    Capacity Building: Section 4 Program Has Expanded and Evolved
    (15-SEP-03, GAO-03-975).

    Congress recognized the importance of building the capacity of
    community development organizations by passing Section 4 of the
    HUD Demonstration Act of 1993. The act authorized the Department
    of Housing and Urban Development (HUD) to partner with several
    national nonprofit organizations that provide funding to these
    community groups for such things as training, staff salaries,
    office equipment and supplies, and management information
    systems. In 2002, HUD provided $31 million for capacitybuilding
    activities. To help Congress with its oversight of Section 4, we
    reviewed the evolution and use of Section 4 funding, the
    importance of Section 4 funding to private sector involvement,
    and the management controls and measurements that are in place to
    assess Section 4.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-03-975
        ACCNO:   A08460
      TITLE:     Capacity Building: Section 4 Program Has Expanded and
    Evolved
         DATE:   09/15/2003
      SUBJECT:   Community development programs
    	     Cost sharing (finance)
    	     Federal grants
    	     Financial management systems
    	     Funds management
    	     Grant monitoring
    	     Grants-in-aid
    	     Internal controls
    	     Private sector
    	     Nonprofit organizations

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO Product.                                                 **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ******************************************************************
    GAO-03-975

    United States General Accounting Office

                         GAO Report to Congressional Requesters

    September 2003

    CAPACITY BUILDING

                       Section 4 Program Has Expanded and Evolved

    GAO-03-975

    Contents

      Letter

    Results in Brief
    Background
    Section 4 of the HUD Demonstration Act of 1993 Has Evolved and

    Expanded Over the Years Federal Funding Has Encouraged Private Sector
    Involvement in

    the Section 4 Grantees' Community Development Initiatives HUD's Grantee
    Monitoring and Oversight Is Limited Conclusions Recommendation for
    Executive Action Agency Comments Scope and Methodology

                                           1

                                          2 6

    10

    19 22 26 27 27 27

      Appendix I Contact and Staff Acknowledgments 30

    GAO Contact 30 Acknowledgments 30

      Tables

    Table 1: NCDI Funding, 1991-2004 (in millions of dollars) 12 Table 2:
    Section 4 Funding, 1994-2003 (in millions of dollars) 13 Table 3:
    Additional Federal Funding for Capacity-Building and

    Technical Assistance (in millions of dollars) 18 Table 4: Private Sector
    Funding (in millions of dollars) 21

      Figures

    Figure 1: The Organizational Structure of Section 4 4 Figure 2: Locations
    of HFHI Affiliates Receiving Section 4 Funds between 1997 and 2001 8
    Figure 3: Cities Where YouthBuild USA Affiliates Received Section 4 Funds
    between 1997 and 2001 10 Figure 4: Effect of Funding for CHAPA, an
    Enterprise Subrecipient, for Technology Improvements 15 Figure 5:
    Enterprise and LISC Subrecipient Rural County Coverage 17

    Abbreviations

    CDC Community Development Corporation
    CDBG Community Development Block Grant
    CHAPA Citizen's Housing and Planning Association
    Enterprise The Enterprise Foundation
    GED General Equivalency Diploma
    HFHI Habitat for Humanity International
    HOME Home Investment Partnerships Program
    HOPWA Housing Opportunities for Persons with AIDS
    HUD U.S. Department of Housing and Urban Development
    GIS Geographical Information Software
    LISC Local Initiatives Support Corporation
    NCDI National Community Development Initiative
    OMB Office of Management and Budget
    PART Program Assessment Rating Tool
    YBUSA YouthBuild USA

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    United States General Accounting Office Washington, DC 20548

    September 15, 2003

    The Honorable Sue W. Kelly
    Chairman, Subcommittee on Oversight and Investigations
    Committee on Financial Services
    House of Representatives

    The Honorable Bob Ney
    Chairman, Subcommittee on Housing and
    Community Opportunity
    Committee on Financial Services
    House of Representatives

    For fiscal years 1997 through 2002, the Department of Housing and Urban
    Development's (HUD) budget for 20 capacity-building and technical
    assistance programs was over $860 million.1 Of these funds, almost
    $150 million was specifically designated to build the capacity of local
    community development and affordable housing organizations through the
    Section 4 program. Since its inception in 1993, the program has provided
    capacity-building funds and services to over 1,590 local organizations in
    more than 783 cities nationwide, either through direct grants or
    substantial
    technical assistance activities.

    To assist you with your oversight of the Section 4 capacity-building
    program, you asked us to

    o  	describe how funding under Section 4 of the HUD Demonstration Act of
    1993 has evolved and expanded over the years, how grantees use Section 4
    funding, and what other federal funding is available for capacity
    building;

    o  	determine the importance of Section 4 funding to private sector
    involvement in community development initiatives; and

    1Capacity building can generally be defined as strengthening the
    capabilities of program recipients or providers-typically housing or
    community development organizations-to build institutional knowledge
    within those organizations. Among other things, capacity-building
    assistance can include funding for training, hiring staff, purchasing
    software, obtaining expertise from outside sources, and developing
    accounting systems and strategic plans. Technical assistance can generally
    be defined as training designed to improve performance or management.
    Congress and HUD sometimes use the terms interchangeably.

    o

    determine how HUD and Section 4 grantees control the management and
    measure the impact of Section 4 programs.

