov(de this Office with a list of all rent increases calcu[ated based on the , wners' requests and in excess of the AAF factors as published in the Federal Register or reasonable rents as derermined by the HAC,vIB at that time, With regard to the Section 8 Modelate Rehabilitaticn units, rent increases may not !::e in excess of the published AAFs, unless a SJecial Rent Increase (as approved by HUD) is gramee, Regulations at 24 CFR 882.410 states that'a special rent adjustment, to the extent determi~ed by HUD to refiect increases in the actual and necessary exper,ses of owning an maintaining the 'Jnir which have resulted from substantial gener$1 increases in real property ;axes assessments, Jt:iity rates and utilities not covered by regulated rt. tes. may be rs':::mmencec JY Ihe ?HA for a;:prO,\/ai :~j HUD, The HACMB must recalculate all aff cted rent increases using the C8rrect AAF faclors anc reasonable rents, A letter must be sent t all affected cwners indicating ;he correct rems a~c include provisions for repayments to the HA, MB by owners for HAP over-payments, The HACivlB must provide this Offic with a list of tcral HAP over-payments owed to it and verify that repayments have been made by t e Owners or a repayment S8hedule has been exec~tec and approved. 27 Findino #23: The HACMB Is Not Issuing Information Packets or Briefing Packets to Tenants or Landlords. The HACrvlB is not issuing information packets to appiicants at the time the Certificate or Voucher is given, This is in violation of 24 CFR Section 982,301 (b), At the time of the Review, the HACMB did not have an information packet on file to hand out to tenants or landlords, In accordance with 24 CFR Section 982,301(b), when a family is selected to participate in the Section 8 programs, a PHA must give the family a package that includes specific information, such as, the term of the Certificate or Voucher, the PHA:s policies on extensions of the term, tenant's rights and responsibilities, hearings, an explanation on how the housing assistance payment is determined, and other information that will assist the applicant in the move-in process, It is also a good practice for PHAs to develop briefing packets for landlords, The information should oonslst of the above, including the iandlords' nghts and responsibilities, Corrective Action Reouired: The HACMB must develop an information paokage and include all of the material required by the regulation at 24 CFR Section 982,301(b). A oopy of the revised information package must be submitted to this Offioe for review, Findino #24: The HACMB Does Not Schedule Appointments for Inspections. At the time of the Review, the HACMB was requiring the tenants or owners to contaot the Inspections Department to sohedule HaS inspections. By doing this, the HACrvlB places this sole responsibility upon the tenants and owners to ensure that an HaS inspeotion is completed annually, HUD Regulations at 24 CFR Seotions 882,516 and 982A05 require inspeotions to be made on an annual basis, Corrective Action Reouired: The HACMB must immediately develop a system for scheduling HaS inspeotions prior to the anniversary date of each HAP contract. The inspections should be soheduled for at least 60 days before the anniversary date, The tenant and owner must be given an opportunity to reschedule, if the HACMB's scheduled inspeotion date oonflicts with their schedule, However, both the owner and the tenant should be advised of sanotions and/or abatement, if the HACrvlB is not permitted to conduct its HaS inspection timely or the unit does nor comply with the HaS requirements by the HAP anniversary date. Findino # 25: The HACMB's Waiting List Does Not Provide Adequate Information On Bedroom Size The HACrvlB's waiting list does not include the bedroom size needed by applioants, Regulations at 24 CFR Section 982.204(b) requires Section 8 waiting lis;s to show the number cf bedrooms for whioh the family qualifies, Additionally, there IS no oommunication with the Acoounting Department to determine availability of funding by bedroom sizes, By failing to meet with its Acoounting Department to ascertain the number of Vouohers that can be leased-up, this makes it impossible for the HACrvlB to maximize the utilization of its Section 8 funding, This haphazard approach to administering the program may result in an over-utilization or under-utilizaticn of program funds. Further, by failing to interact oonsistently with the Aocounting Department. the HA,CN!B runs the risk of losing millions of dollars in unused funding, Also, HUD may consider recapturing this funding, 28 Corrective Action Required: The HACMB must immediately amend its waiting list to inolude dara on bedroom sizes. and establish communications with its Accounting Deoartment to ensure appropriete funding allocations, Prior to issuing new Vouchers, the Section 8 staff should meet with the Accounting staff to determine the actual number of Vouchers that can be leasee-up, This should inc~ease th,e HAC1vlB's ability to house more families and improve the lease-up ~ate, FindinQ #26: The HACMB Is Not Admitting Single Persons Who Are Under the Age of 62 and Working. At the time of the Review, the HACMB was not admitting singles under the age ci 52, The definition of a family pursuant to Regulations at 24 CFR Section 982,201(C) (J,) includes nct only an elderly person but any other single person, Corrective Action Required: Within 60 days of the date of this report, the HACMB must revise its Administrative Plan to permit the admission of single persons under the age of 62 to its Section 8 programs, FindinQ #27: The HACMB Was Not Abating HAPs For Housing Quality Standards (HQS) Violations or for Failure to Comply With HAP Requirements. The Review Team found several units that had failed the HQS inspections, but the HACivlB failed to abate rents on the unit(s) and continued to issue checks to the owner(s), Regulations at 24 CFR Section 982.404(a)(3) states that "The HA must not make any housing assistance payments for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the HA and the HA verifies the correction, If the defect is life threatening, the owner must correct the defect within no more than 24 hours, For other defects, the owner must correct the defect within no more than 30 calendar days (or any HA-approved extension)," The Review Team questioned the HACMB's Section 8 staff as to why owners checks were still being issued if the unit(s) had failed the HQS inspections, According to the Section 8 staff, if units do not meet HQS, are in violation of other HAP provisions or Section 8 requirements monthly HAP checks should be held. We could not find letters in the tenant riles that supports this position, The HACMB could not provide documentation to support plans )0 abate HAP payments, Additionally, the HAP register did not show that checks were held for abatement. Corrective Action Required: Within 60 days, the HACMB must include a provision in its Administrative Plan requiring the abatement of rental payments for units that fail HOS inspections or in other situations where Owners are in breach of the HAP agreement. Additionally, within 60 days the HACMB must implement this provision and certify to this office that it has done so FindinQ #28: The HACMB Informs Applicants That They Cannot Rent Units Where the Monthly Rental Amount Exceeds the Payment Standard. The Review Team learned during the Review that the HACMB's staff was advising Section 8 Voucher holders that they could not pay more rent than the HACMB's payment standard, The HACMB's payment standards are 100 percent (100%) of the Fair Market Rents (FMRs), A participant may pay more rent than the payment standard, The amcunt of subsiey is based on the payment standard not the actual amount of rent paid, However, Regulations at 24 CFR Section 982.508 provide that at the time the PHA approves a tenancy for initial occupancy of a dwelling unit by a family with tenant-based assistance under the program, the family share must not exceed .lG percent of the family's adjusted monthly income, . " 29 Corrective Action Reauired: Immediately, the HACMB's staff must cease telling Section 8 \/ouc,-,er holders that they cannot rent units which are pricec: in excess of the ~aymem stanc:ards The HA.C~IB must advise all participants that they can rent a unit for more than the payment standard ane: ,1ew participants that they are not permitted to pay mere than 40 percent of their adjusted monthly income. Findina #29: The HACMB's Utility Allowance Schedule Is Not Current. The HACMB's Utility Allowance schedule was originally prepared by a consultant in July of 1996, However, the utility allowance schedule has not been revised and updated since 1996. In accordance with 24 CFR Section 982,517(c), PHAs are required to review tr,eir schedule of utility allowances each year and must revise an allowance for a utility categorj ;f there has been a change of 10 percent or more in the utiiity rate since the last time the Utili<y Allowance scheduie was revised, Corrective Action Reauired: The HACMB must review the existing Utilitj Allowances schee:ule and make changes, if necessary, based on actual utility costs by family sizes and localities, The HACivlB must maintain information supporting its annual reviews of Utility Allowances and any revisions made in its Utility Allowance schedule. Separate files should be maintainee: and should include all supporting documentation utilized for utility analysis and updates of the Utility Allowances for each subsequent year. Also, the HACMB must begin using the updetee: ane: revised Utility ,~.Ilowance schedules, Findina #30: The HACMB's Section 8 Supervisor, Inspections Supervisor and Staff Have Not Administered the Section 8 Program in Accordance with Section 8 Regulations and Requirements. The Section 8 Supervisor has the primary responsibility for the administration of the program, The Incumbent, at the time of the Review, possessee: a general understanding of most of the program requirements, but failed to effectively communicate the requirements and objectives to the program staff. This also includes the Inspections Supervisor. During the Review, the Review Team reported that it provided an inordinate amount of technical assistance to the Section 8 staff, Although the former Executive Director indicated that supervisors and staff hae: attended numerous training sessions and seminars apparently additional staff training is necessary for improved capability and to effectively and properly administer the Section 8 Celtificate and Voucher and Housing Choice Voucher programs in accorc:ance with HUD Regulations, Corrective Action Reauired: The HACMB must immediately procure the services of a third party to administer its Section 8 Programs and provide formalized training for Section 8 program staff, This training sheule: provie:e the staff with a better understanding of the Section 8 programs ane: their reGuirements, including recent changes like QHWRA, the Section 8 Certificate and Voucher ~erger, Sa/lAP and eec, The HACMB must give to its staff instructions on Section 8 policies and prccedures, including when and how rent reasonableness is to be utilized, HUD is in the process of instituting its Section Eight Management Assessment Program (SEMAP), The Sectien 8 staff and management must become knowledgeable of SEMAP and its implementation, '. .: 30 HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH IN-DEPTH CONSOLIDATED MANAGEMENT REVIEW PART III, REVIEW OBSERVATIONS An Observation may be a general comment. cr may oe a ceflciency in arcgram performance, which dces not result in a violation of a statutcr; or res~latorj rec;~iremem, cut whic~ could, if not addressed, result later in a Finding, Observation #1: The HACMB Has Incurred Costs in Excess of $935.569,72 for a Single Parent Resource Center Which Apparently Will Not Be Built. The HACMB has paid about $935,569,72 from its Section 8 administrative fee :eserves for the acquisition of land :0 build a Single Parent Resource Center '-Canter} "Nhich i,,: accar-=nl~'( is unable or unwilling to build. Additional costS incurred since the land purchase inc:uce, re- building of a sea wall, architectural and engineering costs, maintenance, insurance ana 'Juilding and land use permits and etc, Also, we understand that the HACMB may have used accitlcnal funds obtained from refinancins Rebecca Towers North, a Section 8 New Construction craiec:, which is under the jurisdiction of HUD's Office of Multifamily Housing. We uncerstand that :he HACMB planned to combine the Section 8 administrative fee reserves, with the oroceeds cf :r,e 'e- financing of Rebecca Towers North, hOME funds and bank loans to construct the Center. Planning for the Center began about 5 years ago under a former Executive Director, It now appears that the Center will not be developed, Officials of the City of Miami Beach havencicated to this Office that a part of the land may be needed for the re-construction of a bridse, We understand that temporarily the land is being rented for use as a parking lot. Regulations at 24 CF'" Section 982.155(b)(1) and the Consolidated Annual Contributions Contract I::erween the HACMB and HUD permit the use of excess administrative fee reserves for "housing purposes" if permitted by state and local law, If constructed, the Center would provide housing for low income Single Parents and would apparently be permitted under the HUD Regulations, However If not constructed. the funds would not be used for housing purposed and therefore be improperly used, Temporar; use of the site for a parking lot during the time plans are being developing or permits are being ol::tained may be good management. However, long term use of the site for parking purposes is net e .:ermitted use of Seetion 8 administrative fee reserves, Recommendation: The HACMB should make a determination as to whether it is going forNard with the development of the Center, If so, it should expedite the development. This Office has supcorred the development of the Center, and will continue to do so if adequate funding is available, If tr,e decision is not to complete :r,e Center, the HAC~[B m~st decide if it ean use the site for scme ather permitted housing purpose. If not. the HACNiB should Immediately take steps to reco'lsr all :he funding used for the Center and reimburse the various Federal funds, If the C:r;, Counc; :r Stats seeks to use a portion of the land for the bridse re-constr'Jctlon, adequate comoensation muse 'Je obtained for the land taken, One of the options the HACI'vIB should consider is sellins the site if it does not plan to complete the Center or does not have an acceptaole altema:e use 'cr housing purposes, Observation #2: Annual Costs of About $200,000 for an Inter Local Contract or Agreement With the City of Miami Beach Are Questionable, For the last several years the HACi'vIB has entered Into ccntracts or an Inter-Iecal Agreements (agreements) With the Cir; of Miami Beach (City), Under these agreements tr,e City agreed to furnish recreation programs: enhanced police protection: and subsidized c~ilc care for persons receiving Section 8 heusing assistance, The amount of the latest contract was in excess cf '. .; 31 $200,000, Payments for these agreements have been made from the i-L"',C:VIB's Section 8 administrative fee reseNes, As we understand this agreement. the contract amcunt is a flat amcunt fer annual se~/ices. The payments are not individual parcicipant fees charged to ail rasidents of :r,e Cit'j cf Miami Saach. We understand that the payments are to permit participatlcn by famiiies assisted by Section 8 Housing Choice Vouchers, Section 8 Certificates and Section 8 Vouchers, The Review Taam examined doo:.Jmentation supporting the payments for :hls agreement. The Team found that supporting dooumentation was Insumc:ent to show the se~/ices ~rO'lidec, The Team reviewed an invoice in the amount of 5163,330.15, Thera was little documentation supoorting seNices provided for a S96,1 06 charge for recreation seNices, The Review Team oould not iccate any documentation supporting the serJices proviced fer enhancac pOiica ~rctection costing $63,754,15. Housing units in the Section 8 Housing Choice 'Iou char, Section 8 Cercificate and Section 8 Voucher programs are not owned by the HACM8, They are owned by private owners who pay property taxes the same as any other owners, The HACM8 only owns three housing projects. t'NO of which, Rebecca Towers North and Rabecca Towers South, house exolusively elderly persons. Since they are used to house elderly persons, there's little need for the type of sar/ices that were to be provided under the agreement. Also, the HACM8 owns an apertment building located at 211 Collins that only contains 16 units, This arrangement appears to be nothing more than a way for the HA,C:VIB to subsidize the tax base of the Cit'j from the revenues of the HACMB's Section 8 programs, Attention is directed to Section 421,09, Laws of Florida. which provice that no PHA shall operate any ~roJect for profit or as a source of revenue to the city. We know of no reason why the Cit'j should recei'/e a subsicy from the HACAMB for participants in the Section 8 programs, Adcitionally, this Office knows of no reason why providing seNices to assisted families Is more expensive to the CIt'j than the provision of seNices to families who are not assisted, Acditional costs charged for Section 8 participants in excess of those charged to olher Citizens of the Cit'j cennot be justified, These expenses are questionable, Regulations at 24 CFR Section 982.155(b)(1) and the Consolidated Annual Contributions Contract bet'Neen the HACc/IB and HUD only permit the use of excess administrative fee reseNes for "hcusing purposes" if permitted by state and local law, Recommendation: The HAClvlB should terminate the current agreement when legally possible, This Office believes that this practice violates Stale Law, The HACMB must not operate its Section 8 programs as a source of Revenue for the City, in the future, the HACMB should not enter into any similar arrangement with the City, Observation #3: Questionable Payments Were Made to a Discharged Employee. The HAC1v18 made peyments from its Secticn 3 ,",cministrative Fee Reser/es of approximately 580,000 to a former employee, who was disc,",arged and, afte~Narcs, ~aid severance and unemployment benefits, The Review Team was unabie :0 locate a contract or policy requiring the payments to the terminated employee after his cischarge. However, we ha'/e been toic the: there was a written agreement between the HAC;VIB anc the terminated employee whicr, was presumably drafted by counsel. Apparently the decision to pay severance benefits was made by the former Executive Director before 80ard consent was obtainee. Subsequemly, the 80arc considereC the former Executive Director's decisior. and tOOK no action, The Minutes of tr.e Board meeling indicated that the Executive Director may have feared an age disoriminatlon lawsuit against the HACMB, ~ .; 32 Recommendation: Appropriate supporting documentation should be filed with each payment voucher, Also, if needed, appropriate Board approvals must be obtained fer severance payments prior tc payment. Additionally, other supporting documentation such as opinions of counsel regarding the potential legal risks should be obtained and documented, Observation #4: The HACMB Is Not Adequately Budgeting and Controlling Costs Under Its Rental Supplement Program. The HACMB operates a local Rental Supplement Program (RSP), The RSP is designed to provide temporary rental assistance to residents of the City of Miami Beach, The HACr,lB funds this program from its Section 8 administrative fee reserves, Tc receive assistance from this Jrogram, a participant must be: 1) A non Section 8 or public housing resident. 