    To address these objectives, we reviewed public laws, federal regulations,
    HUD directives, budget documents, and other materials that describe the
    Section 4 program and authorized/appropriated funding amounts. We
    interviewed HUD headquarters officials and grantee and subrecipient
    officials at both the national headquarters and local office levels. We
    visited subrecipients in eight cities, and at several we conducted file
    reviews to evaluate grantee internal controls. Finally, we interviewed
    private funders that provided grants or loans to the grantees and
    subrecipients. We conducted our work in accordance with generally accepted
    government auditing standards in Baltimore, MD; Boston, MA; Cleveland, OH;
    Frederick, MD; Hughesville, MD; Kingston, RI; Americus, GA; and
    Washington, D.C. Our scope and methodology are discussed in greater detail
    at the end of this letter.

    Section 4 of the HUD Demonstration Act of 1993 has evolved from a narrowly
    targeted initiative that focused on providing funding for capacity
    building in 23 urban areas to a broader program that funds groups and
    activities in urban, rural, and tribal areas nationwide. Section 4
    authorized HUD to become an equal partner with several private foundations
    and financial institutions in the already existing National Community
    Development Initiative (NCDI). NCDI, currently known as Living Cities,
    began in 1991 as a partnership of public and private, for-profit and
    nonprofit funders committed to revitalizing urban communities. NCDI
    enlisted the assistance of two nationally recognized community building
    organizations, the Local Initiatives Support Corporation (LISC) and the
    Enterprise Foundation (Enterprise) to work with local community
    development corporations (CDC) in 23 cities.2 In 1997, eligibility for
    Section 4 funding was expanded to include Habitat for Humanity
    International (HFHI), YouthBuild USA (YBUSA) and activities in cities
    where NCDI was not active and in rural and tribal areas (fig. 1). Since
    then, the four designated grantees have delivered Section 4 funds and

    2Community development corporations are neighborhood-based nonprofit
    organizations that are involved in initiatives that focus on improving the
    economic, social, and physical condition of their communities.

      Results in Brief

    services as operating support to their subrecipients (CDCs and
    affiliates).3 The grantees determine their individual approaches and
    administer their funds in a variety of ways. Grantees can also tap into
    other federal funding sources such as Community Development Block Grant
    (CDBG) funding for capacity-building and technical assistance.

    3Affiliates are independent, locally run nonprofit organizations joined to
    national organizations by an agreement. HFHI affiliates agree to build
    low-income housing, while YBUSA affiliates agree to provide job training,
    education, counseling, and leadership development opportunities through
    the construction and rehabilitation of affordable housing.

    funding directly influenced private sector involvement in community
    development initiatives, all four grantees and most of the private
    foundations and lenders we contacted stressed the importance of federal
    funding in leveraging funds from the private sector. For example, one
    senior executive from a major lending institution indicated that federal
    participation in NCDI provides funders with both a symbolic and a
    financial incentive to join the NCDI consortium. Symbolically, federal
    funding provides a sense of credibility to NCDI, as funders see federal
    participation as a sign of good housekeeping and reduced risk.
    Financially, federal participation adds more money to NCDI
    capacity-building initiatives, in turn enabling subrecipients to raise
    more private funding. In addition, Section 4 calls for significant private
    sector participation because every dollar that is provided to grantees
    must be matched with three dollars from private sources. Since federal
    regulations permit contributions in the form of cash or verifiable third
    party in-kind services, private sector involvement comes in the form of
    grants, loans, donated land and equipment, pro bono legal services,
    donated office space, and voluntary labor.4 Although all four grantees are
    able to raise these required matching funds, each grantee has its own
    policies and may raise funds nationally, locally, or both. Since the four
    grantees became eligible for Section 4 funding, they have raised nearly
    $800 million in cash and in-kind contributions from private foundations
    and businesses.

    HUD uses desk audits and other document reviews to assess grantees' use of
    funds and relies on grantees to monitor their subrecipients. However, HUD
    does not measure the impact of its grants. HUD is responsible for ensuring
    that Section 4 funds are used according to federal law and regulations and
    that grantees are utilizing funds efficiently and effectively. HUD carries
    out this responsibility through limited desk reviews of work plans that
    outline proposed activities and expected outcomes; quarterly and annual
    progress reports that determine whether grantees are achieving their
    stated goals; and payment vouchers and supporting documentation, which
    help ensure that federal funds are used only for eligible activities. HUD
    receives the same reports and follows the same processes for both NCDI and
    non-NCDI activities but reviews NCDI work plans in consort with other NCDI
    funders and non-NCDI activities on its own. HUD depends on grantees to
    provide oversight of their subrecipients.

    4Federal regulation 24 CFR 84.23 specifies what constitutes a matching
    contribution and how it is counted and reported. These contributions
    cannot be included to meet the matching requirements of any other
    federally assisted program and cannot be paid by the federal government
    under another award.