2) A resident of the City of Miami Beach for 12 months or more, 3) Disabled (any age), 4) A family with children, 5) Elderly, 62 years or older, 6) Experiencing temporary loss of employment or a decrease in income. 7) Recently evicted or facing eviction. S) Experiencing difficulties in paying utility andlor telephone bills, The Review team could not determine how much of the HACrvlB's administrative fee reserves had been used to date. Also, the Review Team found that expenditures for this program had not been budgeted. A system of cost encumbrances and budget controls were not being used for the RSP, The maximum dollar amount that a family may receive is $2,000, If the HACMB assists 100 families, or more, during a one year period, conceivably, the HACMB could spend more than $200,000 from its administrative fee reserves for this program. However, without estimating its funding needs for the RSP, the HACMB may not maximize the use of its Section 8 administrative fee reser/es, Additionally, as indicated above the Section 8 administrative fee reserves are being depleted at a rapid rate. In addition, the Review Team had concerns regarding the type:j of rental assistance that were being paid for some persons. For example, the Team reviewed several RSP participant files, and found some families that were given assistance because they could not pay their phcne bills or utility bills. One file included a copy of a past-due phone bill thet showed extensive long distance charges, While another file included a past due utility bill showing excessive "energy consumption" charges, While these situations indicate an immediate financial problem, the greater problem appears to be poor money-management skills. Regulations at 24 CFR Section 982,155(b )(1) and the Annual contributions contact between the HACMB and HUD permit the use of excess Section 8 administrative fee reserves fer housing purposes if permitted by state and local law, Recommendation: The HACMB should establish Internal Controls and Budget Controls so that it can adequately control the payments for the RSP and determine the aggregate amount of funds used fer this program. In addition. the HACMB should consider revising its program "requirements" and redefine "rental assistance," and the types of assistance it is willing to pay. The HACMB should keeo in mind that Section 8 administrative fee reserves may be used to provide for costs of helping families who .' .: 33 experience difficulty renting appropriate housing. However, the HACMB should exercise caution when uSing administrative fee reserves to cover costs like excessive utilities or telephone bills, Observation #5: The HACMB Should Assure That Payments from Its Administrative Fee Reserves Are Properly Documented and Supported. Few of the payments examined by the Review Team were supported by adec;uate documentation, During a review of the grants, the Review Team noted that only Barry University had supplied sufficient details to determine what ser/ices were periormed for the cost charged, For the grants and Inter-local Agreement, periodic reports are submitted with invoices fcr the ED to approve, Then they ere submitted to the Accounting Department for payment. Upon a review of an invoice in the amount of $163,330,15 for the Inter-local Agreement there was little documentation supporting an amount of $96,106 for Recreation ser/ices, No documentation could be located to support an amount of $63,754,15 for enhanced police protection, No agreement could be located to support the payments to a terminated employee after his discharge, However the minutes of a Board meeting afterwards indicated that the Executive Director may have feared an age discrimination lawsuit. It appeared that this decision was made without the initial consent cf the Board or consultation with legal counsel. On the surface the Review Team questioned whether the expense was justified, Recommendation: Appropriate supporting documentation should be submitted with each invoice and/or progress report that will substantiate costs paid for the services billed, Observation #6: Policies, Procedures and the FHEO Poster Were Not Posted. There were no posting of scheduled charges for services, repairs and utilities, policies. rules and regulations for the low income public housing program in the main office, This information is required to be incorporated in the lease by reference end should be publicly posted in a conspicuous manner in each of these offices, Additionally, the FHEO Poster was not posted, Recommendation: The HACMB must post the indicated FHEO poster, schedllles, policies, rules and regulations immediately, Observation #7: The HACMB's Staff Need Training, On October 21, 1998, the Quality Housing and Work Responsibility Act (QHWRA) was signed into law, This Act makes extensive amendments to the United States Housing Act of 1937, Certain provisions of the QHWRA became effective immediately upon enactment. However, mcst provisions became effecti'/e on October 1, 1999. P~cvisions or this ,~ct and :he Reguiations iS3:..:ec: pursuant to it must be implemented by the HACMB, The HAC1v1B's low income public housing staff possess a general understanding of some of the program requirements, However, additional staff training is necessary for, improved management oapability, and to effectively and properiy administer the program. The Section 8 Supervisor has the primary responsibility for the administration of the program, The incumbent, at the time of our review, possessed a general understanding of most of the program requirements, but failed to effectively communicate the requirements and objectives to the program staff, This elso includes the Inspecticns Super/isor, Dunng the review, the Review Team reported that it provided an inordinate amount of technical assistance to the Section 8 staff, Additional staff training is necessary for imcroved management capability end to effectively and . ., 34 property administer the Section 8 Certificate and Voucher and Housing Choice Voucher ~rograms in accordance with HUD Regulations, The HACMB must give to its staff instructions on when and how rent reasonableness is to be utilized, HUD is in the process of instituting its Secticn Eight Management Assessment Program (SEM,A,P), The Section 8 staff and management must become knowledgeable of SEMAP and its implementation, The new PHAS has now been implementec, The HAOJlB must provide training to its employees and install adequate systems to collect and report correct data to HUD. The HACMB was utilizing temporar/ employees to enter balances and perform reconciliations, The accounting staff did not appear to have sufficient training on the new computer software system and their responsibilities were not clearly definec, The HACMB must provide adequate training to its accounting employees, As pointed out in Finding Number 3, accounting records and systems require improvement. As shown in Finding Number 2 procurement training must be provided to the Contracting Officer and other employees involved in procurement of goods and services, Recommendation: The HACMB should obtain proper OHWRA training for its staff to ensure that they are able to comply with the current regulations and guide!ines. The HACMB should provide procurement training to the appropriate staff members, Also, the HACMB shoulc provide formalized training for the Supervisor and staff of its low income public housing program, This training should ,crcvide the staff with a better understanding of the program and its requirements, The HACMB must immediately provide formalized training for the Section 8 Supervisor, Inspections Supervisor and the Section 8 program staff, This training should provide the staff with a better understanding of the Section 8 programs and their requirements, including recent changes like OHWRA, the Section 8 Certificate and Voucher merger, SEMAP and etc, The HACMB's staff must be trained on the new PHAS, Systems must be implemented to allow the necessary data to be collected, For the low income public housing project. its inspectors must be trained to use the new Uniform Inspections Standards. The Accounting staff should immediately receive thorough trainjng on the new computer software, A new set of Standard Operating Procecures (SOP) should be developed for use by for accounting staff and management. This should help the HACMB to enter all relevant information into the accounting system and obtain a full set of accounting records which can be reconciled and are up to date, Observation #8: The HACMB May Not Be Utilizing Its Maintenance Staff Effectively. The HACMB was using its CT',aintenance staff as a force-acoount for cyclical paiming of units, unit turnaround, work order repairs and installation cf air conditioning units purchased under the C!AP program. Presently, there are nine maintenance personnel who perform work on both the PHA owned Rebecca Towers North (A property assisted through a Housing Assistance Payments Contrect under the Section 8 New construction program) and Rebecce Towers South (a low income public housing project assisted through an Annual Contributions Contract), Because of the wide array of duties the maintenance personnel perform, unit turnaround takes from 14 to 25 days tc complete. Recommendation: The HACMB should evaluate the present workload for maintenance personnel as well as the timeliness for completicn of work, The HACMB should develop a wcrk plan that ensures that ". 35 maintenance personnel are being utilized in a cost effective and efficient manner that is most advantageous to the HACMB. Observation #9: The HACMB Has Not Established Written Operating Procedures for Processing of Work Orders or the Operations of the Inventory System, The HACMB could not provide documented evidence that quality assurance was being performed on completed work orders. Also, the HACMB could not provide documentation evidencing that quality control of inventory supply levels was being performed. Recommendation: The HACMB should develop written operating procedures for the internal operations of the maintenance department including work order procedures and the inventory system, Observation #10: Quality Assurance of Work Order Repairs Is Not Being Performed. The HACMB's Maintenance Supervisor is not performing documented quality assurance Inspections to assure that work order repairs are acceptably completed, Recommendation: The HACMB should develop and implement procedures that require that a samole of the completed work orders of all maintenance personnel undergo a quality assurance inspection, , , 36 ., HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH IN-DEPTH CONSOLIDATED MANAGEMENT REVIEW PART IV, PUBLIC HOUSING MANAGEMENT ASSESSMENT PROGRAM The Public Housing Management Assessment pcogram (PH MAP) was created under Section 502 of the National Affordabie Housing Act of 1990, In January 1992, HUD published an Interim Rule for the PHMAP, a system to evaluate public housing agency (PHA) performance nationwide, The first Interim Rule set forth 12 Indicators for measurement of management performance in several operational areas, The second Interim Ru[e was published on December 30, 1996, with eight Indicators and 22 Components, Beginning with the HACMB's Fiscal Year Ending (FYE) June 30, 1999, it was assessed under the Department's new Public Housing Assessment System (PHAS), An advisory score was issued, Under PHMAP three levels of overall performance by PHAs were established, Based on a PHA's overa[1 total weighted PHMAP score, the agency wi[1 be classified as either a high performer, standard performer or a troubled performer, In addition, a PHA may be designated as modernization-troubled (mod-troub[ed) for its management performance under management Indicator #2, Modernization, The four leve[s of performance and the criteria for achieving those [evels are stated below, Hioh performer desionation: A PHA shall be designated a high performer if it achieves a total weighted score of no less than 90 percent with no Indicator less than a grade of "C," Standard desionation: A PHA shall be designated standard if it achieves a total weighted score of less than 90 percent but not less than 60 percent. Troubled desionation: A PHA shall be designated troubled if it achieves a total weighted score of less than 60 percent. Mod-troubled desionation: A PHA shall be designated mod-troubled if it achieves a total weighted score of less than 60 percent on Indicator #2, modernization. This report contains the results of a final on-site PHrvlAP Confirmatory Review of the HACMB, The reader of this report must be aware that PHMAP provided statutory and regulatory criteria to identify PHA management capabilities and deficiencies, The PHMAP reflected only one aspect of public housing agency operations, I.e" the results of its management performance in specific program areas, The PHMAP or new PHAS should not be viewed by PHAs or other interested parties as an a[l-inclusive and encompassing view of overa[1 PHA operations. When viewing overal[ public housing agency operations other criteria and review are necessarj to determine the adequacy of overa[1 PHA operations, These systems are not designed to be the sole methods of viewing a PHA's overall operations, Therefore, to ful[y e'/aluate a PHA's overa[1 management performance an In-Depth Management Review must be performed, Such a review has been performed of the HACMB, The results are stated in this Report, The subject Confirmatory Review resulted in a confirmed PHMAP score for the HACMB's Fisca[ Year (FY) ending June 30, 1999, Of the eight Indicators, six were applicab[e to the HACMB's operations for fiscal year 1999. This report addresses the Indicators and provides an explanation of the HACMB's PH MAP score for each Indicator, The Review Team confirmed a PHMAP score of 87,5 percent for the fiscal year ended June 30, 1999, The score resulted in a standard performer designation, . ". 37 The information below reflects the resL:lts of the Confirmatory Review, Also, the sCGring report. located in Appendix Number 4, shews the results with a detailec listing of the scores for individuallncicators, The CR was performed during the perlco from November 15 through November 24, ~ 999, The purpose of the PHtvlA? CR was to assess the management performance of the H,"'C~IB by verifying dam certified by tr,e HACtvlB ane the aCGuracy of data derived from HUD files for the lscal year ending June 30, 1999. The HA,CM6's overall SCGre and Its score for an IneicaTGr or Component may be changed subsequemly by this Office pursuant to data inc!ueeer an independent aueitor's repor., The HACtvlB received a grade ofF for Indicator 5. Inspection of Units and Systems ,he HACtvlB shall correct the deficiency within 90 days and notify the field office in writing of aotions taken to correct the deficiency, If the deficlenoy Is not corrected within ninety (90) days of rece,:t of the notifioation letter, the HACtvlB shall submit an improvement plan aCGeptable to this Office that addresses the defioient Ineicator in accordance with 24 CFR Section 901,145. The HACtvlB was also evaluated under the PHAS for its FYE June 30, 1999. Tr,e riAGvlB received an advisory PHAS score of 82,3 percent and was eesignated e standard performer. ~he HACMB should be aware that this is an aeViSOrj sccre, The official June 30, 1999, score wiil ':e tr,e PHtvlAP score of 87,5 percent. Under the Department's new PHAS, a PHA will receive grades for four Indicators: Physical Condition, Financial Concition, Management Operations and Resident Service and Satisfaction. The PHAS is expected to be a more objective measure of a PHA's performance than PHivlAP, Under PHtvlAP, PHA,s received a score prlmanly basec on their self-certification, Under P;-;AS tr,e Physical Condition Indioator will be graded from inspections performed by a contraotor engaged by HUD, The Financial Condition will be graded from the PHA,s Financial Statements as verifiec 0'1 an Independent Public Accountanr (IPA), The Resident Se~/ice and Satisfaction IndicatOr wiil be graded from responses ottained directly from a sample of Tenants, The l'vlanagement Operations Indicator will be graded from the PHA's cerEinCaiion, which is very similar to ,he PHMAP certinca,icn. Since the HACMB's Management Operations will be graded from a certification very simiiar to PHMAP, appropriate actions taken to correct the deficiencies identified in this Report will improve its PHAS score. At the time the HACMB submitted its PHMAP certification, no modification or exci~sion requests were submitted, INDICATOR #1, VACANCY RATE AND UNIT TURNAROUND TIME - GRADE A This Indicator examines a PHA's vacar,cy rate, its progress in recucing vacancies, ar,c ~nit turnaround time, COMPONENT~,VACANCYRATE-GRADEA Component #1, vacancy percentage measures the actual and aCjusted ',acancy i2~e :asec on the number of eays units have :::een '/acant d~r1ng the PHAs ;isca! year comoars':.vith the number of days the units were available for cccupancy. A PHA may choose wrelher tc use the actual vacancy rate, the adjusted vacancy iate or a reduc:ion in the actuai \/acancy rate within the past three years to determine the grace of this Component. The PHA is entitled to receive a grace of "A" if it is in one of the following categcres: an actuai vacancy rate or 3 percent or less: 8r an adjus~ed vacancy rate of 2 percent or less, The Review Tear,"'! examined the H,~,Ci\'lB's rent register, maintenance records and c~e:atir.g budget as sources of documentation fer this Indicator, The Review Team also assassee the ~ ., 33 adequacy of the HACMB's move-in/move-out procedures, resident fJle recercs anc maintenance records. The HACMB's certification indicaled that the f-CAC;\IB has imclemented an adecuate s'/s,er- to track the duration of vacancies, ' . The HACiv1B certified and the Review Teem cenfirmec a total number of ACC 'cays as 73,000 and that there were no adjustments to this numcer. The Review Team revlewec supporting documentation submitted by the accounting department, which rerlected units available and number of days occupied, The HACMB certified to a total number of actual vacancy days of 991 and that there were ~c adjustments to this number, Based on the Review Team's examination of the HAO/IB's vacancy study, the correct number of actual vacancy days as of June 30, 1999, was 962. When calculating vacancy days, in some instances, the f-CACMB had miscalculated the tCla, number of vacancy days by including the actual day that the tenant moved out. This :esults in an actual vacancy rate of 1,32 percent (963 divided by 73,000), The HACMB certified that the "Percentage points reduction of actual vacancies .vilhlr, ;;as: three years" was N/A Since there was no reduction in percentage points of actual vacancies within ,cast :hree years and there were no adjustments, the actual vacancy rate and the acjustec 'Iacanc~. rates are the same, 1,32 percent. Based on the HACMB's actual vacancy rale cf 1.32 percent, the HACMB will receive a confirmed grade of "A" for this Component. COMPONENT #2. UNIT TURNAROUND.. EXCLUDED Component #2, unit tumarounc time, is scored only if a PHA's score for Component #1 is below a grade of C. Implicit