    While it appeared that grantees maintained far-reaching organizational
    structures and processes to monitor and control their subrecipients, we
    found that one grantee had reimbursed a subrecipient for a bad debt, an
    activity that is prohibited by the Office of Management and Budget (OMB).5
    HUD does not currently measure the impact of Section 4 funding but relies
    on its grantees to measure the impact of their individual programs.
    However, HUD is taking steps to develop a framework for assessing the
    effectiveness of its technical assistance programs and will take part in
    an OMB Program Assessment Rating Tool review (PART) designed to help in
    making informed budget decisions, supporting management, identifying
    program design problems, and promoting performance measurement and
    accountability.6

                                       Background

    In 1991, a group of for-profit and nonprofit public and private funders
    started NCDI, currently known as Living Cities, to revitalize urban
    communities.7 NCDI is composed of 17 major corporations, foundations, and
    the federal government-HUD and the Office of Community Services of the
    Department of Health and Human Services. In its first decade of operation,
    NCDI assembled a community development system composed of

    o  	two of the largest national community-building organizations to
    administer the initiative-LISC and Enterprise;

    o  300 CDCs in 23 cities; and

    o  	local operating support collaboratives, which include local
    foundations, banks, corporations, and local governments, that identify and
    draw on local technical expertise and governmental and economic resources
    and use them to sustain and enhance the capacity of CDCs.

    5OMB Circular A-122 indicates that, among other things, bad debts are
    ineligible for federal funding.

    6PART is a series of questions designed to provide a consistent approach
    to rating programs across the federal government.

    7Prior to becoming Living Cities, NCDI was a virtual organization handled
    by consultants. NCDI did not have staff or occupy office space. Living
    Cities now has staff and oversees NCDI's operations.

    As of September 1, 2001, NCDI had provided $234.8 million to its 23
    cities. Of this amount, about three-quarters was for project funding and
    the balance, about $60 million, supported capacity building with operating
    grants and training.

    LISC, founded in 1979 and headquartered in New York City, is the largest
    community-building organization. LISC's mission, involving hundreds of
    CDCs, is to rebuild whole communities by supporting these groups. LISC
    operates local programs in 38 urban program areas and 70 rural
    communities. According to LISC, it has raised more than $4 billion from
    over 2,200 investors, lenders, and donors, which has leveraged an
    additional $6 billion in public and private sector funds. In addition,
    according to LISC, it has helped 2,200 CDCs build or rehabilitate more
    than 110,000 affordable homes, created over 14 million square feet of
    commercial and community space, and helped generate 40,000 jobs.

    Enterprise was founded in 1982 as a vehicle for helping low-income people
    revitalize their communities. Headquartered in Columbia, Maryland,
    Enterprise has offices in 18 communities across the nation. Enterprise
    works with a network of 2,200 nonprofit organizations, public housing
    authorities, and Native American tribes in 800 locations, including more
    than 100 CDCs. The Enterprise Foundation provides these organizations with
    technical assistance, training, short and long-term loans, equity
    investments, and grants. According to Enterprise, it has raised nearly
    $430 million to support community-based development that has helped
    produce 17,000 affordable homes and assisted 20,000 low-income individuals
    in finding employment.

    HFHI, founded in 1976 and headquartered in Americus, Georgia, is a
    nonprofit ecumenical Christian housing ministry (faith-based organization)
    seeking to eliminate substandard housing. HFHI builds and rehabilitates
    houses with the help of homeowner (partner) families, volunteer labor, and
    donations of money and materials. Work is done at the local community
    level by affiliates that coordinate all aspects of home building,
    including fund-raising, building site selection, partner family selection
    and support, construction, and mortgage servicing. HFHI provides its
    affiliates with information, training, and a variety of other support
    services. Affiliates are primarily volunteer driven, though some have
    their own staff. Affiliates are monitored and supported by HFHI staff
    across the country. HFHI currently has over 1,669 affiliates, and in 27
    years has built over 150,000 houses worldwide, including more than 40,000
    homes in the United States. Figure 2 shows the 526 cities where HFHI
    affiliates have directly received Section 4 funds.

    leadership development opportunities through the construction and
    rehabilitation of affordable housing, serve young adults ages 16 to 24 in
    their own communities. Participants split their time between the
    construction site and the classroom, where they earn GEDs or high school
    diplomas and prepare for jobs or college. The buildings that are
    constructed or rehabilitated during the program are primarily low-income
    housing. YouthBuild USA serves as the national intermediary and support
    center for over 200 Youthbuild programs. Over half of the Youthbuild
    programs are members of YBUSA's affiliated network. As shown in figure 3,
    YBUSA affiliates located in 106 cities have received Section 4 funds from
    1997 to 2001.

    activities they authorize. Each grantee has initiatives in rural and
    tribal areas.9 Additional federal funding, such as Community Development
    Block Grants, is also available to grantees for capacity building and
    technical assistance.

        Section 4 Provides Capacity-Building Funding to Four Organizations

    NCDI in 1991 started with seven large national foundations and a major
    insurance company and was administered by LISC and Enterprise. This
    consortium of funders believed CDCs could achieve greater and more lasting
    success if they could count on a significant reliable commitment of
    multiyear operating support, project financing, technical assistance, and
    training. To date, NCDI has had four phases (rounds) of funding. In the
    first phase (1991-93), NCDI funders pledged $62.9 million (see table 1).
    With the enactment of Section 4, HUD joined phase II of NCDI, which also
    included 12 private foundations and financial institutions, as an equal
    partner.10 Congress' goal in authorizing HUD to participate in NCDI was to
    develop the capacity and ability of CDCs to undertake community
    development and affordable housing projects and programs. HUD's
    involvement resulted in some changes to the way funds were disbursed.
    While the foundations provided funding through Living Cities (NCDI), which
    in turn distributed grant funds to LISC and Enterprise, HUD distributed
    its funding directly to LISC and Enterprise. In addition, unlike other
    NCDI funders, HUD provided funding only after expenses were incurred,
    monitored funding more closely, and restricted uses to capacity-building
    activities. In 2001, 17 foundations and corporations committed another 10
    years to the initiative.