in the Indicator is the adequacy of the PHA's system(s) tc track the duration of vacancies and unit turnaround, including down time, make reacy time anc lease up time, Since it received a grade of "A" for Component #1, vaoancy rate, the HACMB is not recuireC to be scored for Component #2. unit turnaround. This Component was reviewed only for the purpose of advising on performance and was not included in ..the scoring of the overa;: Indicator. To pass this Component, a PHA must have a system to track the duration cf vaoancies, and show an average turnaround time of no more than 50 calendar days, The Review Team found that the HACMB did not have a tracking system in place to determine the unit turnaround days, Recommendation: The HACMB must implemem a computer generated or a manual log immediatei~1 to toe:"~ unit turnaround days, This [og must include the following cata for eaoh unit: . Unit number, . Date unit becomes vacant. . Reason the unit was vacated, . Date unit was referred for repairs, . Date unit preparation was completed, and . Date the new lease takes effect. Based on the weighted average, the overall grade of Indicator #1 is a grace cf Component #1 has a weight of "2," Component #2, which was excluded, has a weight of'1 'II ., ,'"..,. , 39 .; INDICATOR #2: MODERNIZATION - GRADE" A This Indicator examines the management of funding allocated under the Comprehensive Improvement Assistance Program (CIA.P) administered by the HACNlB. The review included the modernization program that had activi~1 during the assessment period of culy 1,1998, through June 30, 1999, This Indicator has five Components: unexpended funds over three Federai Fiscal years (FFY's) old, timeiiness of fund obligation, adequacy of contract adminislration, quali~1 of physical work and adequacy of budget controls. A PHA is not required to certify to this Indicator on its form HUD-50072, Public Hcusing Management Assessment Program (PH MAP) Certification, Instead, this Indicator is graded from information in HUD's LOCCS system, various reports submitted by a PC',"" to the HUe Field Office, and from HUD reviews of the PHA's modernization program, COMPONENT #1. UNEXPENDED FUNDS OVER THREE FEDERAL FISCAL YEARS iFFY'S) OLD - EXCLUDED Under this Component, a PHA is entitled to receive a Grade of "F" if it has unexpended funds over three FFYs old and is unable to demonstrate the existence of one of three exceptions or a HUD approved time extension, During the rating period, tlle HACMB had only one open ClAP grant. Number FL29P017904-97 This grant was for FFY 1997 and was not yet tr,ree years old at the end of the rating period, June 30, 1999, Since this grant was not yet three years old, we were unable to grade this Component. Consequently, this Component was exciuded, The grant was for emergency funding which required that ail funds be expended by September 30, 1998, This Office is concemed that the funds had not been expended within the one year time frame as required, The HACMB's ClAP Budget/Progress Reoort for the period ending September 30, 1998, and the data in HUD's LOCCS system revealed that only $21,579 of the $22,000 grant was expended, leaving $421 remaining unexpended, Recommendation: Due to the changes in HUD regulations and how ClAP funds are to be awarded in the future, the HACMB must establish monitoring and tracking procedures to ensure future ClAP funds are expended within regulatory time frames, A ClAP or Modernization Coordinator should be designated to monitor and coordinate all ClAP activities from planning to ciose-out. COMPONENT #2. TIMELINESS OF FUND OBLIGATION - GRADE- A A PHA is entitled to receive a Grade of "A" under this Component, if it has no un-obligated funds over two FFY's old or is able to demonstrate the existence of one 01 three exc8oticns, Since this was for emergency funds, HACMB had one year to obligate ali funes, Time frames for obligation commenced on September 30,1997, and all funds had to be obligated by September 30,1998, The grade for this Component was supported by data in HUD's LOCCS system that showed that all funds have been obligated in accordance with the HACMB's Imolernentatlon Schedule, Consequently, a grade of "A" was confirmed for this Component. ~ 40 '1 COMPONENT #3. ADEQUACY OF CONTRACT ADMINISTRATION-EXCLUDED Under this Component a PHA is entitled to receive a Grade of "A" if based on HUD's latest on-site inspection and audit, where a written report was provided '0 the PHA at least 75 calendar days before the end of the PHA's Fiscal Yaar (FY), there were no Findings ralatee to contract administration or the PHA has corrected all such Findings. Neither HUD nor the Corps of Engineers had performed an on-site inspection or an aueit during the two years prior to this Review, therefore, this Component was excluded, However, during this Review, the Review team examined the HACMB's contract administration for ClAP project No, Fl29P017904-97, The funding from this grant was used to purchase through wall air conditioning units, The HAC~IB could not provide documentation for the competitive procurement of ,he air conditioning units or the selection of the vendor, TransWorld, Inc, The HACMB could not provide a ccpy of a contract for the procurement of the units, although the file indicated that the air cGnditioning units were purchased under an existing contract with TransWorld, Inc, Although a contract with TransWorld, Inc, appears not to exist, the files included invoices from TransWorld,lnc, The Review Team was unable to determine the extent to which the HACi'vIB monltoree purchases under this grant (I.e" ensuring purchases did not exceed the contract price and, etc, ), Also, force account labor was used in the installation of the air conditioning units, but no evidence of inspections of the quality of work was found, Recommendation: The HACMB must establish procedures for contract and file administration for all procurements, Also, the Procurement Officer should perform quarterly reviews of the contract fiies to assure acceptable and well-documented procurement activities and that contract file administration is being performed by designated staff, The HACMB must ensure that all procurement of equipment, services and materials is in compliance with 24 CFR Section 85,36 and its own Procurement Policy. COMPONENT #4. QUALITY OF PHYSICAL WORK. EXCLUDED A PHA is entitled to receive a Grade of "A" under this Component if based on HUD's latest on-site inspection, where a written report was provided to the PHil at least 75 calendar days before the end of the PHA's FY, there were no findings related to the quality of the physical work, or the PHA has corrected ail such findings. Neither HUD nor the Corps of Engineers had performed an on-site inspection or an audit during the two years prior to this review: therefore, this Component was excluded. COMPONENT #5, ADEQUACY OF BUDGET CONTROLS - GRADE A Under this Component, a ClAP PHA is entitled to receive a Grade cf "A' if it has ex~ec,dea modernization funds only on work in HUD-approved ClAP budgets or has obtained ;Jrior HUD approval for required budget revisions. The grade of "A" for this Component was supported by data that showed that funds had been expended only on work in a HUD-approved ClAP budget. Based on the weighted average, the overall grade of Indicator #2 is a grade of .',A,," Component #1 which was excluded and #5 have weights of "1," Component;;;2 has a weignt cf'2.' Component #3, which was excluded, has a weight of "1 y,," Component #, which was excluded, has a weight of "3," , ," - ; ... INDICATOR #3: RENTS UNCOLLECTED.. GRADE A This Indicator examines a PHA's ability to collec: dwelling rent owed by reSlcents In possession during the assessment year by measuring the balance of rent unccllec:ed as a percentage of the total rent to be collected. Under the Rule, rent to be collected is defined as the dwelling rent owed by residents in possession at the beginning of the assessed fiscal year, camed forNard from the prior fiscal jear. plus the recurring monthly dwelling rent charged to residents in possession dur'ng U-,e assessee fiscal year, Dwelling rent uncollected is defined as any of the dwelling rent to be collected thar was ncr paid during the assessed fiscal year, Included in this amount is the unpaid dwelling rent at the fiscal year end of any resident who was in possession at any time during the assessed year. Excl~sions. such as unpaid rent for residents who vacated during the assessed year, unpaid rent incl~ded In a formal repayment agreement. unpaid rent for residents in the process of eviction, and collectic,", losses due to write-offs of uncollected rent, are no longer allowable. The HACMB certified that dwelling rent owed by tenants in possession at the start of th.e year, carried forward from the previous year, was none: th,e dwelling rents billed during th,e year were $428,080: and the dwelling rents collected during the year were $428,080, Based on thiS data, the HACMB had total dwelling rents to be collected of $428,080 and that its total dwelling rents uncollected were none ($428,080 less 5428,080), Therefore, the percentage of rent ~ncollected was 0,00, The balance of dwelling rents uncollected from tenants in possession at the beginning of the year, dwelling rents charged for the year, ending tenant AiR balances and collection write-oils during the year were checked against rent registers, the general ledger, financial statements, the TAR reports and the HACMB's working papers, In addition, these numbers were discussed with key members of the HACMB's staff. The Review Team Confirmed that dwelling rent owed by tenants In possession at :he start of the year, carried forward from the previous year, was none; the dwelling rents billed during the year were $429,915; and the dwelling rents collected during the year were $428,226, Based on this data, the HACMB had total dwelling rents to be collec:ed of $429,915 and its total dwei!ing rents uncollected were $1,689 ($429,915 less 5428,226), Ti,erefore, the percentage of rent uncollec:ec was 0,39 ($1,689 divided by $429,915 equals 0.39),.. A PHA is entitled to a Grade of "A" if the percantage of dwelling rent uncollected in th,e immediate past fiscal year is less than or equal to 2 percent of total dwelling rent to be coilec:eo, Since the percentage of dwelling rent uncollected was calculated to be 0,39 percent, a Grade of "A" was confirmed for this Indicator, INDICATOR #4: WORK ORDERS.. GRADE A This Indicator examines the adequacy of a P,.,A's performance with regard to ::mplering maintenance work items as measured by its work order sys;em. The Indicator evaluates hcw ,he PHA controls its active work orders as well as the timeliness of completlcn, Any work order active within the PHMAP assessment year ;s Inci~ded regardless of when It was received or completed, However, only the calendar days within the current assessment year are included in the calculation, Implicit in this Indicator is the adequacy of the P,.,A'sNcrk crder system in terms of how a PHA accounts for and ccntrols its work orders, and its tif':',eliness in preparing and issuing work orders. This Indicator contains two Components relaring to U-,e following: Emergency Work Orders and Ncn-Emergency 'Nork Orders, . . 42 COMPONENT #1: EMERGENCY WORK ORDERS COMPLETED WITHIN 24 HOURS OR LESS - GRADE A To receive a grade of "A" for this Component. at least 99 percent of the emergency work orders must have been completed or the emergency abated within 24 hours or less during the PHA's immediate past fiscal year, The HACMB certified that it received a total of 58 emergency work orders during the year. it further certified that all 58 emergency work orders were corrected or abated within 2d hours, The Review Team confirmed the information reported by the HACI'vIB, The grade for this Component was supported by the emergency work orders which showed that the emergencies were abated within 24 hours, The HAC",IB will receive a confirmed grade of "A" for this Component. Recommendation: While the HACMB has a system to track the completion of emergency work orders, the system needs improvement. 1, The HACMB needs to ensure that a system is developed and implemented which tracks the time of day emergency work orders are requested and when they are completed, Currently, neither the work oreer log nor the work order form tracks the time of cay the work orders are requested', issued or completed, Therefore, in cases where emergency work orders are completed within 2 calendar days, the HACMB would not be able to determine if the emergency was abated within 24 hours, 2. The HACMB needs to develop a formal written list of emergency situations that are life threatening. Emergency work oreers are to be issued when these situations are present. COMPONENT #2: AVERAGE NUMBER OF DAYS FOR NON-EMERGENCY WORK ORDERS TO BE COMPLETED - GRADE A To obtain a grade of "A" for this Component, a PHA must ensure that all non-emergency work orders are completed within an average of 25 calendar days,., The HACMB certified that it had a total of 961 non-emergency work orders and that the total number of calendar days that it took to complete them was 1300, This calculates to an average to 1.35 days to complete non-emergency work orders, The Review Team confirmed a total of 1221 non-emergency work orders and that the total number of calendar days that it took to complete them was 1300, The confirmed average number of days was 1,06 days (1221 divided by 1300). The HACMB's performance under this Component warrants a grade of 'A," Based on the weighted average, the overall grade for Indicator #4 is a grade cf "A." Component #1 has a weight of "1," Component #2 has a weight of "2," INDICATOR # 5: ANNUAL INSPECTION OF UNITS AND SYSTEMS - GRADE F This Indicator examines the adequacy of a PHA's performance on the annual inspection of units and all building systems that determine short term maintenance needs as well as long-term modemization needs, In addition, this Indicator also measures how a PHA examines the condition of the housing stock and how it initiates all necessary corrective actions associated with identified ~ 43 deficiencies, This Indicator contains two Components relating to the following: Annual Inspection of Units and Annual Inspection of Systems. COMPONENT #1: ANNUAL INSPECTION OF UNITS - GRADE F This Component measures the effectiveness of a PHA's annual inspection of units in accordance with local housing/occupancy codes or standards that were at least equivalent to the Housing Quality Standards (HQS), whichever is more stringent. To pass this Component, a PHA must inspect at least 90 percent of its units during the assessment year; and, if repairs are necessarj for local code or HQS compliance, complete the repairs during the inspection, issue a work order, or refer the work order to modemization, Based on the HACMB's certification for this Component, a grade of 'F was awarded. The HACMB certified as follows: (a) That It had not implemented an adequate inspection program that generates quality inspections and tracks both inspections and repairs, (b) That it had inspected 100 percent of its units, (c) That 133 of the 200 units, 66,5 percent, which it inspected met local codes or HQS, and (d) That it completed all repairs on units where necessary for local code or HQS compliance either during the inspection, issued work orders for the repairs, or referred the deficiencies to the current year or following years modernization program, The Review Team found the following: (a) The inspection form being utilized by the HACMB for unit inspection is not equivalent to HUD's Housing Quaiity (HQS) Inspection form, The inspection form used by the HACMB oniy identified general repairs, It does not designate whether the repairs are HQS violations, life threatening or non-HQS deficiencies, The present inspection form is limited to only 3 lines for each unit the HACMB inspects, .1 (b) The HACMB could not show evidence that HQS inspections had been performed on all units, (c) On the units which it inspected, the HACMB could not provide evidence that repairs were completed during the inspections, work orders were issued or that the repairs were referred to modernization, The Review Team performed HQS inspections on a sample of 10 icw income Public Housing units, Five (5) units passed the inspections, t:NO (2) units passed with comment and three (3) units failed the inspections, Since the Review Team was unable to verify the HAC,\iIB's certification that it had inspected 100% of the units and brought all units into compliance with Codes and HQS, a grade of 'OF" was confirmed. Recommendation: The inspection standards are being changed from HQS to the Uniform Physical Standards (UPS), A sample of units will be inspected annually by inspectors from HUD's new Real J 44 Estate Assessment Center (RE..o.,C), As mentioned above, the scores from these ins:ections will be one of the indicators under the new Public Housing Assessment SystemPHAS), The Ci?,C:VIB must train its inspectcrs on the UPS. Also, it must develop a tracking system that ensures that all PHA units are inspected annually, and that reoairs are ,:ompiec2c on ail cniis wher2 necessarj, In addition, the HACMB must use a unit inspecticn fcc whic~ conforms to the UPS, The HACMB must enhance the system to identi~! whether "spairs identified during annual inspections were performed during the insoectiens, a wcr". order was issued, cr the repairs were referred to a modernization program. HAC:VIB managers must use these enhanced systems to ensure that repairs are completed timely or :,'"':at they are referred to its Capital Fund program, Deficiencies under the UPS system ::-ust be corrected to assure safe, decent and sanitarj housing and to avoid receiving peer ~r failing scores on the REAC inspections, COMPONENT #2, ANNUAL INSPECTION OF SYSTEMS.. GRADE F The purpose of this Component is to ensure that, in addition to the annual inspec:ion of individual dwelling units, PHAs are aiso annually inspecting and maintaining t~e major systems that are essential to decent, safe and sanitary housing. This Component examines the inspection of buildings and sites according to the HACMB's maintenance plar, A PHA is entitled to a grade of "F" if it failed to inspect all major systems of at least 60 percent of its buildings and sites and perform the required maintenance on thesa sys;2ms in accordance with manufacturers' specifications and established local PHA s;andarcs. The HACMB certified that it had inspected 100 percant of its buildings and sites, according to its ,vlaintenance Plan, Also, the HACMB certified that its inspections included perfcrming the required maintenance on structures and systems, The Review Team found that the HACMB did not have a written Maintenance Plan for its FYE June 30,1999, Additionally, the HACMB could not provide the Review Team with any documentation showing that an annual inspection of systems had been perfcrmed, Consequently, the HACMB was awarded a grade of "F," Recommendation: The HACMB must develop and implement a written Maintenance Plan, The annual sjstems inspections must be in writing and be performed in accordance with the HACrv1B's acoroved Maintenance Plan, The HACMB must maintain data showing the number of buildings and sites where necessary repairs were completed to comply with the UPS either during the inspection, issued work orders for the repairs, or referred the deficiency to the c~rrer,c jears or next years Capital Fund program, All written inspections must be maintained so that the HACMB can document its performance under this Indicator, Based on the weighted average, the overall grade for Indicator #5 is a grade of COr.1ponent #1 ane Ccmpor.ent #2 have weights of "1." 30th INDICATOR #6, FINANCIAL MANAGEMENT" GRADE A This Indicator examines the amount of cash reserJes avaiiable to a PHA for operaticr,s as a percentage of total actual routine operating expenditures, If a PHA fails to maintain a cash ~eserJe percentage of at leaSe 10 percent, the PHA shall then be assessed under Component ;;:2, energy consumption, ! 45 " COMPONENT #1. CASH RESERVES. GRADE A A PHA is entitled to receive a Grade of "A" if it has cash reserves avaiiable for operations which are greater than or equal to 15 percent of total actual routine ex~enditures or the ?i-iA has cash reserves of $3 million or more, A coordinated effort with the Finance Director and staff accountant was conducted to determine an accurate cash reserve figure, This included a review of the financial statements, the Independent Public Accountant's (IPA's) audit, tnal balance, cash recorc:s and revolving loan worksheets for the FYE June 30, 1999, The HACMB certified that its cash reserves were $624,176, The Review Team found that this amount was actually the operating reserve ending balance, The cash reserves reported for PHMAP should have been adjusted for short-term accounts receivable and payable, Based on the HACMB's books and records, the Review Team computed the cash reserve figure for PHMAP purposes to be $143,212, The routine expenditure figure was found to be $775,178, Consequently, the cash reserves were 18,5 percent ($143,212 divided by $775,178). Based on the results of the review of the HACMB's books and records, it had operating reserves of 18.5 percent which resulted in a grade of "A," However, the Review Team has serious concerns about the amounts shown on the HACMB's low income Public Housing books and records, The cash reserve amount included inter.fund accounts receivable and payable amounts of $146,851 and $238,511, respectively, The accounts payable amount was a plugged figure to balance with the Balance Sheet. In addition, the Accounts Payable Revolving Loan amount showed a balance of $456,098,39, Also, approximately $251,465 in amounts payable to three other funds were written off during the year, While reviewing the worksheets utilized by the HACMB to reconcile the revolving loan, it appeared that the cash accounts for the HAClVlB's funds were reconciled but the offsetting entries for the inter.fund and revolving loan accounts were not, thus distorting these general ledger accounts. The issue of using a plugged number to balance the balance sheet indicates serious accounting problems which are exacerbated by the fact that the HACMB does not have a self-balancing set of accounts for each of its program fund groups, It appears that the HACMB is subsidizing its low income Public Housing operations from other sources, This may indicate that this program is not operating efficiently, To ensure future financial solvency, the low income Public Housing program should operate on its own COMPONENT #2. ENERGY CONSUMPTION - NOT SCORED This Component measures the PHA's ability to control energy and utility costs in the assessed year when compared to a three-year rolling base average cost. It is oniy assessed and the results included in the grading of the Indicator when Compcnen #1 results in a grade of less than "C." Since the HACMB received a Grade of "A" for Component #1, the HACMB was not rated for this Component. Based on the weighted average, the overall grade for Indicator #6 is a grade of ''A,' Component #1 has a weight of "2." Component #2 which was not scored has a weight of "1 ." INDICATOR #7, RESIDENT SERVICES AND COMMUNITY BUILDING - EXCLUDED PHAs with fewer than 250 units will not be assessed under this Indicator unless they rec::uest to be assessed at the time of the PHMAP certification submission, . 46 ~ The HACMB did not request to be assessed under this Indicator for the assessed year, INDICATOR #8. SECURITY - EXCLUDED PHAs with fewer than 250 units will not be assessed under this Indicator unless they request to be assessed at the time of the PHMAP certification submission, The HACMB did not request to be assessed under this Indicator for the assessed year, " 1. 47 ... THE HOUSING AUTHORrrf OF THE CITY OF MIAMI BEACH PUBLIC HOUSING OCCUPANCY AUDIT Appendix Number 1 ANNUAL REVIEW OF INSPECTIONS - PUBLIC HOUSING UNITS UNITS PASSING INSPECTION AT REBECCA TOWERS- SOUTH: Passed - Apt. 207 Passed - Apt. 616 Passed - Apt. 713 Passed - Apt. 1004 Passed - Apt. 1111 UNITS PASSING INSPECTION WITH COMMENTS AT REBECCA TOWERS- SOUTH: Passed - Apt. 411, smoke detector keeps beeping, Passed - Apt. 1211, damaged kitchen cabinet top, cracked wash basin without leaks, smoke detector keeps beeping, UNITS FAILING INSPECTION AT REBECCA TOWERS. SOUTH: Failed - Apt. 202, exhaust fan inoperative. Failed - Apt. 506, smoke detector inoperative, Failed - Apt. 807, exhaust fan inoperative and smoke detector inoperative, ; ! ... 48 THE HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH SECTION EIGHT MANAGMENT REVIEW Appendix Number 2 HOUSING QUALITY STANDARDS INSPECTIONS THE UNITS FAILING THE HUD INSPECTION WERE AS FOllOWS: 901 7th Street. ADt. #2, Miami Beach: Floor tiles in kitchen floor starting to crack due to lack of decking support, lifted tiles in bathroom creating a tripping hazard, tub in bathroom needs replacement and caulking all around, Security bars could not be opened in bedroom (missing key) and the wood decking, similarly to the rest of the unit, is rotting and is in disrepair, 1415 Meridian Ave.. ADt. #17, Miami Beach: window sill in bedroom shows signs of termite infestation, missing towel rack, toilet needs caulking around base and soap dish brcken in bathroom, 1255 Marseille Drive, ADt. #117, Miami Beach: smoke detector in bedroom needs to be reinstalled and be operational again, sink leaks at bottom and there is a very limited counter space in the kitchen, caulking needed around tub in bathroom. 1930 71" Street. ADt #20, Miami Beach: bathroom and second bathroom have no ventilation inasmuch as the centrai system is inoperative: cracked electrical outlet cover in hallway, refrigerator is missing the door handle and has a poor seal on its door, 2011 Bav Drive, ADt. #15, Miami Beach: missing screen in kitchen window, stove hood has no light; seals are not proper in refrigerator door; cold water faucet knob stripped; broken guide in cabinet drawer; soap dish and towel rack need replacement; leaky wash basin: rusted, back splash needs caulking in bathroom; bedroom window needs guides, springs and balances; water heater rusted at bottom. 1781 Normandv Dr.. ADt. #1, Miami Beach: smoke detector inoperative, settlement crack in popcom in living room ceiling, window pane missing, paint peeling off, sink rusted and leaking at bottom, refrigerator door is off balance, electrical switch recessed in wall, water (mildew) stains in ceiling. wash basin needs caulking and is missing the stopper, wash basin clogged up, peeling paint in walls around tub and window in second bathroom, door damaged requiring replacement in master bedroom, security bars have no egress, 1805 Normandv Dr.. ADt. #1, Miami Beach: missing window screen, rear door frame damaged, door missing operator and screen, water marks above door in ceiling of kitchen, paint peeling off and water leak in window sill, cold water valve leaking, missing stopper at wash basin in bathrcom, water stain and paint peeling off around window in rear-right bedroom, ;l,G unit not cooiing prcoerly, 227 Antiouera Ave.. ADt. #102, Coral Gables: reinstall air vent and fix fan, replace toilet seat cover in bathroom, paint peeling off at door, baseboard damaged at bedroom, smoke detector neec:s new battery , 6930 Rue Vendome, ADt. #3, Miami Beach: ceiling condition is bad, needs re-plastering at bathtub and the tub itself needs replacing due to extensive damage around the drain (items in bathroom), Also, leaky faucet in kitchen, 842 Penn Ave., ADt. #1, Miami Beach: threshold in living room is bent up, creating a tripping hazard, floor tile missing at kitchen door in kitchen, wash basin drain slow in-draining, tub neec:s caulking, .' ". 49 700 Euclid Ave., Apt. 405, Miami Beach: exhaust fan not operational in kitchen (no ventilation), carpet at bedroom doorNay is buckled up, presenting a tripping hazard, 2130 Biarritz Dr.. Apt. #4. Miami Beach: one burner in stove is not operationai, no back spiash in kitchen, cracked eiectrical outlet cover plate, replace door in storage room. 1569 Biarritz Dr.. Miami Beach: electrical outiet not secured to wall-exposed wires in living room. peeling paint, universal crank missing in jaiousies (front enclosed porch), 334 Ocean Dr., Apt. 105. Miami Beach: left window will not stay open, no screens in windows at living room, gas turned off at stove, three ceramic tiles missing at wall, vanity cabinet door falling off, small leak at toiiet flush handle, small leak at wash basin. 1552 Washinoton Ave.. Aoe #5 Miami Beach: window operators missing, wire hangers used instead, paint peeling at all windows in living room area, paint peeling off in the building exterior, bathroom tiles do not match at all, sloppy work and owner should replace, This unit should not be in the program, UNITS PASSING INSPECTION WITH COMMENTS: 531 Hispaniola Way, Apt. #12: 800 Washington Ave" Apt. #901: 800 Washington Ave" Apt. #109: 800 Washington Ave" Apt. #112: 1214 Alton Rd,. Apt. #203; 745 Euclid Ave., Apt. #8; 2814 Collins Ave,; 1023 Penn Ave" Apt. #4; 609 Lennox Ave" Apt. #2 (all in Miami Beach) and 2046 West Flagler St., Apt. #511 in Miami. UNITS PASSING INSPECTION: 800 Washington Ave., Apt. #405, and 465 Ocean Dr" Apt. 1025. both in Miami Beach. 50 $ HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH IN-DEPTH CONSOLIDATED MANAGEMENT REVIEW Appendix Number 3 SECTION 8 FILE REVIEWS 240 South Shore Drive. Act. #3 The HACMB used the wrong payment standard to calculate the housing assistance subsidy, Also, the wrong utility allowance was given, Corrective Action ReQuired The HACMB must recalculate the housing assistance subsidy using the correct payment standards and utility allowance, Mercedes Suarez and Ana Rocha The residents' file lacked third party verification. Corrective Action ReQuired The HACMB must obtain proper verification and recalculate the total tenant payment. Eliset Nieves Based on the information in the file. we could not compute the contract rent and utility allowance. Corrective Action ReQuired The HACMB must review the file and recalculate the contract rent and utility allowance, Asuncion Andersek The HACMB did not use the actual utility allowance to determine the total tenant payment. The owner did not sign the lease. Corrective Action ReQuired The HACMB must review the file and recalculate the contract rent and utility allowance, The owner must sign the lease, 1255 Marseille Drive. Act. #117 The HACMB used the wrong payment standard and the incorrect utility allowance to calculate the subsidy, The verification of earnings did not state how many hours the tenant works per week, Corrective Action Reauired: The HACMB must obtain the proper information and recalculate the total tenant payment (TIP). ~- 51 ~ 700 Euclid Avenue. Aot. #405 The HACM8 did not include the tenant's medical expenses as a deduction, Corrective Action Reauired The HACM8 must review the file and recalculate the total tenant payment and provide the tenant with an interim adjustment within the next sixty days, 334 Ocean Drive. Aot. #105 The HACM8 did not include the tenant's medical expenses as a deduction, Utility Allowance of $33 is included in the calculation of the contract rent. Corrective Action Reauired The HACM8 must review the file and recalculate the contract rent: the totai tenant payment and provide the tenant with an interim adjustment within the next sixty days, 542 Jefferson Ave.. Aot. #106 The HACM8 used the gross rent instead the payment standard to determine the housing subsidy, The incorrect utility allowance was used, Corrective Action Reauired The HACM8 must review the file and recalculate the housing assistance payment. 240 South Shore Drive. Aot. #3 The HACM8 used the incorrect payment standard to calculate the subsidy assistance. The incorrect utility allowance was used. Corrective Action Reauired The HACM8 must review the file and recalculate the housing assistance payment. , 231 NE 163'. Street The residents' file lacked third party verification. Corrective Action Reauired The HACM8 must obtain proper third party verification and recalculate the housing assistance payment. 785 84'h Street. Aot. #2 The family received a four bedroom voucher but the family is living in a three bedroom unit and the HACM8 applied the four bedroom utility allowance instead of the actual size. The family was issued a certificate instead of a voucher, The certificate was issued to husband and wife but the husband has not signed all the documents, Corrective Action Reauired Effective October 1, 1999, no more HAP contracts can be entered for the certificate program. The HACM8 must recalculate the housing assistance payment using the voucher .. ~ 52 payment standard for a three bedroom unit and apply the correct utility allowance, The spcuse must co-sign all documents. 1214 Aiton Road. Act. #203 There is no addendum to the lease in the file, Corrective Action Reauired An addendum to the lease must be in the file, 2011 Bav Drive. Act. #15 The HACMB is using the incorrect income amount. Corrective Action Reauired The HACMB must review the third party verification and recalculate the housing assistance payment. . , JUN-20-00 TUE 09:48 AN BRIDGE HOUSE FAX NO "Oh eo~ ?ona , I J ..., :),JC: .... c..v P,]1 1'1 ' [,: \ . To: Mayor Nelsen Kasdin City Miami Beach From: ~my Turkel Bridge Housa Date: Fax: Re: June'4. 2000 305-673-7254 HousinG Authority of Miami Beac~ Good allernoon, Per our conversation on May 23, I must resign my seat on the board cf the Housing Autho'ily of Miami Boach, I have been honored to serve an the board for the past three yea:s and I am coniidcnt that the work thaI I was involved with will have long and positive Impact on the organization. I appreciate your support of my appointment and I hope that you will continue to be Involved and con- cerned about the status of the Authority, As I mentioned to you when we .poke, IhiS IS a very sensitive limo at the Authority and your assistance, guidance and appointment cf strong, compassionate, hard- working people who are committed to enhancing and expanding affordable housing on Miami Beach is critical to tho success of the organization. Beach. Plaase let ma know if I can ~e ot any assistance to you as II ralates to tne Housing Authority of Miami ::;,/ Z-L~ 'l' i ' II ,''. ". _;lei I :! ~...t.JtV '-...l... ~ ~ '" '^.. ! , , "- " \ /' I' 1 . !.;p 'H " I, 'L.(...r{ ...-...' ,.}-,-, . (1.! - '"' - (' ... ''--''(' ./ ,..' -, /'; ~ ~~(r '>" LCd,1 )(.11 ,}-< /').LJ All 01 the best. ,._...../;I,~ !, , :/ .~ . . , ~r-... -' f)1/,Li...L.\:.'{::... ~-':'L'--I r,;;,:; _~-:::.. '_ ....-: - ., I '"':>LI ;,:"L C!..-:'L<...' '.. ~-L I l ,- BRIDGE House 1632 Pennsylvania Avenue Miami Beach FL 33139 Ph1305532.7200 Fax/305 532-2029 1St Fund, which shail Joration on behalf of -3 provisions of 55. 420,. . , There shall be depo$ he documentary stamp , 201,15, moneys reca . 'e purposes of ss, 420, , and all proceedsd~ ,ch moneys. Moneys In! needed for the purpose. d pursuant to 55. 420. , shall be deposited 10' , be invested as provided In any such investment "' ail administer the fund e implementing the prog. _420,9078 and this sect iitaring the activities of iilies to determine local ""'uirements, the corpora' ;riations from the fun{ ,ei costs, For the purpose :lnce monitoring prov;siOrll oration may request a", al year, When such lundlng llion shall deduct the am Jlating the local housing O,9~72 and 420,9073.' . ;n,),-,o7. PUBLIC HOUSING Ch,421 CHAPTER 421 PUBLIC HOUSING PART I HOUSING AUTHORITIES (ss. 421.001-421.54) PART II MISCELLANEOUS PROVISiONS (s. 421,55) PART I HOUSING AUTHORITIES State role in housing and urban de'/elee- ment. Short title. Finding and declaration af necessity. Definitions. Creation of housing authorities. Appointment, qualifications, and tenure or commissioners; hiring of employees. Commissioners or employees prohibited from acquiring interests in housing proj. ec:s and required to disclose interests in specified properties; exception. Removal of commissioners. Powers of authority. Operation not for profit. Financial accounting and investments: fiscal year. Rentals and tenant selection. False representations to obtain lower rent in housing accommodations; penalty. Cooperation of authorities. Eminent domain. Planning, zoning and building laws. Debentures. Form and sale of debentures. Provisions of debentures and trust inden- tUres. Validation of debentures and proceedings. Remedies of an obligee of authority, A~djtional remedies conferrable by author- Ity. Aid from Federal Government; tax exemp- tions. Reports, Liabilities of authority. Organization and establishment. Contracts and undertakings. Notes and bonds, Co~tinuance of municipal housing auU",:ori- :les when municipality abolished; cor...:nties In excess of 400,000, Housing authorities in counties. Creation of regional housing authority. Ar~a of operation of regional housing ar...:thor- Ity, Commissioners of regional authorities. . Pa~ers ot regional housing authority: cefini- ~ tlons, ~1' Aural housing projects. .; . Execution ot mortgages. 421.33 421.24 421.35 .:121.36 .121.37 421.38 d.21.39 .121AO 421..11 d,21.J2 421.43 421.~ .121.45 J.21.46 J.21.47 421.48 421.49 d,21.50 421.51 421,52 421.54 ~ousing applications by farmers. Acditional cefiniticns. Supplemental nature of sec:icns. S(':or: ~it:e. Caferise r.cr...:sing; fir.dir.g ar;c cec:aration cf necessity. Defense housir,g by authorities. Acting fer Federal Gover:1ment on eefense housing. Cooperat:on by pt..;biic bodies on cefense housinc. Bones fer cefense hcusir.g le;a! invest- ments. Defense housing contrac:s vaiica:ed. Fl.emovai of restric:ions for defense housinG. Defense housin"g; definitions. - Provisions supplemental. Organization and establishment of housinc authorities validated. - Contrac~s and uncertakings of housinc authorities vaJicatec. - Notes and bonds of housing authorities vali- dated, Area or cceration of housing authorities fer eefense housinc. Oec~easing area -at operation of regional aL;thority . Authority for county excluded from regional autr,ority, Authorities; creation, obligations, etc., vali- dated, Housing authority. Orange and Seminole Cct..:nties; iimitation. 421.001 State roie in housing and urban develop. ment- The role of state govemment required by par': I of chapter 421 (Housing Authorities law), chapter 422 (Housing Cooperation Law), chaDter 423 (Tax Exemp- tion of Housing Authorities), and chapter 424 (Limited Dividend Housing Companies) is the resDonsibility cf the Department of Community Affairs: and ~:-:e depart- ment is the ager.cy of state gcver;-:ment respensible :cr the state's role in hor...:sing and urban de'/eic::ment. HI,lor'y.-i. 13, ::'1. '5:1.'C6::i. sa, :'"1. 3~-:37' i, 53,:'"1. ~:;-5:. 421.01 Short title.-?ar': I of ~his c~a~:-er may ':e referred to as the ~Housing Authorities Law,~ Hlltor'y.~. 1. c.":. ~7'i8~. :937; CGL 19.t.C s~::<:. 710(:!3-'.I). 421.02 Finding and declaration of necessity.