    9None of the grantees distinguish between rural and tribal programs.

    10NCDI's goals coincided with HUD's program goals in the Community
    Development Block Grant Program and the Home Investment Partnerships
    Program (HOME). Both programs emphasize the use of neighborhood-based,
    nonprofit community development organizations to provide affordable
    housing and economic development in low-income neighborhoods.

    Table 1: NCDI Funding, 1991-2004

    Dollars in millions

                                                            Living Cities
              Living Cities    NCDI I   NCDI II  NCDI III (Second Decade)
                 Initiative 1991-1993 1994-1997 1998-2001      2001- 2004   Total
             Private funder    $62.86    $67.85       $87           $93.7 $311.41
                        HUD         0        20        16              20
                      Total    $62.86    $87.85      $103          $113.7 $367.41

    Source: NCDI.

    Congress did not appropriate funds for HFHI and YBUSA until 1997 (see
    table 2).11 At that time, LISC and Enterprise were given the option of
    using Section 4 funding to continue NCDI activities in the original 23
    cities or to undertake new non-NCDI activities in other cities, which
    expanded the geographical dispersion of Section 4 funding. In addition,
    Congress required the grantees to set aside a portion of Section 4 funding
    for rural and tribal areas. Unlike the NCDI activities, whose funding
    objectives were determined by the responsible funders, LISC and Enterprise
    worked directly with HUD in creating the objectives for non-NCDI cities.

    11Section 4 grants cover a 4-year period. We are only providing
    information on the FY 1997 grant for HFHI and YBUSA because it was the
    only grant that had been completed at the time of our review.

    Table 2: Section 4 Funding, 1994-2003

    Dollars in millions

                                                            Total $ allocated for
    Fiscal year   Enterprise       LISC      YBUSA  HFHI             Section 4
                    NCDI non-NCDI NCDI non-NCDI
           1994            $10 $0        $10 $0    $0    $0                   $20
           1995               0 0           0 0     0     0
           1996               5 0           5 0     0     0
           1997             3 4.6         3 4.6   7.6   7.6
           1998             0 7.5         2 5.5     0     0
           1999             0 7.5           2 6     0     0
           2000              0 10         2 8.2   2.5   3.8
           2001            10 2.5        10 2.5     4   3.5
           2002            0 12.5        1.4 11     2     4
           2003              0 14          3 11     2   4.2
          Total         $28 $58.6  $37.7 $48.8  $18.1 $23.1                $214.3

    Source: HUD.

        Grantees Use a Variety of Methods to Help Build Capacity

    LISC and Enterprise are national organizations that use local program
    offices to provide financial and technical support to CDCs. The staff at
    the local program offices work with CDCs to achieve community-driven
    goals. For example, through its Boston local office, LISC provided several
    Section 4 grants to the Madison Park Development Corporation. A $78,000
    grant was used to help the CDC improve the Dudley Square Business district
    in the Roxbury neighborhood of Boston. The Cleveland Enterprise office
    provided Section 4 funds to the Cleveland Neighborhood Partnership
    Program, a local support collaborative that provides organizational and
    real estate development and neighborhood planning for Cleveland CDCs.

    According to HFHI and YBUSA officials, these organizations provide direct
    grants to affiliates but operate somewhat differently. HFHI has provided
    grants to affiliates on a 3-year diminishing basis to hire new staff or
    establish warehouse facilities, with an expectation of increasing house
    production by at least 15 percent. In addition, HFHI has established
    regional support centers to bring technical assistance closer to
    affiliates. YBUSA uses Section 4 funds to provide a variety of grants to
    its affiliated network, such as operating grants, program enhancement
    grants, special assistance grants, and scholarships to staff and students.
    In addition,

    YBUSA has used Section 4 funds to build its capacity to serve as a
    national support center and to provide technical assistance and training.

    LISC and Enterprise consider the subrecipient's stage of development when
    making Section 4 funding decisions. For example, a new organization might
    receive Section 4 funds to pay for a portion of the salary of the
    executive director, whereas more established CDCs might receive funding to
    upgrade their financial management software. All grantees stressed that
    because capacity building takes time, they provide multiyear support to
    subrecipients. However, three of the four grantees indicated that they
    generally fund subrecipients in ways that encourage the organizations to
    become financially independent. Officials from LISC and Enterprise
    explained that although some subrecipients receive multiple grants for
    several years, the grants are small enough to keep subrecipients from
    becoming dependent on Section 4 funds for daily operations. As noted
    earlier, HFHI's grants, which are provided to hire new staff, diminish
    over a 3-year period. According to HFHI, the affiliates' gradual
    absorption of staff costs leads to independence from-rather than
    dependence on-federal funding. YBUSA, however, has provided Section 4
    funding to affiliates to pay for general operations during years when they
    had not received funding under HUD's Youthbuild program.