-lt is hereby declared that: (1) There exist in the state insanitary or unsafe dwelling accommodations and that persons of low income are forced to reside in Such insanitarj or unsafe 511 c:,. 1'" ~ ........ ?1J2UC HC1':S;,'iG ,:!C::::~~cc2.tions: ~r.3t 'Nil~in ~he sta,e :he~e :5 2. sr:c:-. age :;: .;;afe ,cr sa~ltar! jwei!:ng ac::,"';"":;;:cr::ati;.:~s a';2.li- 3.::e 2.~ rents WL;iC:' persons cf low ;r.::::~e can aUcr,:: "':,(lC :,'ia: s;...:c~ :erscns are force'.:: to eec'.;::'! over. ~r.Jw::3d ant:: CJnges:ed .::::we!ling 2.c:cr:"\mc~aticns: ~~at ::~.,: 3.fcres2.!c ::mdilior.s ,cause an increas3 ;,'" 2."iC~ ~::r22.,::: .:f -:isease anc:r:i.1e and .:::r,s::::.;;e a~er:2.C? 10 :~-= ~eal:h, safe!:/, r:"lcr3lS anc 'Ne!far~ of :~e i%;. :~,~:3 <:~ :~,e s:::te and ~,~:;air e':C~:::,IC ';3[:..;25: :~3.t t.'''~ese::~diticr.s necessitate excess:',''? or,a :::isiJrc.:cr+ ,Jonate ex:enci:ures of ;Ju::iic tunes ~or cr:r:1e pre'je:l- tic"" 3:-;:: ::u~:s.1ment. pr...:biic health. 'Nei~are arid sa:ety. ;ir~ ai":;: acc:c:ent :rctec~icn. and o~her ,JL.:!:!ic serliC2S and :aciiities. ::;;'Jr. areas :r. ::--,e 3~a:e C2rfiC: ':,= ;::e:::.;~':. ,"':; :::3.n :~~ shcr:a;;e ci safe at.:: s2riit3r/ ::'m:!:in:;s ~cr :er. scr,s:'; lCW inc~:'Tle be reiieved, throu';.:n the c.ceratiC:l cf ;:Jr:'ia:e 8ri!er;rise, and that ~he conS:;:Jcticn or hc~s. ii:g ,:;:iec~s for persor:s of low inccr.1e, as herein c:efine,:::. 'NOL.:ld therefore net:e com;:::e:::ive 'Nit~ pri\'s.te er.te:;: ~:se. (-.;', i ;,e clearance. re::anning and rec:ns,;;,;c:icn :f :~-? ~;eas :n ',;,'iiie,"'. :nsar',itai'/ cr L.:isafe ~ct-.:s;r:;:cr. di;icr,s exis, and the provicing of sale anc sani:ar/ ,:',','s:Jirg ac::mriloC:ations fer perscns cf lew :r.c21..e. i."::::'...;:::ng the aC:::Jisiticn t,y a housing aL.:t~ority ci q;.JO~ :,~;.~ ~~ ~~~~s~e;n~:;: ~~~~9~~:~~~~i~~~'~:i~:-=!~,C~~~3~~:~ F~~~!~ . '" ,.' ~I:C:";~:':S9S :cr 'NnICi: CllOi:C .-n:~e/ '":'ia:; :.:! s~e;,,: 3.r,-: :~"':3:= :;:8e:..'/ 3c::..;ired ar.c a,e ';;o'/'?ri,n:sr.:ai ft.;nct:ctlS of ;Jllciic concern. i":"; 7:i8 .iecessity in ~he public interest fe." t~e .:r:::vi. s:ors :;erei~after enacted, :s hereby:ec:ared as a :Tiat- :erJi :e~is:ati'J~ ceter~lra!ion. His:;:r'.'.-~.;:, ~:'. '~:;a~ ':;':;'7: :::~'- ~g.:o S,,;:::J. -;'.:':'>~1 .l2~.:: Defini~ions.-~;-:e foi:cw:n,; :9r:7:3. 'N~~;-. ~\/e: ~se: ':, reie:-~eG >.:; ir, chis ,:a:... s,~,a:1 ,-,2.','e d.':; ."". :0'.'111; lesp2c~i'le mear.ings fcr the ~I...:r:::cses sf t!",is ,car, '..:~:es3 a diffe:er:~ meanins; c:ea,rl~1 apcears Irer~ (,"l2 c:,~:ext: ',i' ",""utr.o~!~;i' or ~ho~sing aut~c,r~:y~ sn~ii ~ean aJl'/ :; :1:8 :I..;CIIC :or;::or3tjOnsc:-eate::: :y s. ~.:::. ~ .~..:. -., 'Citf s;;a.tt mean any city sr ~'~'~m :f ~:';~. 3:a:e :';2.'/::';: 3 cc::::..;Ia.::cn or mere tL',a.n :::'.:;1.,.;.,). ::..:::,::r,,; :-: :he :,2.s: ore':e'.:ing feGeral Jr s:a:e :?rs:..;s. ~:';e::~f 3:-J~: ~'2,:':.:i ''',e :2;::;C'.;:3.f ::t~, :cr .'i"',:~ _ :::.r::::...,.:;, :' ',: ~s: ,..'~ ~~..~:~ ~~' i:~' ~s ~~." ~~~,: ;;;~ ail l7leai: ::-e ::~/::::l.i::::i. t:->:: ,::,'"T',i7':iSS,CII.::r cn"'.er :e-;;is:atlve :-:':,/:~2.,;:-?c.: -,','::l ,;:::\'~r,"',i;ig t:'":e::t'/, as t;o,e ,case ;r.a'!:.:: ,~:' '~..layc(" $,-:311 i:1ean tr.e rr.ayc c; :~e :::'/ c, ::-,-? officer :~erec; c...,ar;e~ with the ::..:::e3 :....;s::r:-'a(:~.' ir.:ccsec: In tJ1e "T'ia~lOr 8r ,3:<2.::..:t:ve ,~e3C: :r t::e ::tI " ~C:er~.;" 3,'::3.1: mean ~he ,:~er~:1 :~e :;::; ,:r ::-.,::- '::;> :er sf :.18 ::ty c~ar";;ed With tr-,e :'_:ies ;:'c.;s:,:r;".ai::~J 'r::>::se,.: '::: ;~e :!erk (rere,::!. ., ',~,ea or::,:eiaticn"': '2i '" t~e ,case of a :---:01...:8i:19 3r...;t:'":cr:t:i ,:;f:3. ::t:/~2.'/- :.:g 3. :ccL.;:aricr of :ess :han 2S..:CS. srai! .i :::,,;,:e s:..;:,~ ::t'j :;.'"':~ :he area ',';'Ithin 5 i.liies ::Jt :~a :er~:~::r:di ':':;U:':::2- ~::3S :J'":2i2Sf;:3.nc '"'1 '~~ :2.'O.:::f.3 -''::UST;:;'~:.'"u;;:: :: 3. ::;', r~ _ :~ 2::,~:: ':;- -:-e ...,e. _.~-- ~". -C"~., ::: - -- -,~..~ :;!'/ .;;..~::: ::--e:=..--?:,:, '.'11,.'-:1.'1 ~ C ....,.~:es :,:r:i :re :'2,- '-- ::::~:-,:2:'e.3 ::-,e~'?':::: ,:,:'/;c,::,: '~':','J.::'~'~r, :~,c: ::-.:: :;.,~~ ~ ;:::;~:::.:::r: :: 2. -::..;s:r:,:; ::.c..::~,:."::'::~ 3",;i ':::-/ 3:',2: ir~:::~":':2 2,,'/ '!~S-2. .'.::,c~ .:es 'Nit:~:r: :.>::; :er~;::~:.2~::'_-:1' ::::--~ ::-~' ::;'1 :::'3 ,...,.?~~-: :~::__~:: ::;,__: _~-~. :~: .,:-;s .~.::.- .-,:; 3,"ea:' :::~'.3..':~ 3-3." ,- -. ;',';- ~. , ,,"- -"'-' ..... s::;e :f :~e ::::";:-:3.,;e5:: :~e ::~~,-:' ~CC3.:~: ?::::: -,::; -:~3::'; :L::,,::,~:t'~1 3,':;',; ._'_ _ ;, ; ~,:s :,::~.: '" ::...:.>:9 C;i '-9 _:':C:",h c ,~,,--::-.:;."" ''=3-:2'::;', "?:.:';er:",i:-:2r',( -:;,,::,,: ;;c:....~::: .3::::2::, :.-:2=~':2'3.: =.~=;:=:,c", ':',.:;;:,:s:,3.:::~ :=", -~- ~-~-~, ~- --'-. ~-- ~ :::_-=, -' - -' "'. ",~ -- -.-.--. ....,'~~. 3'"':2.:1 ,-.22.1' :,... 2.~=3!/,e-? :':.2 ~;:: :::re':::-:-,::,.a:e ':y -~2.3c,r::~:i;2: ,:2::::;, '.' :...', C.":'.'''::-;. ::_,t',/ =-~ar:;2,......er:; ;r :.;;S:,;:'. '2':< :: .:C"C" 32.-:3,,' :::.,:::i:ies. .:; _, ::-:-,::':~ ::: ::-:252 ':;;:.:;.-5, , . :2:.-:<"-:"'2,""::;:: ::: 32:2::". ":=2,:,~ ::::":; -:.'. s:s. -::'..;S:,- :; ~ -.,' ,,::;:c:.;,' ...,' ::" : ~ 3:-,.3.:1 -,-'" -." ,',...-. ,-" "~'- -- ", ~. .J :e:71c~:sl:. .... ,:;::--::'/e ~ ..:::::.~;s .':'~ C:2:::.;, 2..- j S _'"'" 2-23, S~:'" '.'I,::,<:r '''':r':C:;;;''':3.,':'"'':G :-'2':' ei:"::~;'" :,"'e 2::2::ic'-~ :.f S'_:.l 2;92 to :c::i: :'..:'-::'::::25. ~'-; -,--',- -- ~ ~,,:;. '.;> - _. ~~-".. ., ~ ~- - ----, -eo ;2':'-e2.::'::::3,:.:;, :':,-_:7::..:,-.,.'. i':" :.-:'/::e :e':2:',:. 5,3,:2 =..~: 3a,~ ,.r:?, ':-;5, 3.:~,-::-:-::;-:3::; :::.-,e: ''''; 3:::--:~' -"-= , . :'(;1.3 ::~ :e'-S:I_3 :: ,0','/,':::,,"",",:::: L':.- ",':,-':::,- ..:,:=~l,~' ;~~: ~::':"<~~~~~ ::~"::i~~:;i!s~'ri~;,~~:/:,~" ~;:-=~"3;~.'~ ~~~ "ie.-::::_~: ~~ ::2~:'-::.::2 3.C:~~e;.a:':c:e~, 3:,~':::S. 32'.":~ 'S:':~- S,2~'i' :3.;'<:S. 3::e ::re:-:::';3:ic,~ :.= -:=~ ;"';' :2. :::.':.-~;-:,s:~~::' e.::-;;:":~::J, ::e~::~ "'::;:;22.:::~c:. '.?:'y:"'" ",","'- '."....',:;: .'i~,::=.,~'? :," :''"e- :':...r:S3'?S' ;3:-- ? :::--:-....:0.: _ ,u~_":.....:. -,~ .- -...... "-~, ,~,-- - - , - ~ - -~ :re:'?::' 2.3.: -_2.' .,-;: :: -~~ '-,;-::,'. a-'."s~::- ::-; < ;:-:~:: _:~....~.~~~:~,;:~.:~~=. :,:.::,~.;'~_;.j:~,' 32- ::'3 :-'::;;:-:-'--=c: :'/ _ _ ____.~ - - - -- ,-, ::.~ co - ,:, .',"-:' _ - -. . :'~:#"- ." - -';"::',"." ~'-' - -" - .- ;:-~-~".',-',-- . - ~,~" ~, -. ---% --::.' - -,.~ ,-~ :;.:; ':':,' ':':2,'-':',', :;"','::'.-:; ~, .. - -----'C..-; -. , ~"-"-' - -' -.::.0 ~, - ,- - -' - "' - -,~ - ~ - -- - - - - -~- ,:;~, ::;'" :;:;- -. -";'- -" ::,,,,,,,, -> .-,:, 'c;' ,^.,---" -~--,~ - -- ~,~- ~,-'~-- .....;S:== :.: .-~ ~,::.:;. "':;"''''. ::::--::3;'-'; .-~.. ':J, ,..--;.-', ,'--' . :r.' ;:.:: '0';._ _ --;:;: -. 2.:;.: :,-;'~ ~ y;':',i :,?- ''-':'-':',-' ",,- - '- ~ - j 3. :3,"":': _,1:;'-' :l<' ~: ; -,'~.~:::.~ ;.::: -~ ~'" ;:., -'. ;'''~ . ;.S --:: - ~ - -- r.~~ .-:=.: 3:"':- :::.'..;'---- 'es~ :' ~<;;:-::S2 ::; -- :=;:. :;-.--; ::::. .' ~~ :;"-,; '-2: .--?-s- '5 -e~: ~" -::0'''.- _" -:::..;: - ,::',::;r. ~: ~~ ~ ."' ::: -, - -- -- ~ -_. - - - -. - -,;' - ~ - use--; ::-,:;.: :,-,:-e .'0 '"'-=".?: '" 3i.:::;,- :::"/ :;:,-: '-=:'..;es':-; :X::;'"'.? ;:-~:,' ~~- ~::;;:~'ic :~:: s: '. ,. -:2."',:Z,~i :~ ~, 'c::.:; :; , ::'\-::~::-: ecs: -' --_. - :~ '''", , :1cus:ng authority of a cirj ~~:;~;: :CO or rr.ore snail IliC!uce s', Ir., 1 C miles from :he ier;jtc~ :'1:Ged howe'ler, that the ar~ ; authority of any city shail a ct 'ies within the territorial ::CUt;~ as herein defined; and ~lJ~J': f ,:::~eraticn sr.al1 not extend Cf."" ;r :i:e Cou;;t'l In 'NhlCh the c:;~ .:" . '\'1~ . .authority s~all h~'~e an,! pcW1t r :he count'l In 'Nr:ich ih... C'!o.J' J ~ "/ l ~rr;ent" shall include .the United' srr;er.c'l ~cmJnlstratlcn of ?t;b. ;enc~1 or ;ns:rumentalilY, ccr:o. ? ~:-:ited States. : ::21"'. any ar:a .'Nh~re d'Ne!!ir.~ . re3son or cliapldaticn, cVet'. ~ri',er.t or ces:gn, lack of '/en:il~ 'c:lit:es, cr. any cO~CIr.alicn ~ 'er;ta! to saiet'!, health alic 0110(. ,," shall mean ar,y wor~" or ~3r, Sf remove buildings ~rcm .'< or i.,mde1.3.<ing may emcr3.e.l :a ~o ;:::uclic ,:r..;~poses, inc::..;cil",q :~2.J or corr:mL;nlty purpcses: cr nt. safe and sanitary urtan 'Cf ....,ts or olher iiving ac::cml7lcca. ~c::r.1e; S:":C:' 'Ncrk or u.":cer:ak. ;s, land, ec;uipment, fac:lities ~i ;::rcpert~1 reI" necessarj, c.::n. :urtenances. strgets, se'.'lel"3, s::? :."eaa"a::cn, c:aid?n:ng, "I ....' ~I'h r""....~""~riC;-i ~,-;",.., ','" ~,l" ~~,~;::" "c::., .....~. '..;.":e-ses; cr :::::m::naticn cf the fcre-;cing. c:" also may be applied to l1",8 -=.nd imprO'/ements, the ac~uj. ~o(jticn of existing struc~ures, ~;..;ctjcn. aite:2ticn ~rc recair 01 ail ether 'Ncr:, in connec:!cn ',CCrT:e~ shall mean perscns cr :t..;nt .or ir.cc~e 'Nhic:-t is Me as- .:-:e aL.:therity undertaking lhiJ ~:Ie them, withoL.:t financ:al :ent, safe and sanitarj cwei~ ~Q. I~"ilean any netes, interim C9(' :r.ue certificates, or atr-,er cbii- crity pursL;ant te this cha~ter. 3.:1 :nc!ude all ~ar.cs, inc~l.'C:r.~ -=os ~~er~cr_. arc cr::cer::1 ct ~er-?to, or !..<sed in c::nrec::cn re. in~erest and right. !egal or r.g ;erms fcr /~ars arc,ierJ ;--:'~aGe or c:>:er.'/ise ar.c :h, .;;uch liens. ~;. 1uthorit'l" or ~cbljgeet sha~ ~!'ltures, 'trLis:ee cr trus:e~5 f~ ocr demisirg to the autr.c~t'f ,"'" ?'..!BL:C :'---!CLJSiNG 0:::""1. ~2: /~ert'! used in con.nec:ion ':'ith a ';st...:s;r.g:r:!es~. cr ~Jss:gnee or ass;g:=ees cr sue>: .ess::r'~ ':::~,es::r " art 'h~"""....' ::a"'d 'h~ =~r'"'-~al '-"~"Q~~""'""I'"" ,./~.......:. If'? ." ~,-....."~,, ' l '... . ~~<:;" ,...:;... '~",""-'" , .'."." ,\ l~art'! to ,an:ccc~tr,:c~,::vl~,~ ~~~e ac~t:~~~:::/. ~::~_' 2J~C-;;, ':'3'502\,,9/4, ;.:~5;"'~.1;v ;.l..~.; ;7'.~~'''''';'': :-Gl1.04 Creation of housing authcr;~;es.- In '-0'" '~;"/ as ;...-,,-',~ ,-'-':_""r'"' .'"'~",,:- --"-1'""/ (11 ~a " ....". ' ,,<:;'. ':: ., ...<::." '_~. "'. ,:;', ~ '" ."';':;.... ..dl~d a pubiie ccc:/:cr:crate anc:clir;c :0 :e'"r-:;'.'In "-.e ."OUS'"g '~"''''or'I'I~ a' 'r-"" ~.t-... ---'/'....0'""' ,.....,v ,s';l I, ",' 1"',,,",,, : J , '_""~ 1..,,/. ~"~ ,~_~..., ,....,,' If!(' that SUC:1 authorit'j s,ia:1 r:c: ~r:::::sa:_~ ar.'/ :1...Si. ~ ar exercise ,its ::c\'Iers her2'..:.-c::e: '..:~~:i cr :j~12S3 "e,;c~~rn~r.~ ::~::' c~~:~,~:y?; ::-,~Ee:.~:~7:i;";,:;c_~,~:2!1 ;jeo:::ar::: .hat ,he,::; ,s "~_~ ,_r =.., ,:;:~,' -c. "f "'-' lH~l.,,~', r ~~ ~:~t:d T:~ea;~:,~;..;~/;;~t:~r\~~;sc::~~':'J~2r~,~, :her::; is 'a) :'ilay::::e mace t:y ~he ;c'/er:ilrg :c::~, ::r :;:;: ::'Ni. ~~!cn: 8r ':ti Shail ce mace :'1 ~r:e:::'::;'-i.~,.:: :-:::'j ''':C:Ci :~2 I ,,' -. ,..; _; ,,;,... r' -,...::: __ :~-_....._ _ _ .'- _ ~... .iit:gA a ~e"l"cn ",gr.~~ ~/ .;::.... .:::S"~:::,..,, ~r 'd,':;: ~.,/ )SSer:ing ~hat there is neet ~cr3.~ 3L~~,:r::~1 ~,_: \;,-<:::,:'1 n S;,;C~ cit'/ arc: reC;L.:estir.g ~:-,2: ~:-,e ',;c'/=.-:-.:;,:; :c::.' 3": ~e-::are. :::' The goveri',ing tcdy :T:a'j accer a resQi:,,;::cri deC~aring that there :s neec fer a i":co..;s:rg aL.:thcr::~/ :r te '~:~j if it s,~all find that: '. ,_ , ,. (a) Insanitary cr ur.safe Ir.r-:aCllec: :',';'?ill~g 2CeCi':'"'.' ,11CC3licns exist in sL;ch eily: or (b} There. is a ~,'"':crtage cf safe?r sa~itar/ ,j"'.'8[;:rg. K~:::r.:r;:cda:;cr:s in SiX;-: c:t/ 3':2:;2::e :: ,:erscr.s::r '(ffl :nc::me at rentals they can affor=. Ir. :::e;err:;ir:r.; Nr.er~.er ,jwe!linc acccmmccaricr;s are '.lr;safe '-Jr :r;sa~. ~ary saic gov;:rnir.g bccy. ma,! :a;.;e ir::: ccr.sice.r~;ic~ ~~e ~ecree 0i oV9::~rC'Nc::r.a, :~e ::9,"::3."':;:3.C9 Ci :2i:: ~::',e:;';e, the Ii~nt, air, s:Jac9 =.;'":c a.c::ess ?~/ai]2':!9 :c ~~e ir.;-,abita;:ts of SL:C,'1 cwe!!ir.c: 2C::::,'7'.I7"",c::a;:::;:s, \'-:2 ~i;:e and arrai.gement or t:-'e rcCt:is. tre sa.-:itar/ :ac:ii. ~jes, and the extent to whic:, ccnci~icr.s exist in SL:C,'"': e~:icif'igs which endanger life or ;:r::;~e~/ ::::1 ;ir9 or ..:; 1:-: e: causes. (3) In any Sl.iit, ac:icr: or pr:ceec:i,,,,;g ir.'/cl'lins; ~,'-;e vaiicity or er.force:.'.er"',t of cr ,::;!ating to ar./:::ntrac: ::i I~e aut~orit'J, the authori!'/ shail be :Jnciusi':9!'1 ~eemec ~c ha'/e become aStaciis;;ec ar.C aL.:t~crized:o transact business and exercise its ~cwe:s i--:erso..;ncer !,teen .:rcof cf the acccticn of a rescll.it:c~ '::'1 ~,'-;e ':::::':_ 'lming bee,! cedarir.g 'the need ;or ~he ::L::-:crit".J. S-l.lC:i rosoluticn or resolutions shall :::e suffic:e::r :1 it:j'ec:ares :har :here is such neec for an 21.1thcrirj ::.r:d rir.cs in Sl.it:- 1lanliaIJy the foregeir.g terms, .-IC fL;:-:h~: cetaii ce:r,c necessar/, that either or both of the above enumerar~t c~ncilicns exist in the cil'l. A CGC'I Df s~c,l rescit.;tic('~ duly certified '::'1 the c~er~~ shall t~ acr:-:is3:~ie in aI/i- r::~~~,_:~;2~{~S'~:~;8: a?3~~;'~g: :~~;~,~:;~~~S'2-. 421.05 Appointmer:t, qualific.]tior:s, and ~e(1\,.;r: ,:;f commissioners; hiring of emplcyees.- (q W:-:en ~he governing coc'!;; a C:,"/ ac:cc:s a "SS- ,:Iutlcnas aforesaid, ~r.e mayer, with t~e ~:crC:"'/2i cf ~~.e povernlng body, shall cromerl,! accoir.[ .-:0 fewer :han ,IV') oerscr:s, and no r..ore ~han se'/er: cers,:;r.s. 3S ::Cr'7"1' ,11ISSiCr.ers of the authoril! c."eated ;0;' scc,,,,, ,'::;:/. -;-~rse . . ,. . .' ::i ;r.e:crr:mlssicre:3 '.'Jr. -:es;gna_ted to serle Tel" e~~9s ::~~' ~,C~CI~~a~ r~~.:::::r~ "9s:::e:::'/eIY: the re~a~r: Gg :::,-:."T",IS3icre:3 :;:, C,' ='= :esa;r:a:e~ te sera Tel" ~er77'.S :f .l /e3rs ~a:,i, :r:::;-- ~~e ~~I::~i~:~irab~O;~~~';t~~la:~;~:!f~"a:~:: ::a:,~: '::::~i ~~:;~:~~r~":I'~ :~:~ ~~'i~~:'I~';':~~:\,~/~',~e::-~;:~; ~f:er sl,;ch '/acarc:.' ::o::.:rs. ::2C1 :.~cr,,;s:,,:; a~~.~c::~', :.;0;_ a:ec: pursuant te :J'":is ,:,'l2.c:e; s:.~2il ;~2.'/e a: '022.5: ::;8 cCi'i,'7iiss;cne." 'tI,-:Q s.'-:a;[ :e 3. ~es;ce::t '.'I~c; 's::..:~"'?:~ '...... ~?~t:r: a '":cusi,'i:; :~'::'=c~ cr a :erscr, '.:; 'C'N :r "9- _" .~~~~~~e 3"~~~;::~:2~'~' ~~t;~.ts~~~/~~':~~;~~;; ~::~ ~~ :~~~ ~'"' :~~' :~~~; f ~~~c~ ~::~ ~ ~~ :~~~: ~~~:; e:~ ~'~~:t~C ~-: ;;: ~ ~ ~ ~.:~ ~C''';S:r.,; aL.:t~c:::'/, '.'r;:C.~.::~~.33;:,""'e" s,-~ ::;:=ci~!~c: at ~~,e ::;'7'02 ~ '/2.::3r~.:': -:::<:::;:::. ,,,",: ",-e :23e :: ,~~ ~ ~i:~~~~ ~/rr~~.~.~ ~: '~~ ~~i';t~;~ :,~~:::j ~c: e::~~; ~..... ::e ~-,:.'= ~ ~,,,," r. ;,';e ,'irs; .:,-:.e,c::f :r,e 3.V~c:t./ "2'/~ :ee..... ::::..:' .='ec.. Tiie ::2SS2.:;':.~ c.f a t9.'"ic'-;"::i.":i.":ss:c:,e:s :e.-" al-:c,/ in a hous;r~ :r:jec~ :r :~e cessa.t:cr.:f re.~: 3:"':' ~~~~e~;~~I~ ~er:~~'e~~ ;~~~:;e~,:~~i~,~,~~i~~~r~~;2;-::_: ~9c:uired !cr the ':77:,:e s.~a:1 ::e a::::::,r.te::cr ~,'-;e ,,;,~e:(- eired ccr:icn ci ,;';e ter:7i. A.t:2r ail ~eascna:le e:":.-:s :'a'le ceen maCe and Gcc~me!"i:ec:. il the :::::i.":.i7'IS.s:.:,. e-3 :;nc ::-O,at no :-:c'..;s:.'"ic ::r::ec~ res::~.~l:- --?r"t ::;:";:.3:::'/ ;eS:Oleii~ is a'/3.ila:le ':0 ser"le as a .e::.=.....; :cr.,'missioner, t~e ex:s:inG '/acar:c:1 sn2]1 then :e ::,:2': ;,i,Cl.:gr !,k,e ncr:-r.ai a:::::cir::;-;;er.! :....c:ecl...;;es set :cr-:,- ;r ::-:IS 5<..:csec:ici.. :-:::'.';e'/2:, $:"::.: ~:;i.":2.: ::.::c:r:.-=,~: 5,'iail ~ct ;:rec:l.lce :,'"'e -s':'..;;'-er:-:S:i~:~ ~;(2-C;Se :i::;:8.....c9 :- a:! s:..;cceecinc 'i2.':3.r,::es ::: arts:.::;c ::;st .3C::,-: -=. :e:lar.:-':Oi'TlrT',iss::,'ie: r";citi! at :::3.3; cne te:;2.,-:- cJmmiss;cner has ::een acccintec. No ccr:-:r:-:iss;,:;r:e; d an aUl,"10r:ty rr:ay be ar: a'f7icer or sli'iplcyee of :he ::t'/ fcr'Nhic:-: ~he a~t;;cr::'J is ereater::. A c.:r.:rnissiener s,-a.:1 :--.cic cif:ce until a s~c.:ess:::r has ':een acccir.te~ a:-: :-:as ':;t..:a::fiac:. A cer:ifica:s at ::-,e a:ccin;merit c, ~=s.c' ::Clnti.":.9ri'( of an'/ ::i7'.['":'"'.iss:cner 5,"';ail :e :ilec: ','/:L'- ::-e clerk, 3nc: such-csrtii1cate shail :e::::crc:L;S;'/e ::;'/:::8:-::= .:f t,~e c'..;e and ;:rccer a;:ccir.tment of s:...:c:: :::,"";"'; 5- Sicr.e,.)., ccmr:iiss:cr:er s,'"':ail recei'/s .--:0 ::r..:e'--:S2::- :.::r his c:." :ier ser/:ces but s;';2.11:8 ert:t;ec: ~o :r8 -e:-=~' sari ex::enses, inc::...:cir.g tra'lei ex.cer:ses" iGc'.,;r~e: - t.ke G'isc,~arge of iiis or her cL.:ties. T:--:8 re~L.:ir~~e'--::3 :f tr:is sL:=sec~lon wit:' rss;:es: ~o tr:e ."':l.irr,ce, ,]; ':::--,:-,:;;:, sicners ci a hcus;.,::; autt'icrit'J a.::!:;lj wlthct..:t.;=-=gs..: ': :,'":e date '::r, whicr: ~~e ;,eus;::g aL.::;--.cnty '.'Ias :~ea:e:. (2; T:~e ::;cwers ,:f ~3C.1 aL.:thc.":~'/ 5:-,2;[ :s:es:e: :- :ie:::,"";"',~;ss:c,-e;s ':-:e:.:;cf :r, :f7:,:~ :":,- .,-~ :: :-:iajc.":r/:f ti:e:::~"'-::ss:cr:e:s s,-:a!l ,:::rs:::'~:-? ::. :_:- ~'~~;/~S~.e2:~t:~~:~';:~~;g;r-:~s ~:L;~~/~~: ~~~::'~ ~'~~/~~~_ ~~ :I~r:cses. Action ~a:/:e ~a:-<en by tre 2I.L:-:cr:;,/ ''':~:- ~ ','";;e or 3. ."7iajcrit'j ,-:f :he ccmr.:issicr."?rs ;:r'?se:.~. '~r_;e.ss in ar:y Gase the by!a'Ns cf the autrcr::~j reCL.:iro? 2 ,2:~-e- ~t.:r;;ber. T;;e mayc." 'Nith t~e ccr:c:':."~er.ce:f :,'"",? :;:., err,ir.g :CC:I shail ::::ssi~r.ate wr:ich cl :~e :crr~:33:,:~' ers ac:::cir:ed sha;::~ ~r.e firs: c:;air, :l.t ','i,"',er: "-~ :n::: C;," 421 PUSL:C HCI;S:NG .~C' of ~;:e :hair of the authoritv thereatter becomes vacar.\. :~e 2L.:thority snail seiect 'a chair from among its ccm- r.::s3:oners. An aUlhorit,/ shad seiect from among its c:::r.:missioners a vice chair; and itrnay employ a secre- ta..../, who shall be the executive director, techr.icai e;<~erts, and such other officers, agents, anc emcioy- ees. permanent and temporarj, as it may re(juire anc s~-:ail aetermine their qualifications, duties, and co(';".- ~'e,-.sation. For such legal services as it ;nay require. an a:..::::cr:t'J may call ucon the chier law otficer of the ::ry or ~.ay empioy its own coulisei anc legal s~arf. ..:....~, 2'...::r.crit'j may delegate to one or more of its ager.ts or e~qioyees such powers or duties as it may deer;; pr::er, -';' N0twithstanCing the limitation contained in s:..:c- se::rcn (I) on the number of commissioners of a hoL.:s, ir;: 3:..:t"ority. any housi,1g authority that r.as incre :hai", S='i~r. commissioners on Marl:h 23, 1991, may ni2ln. ta,n :~e same number of commissioners it haa or. Ma,:h 28, 1991, History.-s. 5,cn. 17981. 1937': CGL 1940 Suc:o, ]lCC(3.el: 5,l.cn.5:1-413 ~ :~. ':'3.165: ,s. 1, 2, c~. 30-357" s. 273, c.,. 31,259: s. 1, c~. 34.250: s, 1. :.'1. 3~'::: ;s. 1. 2. c~ :01-6: s. 32. c:1,:17. le3. ~21.06 Commissioners or employees prohibited from acquiring interests in housing projects and required to disclose interests in specified ;Jroperties: excaotion.-Exceot for the leasehold interest held b'/ a te.-:aGt.-::ommissioner in the housing project in which ':-:e or she is a tenant, .'lO commissioner or employee of an a:..::~cr:t'j shall acquire any interest. djrec~ or inGirec~. i~ a;,~1 ~"'\OL.:sir,g prcjec~ or in any property inc~L.:Ged or ;:ia,~.r.ed to be inc:uded :n any project, nor shaii he or s,"',e ,"'lave any interest. direc~ or inciract, in any cant.-a::: or :rcoosed contract for materials or services to be fur. nis~ed or used in connection with any housing ~rojec~. If a :ommissioner or employee of an authority owns or c:...._:rJls an interest, ciiet.::t or incirec:, in any pr:pert'l in,::'..;:::ed or planned to be inciuced in any housing ,:rcj. as:. r,;a or she shail imrr:ec:iate!v ,~isc~ose the same :r. 'N~<;",;:: to the authorit'l, Suc~ cisc!osure shall '.:e e."":ere-d upon the minute's of the aL.:thorit'j. Failure so to dis::cse such interest constitutes misconcuct in office. 33H~~:~~~:;~.5. :;:1. 1798:, ~937': :Gi. 13~0 5";:0. 7'lCC(3.1~ s, 2. :;:1. 3.1.~~':J: s. ~21.07 Removal of commissioners.-For ineffi. c:e....,c/ or neglect or cuty or misconcuct in cffice, a COr:1- r.::ss:oner oi an aUlhority may be remO'leC '=':1 the mayor w::'": :he concurrence of the governing body. but a corn- m:ssi-.:;ner shall be removed Orilll after he or she s:-:aJl h2>= :een Given a ::='1 -:d :he ::~arc:es at !east 10::3.'