    Generally, Section 4 funds are used to pay for staff salaries, training,
    technology, and office supplies and equipment and to fund the operating
    support collaboratives. For example, with its 1997 funds HFHI provided
    direct grants to 60 affiliates to pay for staff salaries (usually an
    executive director). The YouthBuild Boston affiliate used Section 4 funds
    to hire an administrative coordinator and enhance its technological
    capabilities. The Washington, D.C., LISC office provided Section 4 funding
    to a local CDC to pay for some staff training and to purchase equipment
    and other supplies to outfit a homebuyer's training center. Enterprise has
    used Section 4 funds to develop on-line tools, such as a best practices
    database, and to bring current technology to CDCs. For example, Enterprise
    awarded one nonprofit organization, Citizen's Housing and Planning
    Association (CHAPA) in Boston, Section 4 funds to administer the NET-Works
    program, a program to enhance the technological capacity of CDCs in the
    New England region. As a result, 36 CDCs received computer equipment,
    Internet access, and assistance in developing websites. Figure 4
    illustrates the broad impact that Section 4 funding had for this nonprofit
    organization on other CDCs.

    Figure 4: Effect of Funding for CHAPA, an Enterprise Subrecipient, for
    Technology Improvements

    Congress did not require grantees to set aside Section 4 funding for rural
    and tribal areas until 1997.12 All four grantees currently have
    initiatives that focus on these areas. For example, LISC has a rural
    office that supports both a national program and a program in the
    Mississippi River Delta Region of the United States covering 56 counties
    and parishes. In fiscal years 1997 through 2002, LISC awarded Section 4
    grants totaling

    12For its rural and tribal programs, YBUSA generally follows the Rural
    Housing Service's requirement that most households receiving assistance be
    located in rural communities with fewer than 20,000 residents. HFHI
    classifies rural counties as those with fewer than 100,000 residents and
    rural cities as those with no more than 25,000 residents. LISC defines
    rural counties as those having no cities with 50,000 or more residents.
    Enterprise considers communities rural if they have fewer than 50,000
    residents.

                          Source: GAO analysis of CHAPA data.

        Rural Areas Now Have Access to Section 4 Funding

    approximately $9 million to rural CDCs. Enterprise has awarded $6.2
    million in Section 4 grants to rural CDCs. Unlike LISC, Enterprise does
    not have a rural office. Enterprise services its rural and tribal
    subrecipients through partnerships with other state and regional rural
    agencies and the Housing Assistance Council, which administers
    Enterprise's Rural Capacity Building Initiative, and through its regional
    and local office structure.13 Although 218 of the 1,003 LISC and
    Enterprise CDCs provide services to rural and tribal areas, many of them
    cover large geographical areas. For example, 57 of the 72 rural CDCs that
    are funded by LISC, operate in more than one county, and 64 of the 146
    rural CDCs that are funded by Enterprise operate in more than one county.
    Figure 5 shows the cities where LISC and Enterprise subrecipients who work
    in rural areas are located and the multiple counties they serve.

    13The Housing Assistance Council is a national nonprofit corporation
    created to increase the availability of decent and affordable housing for
    rural low-income people.

    that as of July 2003, 84 of the 203 operating Youthbuild programs were
    rural and partly rural.

        Grantees Receive Capacity-Building Funding from Other Federal Programs

    LISC, Enterprise, HFHI, and YBUSA also receive capacity-building and
    technical assistance funds from other HUD programs (table 3). The primary
    difference between Section 4 funding and other federal funding is that the
    other federal funding for capacity-building and technical assistance is
    generally awarded competitively, while Section 4 funding is
    noncompetitive. Several federal programs offer capacity-building funds:
    CDBG, HOME, and Housing Opportunities for Persons with AIDS (HOPWA). All
    grantees' Section 4 capacity-building funds exceed those received from
    other federal programs.

        Table 3: Additional Federal Funding for Capacity-Building and Technical
                                       Assistance

                                  Dollars in millions

                                    Total other
                                        federal
                       Intermediary     funding                   Federal program
                               LISC         8.6         CDBG Technical Assistance
                                                        HOME Technical Assistance
                                                                      (1994-2002)

    Enterprise 13.1 	CDBG Technical Assistance HOME Technical Assistance HUD
    Technical Assistance /Capacity Building HOPWA Technical Assistance
    (1995-2002)

    YBUSA 20.2 Youthbuild program (1997-2002)

    Corp. for National and Community Service for AmeriCorps (1997-2003)

    U.S. Dept. of Labor for Welfare to Work (1998-2001)

              HFHI 7.5 Self-help Homeownership Opportunity Program (1999)

                       Source: LISC, Enterprise, YBUSA, and HFHI.

      Federal Funding Has Encouraged Private Sector Involvement in the Section 4
      Grantees' Community Development Initiatives

    While it was difficult to demonstrate empirically that Section 4 directly
    influenced private sector involvement in community development activities,
    funders and grantees said that federal involvement served as a catalyst
    for private fund-raising and provided credibility to subrecipients in
    terms of their ability to comply with the requirements that are associated
    with federal funding. Some local funders of CDCs and affiliates were not
    aware of the specific Section 4 funding the subrecipients received but
    indicated that both federal funding and diverse funding streams are
    important. Since matching funds can be raised either nationally, locally,
    or a combination of both, each grantee employs its own matching policy and
    raises funds from foundations, corporations, banks, individual donors, and
    nongovernmental sources. Since the creation of Section 4, grantees have
    raised nearly $800 million from the private sector, in matching and other
    cash and in-kind contributions.

        Grantees and Private Contributors Generally Believe that Federal Funding Is
        Important to Private Sector Participation

    The grantees and nearly all of the private lenders and foundations we
    contacted stressed the importance of federal funding in leveraging funds
    from the private sector. For example, officials from LISC, Enterprise, and
    Living Cities indicated that private funding and lending have increased
    since HUD's involvement. In addition, Enterprise officials indicated that
    the private sector believes that federal funding provides an incentive to
    work in areas and projects that would be less likely to receive funding
    without federal involvement. HFHI officials said that federal funding is
    imperative because it is the only way for all-volunteer organizations to
    transition into staff-managed, volunteer-based organizations. YBUSA
    officials said that federal funding, especially funding that leverages
    private funding, has enabled YBUSA to be proactive in assisting Native
    American and rural programs.

    NCDI lenders and funders indicated that Section 4 funding had both a
    psychological and a real impact on private sector involvement in the
    initiative. For example, one senior executive from a major lending
    institution indicated that federal participation in NCDI provided funders
    with a symbolic and financial incentive to join the NCDI consortium.
    Symbolically, federal funding provides a sense of credibility to NCDI, as
    funders see federal participation as a sign of good housekeeping and
    reduced risk. Financially, federal participation adds more money to NCDI
    capacity-building initiatives, in turn enabling subrecipients to raise
    more private funding. Another lender said that HUD's participation in a
    CDC through Section 4 funding served as an indication of good management
    and internal controls. An insurance company also noted that Section 4
    funding showed that the federal government was strongly committed to a

    coordinated effort to build CDC capacity, and a foundation told us that
    the federal presence legitimized NCDI as the CDC capacity-building vehicle
    with the greatest payoff. Furthermore, nearly all of the YBUSA and HFHI
    private funders that we interviewed said that federal funding was an
    incentive for their participation in the program. For example, one funder
    said that federal support was like a "seal of approval." Another funder
    said that Section 4 funding created a positive incentive because the
    availability of invaluable hard-to-get federal funding increased the
    viability of any project.

    Most funders and lenders that provide funding directly to CDCs and
    affiliates stressed that federal funding was beneficial, but some of those
    local funders were not aware that subrecipients received Section 4 funds.
    Some LISC and Enterprise subrecipient funders explained that federal
    funding and diverse funding streams were characteristics of a viable
    organization. One funder suggested that public funding was critical, since
    private philanthropy could only do so much. Another foundation indicated
    that it looked to organizations that had a diversified funding structure,
    since it could not provide sole support for an organization.

    The four funders we spoke with that provided funding directly to the
    YouthBuild Boston affiliate were split on whether federal participation
    was an incentive to their involvement. Two said that federal participation
    was an incentive; while the other two said their decision to provide
    funding was based solely on the affiliate's mission.

    Officials from most of the five organizations we spoke with that provided
    funding to an HFHI affiliate in Rhode Island indicated that federal
    participation was not an incentive, but two said that having other sources
    of funding encouraged them to participate. An official from one
    organization indicated that while federal funding indirectly provides an
    incentive for participation, the organization provided funding primarily
    based on the affiliate's reputation and mission.

        Cost Sharing Requirements Are Specified in Law and Grantee Policies

    Section 4 funding calls for significant private sector participation in
    community development initiatives because Section 4 requires that grantees
    match each dollar awarded with three dollars in cash or in-kind
    contributions from private sources. Matching funds are raised nationally
    and locally and come from nongovernmental sources including private
    foundations, corporations, banks, and individual donors. Each grantee has
    its own matching policy and procedures for complying with the matching
    requirement.

    LISC and Enterprise generally meet their matching requirement at the
    national level but encourage CDCs to seek private contributions to aid in
    the match. However, LISC requires subrecipients in rural areas to raise at
    least $1 for each $1 they receive; the remainder of the match is raised
    nationally. Conversely, HFHI and YBUSA require their affiliates to raise
    at least $3 for every dollar of Section 4 funding they receive. While both
    HFHI and YBUSA impose this requirement on all of their affiliates,
    including those in rural and tribal areas, if YBUSA rural and tribal
    affiliates cannot raise the 3 to 1 match, the national organization will
    provide the difference. Officials from the four grantees told us that
    raising the private matching funds had not been a problem. For example,
    for the 1997 grant HFHI and its 60 affiliates that received Section 4
    funding raised almost $155.6 million in private contributions. YBUSA and
    its affiliates raised $26.6 million in private contributions to match its
    $7.6 million grant.

    Grantees Have Raised Since the four grantees became eligible for Section 4
    funding, they have Significant Amounts of raised nearly $800 million from
    the private sector in matching funds and Private Sector Funding and other
    cash and in-kind contributions. However, we could not demonstrate Other
    Resources empirically that Section 4 funding influenced the grantees'
    fund-raising

    owing to external factors such as economic trends and private sector
    interests. Between 1994 and 2001, LISC and Enterprise raised $457 million,
    and from 1997 to 2002, HFHI and YBUSA raised $341 million (see table 4).