/5 pr'cr ~o (he ~hearirig thereon a;-:d had an occortunity ':0 be~8ar: in persen or by counsel. In the a'lent of ::;8 re...-:'::',':!.Iof ar.y ccrnmissioner, a record 0; the ,~rocee-:' in:;s, :.;gether with :he charges and fincings there:,:. s:iaii be filed in the office of the clerx. ~. ~~st~~Y:j;sl':J~'. c.". 179a~: :937': C::it" 13.10 3"::0. 71::0(3'g;': s. :. ::1, S,H: J: ~21.08 Powers of authority.-An authorrry shail cors:itule a public body corporate and ;:;olitic. exer:::s- ing :~e public and essential governmental functions set fcr:~ in this c~aptar. and having all the pewers neces. sar/ -:r convenient to car,,! aut ane: effectuate t~e ~ur. :Jese and::rovtsio~s 01 :his chamer, inc!udir:c tne ~G IO'....:i1g po-':"ers in 3cditlon to others .'lereln grarltec: '~, -:-::: Si..;2 ar:c' ':e s:..:et.::;:c ~c'/9 3. s~3i 3.~:': ;"':. :re sar:-:e 3.! :!93S''';,9::: "':2';e ,:~~:e::";2; :;:";C::::::O :-:': ;::2...<2 2.~,: exec:..;:e ::."'::~3.c:s :;,~: ::,-;?; ,;S-"_ -~-:'" r:ecessa."'/ cr c~r'Je:::e",:-: ::-:e e:<er::se:i :~= ::"'':.': e! :."';9 2~t:-,or:ty::e 2:::ea.":i1 eeL.::": :.i...::";:- 3.,~', ce,s. a;er:s, or e~::c:,'e9s. rc; :,~e ~xe::..;s:'_-= :_~::-: sf :ii:r.g 9',':C::C..... .:3.:e,-s: -=.rc: I: -:a:..;e 3.::: :-:- . -"" '. t,.~e 2;-:-:9.-:: a,"',::: ~=:e3.: ':~/ia",'/s. ....;:es 3.:,",:: 'e:;:'~ 3.: :-:: r',et Tee.is,slen: 's:",": :~:s :,-:2.::1e.". :::2.."-:' ;r:: e"-=:: ._~ ::'.'/":."$ 3.,~,,: cL..:r:::sss:: :,-e 2:..;t-:.,.. 2; '/t:hin its 2,"e3:! :::'er2.:,:r:. :: :r9:3'-= :2:-, OL.::' aC::..;:r9. !ease, a....,: ::ar3:9 -,::..;:;;....::: :': e:::; 'y ;:i:'ii:e '.:;r :he :::-:s:r',,;::::::.~.. :e-:::~,s:;'-:::c:- . _ ~ ''';_ ~9."":. a::2o;::.~':."':.:r -s:a:':: 2,:'/ -,::..;s-: :;;: e:':' ;;'-. .:2,--; :.-:s.'ec.. o : ::r2.r..::e:. ::~::3-::: ":,' '-:9 .._..-:;;.... -::: , , ,^ :;:. ;:..::;-"'-e~::' .-~ :::"--:, _:; ':0. ~. ....-,::. - '?' ~- .~ -= - - . ~,- - - .. ,~--:-. ..:: ~ - ~ ~ - . ~ - :::. .' c__:: - -0:. ~2o's::: :,' 3;:;'-,:',.:~:,,: ?r:- 3. e ':' ;;-?- ::::; :c';:es. ','..:r:-:s, C': :2.::,.::85 :cr. c, ;"'; ::.-:....,-::c: :.- _ r.CL.;s:,'1g .:;rcjec: c: :."19 ::::..::a.....:s :,"',9"20'::;;: :-:. ~~_ r-,CNe'.:e~, t;---;at no,.'i::::s:a~c;.iC =.:~,'''' ,elr'sr :C'.'.-?,' :. :~:- v:s:c,~. ;;-: :~:s c~a::e-. ::--9 ::.~:~:r'~." 5,"':2: ::C: ::-Z"';::, lease, cor,:rOi. ;:L.:i:,"';2.Se.:r o:r,e....,...:se eS:3.C.:5,- - ::.-:. nec~ior. ','/ith or 2S a ;:art 'Jf ar,~1 ~0t..:S;,'"':; :r::;e:: :." =....:... et:-:er real::r ar':y :::--o,er :,c:er.,/ '.:~::::-::r ::5 c:,~:-: _ s:.-s:=,'7':. '.'Ie":" ~a-:,!:::es, ::2[';:S. :.. :l'-'-::~ e:'_,:-e~: tt".e :t..::-":-::se d fi..:r.'"':!s.:ir,; '..;t:lit~1 se;"',!:e ::1 2....: SL.:C,-: ;::rcjec:s 'Jr to ary le:-:ar;~ 0;:1::::.1:20,.: ~;-,e:e:' ~ :.-,e 9'ie:-:t :~at a sys'!e~. 'Nor'..;, ~a:::ii,/. :i3..::.:r::.--e.' e:'..;':' r7'.er; il:: :~,e iL;r::<s,~:,,~ :; :r,e sa,7.~ _::':;,: s-e-, :?: :.eir;g 2:t'..:2.i[y c:e,'a:s-c:y -=. 7'-..r:::;:2:::> :- :.:.,';.::: :::n:9.'"':'1 'n ::,e ares. :; ,::~ra;::.~ :r ::-:2 ::I'/ :.. '--e :e'~:' :c,~/ :;:;:-:-.ecia:eiy 2:!2::=....,: :;.,e-=::: :~:'::Ge':, --~, ~hat ;,ct.....ir.g herein :;:--;2i! ':e :::-,s:::..;e-: t: :r:-:: '~Q ~e:~~:,~~~~~;~~i~it~~~,\~:~::~~:;~G:t~:~~~~~:~~/:t:~ ~~'e 3i',_5~ ~~~i~~~:~~.e:~~~=c~_~~':~;~,'~:'~::~i~'.._ ~:~!~~~ :;'~~ ~~~':,3;~:~ ~; s:.:::-, _:::it~/ ,3e:,'::~s:: :;';~ :.:.~-:: 2o.-::J :,~= :~~:;::'":3 2:-:: ::::'':::2.-::,3 :~=~~:': a-::, :-:-,.. tc :r,e ::j';~;'2ry c::~:,a;~e: :,: ::-:is :~~~~~-. -:~'~~:;: ./-~ ~~--; ;:rc";5:C."'; :f :2W, :: 'r:::..:::; :,-: a,"':'1 :cr~~2:: :e1:- ~--~e:' tic....., ','i:t:~ a ::r,Jje:::. s::;:'..:;a::(;,.s' ~=:''';li::; :t~2: :~e ::~. ~~~f~:~;~~iZ~;~~~f~7;!~f,:~~('~~:~~:~~,~:~, ,. . c, :,~,e :~::ect. -, ': ~ase c:- '9.... =.~. :;'.':e '--;5. -:'.:S-3-3 :.:::-' --~-",--- , - _'-'..~. 0>, ,~, ,~,~, -" -', ,- ~ ;;>'.. ---- :;;:;, :~'se-e-:. :=.:--:.= -2.. ,. ~ ._~::::"" ':: -:=.- ;-" "co- .-~'- --- ,- ~-~- ~,~ . - _",,~,. -:0."" ""- . -~-;: "';- .;;~ - ,- -- - - - - ~, -- -- . ',.- ~ .- -.- ~ ~, " .; :;::::;:- " -e::-3 :.-: - ..- --- ~. - ---- 2-:r2:::&''::: .... 2......./ ~:~s;r: :r::-:?':: ':':::. ,3'';:: 7:: ~ .-~ !::":'"::2::::";S ::::-'1:2'::2': :.... :.::s :~2.::=:". :: 25::::: :;~ :::. ~ r~'.32 :~:; ~:;;,:S :- :~2..":~S :.'"':2,-=':~: :: :....r' -::;;. ~ i........,:~:'..<:? -ea! :::r c=:-s:,~i. :r::-2:":'..' :: :'",:~:.-,.:.::;~ .:.;.:;,:, ,::tai.-: ::::::'-';5 o...;:::r. ac::..:ire :'/ ::::. :~3"":. :-e:..:> ,:::e',;se,:r ::."';2r....;s22,-.',' -9al c~ :2r3:-:2o: :'::e":', ~. arJ ir,:~:es: :;'2r=:..,; :: ~::::..;ire:':, :.-:2 eX2~::,3=: : .~= .:':','i::.":: e.'7",:r,er':: :.::..-:-:a..-, ari'/ 'e2o! :~::e:-:'.' ~-- . ., ieas2, 2:<::-2;,,;ge. :;3,"'S:.:;: 2SS;gi. ::2-:;e, ::r ::s:::;;; ~~ 2r'/ '23, :r :;e:sor,3.: :'-::e,,,,:/ ;,' :;.,-:'.' :;~:2:25: :.--?-e~: ,. Ir':s:..:re :r :':'.'ice ':r :.-:2 :,-,s:..:ra:-::2 :f 2.,-',' -..::;:. ,,;,:-:,' ,::~; 5'::':2.I:r:::e:":,/ cr ::=:~2:.:rs :' ::--2 ::;...:::-:r:-': ~__ ar/ ,':5:-:3 :r ia:a~:::s: ': :,z:..;~:;:r 3:;9:; ': ::::2'- -:; .. :;:;:' ~ - '::";:2::,,;e:,.: :~ ;rSL;r2(';:e :r ;:''';2.r3..~:.:;es .....,.... .~.=. =~:;;'j; - . ~ - -. ~ -. ~ - - - - - ---- .-- ---;:" --:: - ~_. - - - - ~ ~ -- ~ -- ~ - - . - - . :::1- ?:-: -2::-:-';-- :~: :-3 .~ -- "e: a-- -: =..~: -9:: '.-e :~:: ~- :. :':,':-; :;;':;:-5 :. '2.:':~S :;:--: :::"'2~ :.::- ::,.;...:~s. :r :._=~ 3.'...;:....:~ - s:~=:'..=: ::~~.':=s ;. ~-? ::_ -'.. ._= :;:2:= :- =. :.:::~ '.3,<=- - ::---;-: .: -::'"::::.::e '" '~S2o=.r::":, s: '.~e ~_:e:: :' -:'_5:;';. . ~..- - .~ ,_. -- - - ~ ~-' - ..- ~. ~ . -- -.. .. - ",,''''' - - ~ ..,.;; .::.::'" - - ~. --' - ::-:.:: e:c;,- -:::.:::~s ::. .' ;.-: '.3.";2 :~::' ..~. --- -'" ;;:::, ,;~.' - -:::""'" ::- ~ ,S:2- 53. ::::e-:3....:=: " :....2SS~S ---- ,- - - - .~ __w. _ ~, _ ._ _...- --. .::.::~= -~ .. . '- - -~ -- .' ". :;.;;.:::;.:: . - - ::.= ~ - -. ~ -- . - -- ...~ - - - ~ - - ~ ' ., '" ~ :::'::- -'- - -:,_: _:: '-:=;,;. :~=~;e .:;- -.-- . - --= ~. -- -, -, ---- -_._- -~-: ::;: ;,~?= :; ::~-3...': - .- ','- '=--::-- :X:' '. ~ ,:.... ;:e ::::.~ :;e' ~c':: :'. :. .;;.' co 'co e'::- -.::. --,- - _.- I I i . I I I I i , I i ':;. - - ~. . - ~-: ~. . ~ ~, . - -".:: ~ , -, -":-',-- ~2' .:9 ~.s :'.::':2 : :-:-:;:::- .~ =.: -=::.:- ~-= ::-:'-:"= .- - - .::":: .:: - - ~ - ~': '::'?: e ~':-3 ::.: '--e :':. :: -:::e :e-' --. ~~~:~"~ ~-: >, j; to have a seal and to 1'18 perpetual succeSSia . lets and other instnJm~~ ) the ~xercise of the "'0 ~ i C?Ur11hraugh a,ny O~ts~, S, ,or the exclusIve PlJ~ 'c :0 make and from time. Ill" "aws, rules an~ regUla!i~_. a~ler, to carr/ !nto effect e authority. "~ ;~eralion, to prepare, ~ .,,' Jerate housing Droil"c'~' I '. .' '~'~, iQ .",": :' reconst~~ctJon~ irnprovt:<f.~' i any hOUSing prCjec: or ~; :. . .:;,' let for the furniShing by ~'i4 : pn'/ale, of ser'.ices, prrr1o,q )r, or In connectlor: with,..Jt :uoants thereof; pravid&d"i':- r,g any other power or Proo~:' Jthorlty shall not canstl1.l~:j,: ather.vis~ establ.ish in CC~~'. 1ny hOl,:sir,g prclee: or atfoJ"'(~:. :ert:1 uncer Its COntrel, anyt ;l5, or other equipment fOll, ;:iiity service of any kind tQ'~:. t or occupant thereof in !f,.r~~ c'lie;, plant, or other eGUi~~'.~; he same utility servica.-lc . a municipality or privale r ticn or :he city or :he terrf.'~ hereto: provided, further;~ construed to prohibit the.';f. / the authority of any SYs-':~: =c;:.:ipr:1ent fer the 30le alic'-'~~.' ity services from any SI..'C,~,l 'oncem and then cistribut.~lj._ d'~ project and to the tenants;; notwithstanding anything"f:_ ~is chapter or in any olhe(l lr:y contract let in connec':"-* ,s requiring that the c~r(' t:, :rs comply with requi~~~l; and maxlm:..rm hours of ~ ::nditicns which the Fgd.~~. :ached to its financiaJ aid'~~ ..,~;~ '/ellings, houses, accem. r/ stiuc:ures, or facilities:!; )ject anc, subject to the) .'lanter, to establish and! ?refor; to own, hold, an~,._~ ~r.y; to purchase, lease,;~. by gilt, grant, bequest,}: or aerscnal orooerty or -:: ~ by the exercise of the j / real property; to sell, . ;n, pledge, or dispose 01 r an'l interest therein; to . 'ince of any real or ~er.'~ Jt the authority agamsl f; ra or agree to the pro", Jr.tees from the FaderaJ .t :~ "';~: (f1rr.e~t c;f the payment of ar.,! such cec!s ,::r ;::ar:s . ;"~of, wil9ther or not ir:c:Jrreo: .by saic ar..::,':cr!t:/, ~~.J:",{edl'n"" :;"':e OQ'N9r to Ga'l cremll.;ms en a~'/ suc~ ~ 'p:iu,' . , c . r3f1ce. .~~) To :iI'/9st any funds held in reser/es or 3;ilk;ng ;t~4"( ,or any funds net rect..;ir~~ fc~ irr:r.:9~ia:e .cis- -5_~~ men!. in property or sec:.mtles in 'Nr:lc~ sa'/Ir:gs :..--...~ , rally .,n'/os' 'un-s -. '.0''''',.... '0 .h""i_ --0'-". :<;;j:" ksmay,E.:;I , ~" ,'-' ~... ;-..., \ u,~".~ ,lL'.", l;}D'f. (Chasets decer:tures at a .~rice .lot i'71Ci:; :.""2n :~e <f;;f-i).P~:pal a~cunt thereof and ac~rued ir.teres:. all ;::~,;}(l{1 ntures so ;::urchasec: to t:e car:ceiee. "" _ :.&.,Jo.e __ . . . . . "",'; (6) Wihn .rs ar9~ or operatICt,,:. ~o in'l:;s::s:a:e li1tO ~9 cwed:ng, and ncuslng ccnc:tions ana :r.::: t~e a~s and ;;iethods of imprOVing SL;C,' c::rcit:crs: ~G ", , . roro slu~ a'eas ex's. I'"'~ "'no''''' ...-."" ;s a delermlr.e_;'I__~~:1'"' _'~~"" L ~~~ ~~~:~_.,,; :, ':':~~'~':',___~ . . JI'lOrlat;e 1..-. ...--..... ,t. .:>e...,_. '_L ,,- ::;,..... ",e, 'j .....No:;:.",,~ ._."...."'r .,.,cdaticns ;er persons of ie'll income; to r.ia;:.;e s~:..;cies and reccrn~er.datiQns relating ~o the prebler71 cf ,:~ear- 119. replannin?, an~~ecG~stru::~lon cr slur.-: areas aile "G ,crcDler.: .:;r provlCIr.g ::::welll~g aC':':r:'rTiccar:c...,s f~r ptrsons of :cw Income; to admllilster fair hCL:su-;; ?rcl- nances ar.c ~ther cr,:::inances as a~c.c:e:::::i ::::8S. eeunties. or ,::~.'ler authorities 'Nr.o wisoi to c:r:r..'ac: ,~cr jCmlnls:rative services anc to coq:erate with :r.e ::ty, If'le county, the state or any political sucdivision therect WI action taker. in connection with S:":C:l prCC!erT.s: ard 10 engage in research. stuC:ies, and ex;:erirr:er.:a::::.1 en '.:.. tle subject of ."'Iousing. .. "(7) Actjr.g through on,e or more commiss;cr.a:-s or . Ol~erpersan or persons cesignatee by the 2'...;:r.cr::y: to conel,;c: exar;-:ir:atians and investigations anc: to hear l.stimony ar.:::: take proof under oath at public or ;:;ri'/ate hltanr:gs on any matter material for its information; to Sdminister caths. issue subpoer.as req:.:iring the .llendance or Nltnesses or the pr:duc:ion of :OCk3 ar.d papers and to issue commissicns for the examiration 01 witnesses who are ct.:tside of the state or r.:r:atie to Itlend before the authorit'/. or exc:Jsed frem artenc:- Inca: to make available to appropriate ager.c:es, Including these charged with the duty of abatir:g or ttquiring the c::rrecticn of nuisances or like c:::r:c:it:cns, cr cf derr.olis,.....inc unsafe '::r ir:sanitarl structures w:\I'"1in . :t.s area of operation, its fir.dings and ~ec::ml7:er:ca::cns 'WIth regard tc=r:'/ buiiGing or :)rccer:v 'Nhere ::r:::::':I":s axJ.~t '''''lich a~e::'angerous :0 'the ;:::UCiic health, r.io.als, lafely, or weifare. (8) To exer'::se all or any part or cOrr1Cinatio," cf powers herein granted. No provisions of law with respect to ac~uisition, operatior., or disposition or .:r::;p- tny by other :~blic bocies shail be acr:;iicacle to an .l.Ilnority unless the Legis:ature shaH specificall'j so llale, .,.tory._,. a, -:.', .;-:;a: !Si.')';"- CGl ~'t4C Suec, ;-::<:13.,,);~. 37. :,. ~5. 9::;: I. .d\.37'lG1. PU6LJC HOUSiNG C;:l. -t2~ re'/ar:!...;e ~': ~!;e::~/. 7_,:) ~,"":s -?:":: 3.r. 3'..;::--:(t,/ S'~2,~ ';x ~r.:> rer:tals te,' ::we!iij'~gs:r:.:s ,::-::e-:: =.: -: :~:c;,-9; -2.:2 :.":3,":: it shail .'ir:c to :e ne':253a,-.ii' :;r:e: ~: _::-:C:~c::: i:::'''9_ ~~~esn ~';.ici'~'C ~~~: ~~~~r /I.~~::,'~ :'~ :,~~. :~ .~=~'~~ ~ e:; ~~.~ ~~ ~~ ~ 'Nhate'/-?r 3curces:::e,:'i9'::. -,1,-: :::: s:.;;'::::er.:: . ! ~ I T: ;a:/. as :re sa::e 3~a:! :'?'::~e ::~'= ::-e :i:,_ c:cai e.r,::: ir~:,=res; :;;-: :.....e :e:-?-::..;,es :~ '.'":'; ::..,,~.'-:~ :',: 12: "'0 ceee' :"e::s: ::. s-c :: :::,'Oe .:: -CaiC- tainlr.g ar,c Gce:-ar!,;c; ~:~e :~::='::S. ,i'::::..;::;~r; :.-e ::5: :' ar_,! ins'-.:rarc2. ai':e :.~e e.:;:-;i":s:~a::',e ~X::;-3-?S ~ --::: a'...:~hcr::'I; ar>: (3) T,: -:r93.:9, ct.:r:....,; -:: :e3s :,-2.,-: :....e 3 /e-=.,-s ~~~:~~c~ 2.~t:~:~r~~C~~~~~i:;~: ':;~ _s:~~a:~ ~:::. 2~~:;:':.: ::~~~~ ::,:8 :....:=..~s: :2:'--:-:9-:5 ,'1,- :'~ ,'.< :e ::....e :,- 5:.;.::-; ::e:e~:L.:~es :n 2..~:f' ~e /e?~ :.-e.".;a::e-. =....,::: :: 72.:.::=.:."" s:..;c~ reser/e. i-'131::rf._,.:; :~, :~12:. .;.:;- ::~ ':~: ~ .:: ~.:: :. 421.091 Financial ac=::(.;...~t:ng ar.: in'/es:i":-:e.'":ts: fIscal 'fear.- (~) )., :::7.:.:::e ar,::: "'"' .:.""2....::a, =.::::.",---; 2.,-,: 3l.:Cit ir, ac:::r::a,~ce '.vi~,~ ~e':e~:::: a:.;::: Si2,~:ar:s :;::....:_ iie ;,oL.:si~,;: 3.~er.c:es s;-:a;r:e -:.a'::6 :;8:-.r:.a,ly :':' a:2r:i- fiee ::l.:c::c accc!...:,-ta"'L )., :::': :i s'-c:~ 2'';::: s,-e.,: :e :;ie::: ','/1:.'-: :,"':,e ;c"ie:~::-.; :::':' 2-: ,.,:::- ~."e ,.;.:...::;::- :::e~. aral. (?) -;.,,,,, l;s-~i '1e-."";;;l ;."...."....i...c :::l,,~"",...:.'/ ~;";::,I :..;;> !~~J~~~~i~ ~/~e~: j~l~:~i~~~:~~~ ~~:::~~~::;, ~-~:~;~.L:?'~\':.e~~;~;~~ .21.09 O~eratjon not for protit.-:~ is ~he pdc':, ~I thl&state that each housing aUlhcr:ty 3;--.a11 manage 2:~d operate its housing projects :n an eifie:ent marrsr so iLl :0 enable it to fix the ren:ais ~cr d'Neiiing ac:crr.r.:o- e.all~n~ at the iO'Nest possibie rates consistent 'Nith :ts PrOVlclng decent, safe and sanitarj dwe!ling ac:c,rrn:c. daflons, and that no housing authority s.,;ail cor:stn.;c: or ~rale any Sl.;Ct: project for profit, or as a source of 421.10 Rentals and te::ar,t $ejec~icn.- (1) In the ccera:icn cr ~2.r:a';e~er~t r:f ,~::!...'s;r::; cro.iec~s a.'"1 3'-,~r-Cr:t"./ 3,....a:1 =.~ =..: ::r~s ::s8:-,'e ~"e :::_ Icwing::..;::es 'Ni;~ j'~s:e':::: ~e--:a:s 2;:': :a:-;2.:::s 3e:ec- t:on: . (a) It .~a'j r~r.t cr [ease :.;",a :',',ei':ng a-:c:~~cca- liens :here:rL onlY te .:ersc:-s :. C',';' :"':c::r:-.e 3....: 3.: rett- ais within tr.e finar.ciai re2.c,~: ':; s,..:c:-: ,:e:$,:r:s ::f :C'N ir:come. (b) it r-::2Y rent:r :ease t: 2. :e:-:ar.: :',';'8i::r,; 2.c:::er~> .7:cdatioris c:::nsis::.-S; :f tr.e ,~:..;,~i:e; ::i rCCiI_s. :!...'r .~c greater n~rr:cer, wr:;c~ it cea:-s .iec:::ssa,~/ Ie C~:'..:':~ safe anc: sa~:tar/ ac::c..;:~CC2.~>:'-s :: :.~e ,c,':: :s'?': cc:::~par,:s r:~ereci, wi:,'1cut e'.e;-:r:'.'IC:.~:;. Ce) it s,:"ail ac::a;:: any .ce,~s'::i asa :e;:2:-: :,; =.:~:; ;-:cusing::'Jiec: acc:r:ing:? t~.e ::crcc~a:= ;'..;;::e::;,e~ as es.~atilshed C/ :l":e L..'~I;.ec ~:a:as L..'e.::ar::'~e~: c: HOUSing a:1C: Urea;: De'/e::::::r-e::t er ::~:e; 'e':.e~2.: a,;enc:es. . , '. _ . . , (d) The :Qepar:r:-:e.'"1t ':r .-ea::.'": 21;: ;-ar.a:', :2.::',e Ser/ices, ;:::L.;rs!...'a~t:J.t5 C..=..=. s. 23.2.2'::'3;': ", ~. ~aj not cor.sider ss :r.c'J."':":a ':rcar-:;c,:::2,":S .... '-e '//),-3::5 =~:::;.3ri 253:S:3.:--:e ''?:e~',e: :'/ '-=: :'e-:~ ~~:.'"1 ctl~er acer.c:ss ,:r :r::0::....,::::::C.;3 3~:,: ::2 :..;:::::': r.CGS;r.c o::~:!;cj';ties. - (2) ~'Jc:,~i:ig cc.;~ai,ee '.'1 ~.'-:s 3e':~:c"-: :;r s. ..:.:. ::. s,"1aiJ be c:rs:r'.,;ec: 3.S 'ir:-.i::r_g :.-8 :e',v,?: ct e.n 2.:..;::-:cr:;:: tG ':est in :n..,:?ige.:, :~~ r:~:, ~~'_~~: .e'i:~t, ,:< 2 :~~:~;: by J~e aut. ,C,llY, to \~.:.;a ",0 s""e.s,;, ,...,'"1 ~ra "c~s" ,:; ~.........~_, or cause ~r.e ap~clr::l7'.er.t ':: 2. ''?ce!'./er ~L:e:ec:. ;:-e.::: ;.0rr1 all :he res:r:c:icr.s :.'"':""::see :'/ :;-,;s :r ~,""'? 2preceding 3ec:ion. 515 c::. ;21 ?'~BL~C HCl~Si~JG ~ ..;, ';on - "T:-:is Scc~ici"', shad let a::cly :G '"'":.:es~,"'":;; :ac: ;;;es ".~,2:-:eC: ':/ ~car.s ~ace ;cr :l"',e ;:~_-::~S2 ,:f ::r:'" r<',...,~ 3~::--. ~ac:lities r~r CGr.1es::c ~a"'i.1 i2.::r :!~r:;:"2.r: .. ~. ::...:. Jr :ha :=ec:er2.! ~CL:s;r;g ,A.c~ cf ~ ~..:.3. -;13tory.-~ .'J. ::"1_ ~~'je1. ~gJ;- ;. '. :~. .95':. ',:9: ~__.. 'SoU: --~- -.::>1;'-;-, ::'1. ::S:3. 1945;~, .,:~, 15.<:::;:;:, :.~" -S.''05. ':J,:~ 1 ~ :::! ::: ~;:~ta~;" Z.~,:;i:;''3:~l~ ~~~ ~.;~ ~~'.~~:~'~} ~,.. ~;;3_~" .~~ .'~~ _~ \-:~-~l!:~ :~:l~,"">lr,::: ~qa;:~ ...as :~'la;eC ':;'/:;.3. ::'1_ -;.6...-:: ",,:;~.-.\s ~~'lc:a':: ':., 1. ". '-,a~, .']:;;- ~'l :.~, ac',,.~ ,w ;<-:. :~, ,",,11 ::: ~': "C;;, ..;::.~'; ~2~.101 False represantaticns ~o ':otain :cwer r~n: ;;-: :...ous:ng ac::cmmocations; ;::enait'j.-'/r~,:e\:-:r - 2-,25 3 ~ai59 5:ater.l9(';\ Jr represer,:a:icn. :<;,'iC'.'-li,~,'; :t :: :~ !alse, or Ki',cwingiy :ails to e'is.:~csc .3 ~2.:er:al 'a'..:; - :,':e,~:: ::t:tai.'i a :C'-Ne~ ,-art for :i::::..:5i;-::; :3.-::::;-:--.:-,::2. :::,~3 in -3. :C'N-tar.t hc'...:s.,'ig ::e'le!cCi.'s:-:::er3.l:!': ,:'...;r- 3:_2..-:: to ~r,is C,"'.2c:ar, :~a:1 the r:=:-::ai 5UG."1 ;:erscr, :3 '"=::";Ire-: to :a'l purs:...:a;'it to fecefal:r state s:a::..;:es, :s:,~~'::::uie ci rents or re:as and iec:',.;!aticr,s 3S :8t8r- -,:-~':: a......d fixec' ':y :ices;r.g authcr:;ies:r~2.:ec:::'..;rs:..;- :;',_::: :;-::$ G....,ap\er, a;cresaic, shai\:e ':;~iit'J::i a ;7'::sce- --2-2.:-':C"':;; the second :e-:;ree. pUi',is"acie 2.S ::r8viced '- 3. 77S.C82 :r $. 77S.:EJ: ar.c sac:- $:J'::l false 3:ate- '72:-; Jr repr9ser1tation cr failure to ~isc:cse 3. .~2.:efjal '2.:: 2.8 aroresaid shall c:r.stitute :3 separate cf79:;sa. _~,~;~ry.-~ '. :~. -;1.4S<!: 3. 1SZ, :.'1. ;->l}Q. .....~ ~. -..... , C';OP::!!"3t:cn :1 authcr\~ies.- .:'.ny :'Ne J; rTICie i"'":cusing 2.L.:L-:cr::ies :-:'12./ .c:r.:r ::::9;a\9 wi,,"': ane ancrr,er in tr,e 8-:::8-r::S9. e:tr_er :>_:~~,' sr :tr-;erw;se, ct ary or ail cr :i':9:r :C',',8rs '...., '1-.:. ::..;~:cse ci :iranc:r.:;, jr;c:ucing the iss:..;a("i:~ ,:1 ':cr;cs. :~:-=~!'..:r9S, nctes or atr,ar obiica:icns ane' :::vinc 3~::";;:,/ t:iereic;: ::!ann:n;;: un:er':2r'\i;-;r;: c',vnir.,;:: ,:c,;--:' ::'_:::,""1;. :;:ers.:;,'i;: cr :crn;ac,ir,r; 'Ni;~ ;-:s:e:: ~G a - ,:',,;sinr; :J;,::;jec: :r ;=...cte::s !cca;e~ ',';':~;--.in ,:--:e 3.rea-:,~'_,: ::-=~3.:I:n Gi ar.',icr.9 cr :'T1cre or sa'': aut:--:Grities, -'';' ,', . ~~~.- :'_~:,::;e. 3,:" 21:";;:--,:;:::" :;.a::' :'/ -'?S::'..:ti:~ :'~,;:.:;::-= _, ~ 3L::t:cr::e ailY c:~e: housing al..;:~cri~,/ Ji a:...;:r,cri- . ~s sc ~cininc cr :::ccceiat:ng w:tr. :t. :-: a:: en ::3 :e:...ai: ~es:Jec: ~o any Jr ai: such ;Jcwers. ,J..,,-,'/ 2-",:::--:c;Lt~es ,: -:::;; cr cooperating '.-'-lith one ar.::::~ei m2Y 'JY resciu, . ::-s a:coir.t :rem a:;;cng the C:H''0;;;ss:c"ers :i sue:; a'_::-:cr:~ies an e:<ec'..:ti'ie :ornmi:-:ee '.'lith ::'.:il .:C','18, :0 a::;: :n :,er;ai: :r .3-"':c;; a:":7"1or:ties' ','/;;:-: ,.escec: :c an:,' ::r :: ;::e:, pC','i.,:::S. 9,5 ;=...escri':::;ec: ':'.i , . 'esc!:..;::cr:s ':: 3:';C.; :::_.-,:...:::-:s. ~.L-:'.' ::<...;r.:j ;":':L:3~.'ig aL.;:,-:':,':,'! ~'?j =',:2-:-,:: :0..... : ~~~~CS:~,i~~;:~.~;~'~~:~~'/~;~~,~,'~~~~ ~::3~.~. :~~,~:. ~:~':~;'::;~ :~ t,\~.':CC2; ecec.,::r?::,:r, ,':c: :: ~ :.-::, ',,,';:....,.'=:;:3:: :: :": ~::3:r ::r:,:;rar:;s :C::3:2': '.'I;:~,;'" ::--,e ::'~(';:'/ ::;~ Jr :::: 3c:?~t :01..:1','.' an:: ~;''j :::'1 :-,::"5".; 2''':~'-;C~:''f .~a~i -=~:-=r ::-:0 S:"':C.i as;rser;-,e.'it 'Ni:~ ~eSC'8-:: :: ~rC!e::3 :;r :"::;ra,"7",S b:2.:~:: ','/:t:-:I;'; \:,e :::::1";:-::-/, :r::,',':se'.:: ::;2: ::: .';er:;rJ.r,te'::: an aet~crity '...;~,:e'" s. ~2' _:8 :"7";;'1 ::;'8- -~s~,:e-':! :0 cr ~xer:::s~-: ':y a :CC31 :;C'a,....,!,~; ~'-,~' _-:3, s...;c~ a:;re~r;;er1L ':;;",;;,_:: -,s:cr'/-, . ~';~. . j:;- ~--'- ~~.'-S:::,: 23. :~_ ~~.'J2 _.. I. .. :::71:nent dOf':",Jin.-":',~ ".,,,,"1: :l' .~....