    Table 4: Private Sector Funding

                                  Dollars in millions

                                  Grantee    Private sector funding   Time period
                                     LISC                   $319.9a   1994-2001
                               Enterprise                     136.7   1994-2001
                           YouthBuild USA                     26.6b   1997-2001
                                     HFHI                     314.5   1998-2002
                                    Total                    $797.7

    Source: LISC, Enterprise, YBUSA, and HFHI.

    aLISC private sector grants for 1994 and 1995 contain government funding
    due to different accounting practices at that time.

    bThis number only includes YBUSA's matching funds and not all private
    sector funding.

    In addition to providing funding, the private sector has contributed
    in-kind services to CDCs, including managerial skills, mentoring, and
    volunteer labor. For example, representatives from the private sector
    serve on

    LISC's local advisory boards to help local program offices make funding
    decisions and are members of operating support collaboratives in several
    cities. HFHI's local affiliates use volunteers for office and construction
    work and for their boards of directors.

      HUD's Grantee Monitoring and Oversight Is Limited

    HUD monitoring is limited to desk reviews of the grantees' compliance with
    their grant agreements. In general, the grant agreements require several
    kinds of reporting information including work plans, semiannual or
    quarterly financial status reports, requests for grant payment vouchers,
    and final reports. However, HUD's involvement in reviewing grantee work
    plans differs for NCDI and non-NCDI activities. Since HUD does not
    directly monitor the subrecipients' capacity-building activities, it
    relies on the grantees to monitor and oversee them. The grantees have
    several mechanisms in place to ensure that subrecipients are complying
    with their individual grant agreements. However, in a subset of files we
    reviewed, we found that a grantee had funded an ineligible activity for
    one subrecipient. Also, HUD does not have specific impact measures in
    place for Section 4.

        HUD Monitors Grantees but Not Subrecipients

    HUD's efforts to monitor the grantees include desk reviews of work plans,
    annual performance reports, semiannual financial status reports, requests
    for grant payment vouchers, and final performance reports. According to
    HUD, the four grantees sign grant agreements that obligate them to comply
    with HUD and OMB requirements. For example, grantees must submit work
    plans that identify when and how federal funds and nonfederal matching
    resources will be used and present performance goals and objectives in
    enough detail to allow for HUD monitoring. In addition, the grant
    agreements require grantees to submit annual reports showing actual
    progress made in relation to the work plans, plus semiannual financial
    status reports that show private sector matches and grant expenditures to
    a certain date. Grantees are not permitted to begin activities or to draw
    down funds until HUD approves the work plans. Furthermore, the grant
    provisions require that in order to receive payment, grantees must submit
    a payment voucher with supporting invoices that provide enough information
    to allow HUD to determine whether the costs are reasonable in relation to
    the work plan's objectives. Finally, the grant agreement stipulates that
    within 90 days of completing the grant award, the grantee must submit a
    final report summarizing all the activities conducted under the award
    including any significant program achievements and problems reasons for
    the program's success or failure.

    HUD officials told us that staffing constraints caused the agency to focus
    mostly on grantee work plans and payment vouchers. HUD reviews how

    the grantees select subrecipients, set benchmarks, and plan to build
    capacity. HUD uses different processes to review NCDI and non-NCDI work
    plans. As an equal player, HUD reviews NCDI's work plans together with
    other funders and meets twice a year to discuss NCDI initiatives and goals
    for each city. However, HUD reviews and approves non-NCDI work plans by
    itself. A HUD official told us that HUD staff focus most of their
    attention on the funding aspects of the work plans. HUD officials told us
    that they check the semiannual financial status reports and accompanying
    narratives to determine whether the expended amounts are in line with the
    amounts stated in the work plans.

    Section 4 grant funds are provided to grantees after costs are incurred,
    so grantees must periodically submit vouchers and supporting documentation
    that detail expenditures by city or project in order to receive payment.
    HUD staff review the vouchers and supporting documentation to ensure that
    funds are used for the eligible activities stated in the work plans and
    that expenditures such as travel and indirect costs are within HUD
    guidelines and do not exceed available funding. HUD has denied payments
    for activities not contained in approved work plans or not supported by
    the required documentation. For example, in March 2003, HUD withheld over
    $650,000 in Section 4 funding because one grantee did not submit a final
    report, several financial reports, a work plan, and two annual plans. In
    June 2003, however, the grantee provided the necessary documents and HUD
    released the funds.

    In addition, grantees must submit financial status reports that show
    whether the organizations are meeting their matching requirements.
    However, HUD relies on the grantees to ensure that they and their
    subrecipients are matching funds correctly. Both LISC and Enterprise have
    a formal matching policy. LISC's policy explicitly states that counting
    the same funds as matching funds under more than one program is prohibited
    and requires its subrecipients to identify the sources and amounts of
    matching funding they have received twice a year. Enterprise's matching
    requirements are tracked on an ongoing basis and are certified by an
    Enterprise official. YBUSA requires its affiliates to submit documentation
    that supports the sources and amounts of matching funds committed before
    it will release Section 4 funding, and HFHI requires affiliates to report
    matching funds data quarterly.