- ,'j '-7 ':,;::-,::0 3c.::;:...:ire ='1 ::--2 e:>:e,::::;2 :; :.-,~ :::,.,,.~~:' ;>.--- ...;....' ~,-~,:l,... ,,- ""a' "'---...-' N:::::,- : -2".' - '-,,;,~,~:~',,-~" ':; :'_~;:'s~s~-~~'~'~, :,~,S :'_~:'~~:;;.:;c..::.~~~ 2<.:::::::-- :'/ . :: 3. ,-eS':iL.;~:'::"' :eS:3~:r,; :.-:;:': ._~;.:-:_.:.:.. :::- :~ ::-e --::2, : "::er:'/ ::es::~-::-::s :~,e;e'rs --=:~:;'~"I ~sr s.~:,~, ::,,:,'::52S. ;.~ 3.'..;:'-c~:" e:,-='::~ ~ :c','ar :: :::::-,:,-~-_: ,:0:-:-.2:.... -r': ::--e 7ar:-er :':'. :i':2::-:=::; 7: :;.-::: - ..:.. p ':: s-,-': 2i...e2,:.... :.,::" ::e:: .: ::::.':' .: ..;se "7"2.'.' =-e :':.:::..::re': .~, ',:.,:: :":"'ar--::r. :':. : ~-: ._". .... . , .?:: :'::e:.,::~ :~;:!i";:': .~.:> ,~~, -" -:--:1 ~ ,_ ~~''- ,.. r 3~CG:'i'.s,:- ::::_.~ '--, . ,.- ..-, ,;:, ---- ~""-' -~, --, ',. .."st:,-,.-.; . ;.:: 3.;~ ..::~ i-: :=I::.:-~:.'i:;, ::~:~; J;:C ':;1..: i'_. ::"1;3.-~1 :-,.::..:s;,:; :~:-e:~s :: an 3:..:::- :~:t./ 5:--,3;1 :.,:: S~: e:: ."4 - ~ -,.. ._- - ..- - -,,'~ --,;~ ---,..-~ --""' .- - ,-"-"'~ -~,..",..-- - ,~ .;.:, _.::::;, ;;, ~ :; =_,0::.'..<.. " ::._~,;'~.;;_'--; '.'-ii:C:, ::-8- ,-: ~~;:-;: pr,::e,:: S3:~'~2.:es. .~ -= :,2.--.1 2:--::::':':'::::;:- :: ?'i,y hC:";S,:-;: :I::e::. 3..~ 2.'..;::-:,'::'.' ::,.~ :2'~,=: -,:: ::is :.=:-3.:icr, ::--~ -e,=.:::iSi':,: :. ::- e :'::;~ ~ ;;,':8-' ::=.- :~ C,'i;.'~.--,:;e :~::;r:;..~ ':,- ~-?_~,;:I ::-,9 in wr'c.-, :.-,e .,,;.::..:s;:-:; 2.~::-:' :.,' ::::::5. ,-,31::.r' -s. . - ~ . , --,,; ... Ce=~.'it:.:res.- '. ,-,', ;....~-=s .':- .-: ~ 3,''''::- :~:;:/ ."T'.2~"SS''';~ .:-- :-: :3 :S:~=::::,",,, _ ~':: ::,-::':='::= ::~:-:::.:1, ,.:..,~ 2....:.~:;,':~.:' -,:="':' 3.:03:23..:= .S:'_-::i,; :3:-:-:-:'.:;!:I ~:~~ :'..;:-::5e:' :2.yir~:r .'e::;:r.:; :;;-::=r::...r-=s :,':;. :,-::1 2Z....;2::: :',' ':. ":'.i ae~:-:G;'::'." ,--;a'/ :55:..:e 5..::'-- :',:-=~ ~ :.,:::-.::.-,:....;;es 2.S : '7'.2.y :a:.,::~~,,_e ,-C,:"::.:-; :S:-=-:_~ I J,. ','i:'-'ic~ :~-= :,":-::02.1 3.....,;: :....,;-3r-::5: 3.~e :3.', 2.:,~: ..,- _ ',....., . . :-, :--:-::-=- "'---- -'=.,::;:--~.- '. _ ~"...:'_;:; '.el'/ ,.::;,,, p-'':: --- '- - - -- - - :~,-= ;'::"';S:i:; :'::e::t ::,,8:--,:.=:: 'N:::- ::~e- .:-::=-~:s::!-.d ,-.::.,::=e.....,::..:~es. ../:t:-: S''':::- :r::.:='?::; - =- " .~ i ,-;.-;~ :~-- 'e:er21 -:::';=-'-'---::'~. - '.e,',' :r:"7" :;.. ~ 'S-. e~'-:~ j .0'.0' ;' '1 ..,:,;.;ed _.,~ ~.:. ,::~S- ,-: :':?s;-:::~~ ;i,:":S ~ :i e',.' ',"'S ~e 'i.~,2..-: .::': in '.', ~,.: :;'J:i', :e:-e,-:'.;res: cr =-::-:-:3 -9'1e;,'.,.:::5 :ei"'_S,-:=, -",.' ~ S''';:;- :-=:-=r,~:"':~-::s ~2'" :>:? :::'::::::-2. ':'~;'; " - -=.,-~Cl -, ::~. - - ~ - -- 'y' - . 'e'.'e;-'~;s :; co:":'." e'::.3 :~ ::~-?- : '::~r:./ :. '-'? 2,:_ .. _..,1 , -'- -, .-- ~~--',,- ,:;' -:: ':: y- -;,-::;,'- ::. - -=,,-. ,.,...~ -, -.' -'~ -~, :: - --.;;;~ :; -:::~, ".",' "" ,~- ~._,~ " , .3;"';~ ' ::"'-2 3:",;e :r -:0.:",'. --=. '-.:>~ .-.:. -," -' .. - ,-- '-.:. ~~, ~, -, ,- ~ ~ -". ..:,-;" :;:_:::'.:s:cr. .- - ,- -- -~ ,- ':;;'::-' ':;',,,:;', ,'. -" .:;, ::.~. ;:;, :0:" -~. - - - - .~'-~ ~ .~. - - ~. _ _ r< _, ,_ - " . ~ ~_.~--, _ r< ~ _, ~~,.. - -- ~::- .'::'~, -:;.:;:'; ::":,'" '-e -e2:-:-; .:i ~,- -T"':' :,- ':::2.:'_::-, :-?:: :, ::,-,,: -,,:::r',,-; '-,5' .~. ,-;,:; .:: ~ ;0: .::~ ,,',c. y f ~ . -:c.- j'.' ~ ~'". .- 1-: :::: ~ ,':1:3 - - ~ - : - ~ ~ - j.t--:. ~:-:: :,-.::. -::. - -- ~e:~~'~ 2:-=,".:=.:;.- :~"'"~~: jes -c: -=:~::-=~:~:: .---~~.".:: ~.: :..:. - -=. ~ .. ~-- -.:. - . ~....a?~ :: ~:: :_ -,.::S:;:::':.:- ~, -:: - -. ~ - -.--::- J;.::- -- ---- - -~ - ~ ;;,-".:, ,. ;.. 'Jrs:' .-?::=-:-::.:- :15-: _::: - : - . 3 '. ~. - --=. -.:.-::,_. -::,--- ~~:'--:'':~ :_2o:-=-: :-~~ :.ci ."" '.'"".., -. _j :-- - :l _. -. ~ - ~ ,. ::::. ;~:,;,:i'~.':~'_i~:~- :~: . . 1<:,,-,,-,_' 1: ::..::: :;2.,e _, ~__~:;:: ~~:~~~= ~~~ :~,;;-==-~~e~: :. :_ ;r~::o_~;:}.~.~.~?~;~ --' _:::.: ::. .'i~ -=5: _' _, __ ~ _ :c ',,,,,= O' '.0 - -, - - ~- . :::.:a:.-=: - ~ ~. , - - U,.~....-. ~_ ----- .~ (!: - ~...'" ,,~~:, . - -. -- 1U:.~,:~ ~-':_:>,:;-::..~---- -- }y:r :," '0. .. :.. .-.-.... .-. ~~,:S:~;:~~~i:_ :.~,~ ~,.,. ..llt.;-..- '.. ~}!:H- '~;; ::-:';:s :940 Suep. 71CC(J..~1 i-t: , -.~~. ~e debentures from time ~ . or its corporate purpOst..~. refunding debentures for ":ng debentures previously ':' 71ay issue such types ~ :ine, including debenturlH" ,terest are payable: income and revenues cA with the proceeds of St;C~ ;roceeds together with a nment in aid of such pro}. income and revenues cA projects whether or net :r in par': with the proceed, nerally. ':e additionally secured by any housing project. prcj- authority. cners of an authority net ebentures shall be Iiatl. by reason of the issuanc, : other obligations of an :5 and abiigations shall so t:e a debt 01 the city, tr.~ it:caJ sucdivision therecf. 1..;,"',1'1, nor tr,e state or an:1 ,lail' be liable thereon, I'1Cf I entures or obiigations 'Cd -Gcerties other than thas, ;res shall not constitute ar: ,ing or any constitutional ~ation or restriction. 1010 Sueo. 71CCiJ.y) PUBUC HCUSiNG .' ;;. 15 Fcrm and .sale ot deben~ures~_ ~1. oecentures CI an a~tho.rrt'! S"2..': :e aL.::hcrized (1) resCiL.:t;~~ and may ce i5-3L.:eC 'r: ere ,,~r :'7'.cr::: IS nd sriail cear SL;C,' c:ates, mature 301 S~C:i ;:fi:es, a . t. . . I. average In eres, <:':5:: rale net .:r :ec:era SUCSi- a~ exceecing. the rate es~at:lishec 3.c.::r:ing :0 s. ~ be in SUC:l ~encrT':inat:cr:s, te ,r: S:":C:1 ;c r:;"] , 5."'" en "'r "er'ls';:>r;:>r! -ar"'/ 5""'... "'-...'.o,........r: "'r , (ccu:: '..... I :;j ,~ -....,.... '.. .......', '_";'~.~'~t.... '_'~ .~lratICr. pr,I'/lie;es. ha'i.e s:..:e:": -,an,., or :r:cr:ty.. ce -1t9S 1,>1 'n 5;..C.1 manner, ce ca'yacle :n .SL;C:l rr:eClum., '...,,-J " , p.- ,ent. at SL:ch places and be sL::jec: ~c SL.;C,' !oF- par; rederr:pticn, with or without ;Jrerrin..:r:-:, as SL.:C.1 'li., luticn or its trust incenture may pr:;vice. )./;;~) The de,:~ntures may be sold at :<..:ciic sale :'e!c :~'~';+~(nolice ~ucllshed once at least 5 da~/s _:,,-:cr to suc.' }1;-= in a.r.ew;i:ape;r h~~i,;g _a::l~e;~r~!i~~~C~~~2._:;e.n in ;~~e ',;:'-, tit and:n a "r:anc,al "'- ,/s~~f--e, r"L:.....,;" '_'4 ,n .r,e ""''''1 ::'~~"'d c:'icago, IIIir:ois, or in tl":e City of Ne'N '(on<, New "/"'Vorlc:: howe'ler. suc,~ deb:r.rures .11a:/ :e sele to ':'"':,e . Ffderal GO'ler~ment at pr:vare sale 'Nlt,"':OL.;: 3n} PL.;CIIC ~er1isIe~l..een~'/ent an ~I.'~r 'I' an 's"" ,.~ ...i '""'~;-'~"'" '"-s (~) n <I. ~ , ~ '_, ''', ' ~ ~'-:'o:: ~I__~'::,.':_",:: i public sale .:rcc'uces no :IC, ,0'- :r. ~~e .s', ~~: .3.li :,,"=5 ff(8lVec are reJectec, the aL:tnor:ty :s aL..~:-:cr;;:sc:: :0 "..;otiate ror the sale of suc~ ceoentures L:~der Sl.:C:i rales and terms as are acceptable; he'Ne'/sr. ur:cn their J&le, the State Board of Ac'mll":istraticn s;:ail:3 t,elif:ec, J(Jd no suc~ cones shall t:e so sole cr:e:i'.'eiec on l:ftmS less favorable than the terms cor.tair.ed in ar,y bids rejec:ed at the pue!ie sale thereof, or the terms eenfained in the notice of public sale if ;;0 :ICS '.vere /'OCsived at st.:ch pUblic sale, (4) In case any of the commissior.ers er ot7icers of ~e authOrity wnose signatures appear en any deb en- IurosQrcouDons shall cease:o be such c::mr.:issioners o(off1cers berore the de!1t/sri af s"c;, ':e:e~t:..;res, st.;c:' '~nalures s,";811. never-hele's3, i:e 'lalid ar.c s:..iffic:ent lor ail purposes, the same as if such commissioners or olticers had remained in office l.:ntiJ such ceii'/ery, Any provisicn of any law to the contrar/ nct',-\Iitr.s~anc:ir.g, In'l cebentures issued pursuant to thiS chaeter shall be fully ne~otiable, . (5) In any SL.;:t, action, or ::r::ceedincs invol'linc the vajjci~1 or enforceability af any cet:enture or an author. itycrthe security therefor, ar,:1 SL:ch dece:::ur-:! .ecit:ng !.n substance that it has teen issued bv 11"'.9 :::.:..::~cr:r/ :0 !id in finar.c:ng a ~,cusir.g projec~ to '~r-J'Ij:e :'Neiiir;g !CC~mmcdaticns fer persons of low inc:~e shall be ccr:c~usjvely deemed to have been issued :cr a :,,:cusir:c project of suc" character: and said project s;;ail oe con: elusively deemed to have been planned, Icca:ed, and constructed in accorcance with the cur::osas and crc'li. sicr:s of :r,is chaetar, " , 1. ~1!~,ryJJ.~1~5, ;". ~7}ai, '937"; G:3l '9':C 5Ut::C_ 7'C-c(:!.~;;~,;, ;,.,. 73.'5~ C:'. ~21 (2; iJ cove::2.r.t ~;:::.:t':s: :,ecgmg a!i ':r ar,:/ par: -:f its .-er.:S, te'?s arc ,"e', ~~'.:es, :,- 3;;2it':-s: ,T.cr:;;agil":g ail C~ 3r:~/ .:2:::i Its "~aj:" :e~:;:~ai ,:ro:-:.--:;. ~c 'NI"::C:; it3 :;;~~e~rc~t~er :~~~:;;~~;:i~:.=-;a~~ r :;~~~~r,~~; a~:;i:~'-~t~ S:.1C:"l '-e'/erues :.- ;:,-'::.s.""':",I: .: :e'/erart 'NI;~ ~es;:ec: :C iir.iitat:::iS (;,1 :ts -:;....,;3 ': S2 ease s,-:: :r~er.'iise :::5- ;:cse:f a"1 hcus:,~; :":.-=:: :" ~,",'/ :2:-: ~~-=reGr: ar-:: ~G C:'/er:a~t 3S to ',-I{,"'a: :"-e,",:- ~::;:;cr2: :-=s;s~r,:t:ig2_ l:c~s ,""':"'.ay be Ir.c:..:r~e-: :~/ 'r, (:2', To cever.ar: ~2~: :.-:- :e-:-:n:..:r~s:::e is:;;:..:ec: arc as :0 ~he iSsL;2i.ce :' 3''':::-- :e:er.t:..:~=s:r: ese.c':I:r ot~e:Nise, and as:o ::-s ..:se 2,-: ::s::cs::icn af the ,:rc. cee:;s :~erecf; tc:":',':: 'c- ~,-,e re~i2'::;",er,t oi Ics~, ':::es~~cyed cr rr:u::;a:ec: :2:2,-:'_res;:0 ::'/er:2.'":t ag2irs~ e:~e:c:,~,g :....e ':~e 'C," .-:; ,:=.; -e-: :r ::3 :e:';;:1[..:,--=s ':.- interes:: ~r,e;ecn; 2:--:::~: -:;::::.s- ::-:e de:ert:_;res, and :e cc"e~ar: fer thei~ -e.-:e-::;c,~ 2;~C ~J ;:r:'..:ce :r,e ~e;:-7',s ar~c ,::rciticns the"s:::. (" -) 7: C::"'9:2..":. 3'~::e:: :: :~e :~::2::C(';S :::,~,_ ar:: :ees :0 :e 421,16 Provisions at debentures and ~r~s: ir:den- tureS._!n c.::nnec:icr. With the issuance cf :e:entures Or :he incurring 'Jr cbligations under leases ard In order :0 sec:..:re the payment of SL:C,' ir.dentures:r cbliga. ticns, an authcr:t,!, in accil:cn ~o its ether .cc''','e~3, shail ,'lave power: (1) To pledge all or any part of its ';jress or ~et rents, gross or net fees or gross or net re'/enues to 'Nhic.1 'ts nght :hen exists or may therear.er come inlo ex:s:ence. tai~e: in t,";is ,:.-1a:"s; 25 :: '-e"ents C.1a.-;;ed ir: ;~e '::e-=.:;:~ :' ~ -:L:s:,~~ :"::-?:: :r ,:;:.:_ 9C:S, :.ie ar:1CL.:r:t:: :S "2$,-=: e3:,~ /ear:r :t,,;e; .:::9;:ce of ;ir:-:e :'/rents, fees 2,-: :~!-e" -a'/er,ues, ar;c as ~o the use and "dis::::csiticn :0 :9 "":':a:9 :...:ereof; :0 create cr te au!~cr:;:e ~h'e ':~ea::c:; :: 3:-=': =. ':.;r.cs ',:r '7'::;eys r,e:,: rar c:.~_s;r'..:cticn :;::e"3:~; :OS;S.:9:[ service, reseries, or ether :L:r::ses. =.,~::o ::cvenar,t as to tr,e use 3.r.e djs.::ositic.~ :f :,"'9 '7':"'9'/S ;-,e!c 'n Sc..;c,~ fL.:l":cs. (5} T:: prese,-::e :re :-::2::..~e,:1 any, ::/ '.'Ir'.ich the ter;,;;s 'ct any C:::n~;ac:,',':.~ :.-e -:cicers:r casenru.-es ma'! be amer:ded:r a:::~::a:e:, ::;e amCL.:nr cf deber.. tures tl":e holcers or wr::c,~ ,~'':S: ccnsent :hereto, and the rra....,-;9.- 'n wrici S<';:,- ::;'$e-~ 'i12:/ ':e ;i','en, (E.', -: :0'/8'.2.-: 2S:: :,"',9 _~~:: 3.::/:; 3,;:1 ::5 ,-eai or pers,:nar :'-0'::9;-::'-; a;,~: :: ::'. 9ia,-:t as >: :~e :nainte. nanca of its real ar;e ~9.-S:,"'2: :~:::e.'\/, ::-:e replace. merH t~erecf, the ir.sc.;ra....ce ~: :e :arrie-: :,"':erecn and the~.:se_and dispcs;:icr-: :~ :(,;S~_;~2:-::e :::?r;~/s, (i) : 'J covenant as t: :,~e _.;,;~s, Ila:::I:ltles, pcwers and c:..:ties arising :";::or ::-:e :i9ac" b:; it cf anI cO'le- nant, c:r.Ciiion, or :::Iig:=.::-::;, 2.-:':: c:verar.t ar:d pre. sc:-ibe as to e'iems:f :e:2:..::t :;,~: :ei;T15 anc ':::nCiticns upon 'I/.'iic:-: any:,- 3ii -:: ';s:e:e.~.:i.:res:r c:iigatfor.s sha:1 :ec::;;e or iT:a:i ':9 ::=':C:2-2: :~e ':~::;e T.ar~r:t'!. and as :c tre ter~s :;,"': :::-::::,'":5 :'::r:r.N~":~c~ sue:": dec:ara~cr: ar',d its :::rse-::..:e.-:es ,~ay :e ','is'i'ied. . (8, ! C 'lest in a :;'..:stee :~ :1'_5:ee5 or :!;e .-:cic:ers ::i debentures or any .en::::;.:::- :: U1em Uie right to enforce the -payrr:er.t :f :,"',e:e:el'.~ures ,:r 2(,;,/ ':::::ve- r-:ants sec:Jr:ng or ie,a::r: :: :"-9 :e:er,twre5: :0. 'I'~s;: ir, a trus::s'? ::r :rustees ~~e -"'s-:--.[. :... :,~e 9'1e:,t:; a :eiault b'y sa.c' ::I' 't"or'.t'/ '0 '-:..~ ...-...--- --'.-'" anr' ,-"" '~"'Q"""~ I _'-'" ",' _c:,-.,~ w~~~'::~~._" I~ ~~~. .~~_,c;:I._ and "arage ar.'J ,-;c1_s;,-:; :-::'9:: :-:a:: :,"":e~9'::. :=.:r,j:o ~~~e~~~~~ef ~~~t,~ ~~~~~'~.s:'~~2e:s:~~-~a~~~~~'~::~~:;'-:~: :~.~:~ me'nl ct :,1e 3l.:thcrit',' '..;::,,": 32:: :~'_s:ge::O' :'-:'.-",::e 'cr :he powers arc G'..:ties ':: :=. ~~'~s:=e :- :_-...;5:ees 3;:: ::: ::rr:it the lia::liil:es :herec;: 3,-:: :: :-:, :e ~;-.e :8;"-:;5 31:': ::or,. ditiers l.:con wnich tre :~\..:s:.s-=:.- ~.-'.:stees::r :;:e ,~cieers of de!::er.ll..:res or 3r;:/ _:r:::r.:c.-: :~ :hern ~a:/ er.tarc2 any covenant or .-:~ns 3ec:..;,-',~,;: or reia::!"_,:; t'J the debentures. 517 I Cn.421 PUBliC HCUS:flG .=.3. ~ 997 19\ To exercise all or any pa,1 Jr c::mbinaticn of ir;e pcwers herein granted. Hislory.--1. 1f.i.:.'l. :;"~81. 1937; S:i.. :,,4(; Sueo 7'c:-c(J<Jill. 421.17 Validation of debentures and proceedings. (~) A housing authority shall ha'/s :he rignt, if it deems it expec:'ient, to derermlne its authority to issue anv .:ebentures, and the legality :)f ail proceedings .'lad or'teken in connecticn therewith, in the same mar.ner anC tc the same ex~ent. except as ::therNise provic:ed in ~,'"i:S sec:icn, as pro'/iese in ;::-,2;::2; 75 for ~I":e ceter. minalion by a ccunty, municipality, taxing district. or other political district or s:...:bdivision of its aulhor:ty to inc:..;r bcnded debt or to :ssue certificates of incected. ;less and (li the legality of all proceecings hac: cr ta:",er. in c:nnection therewith, (:~ 7Me petition to vai:cata suc,' cebentur'?s, and the ;Jrooeedings had or taken in connection therewith, shail:Je filed by the housing authority in the circuit court for the county in which is located the city for which said hOL:sing authority was created, except that wner.e'/er:t aeeears that a housing authority is empowered to fur.c- tion in more than one county :he circuit court of any count'l in the whoie or any part of ',vhich the housing authority is empowered to func:icn sliall have juris.::::ic- lion or the cause in the same manner as provided in said chapter whenever a municipality, taxing dist~ict or other political district or subdivision shall extend into more :han ene county. (3\ The notice :-equire~ ~y s. 75.06 shail :e adcressed to the taxpayers and citizens of the city for whic:"1 SUC:1 housing autheri:y r:as '~een created alid or the:ounty, or counties, in the event such housing authority is empow~red te function in more than one CCL;r:~:/, in the wi"':oie :r any par:Jf '.vnich the housing authority is empowered to functicri; and by the oubiica- tion of such notice as recuirec bv saie chaater 75 atl taxpa~/e~s and citizens at such c:ty and such county or eau,~;~es, as t:-:ecase ma'! c'e. s:iaJ[ be cons:deres as parties Ijefendant to such' pr:ceecings, and the circ~it court :n which the proceecing is brought shall have iurisc::ction of aU of the same as if the'l were named defer,cants in the oetition filed pursuar.: ~o said c,"',a:ler and ;::ersonally serJed with process. (...1'1 In the event no appeal is take.'" within the time pr~s~ribed by said chaoter. or if ~aken, and the decee '/alicating said debentures is a:fir:-ned b:/ the Supreme Caur:, the ,decree of the circ:..:it CJL.:rt va:idating 2nd (;81"1- firmir:,: t~e issuar,ce of the ::eber.turesJ: the :;sus:n: authc~::y 5,1all be fere'/er eere:usi'/e as to the vaiid:t:/ ':~ said :et:entures against L~e housins authori:"! and ag3i~s; 31_1 :ax:Jayers and c:::zer.s ':if :~e .city ;'Jr Nnic.'; saic: :ic:Jslng authonrj 'Nas :~e2Iec: anc ,or the cocni'/ Gr coumies in the whole or :Jart of whic.' the r"lOusing authority is empowered to ~unction; ar.d the validity sf said debentures shall never:;e cailed in c;ues:ion iI", any court in this state. Debentures d a hcus:ng au:~,cri~,/, when issued 'Jnder the prOVisions of said ::hacter. shad ha'le siamoee.! or 'Nnllen ~hereen :Jy t~e ::;rcper Jffic2rs of the hOUSing aUlhority iss:...:ing :he saine, the 'Ncr::.:s: ~Validated and Confirmed ::y Cec~ee of the ere:...::t Cour.,~ scec:f\/ins; :he date -Nr:en 5L.:Ch :ecree 'N~S rer. jereC 3~d :r,~ court in wnic."i it ''vas re:idere':,Ni'.:C:; shall :e s:;...,ec oy the cier:", of ::~e ::;::...;it :::::ur: :r. 'ti:-!C:-: n"',e jec.i'?e 'Nas fer.c::eree. 'Nh:,:,- er,:'("'/ .3,~aii :e ::';:;:i:"121 e'/:ce."'1ce:;f sa:c :ec.ree :n ai"/ :::::1..:"-: ::"1 :~:s 5:2:e. HlsIOry._s .-; ':~, :7~8~. 1937; C':;... :..:.:: :~::, ~':':,:.:::Ji. ~21,~3 ,=lemedies of an obi;;~e of autnor:ty._..:...., obligee :f an 3L.:thcnty shail h2'. e :."'1e .r:;,-:; :r, a::i:icli ::; ail o~,"'1er r::;;h:s whic:l rr.a~l je::,"":;e~re': on 3:...:e~ :::~:I' gee. s:J::jec: OJ;iy to any c::ntrac:~a: "es:~:c:iCi'.5 :ir;c::~,; ~cc,.... Sl..:::;~ ooli;ee: \ 1) =/ i"an c:a:"1i us. suit. aC:::::::r pr:ceecii";: at '2..... cr Ir: e:;uit'/ :0 c:Jr:ipel saie: 3.L.:t....snty a,....c the ::~.r:":is. siere,s, c:f:cers, agents or eJl"1::o:;ees :heres: :0 ~er. ;:r.'71 eac."'1 ar:: e"ier/ term. :rC'i"s:cn 3:i::c'.;e,~2~: ::~.. tai;:e:: i.1 a.....y :::ii;rac~ af said ~_::-cr:ty 8:th ,.:r ~c, :,~e ::e:;efit c:f S'JC.1 ct:ligee, aii: te 'e':'...;:.e the :::a.--:':.~; cut of an:; ::r ai: s:..;c,~ :ov9r.2;::S a,-: ~gieernen:s :f sa:; au;:r,ority aiid the fulfillmer-:t ,':}f s,: :\';:185 :mcese: ''';:::i said autr,or::'/ ':'/ :his cha:::ter. (2) 3y 5i..:'it, action or ~rGcee,::,....g :n ec::..:::/. ::: e!'":;.::n' ar"1:/ acts:r ::,,:r;s 'Nhie:1 r7:a:/:e ...: I.: a'..,,':...: 1 , ,:;r :,"'9;:::2' tion of any:t the lights of s:..:c:,::':;ee of saic 3:,,;;:":cr:ty. Hls:ory.-s. '3. :~, ':",,81. ~9:i7; ::Ji.., :9.:: 3~::, -'::,':<::' 421.19 Additional remedies conferrable by aut~cr. ity.-An a~:~erity shall have ::c,'ler :y its resciutkr., trust incer,ture, lease or ether ::n;rac~ ~o :::.r,fer t..:;;::n any obligee halc::ing or recreser.::,-; a s:::ecifie.: ar;c:.'."'.: in ceber:t!..:res, or hOIc:ir:o; 3. !e2.se, :~e ~:,;,...." :1" :=,:::::::-::"1 to ail richts ~'''Iat mav otherNise :e :Jr,f-=r~e':. ~:':" ~t':a has:Jen-ing cf ar: ~'/ent of salault ::.s :efire,: :n 5:..;::"l res. oil.;ticn or ins~ii":r"i1e:lt. by siJit, action :or pro:::ee::~; ::'1 a."'1/court :of cCIi"l::etent jur:sd::::::-':: (1) To cause p:Jssess;cn Oi 3.."'./ ~:'..;sirg :r:!2':: ,:;r a:iy ;;art :he~eof to :e sur;er,dere: ::3r,y 5ue~ :::;;9o? 12: To obtain the 2c::,:i,'l:r1~:-: :: :: r~':2i'/-=~ :: 3,....:r ho~s;r.~::r:je(::::'1 said a:..:tr,ority' :.- any' ;:2:1 t,"'1e.-e:f ar: ci :11& renlS and ~r,:;f:ts therefrc~, !: S:JCi'. rece";8!" ~d ace,cintec:. heJr Si"',e ....ria'l e,"!tec ::.:-: :2.,~e :QS32S:;:::;n:! SL.:C,'; ,..,OLls;r>; ;::r:je..::t cr. ar.;; .::a-: ;i"',8:'8C: .3.r:c ::~:3:~ 3r"1d rnaL'lta:~ same. and coile:: 3.r.: ..e':2~ve a:: :e'?S, ref',ts. revenues. or other cha~;es :~ere3f:er 3...:5i,....; therefrcfL1, ar:c shall kee:: suc~ -;or.8'/S in a 5es3ra:e account or ae:al..:r,ts anc:: a::;::: Iv l1'"-:? sa,C;;e:.--; 3.ce:r:2:~::~ "I,.'h '''e "''"'',.~a';~n -' S",.... ~u'th~.'.',' a'" 'n.::. -'-'.": S,..,;;!,; , "", v....,":;:' l.u VI c;:. '-':::l '_"'.,' "'" '. y",U cires~. (3) Ie re'::;uire said au~...,ori:y 3rc the c::::r1~:ss:cr' ers there,]!:c aceJL:n: as!l:t arc ::-e:" ',':ere :~e :~'",;S:9~S cf a:-: ex:::ress ~r:..;s:. ;_H_i~:.OfY.-S .3, :~. ::"35', 'j:~::;... ~:;~: ~_:: ~. .A"....A ._ ;;;, ;:>. ..!.2~ .21 Aid from Fecer3i Gc'.'~ri'.JI"1e!"i:: tax '?:err.::"" tions.- (~) ii':, acc::;:cn to :h,e ;:c'/.'e~:3::."1~e~:~c: ~:;,~...:;~ authority ,:y ct.'ler ~rovISlc~S of (;-:5 ,:i'12.~:er, 3."": 3'~':'''..{ ;"/ is ""r."J.....o".Q."'.... '.., ber',"'''/ ~o-::" ,...~ ::>--Q...... :~~r,5 ~ ~ h -~.. ~ ..,";-' -~ '~_. '_"~; .~;.,.-.~;. ;.:>'-;~~-~. ~:;;\;er.1"' ..I.,er .:na.;c.al 2S'::"::'lan<...~ ,r"", "'_, __~,_I, .p! ment IO~ "r'~ aic"" ~n'l -^,,~:.,,~ -.-,.::.r' -",~_:.... ,:::; J,~ ~~:f~j};f~li~;!~~~:~,~:,~:?Iij~~ -. Q o,~ ~~ " 1=.3. ~ 997 :-:ient ,:r :es;;30Ie. ::-:2::er to a:";lhcr~:e :: ';~:i':;;S :~e:es3ar/:r:..o- r;r ecocefation o't ~re ~ ~a..<liig. eons;;t..:C:iCi,_ _ ~cuslng crcjes: :'1 _L: ,'2) In acciih..l :: j'..:t,'iorit,/ oy s:":os<::c:,:- ,:~aCler, an authcr;:'. :: :c::ect ~ar.ts or c:....-:, ,-eceral'"Jovernme!'":; _ ~3:;9 (?'..i:).:.... ,\Jo. BE': ',,'i_!:e'::! Sta:es S'~:~- :e"ie!c:,'"i'.en(,Ni';;:,- :. :,"'e maXI,"7',um ar."1C'...:i': :cse ci assis;:nc:e-:c: :,ice he'..:sing an-ej ;e:;. ar,c eicenv ,:ersci'.s '. (a) ~ous:r,g a'..lt~:- 3.r3 aut,":cr;Z9C: to ::'=: . ,. ::iier reriT:S ,cr :r:Ce::s ,T,ents, contracts, cr ::. t.,;nited States De:a.-- C,'!elccment in cecc, ;:l.:,"ccses set forth Ii ::-- \0) I n:s :::rOV:Sicn . t~e ~Icer:y is. cum:...o;a::', ,i','e."I:c :-:eusing a~:~.:.- ~:3;ra,,'i:ec: g~r,era:i',' : F10nca relating :0 :si:...;~ :'.;~es, and ether ,-;;e;,"',: ~iS'J t~ :1o.using aut:-,:: r': .1:c;=atJon in prcgra,-s : cl :~cus;ng and LJr:a~ : (31 :t is the lec:s:::.:;'. c! ,A:c'..;s;r,c aL::,~er::J=3 : ~:aC:ficaify ar;piy ,: _ '~~:ar :his S2C:;::;"",. li~,I~~~7..~~~ : ;~.;.~~.:. -~:. ': ~21.22 Re':orts.-':' U',alll::", ''1i~h "h'::'- =:..... pr~a~'i~~ \J~a~ '~"'~~---.:: I " - J - . ~..... :;",- l'S,ere:;,-", '0 $' ,-'" :::'--:. 1$ :1 ::ey;....:,s i:~~'~$-S-~-~. %5es :;1 '''',5 :~a:'~' "'10"'" -1 :::: ~~ -": -;" ~~,1,2J l..ia:::iiiti~s:: ~,~::~~~~~~;~y~-,:, ~SICies-_;i'~l...:_ ~ __-- , ~F11. ,.-"...:1___ ~<,~.:~;~~.-. :2. :.~ ':~~l_;", '21 ., ~ ;i.",.,.;. ",.. Or~3"';-"':- ~tF:;~~bli:~:n'=i,t ~=.~~-:~-:;~ .- c~.. ~~s'c:,;::"''''r--''''''''::'-'- "( 1.'r~~1{,~ ~w :f"",,,~:~' ~.,::-.: - ~~~ -_",;:;,-0>,....- ~~.:~~ :I~' :~~~;r~~~~;~,~~. F,S. 1997 -... f, the circuit court in which ~Ich entry shall be original ''1 court in this state. ~. ~03uCQ. 71COIJ,01)). '!~. . )bligee ot.uthority,....:',\;; 3.'Ie the (lgnt In addItion to ? conferred on such Oblj.. 3ctual restrictions binding :tion or proceeding at I~~' uthority and the commis,. mployees ~hereof to per. ;vision and covenant co~ j authority with or for the a require the carrfing 01.1 and agreements of said i all duties imposed upon , ?eding in equity, to enjoi~' be unlawful, or the viola:' obligee of said authority:"; jol.O Succ. 71ccr,;'~CL .,,' ~s conferrable by author. power by its resolution'" :" contract to confer uPC~ :nting a specified amount' 3.59, the right, in addiliol1....~ 9 be conferred, upon Ihe~'. lit as defined in such res.""; action or proceeding rn'" :tion: ;:..~ JI any housing project ai' , ~red to any such obll!;ee:-: ""lent of a receiver of a~Y' .'/ or any part thereof and ,'om. !f such receiver ce" j and take possession. of ..... Jart thereof and oper.l~ ,. :ct and receive all fees~:.: ~rges thereafter arising" h moneys in a sepa~a~~~' ~he same in accordanc..-,,~. .10rity as the court s~J: "bot: ty and the commissjon..~..~ d they were the trustees. ;";;- ., g40 Sucp. 71CC(;3.~dl: s. as. '^i .~';;'.!'. '. overnment; tax exemP"' ;.. .'~::h ~rs conferred upon a"..~.' tl",is chaoter an authOr. ney or accept grants 0'. :l the Federal Govern- " .g project within its area ;,. ;e or manage any hOU"~: ructed or Q'.vned by lhf :_7, '..... :se ends. to comply W1U.'.<; such trust indenlures~ be necessary, conv~ ~1997 PUBLIC HOUSING C:" .::~ ~jenl or cesirabl~. It is the purpose and intent cf this d1apter to authOrize every authority to :::0 any ar-: all ~ir.gs necessar; or cesiracle to secure the rinar:c:ai aid otCCoperation or the Federal Government in the ur~cer. taking. construction, maintenance or operation or any hOusing proje~t. by such authority. (2) In acdltlon to the powers conferred UCC.'i an autrlOrity by sut:sec:lcn (1) and other prc'.'is;cns c: ::-".IS c.il3pter, an authont'j is empowere-: to corrow mona:; 'Jr acc!?pt grants or other financial assistar.ca from ~r.e Federal Governrr:ent under s, 202 of the :-foL;sing .-1c: of 1959 (Pub, L. No. 86-3(2) or any law or prcgram cf ~,~e united States Department of HOUSing, and U,:an ceve!opment, which pro'/ides for cirect fecara! loa:--:3 :n !t1e maximum amount, as deiined :herein, for the:'Jr- pcs~ 01 aSSisting certain nonprofit corporations :0 ,:i'C- vide housing and related faciiities for eic:arly fa~iiies and eiderly persons, (a) Housing authorities created uncer this sec:ion are authorized to execute mortgages, netes, bills. or other forms of indebtedness together with any ag...ee- men IS. contracts, or other instrt.;ments re~uirec by ::--.e United States Department of Housing and Ur:an CeveJopment in connection with loans :-:-:ace far ~r-.e purposes set forth in this subsection. (b) This provision relating to hcusir;g fac:lities :cr ~e :lcerly is cumulative and in acdition to the OO....I.:;:rs given to housing authorities under this cha~ter. All .;::cw- .rs ~ranted generally by law to housing authorities in Flanca relating to issuance of trust indentures. deten- Mes, and ether methods of raising ca~iraj 5,'iail ac;:;y also to housing authorities in connection 'Nith their :ar- lic:pation in programs of the United States Department of Housing and Urban Development. (3) It is the legislative intent that the tax exe~c::::n of housing authorities provided by cha;::ler ':'23, .s,~ail s~edicaily apply to any housing authorit:1 ':re2.:ed I,lncer this section. MIIOry.-S. 2,. eh. 17981, 19;37: CGL 19405\):0. rCC(:l-if}; 5S. t. 2, :.". '1.1~7; 5. 7, Co". 73-165. 421,22 Reports.-At least once a year, an authcr;ry Ihall file with the clerk a reoor! of its activities tor :he preceding year, and shail make recommendations with t1lerer.ce to such additional legislation or otl-:er ac:::n lS it deems necessary in order to carr; out the .c'...;r- poses or this chapter. ItIIOry.-$. 22. C:1. 17';81. Ig;37: C.3L 1940 s..cc. 7~OO~:l-,;;:. 421..23 Liabilities of authorit'l.-in no event s.':ai! the liabilities, whether ex contractu or ex delic:o, cf an luthority arising from the operation of its housing ;:r:j- ~.s. be payable from any funds other than the re~:s. ifes .o~ revenues of such projects and any grants :r Il.tslc:es paid :0 such authorit'l bv ~he ;:eceral -:30'l~r.~" ~nt. ' , ;:tOry.-i. 2;3, :.~ 17sa~. ~9J7::Gi.. 'g-lQ S"CQ, -:-~CCIJ.~~,:;, 7 ::, 2:::~, ..21.24 Organization and establishment.- _.~~ ~tablishment and organization of housing, authori::es S:e slale un~er the pra'/isions or the HOUSing Aul~cr:~ ar:.s Law of thiS state, together with all ~roceedir~s. and things heretofore undertaken, cerformec: or done .vilh reference thereto, are hereby v.aJicated. ra'," tied, ccrfirr:ied, ac:prc'/ed ar.~jec:a;~<:: ,e>;ai in 2,: res::ects. nctwitrstar.c:ng a;.~1 :e!~c~ ~r ,;9-::'..::2.; :'.' therein:r Sr',Y 'Nant cr s:atut.::r/ 3.\"';,l":or::,/ HI!tol"'f,---S. ~. :;.." 19S~~. '9Jg: :::ii.. .;4"; 3~:::, 7~::\;'J'" 421.25 Contracts and uncertakings.-.-1:: ~rac:s, a;reemer.:s.::::;a::crs. 2r:d..;,;C-::.2.:";:L:';s :; Sl.;ch hc:..;sirg autr-cr:::es :;er9::':...e e:-:9':': 'r:: "9=.:- irg:o fir;ar.c:ng or a:c:r.; ir ::-,9 :e'..eiq:r:'".9:-:. :::-:5:;....::. ticr.. j,",ainte::ance.:r :::eraticr:, :r any ,-:cusi....:g ,:r-::!e-::: or ,:rcje::.:s or to cbtai~i~? al~ :.-e;e:or. :,r,:~. :,''''e l.."r-:::e: Slates L..e~artmer.t or ,~cusir; ar,e :...r:a:::e"/9:'::_ r.:ent. irc:ucing. withcu: li~ir:.....:; :"~e ;~~er2,:r'j :1 ::-2 fcrag-alIig. !can and arr.:...;aJ c:......:r:::..::icrs.::,'::r2C:S =....: leases '.v:tJ~ t~e Ur:ite.: S:at9s : ecar::7.e~: :, :.-:0 LiS..- : ar.: Urtar. :'e'/elc=r:;e~:. agree~e:itsNi::-'~''';:;::::2,--:' ties or ctJ-:er .:ublic bc::es. ir,.:;'..:::r,g ~:-:cse '/li";ic:-: a.-~ pied,;ec :... ar..::hcr:ze-: :: :e ;:::e:;ec Ie :t'e :rctec:::,- cf the r.cicers of an'j i.ctes Ci ::r-:csss:..;e:: :'j S:";:,- hcusing aut~crities or 'N.,:ic,1 are ::J"".erN:se ,"':":ace a ;:a-.. of the ccr:::-act wit~ S:";C..., r:c:ce...s d :;c:escr :cr::s f~~a~~~~~:'~~~~~~;~~~~'~da~~; :~,~:~:~c~~ ::~x~'~. ~~~!;.:~ Irg ,cr ml.;J-:c:cal sar/lces anc ~ac:.:::es, a..c :.~e S!i!":"',i,-a- tien of ur.sale anc :nsanltar/ ~',:.'e::ir:gs, ar:c::mrac:s rer the ccrstructicn of hcusir.c :.-:iects. te:e:!'";er 'N:.-- ad proceeGir.gs. ac:s. a.~:: :~.ir,;s ':-e-9::;:--: undertaken, :errormec. or dO,ie ','/:::--: rererer:e :~eie~: are hereby validated, ratified.:ciifirmed, aCC,QVe':. and cec:arec legai in atl resi=ec:s. ."':c::,'i:hs~2,"':dllig 2.-'., Cefec~ or ir:-egular;t'l :r:erein .::r 2.;"',,/ wa.,,:, :t sta[:..:::,.-: author.ty. Hlstol'"'/.~. Z. :.", ~951~. ~93i: :3L ';4C Sw:::. c'cc:"j': l.:. ::-, -:..~: 421.~5 ~otes ~nd =cnds.-:-~:! prc.ceec:,-;s. a::3 anc thlr:gs ...:eretorore ;.;."':cer:a...;e:"".. ;:er:crm9': ,:x:c"',e in or for :r.e authcr;z:a::on, iss:..;a.,:ce, exec:..:i:r a.-: ce!j'I'=r'; cf ~,ctes arc :cncs :., ~::.;sin~ 3.'.;:~cr;:;es 7::~ the purpose of finarc:ng or aici~g.r; the '::e'le:c':i.ier.t :~ :::;:struc::cn of a housirg prcie~: -:r prcjec:s, ar:d 3,; ....:C1:es anc ::cr.cs heietcfcre iss:..:e-:: :y i,cus.....; :!u:r.c~:- :ies are heie:y '/alica:e~. rati;iec. :cr":fir:-r,ec. a:crO\i9: anc c:ec:are~ !egai :r, at! respec~3, ~::;-"":t::s:a:-;:::ir:g ar./ cefect or ir:-e-:ular;t'j :,"':erein cr :'.-'1 WSi':t cl 3:2.t.;..:tC..... aL:thcrit'j, ~ , . Hlstol"'f.-i. 3.~. ~9511. ~939: C:l", 1940 s~:::. 7.:Cl:"~.'" 421.261 Continuance of municioaJ housinc authorities when municipality abolished; counties ir. excess of 400,OOO.-'Nr,ene'/er a i.lunic:pai:::'; :n ar;~, count:; ha'lir:g a pcpulation ir, excess of J.GC.C:C: ac::::rding :0 ti':e mest recent c:'7:c:ai censt..;S "as ':ee:-: cr hereat:er shaH be a:Cc!is"ed. ','I:-:e,ein at :i-.s t:r;j~ :: s:...:ch aboiis,inient a iicusir,g a:"'::~':rf"-I ci S1.;C," ~ur::c:- caliri was :r is in ex:ste~ce. s..:::'" hCl.;s:r,;: ~..::....cr::-. snail ::er.;::--:-..:8::: :ur.c:icr.:r: all ~es:e'::s: :r:',':e:. :~.C'.'." 2'ier. tna~ :l"e ,-;ar.;e cr s:..:c:-. :-:'...:3:0':9 ar.,;:t:,':::i 5,,,,:a :her:ceior:h ':e s:..:cii as .'"iIay ':e :ete::":iir:ec :~I :.-e --u-". r....-,....,;Ss.,c-e.s ....; ~"e -~'........, ...'.....:>-'0.- ""'r-- '-:... I" j _ ~"',' ,I." , : 1 . ......" ,,_ .... .'J . ,. ,_. ~." ,~ ,.... .: :Icns. C.ac~ SL:C.1 iicus:r,g aul~c"'::-/ ar.c the '::r7":r.;;~. sicr:ers therec/o within the area :f cceraric.'i cf sue... nCl.,;sing al.ltr-:crity as hereina~er :e:i.":8d. 3t':2.:: :-:a'/'9 :;-e same fur:c:icr:s. ric:-Jts, ~owers, .::..:::es. :mli:u,"':it:es ar: ;::rivileges ;::rcviced ;or ~cl.'sir:g 2'..;:hcrft:es:~~a:ed :cr 519 C~. .!21 ?UBUC HCUSfNG - '.., ';;" ;:. ~ :?9i ~ c:ties. :::ac.1 SUC.1 housing a t,'icrft~1 shall c::r"ir:t.:8 :'J c:;Jer3[e and prcsec:..ite aIJ .:::rc ec:sJperatel.: 'Jr irHtiated :v it Gnar to the abolishmer, ot the munlc:oaiit'/, and shall :e entitled to all :enefils and ,Jnvileges the~eatter ccnfer~ed upon hOl':Sir:; authc~:ties Ter c;ties. The CCIT;- i.1:ssicr.ers of each 5:Je.1 hClJsing authcrir~/ snail cer:- ti:,ue in cific:3 after the abciis,'imer,t Gf the car.ic:..olar r~lJnic:r::aiity fer the ...er::3incer Jf their respecti;;9 teri'71S. -;-'"leir SucceS3crs 3,".211 ::e as:oi:itee by resciL.:non ci ~.'ie commissioners of the c:::unty. ~,s l..:sed in the Hcus- ing Ai..ithorities Law, t,".e terms ~;T1ayor" and ~;ovemir.g body' shall be ccr:str'Jed as r"eaning ~c.:)unr:, cornmis- s;cners." the ter:i1 ~c:ty" as '...:sed therein shall :::e cen" s~~:.Jed as meaning ~c:unt'!,~ and the term ~clerk;" as '...:sed therein shail ::e::'list~t...;=d as :'T1eaiii~; ":!eii< ,:Oi :r~ ;::r::"':ll CJuft:f the :~JL.nty: :...:::iess rjiife:=r: .;.e2.';- :,';C5 (;:23.rl'/ aeaear ;rc~ :he c:Jr.ta;,ts. The area 'J! ,Jpa:. arfcn of an.y su'ch housing authority shaH Gontir.ue to =e the same as that before the acciis.'iment of t~e i":1t..:iiici- caii!'I. unless extendec: bv resolution of :,~e coun:'! c:::mmissicners, crovieed tha: no such exter.sicn shail ir.c:ude ariy ter~itcr! lying within a city as ,:efined in the hcusin:; Authorities La'N. iiislory.-s 1.cn.293(:S,1953 421.27 Housing authorities in countieso- (1) '" each county of the state there is hereby Gre- ated a ::::t..::lic boe'l co~orate ar.,::: JOiit:c to :e "G':C'N:i as :he "housing ,a~thorit'(~ ct ~he. ::::unr(: provicec, hew- e'/a:, tha: suen ~::,uslng 3.L.:mcr;~; 3......ad not tja::sac~ a:'l:1 ousir,ess or exercise its powers nereunC2:- i..Ii";Ui '::~ t.:r~iess tr.e governing 'oc':y :f such county. ':y ;:rcper res.JIution shall -:ec!are at anv tlr719 hereafter ~hat there is r:eed for a housing authe~:t~1 to fune:jen in and fc: s:...:c:' count'l, whie.' dec;a;atior s;,aii 'Je mace j'j sue.: governing body for such coulity in the same r.ianr,er anc sut:Ject to the sam9-conci:i::rls as the ::e::~a~atic~ cr :~e :;8'je....,'l:~c bee'!:f 2. ::t"; "e::...::;ec: '::'/ s. ..1.2~ .:"::' :cr U-.e :Jur;Jcse of 3lnhoriz:r.; a 'hcusing aut'hority created for a ';:[',.' to transact business ar.d exercise its cO'.'Iers. exc9:Jt that the :Je~ition ~afe:~-=c t-=:, in said s.' ~2i .':':' s,'iail 'J9 ,signed ='X 25 ;esl;::~:;ts 'JT SL.;C~ C?Ur.t~/. , ;''-'' l..-,:':.... .:ct:Tlcat!C~ :: :,~,e 3::e:,!::-: J; st..:c:-; -eSQit..;. tier. :i1e c::mmiss:oners cf a nousi,'lc authori~1 ere-alee fer a c::ur:ty. who shall be qt.;aiiTied eiectors of suc:, county, shall be ap::;oi~,[ed ':;y the '?o'l,ernor in the sarTie j.La~iler as the CGrnrTiiss:one:3 Cl a nous:ns 3L.:t:;':r1t./ c~-=2ted ;c.... a c:ty r:iay be aGGOI~:~C: :y :,~e .,.:=;"icr' -3~= exc30t as ctherNise ;::I-'Jvie~c :'"'lere!n, ~2C.'1 :;:::t..:s:....,,~ a:..;;~cnt'l ,.:~e:=;,tec ;or a '.:c:.J~,'! ai-;: ~~e :::I"::~:S:;,:"2,-3 :r.e:eci. ','nthi.'l the area 'Ji ooe~~:i(;nJi SIX:-'."'1CL..:s:~;: aUl::Ofity as ;""1ereinatter :efir.es. sr:ail :":a'/~ :,';e sa;--:;e :r...:r.c:ions. ~ignts. powers.:uties. ';;:mL..:,'1lties 3:;d :::;ri'/i. leGes provided for ,'1ousinQ 3uthcr:ties c;eatec ~or c:ties ar~c :.':e c:::mmissior,ers:f suc.'i .'1cL.:s:na 2uther:rles. ::-; t.'ie same .-nanner as tncL:gh ail the ,:rovisicns cf :aw acciic3ble :0 housing aL.;:~or:tles :;eated fer c:t:es 'Nere a::::c;ic3ble ~o housing awti":or:tles c...eated fcr:-cc;:;ies: ~r0'i:sed, :~at lor SL..:ch .:ur~ases ~he :erm ~~ayc(':;:s ~~~; ~'~~i:.~ :;:~ ~u~~~~~~ ~,t~~ ~:~i ~:r;a :';~~:~'n7 ~c;:.~ ~ ~~.;: ~'~ ',,;S"?C: :heretn sr,ail ~e ::::.'lstn...:ec 25 ::".eafilfig "::;u.....:/ t;;orn1.1lssiorers," :he ~eri."1 "::r,/ 25 L..:se-:: therein s~aii ':e ::r.s~~:...:-=C as "7':ear.:::,; "-::r.;nt/." a:::: ~~e .2'- "::s,...:";;: :..;se'j :.'":ereir 3.'1ail :::e :::r.str'.;ec as ,"i"'.ea,~;,~; .::'~,~'; .::er:--(." as iierein Ge~::-:e.:. uniess a :::;r~e"~,~: ,"7'.=:?,-;.~~ -::earty acs~ars frsi., :.'~e ,::ontex:: ar;C ,:":'.:~o::: .:...;:--:-,,: t:"'at :h~ <3cvsrr:Gr ~ay aspoint ar~y ~ers:~s 25 '::::-:,-,;. SiCGerS ,')T 2. :-;Ol.:S;;;g a:..;:h:rity ':~eatec: ':- = ::'''';.-.': 2,re:;-'..:aiii;ec -:!e'::'Jrs :.'"'l SUc."l CJL.:i,t/: 2.~: : ":'i::~: . ... t~e'" :,';at Si..:C:; '::.-:,i.,:S3:CrierS '7':a'/ ':e --=~ :'.~:: :.- :_> pe~cec :0"1 t:'e sar:ie ~a,~ner anc Ter :.~e S2.,~e "=:?~:-; as ::1.....,e; ,;ffiC8,$ ac::,ci.....ted by ~."1e G':'/e."~:" (31 -:"e a;~a cf:);:e~3:;an cf 3 i:Ot.,;S;i: 2_~:-,::",:'/ -..:>. "":"';"0' 0:: ,--, '-"/ s"'-'I '~""uc.e a'J -' ...."" _:, -.', ',-.' ,:,,:.,:-... a._..., .. _ ~........'''. ,'CI ,'...., I '..... "'_ '__ _ ': _ '_' it is :~e3:ec ex:e:Jt ::-.2: :crtlon .:i ::-:e ::~:-:-. N....::.- :~: -.::;- ::.- r..::-:,-':'/i%::S .... ,:e,: 1::',e, '.~,e ;'.::: 3. :e-=: :: 3:"':- i-:'~:-::'/ ...,:- '::- ._~-~ .-:.::~:2' :~ :ee::s :. !""'i $, :":'.':':;;': :-2~- .~:. ;;::e:: .--::, -=:: ... "; _~...;:~c: ~:"_':,~_.,_ ~ ~_ '::" ~-'~ ~ :~:~S ::~~:;es 3:-2 $. 3. ~eec: ':..::-e 'e~ ::e: ::r 2,. :1 3:...::- :: -:-,,~ "...;r:::::~-; --=-~ ,..,i:.';~n :;""e ter..:t,:r:al ::",:,-::aries c; ar.'/ :::. _" -"'-=.- ;_:~ ::'..:;;.-~;- :::: t,~e"';:L.s::"';: ,~:";:~C"i:,2S _3','1. 8S a,-:-e~:e: .-:,:::r'.--; . ~<::. ;:: 421.23 Cr'!atjan of regional housin; a:..::.l.;cri;y.":" :~ t~e:;,:1)9,~ir; ::cc:y 0: 2ac~ :' :...,: :,. -:.': c:>-;~i~:...:c'...;s ::::'''':i;ties ::" "Ssoiut;on :e'::a~ss ._~t ~~~.~ s a .iee.: ::r:r.e :--cusir; 3.'..'thoritj ~c ::e :~2=:=; :,:.' ;..: :: s'...:c:': :::untes to ~xe;::se ;::awers ;,~: :::-e" ;'''';,~c:::~s ;-.~:~!;-; ,::-9sc~~::-ed :i. s:...;::; cou;-;::es. a,::":': :::':' ::'. pcrat-e ar,e ;:ciilic to :e ~iiown as 3 ~s;i:,~a. :;::r...;s:t; at.;t,,;crity si':ail thersL.:C:.'1 exist :cr a!l:f s:...:::-:::::.;:i::es a~<j axer::ise :ts ::::cwe,s and ,::t,"ier ;I..;,":C:; :-5 :r; $'...:::,. :::i..i:-;:ies: a:iC :~ar9!";:::~ eac."i .'"::L.;s:.'"'l: =_ -- :..':': ". ~ are.: :~I s. ~2 -; .27 for =a::.~ of SUC.i :::t.:r~!es s,~=li :2=5~ to e:<:s: 5xce:::t :cr ::--:9 :'_r:cse :' '..i....,,::,~; _: :3 ?:'o;.,:S aiiC 9xe::...::.-;; 2. :eec :: ::-;8- reg:crai .lCL..3-; ?.:,-:....'. as i;e,-ea~:e: ,:i::".;i:e'::: :rov'lced ::--:a: :.-e ::'/2"."':::-: bOC:1 c:i 3 ':::U.'it~/ s~a[: ict adept a ..as:!v;:~- 2.3 ?':.~: sa:: :1 :.-.=~e is a :-1GL.:3;;:; al.lt,'i::~::,/ ,:,-e~~e: .:' 3:";." !:::l7::':'"1cc:a:::::-:s -=:< !,~:"":a';e :. sa:e 2.-:: :~ s ;"'; s:"':::,- ::~:- :': ;.: ';.:-:a:3 ::- e~: ~~. _ " 7'-,a: a 'e;':::~ -:'9 ei-:'::::e...::.. =~: .~= ~:'...;s>; =_::-:..: ;,_o:::ses:: ::--::5-: :n a."':'/ S'...:!:. =,- .,;..-... ~_ =-~._-~c::-;:. -' ~ ~. ~ -. - '-e "=;::~3., ~:....:s:;~ :L'.~::':'/ ,;-?:':9:::- :.:=.:e: 3S ::. :.:,,::: - -:...; :cc::-s es:.?:.: :'.S':iSSS a:"',: e:<-=': :.::: :f ::-2 =.::::;:::- :::'i :; 22::- :' .-s:: ::o'...:.....:~; ..,...-,ic~ '":as 2:'Y ~,; =.''":.~C';":'''' :9':.-="'- ,-; 2.:..:h:r:: ~3.C:-, L"':;~~: ": :ec:a-': ~::..s::--:~ 3.'_::-:~:;\/ a:"' :-; '.e:-;-:"s. -:. .'_-.:--=' ::-:.:'C:"5 -?- ~:--e'::.' :::i~3.::e~s ;::";:3:.::.,-:;~; _:",::::::;3 iirs:: ,":':1 :::ii;:::es af C::I";i.:~i .~,:;L.;S;~: 3",," 'v ::'-'-., =.,~': :2,-::e5 :.: ti',-2::.~.'::.:::S. ::c~:s. -,::95 ':::'-,':: :::-~. :~~:a'~~=;~~i ~~c~~~~};~{:~~~tt,~ a:;~~~~ ~'5:~~'.; :. 5;":.1 .~s: '_::::' :. hC....;S;il~ 2.:":i~er::/ cn eif 3~::~ ccn:~.:;,cts. :c,~:s ~::es :;. -"'.....=.- - ~_. " - ~ - . ::[J~-=: ,::C:,i;a::ci,s: =.'-.: :~ ?:.~iS5;:,-= ;"'; ~'. (:1 ::e :::.:1r.'::SS:C.-9rs cf s:..:c~ G:'_....: "':;:'...:3:-; aL.;:~c,::--.' aGoe; =. res:::..:':n cor.se~;i.'i': :: :-:; :~3,:;3:e: G,f ai! :.";e .:;:.~.lS, :::lIt~2G:S, :::Iiga:i,:;:;s a;: :'::-e:"":': .23; anc :'5!:S:t2!. :: S:..:::..... :: ~-:./ ."let...::::",; =.:..;:~:" :: 3";:- ::~~:~I~' .:.... .2"2 ":"..~ :: '. .s;.:....a, ~'::'...;s;;....; }:,,:,-,:-' :e: -- "'---.- -'.- - -.- - - - _.- -- - - '-'.~ 3:::-: :':. ..;....9;~ ::-= :::.-:: .~~~'~;:a~:..;-;_~~~:;:;: _ :':;'3 ?.--? :,:rr:::I-eG .','.- ~ '-' ::. -, - ~-~- a~:....,:..':--/:s c:~ea:ec?r:: ?:..:.~';r:~~~'~':,r~;~:~.~e -:~':~',.,: S:3 ?:'c ::,-.er ....;."C:::r.5 3.!i ~:::.::3. :::II:~a::s, :;.;~e:'" ;-7',e;.:s. ,::::'-:;2.:::.-s 2r:::::'::-e'-:'/.:1 3\..:C:--1 ::_,~:. ....::'~.s::"'; ~~~;~~~i' ,....~~~~/.~ ~s~,~~~~'~~.'.;:~ a~r:'~~~2;':~:'~;; ~~.~~~ cC:L.;.~:'i '-:''';S:~:: 3.:";:,';Gr':'i 5.12:: :e ::-'2 :: :::: :,"'5 "' .....-"- .::--;::"'2.i - :~S -: .;.~' ~~~:~i :~~~~,,~~~~:~"':.....S:;a~r~~;~~j~~ ~~~~;:./.};~;,~'~_. ::;l~~~~~_", I ~':-~ :~ ::".~:- :::.:.. . - ...;--.'-;:...:::,....-,.,;0 ;'/ ,-:3.:/ :a ~s::e~ec. 9~;:,-eec a.~:: ;::r~se~_ --:::: 3;:>~.:-~ t .. .~~ ;:~.e-.-~~ r: = s~c.~ ,-~;-::;ra.: ~c:..;s;r,; :_~.;Gr:t'j:: ::;e.:;a,-~ e,-:-,:r::.:; t ..~ ~ "",.,',,, ',.. "",," '"',,", ,. ",. ...l.'..... :~~_':,:,-oo.o . - -~., "-'. - ~- Ct...:!9C 2;:2i,-5: '3:..;:..... --,~. ~""I;~ ~,-3.'....:::-,:::' ---' .1.", ::'-~:~ia: ::._~:::.-.;_ .. '''-".'-- -" ~. ',,0::.. ",' '">',: c ~ ~ ~ -- - - ~ ~ - - . ~~~"::/~~-,~ ~:\,~ ~ "!"