        HUD Relies on Grantees to Monitor Subrecipients

    HUD does not directly monitor subrecipients' and affiliates'
    capacity-building activities but instead relies on the grantees for
    monitoring and oversight. Like HUD, grantees initiate grant agreements
    with their subrecipients and affiliates. These grant agreements generally
    include such things as the purpose of the grant, grant amount, time frame,
    disbursement conditions, causes for suspension and termination,
    restrictions on use of grant funds, and reporting and accounting
    requirements that describe how the grantee will monitor the grant. The
    grantees use the grant agreements as the basis for monitoring their
    subrecipients' performance.

    The grantees use several mechanisms to ensure that subrecipients are
    complying with their grant agreements. For example, LISC and Enterprise
    officials indicated that throughout the grant period, local offices
    communicate with their subrecipients by telephone or email or in person in
    order to follow their progress. Similarly, YBUSA staff told us that they
    monitor affiliates by telephone as well as through on-site technical
    assistance. LISC, Enterprise, and YBUSA require each subrecipient to
    submit a monthly activity report, semiannual project reports and
    narratives, and final reports. However, the grantees have different
    procedures, forms, and checklists that guide their monitoring activities.

    Operating support collaboratives aid LISC and Enterprise in their
    oversight through proposal reviews, organizational assessments, work plan
    reviews, on-site reviews, quarterly report reviews, and annual and 3-year
    evaluations. The LISC and Enterprise local offices use the collaboratives'
    monitoring information when making their Section 4 funding decisions.14

    HFHI and its regional office personnel evaluate all affiliates every 3
    years based on a "Standards of Excellence" program. The program has three
    elements: best practices, acceptable practices, and minimum standards.
    According to HFHI officials, continued failure to meet minimum standards
    will lead to probationary status and eventually disaffiliation. The
    program provides clear guidelines for affiliate self-assessments and HFHI
    evaluations as well as a systematic process for ensuring that Habitat

    14The operating support collaboratives vary by city. The one in Cleveland,
    for example, distributes money competitively each year, while the one in
    Washington, D.C., has a 3-year funding cycle. They may be run by an
    independent nonprofit organization or as an entity of Enterprise or LISC.
    In some instances, subrecipients that received funds from the operating
    support collaboratives also received Section 4 grants directly from
    Enterprise or LISC.

    affiliates are complying with the organization's basic principles. If HFHI
    national or regional staff are aware of illegal activities or violations
    of HFHI's minimum standards, immediate action can be taken to correct the
    problem. The evaluation covers internal controls and audits. All
    affiliates with an annual income of $250,000 or more, assets of $500,000
    or more, or both are required to have an independent annual audit.
    Affiliates are also requested to submit their annual report to HFHI.

        Even with Comprehensive Controls, Problems May Still Occur

    While the grantees appear to have comprehensive processes to monitor and
    control their subrecipients, our review of seven subrecipients' grant
    files identified a subrecipient that suffered from organizational and
    financial problems that eventually led to its demise. This subrecipient
    was the grantee's second-largest in terms of Section 4 funding, receiving
    10 grants that totaled almost $1 million over a 7-year period. One grant
    for $143,000 paid for several activities, one of which was a bad debt-an
    ineligible expenditure according to OMB Circular A-122. Since HUD
    officials do not receive and review subrecipient grant agreements and
    payment vouchers, HUD was not aware of the ineligible cost. The grantee
    has since taken several steps to ensure that similar problems do not
    occur, including having a staff member perform increased subrecipient
    monitoring to verify that sufficient management controls are in place to
    ensure that grant funds are used appropriately and effectively. This
    monitoring includes a full review of the grant request and award
    documents, followed by a review of supporting documentation to verify
    compliance with allowable expenses and consistency with the work plan. In
    addition, site visits are made to subrecipients that have received large
    amounts of funding and a "watch report" is maintained to track all
    subrecipients that are late in responding to requests for information.

        HUD Does Not Measure the Impact of Section 4 Funding

    HUD has not measured the impact of Section 4 funding on improving the
    capacity of its grantees and subrecipients. However, HUD requires its
    grantees to submit annual work plans that include specific details of how
    federal and private resources will be used and to identify performance
    goals and objectives that should be attained during the grant period. In
    addition, OMB is currently requiring HUD and the NCDI grantees to conduct
    a PART review. PART assessments are used for making budgeting decisions,
    supporting management, identifying design problems, and promoting
    performance measurement and accountability. The assessment includes
    questions on a program's purpose and design, strategic planning,
    management, and results. Furthermore, in response to a GAO report
    recommendation that HUD require program offices to determine the

    Conclusions

    practicability of measuring the impact of technical assistance and
    establishing objective, quantifiable, and measurable performance goals,
    HUD is working with a group of national technical assistance providers to
    develop a framework to assess the effectiveness of its technical
    assistance programs. 15

    Living Cities has also contracted with a consultant to develop impact
    measurements for the 23 NCDI cities. Other evaluations16 have resulted in
    measures that gauge the capacity-building system in NCDI cities and
    categorize organizational capabilities into five different stages of
    growth- initiation, demonstration, professionalization,
    instutionalization, and maturation.17

    While Section 4 funds must be used for capacity-building initiatives,
    grantees are afforded a great deal of discretion as to how they
    administer, use, and oversee these funds. HUD is responsible for ensuring
    that grantees are utilizing Section 4 funds according to federal law and
    regulations and has several controls in place to ensure that they do.
    However, HUD relies primarily on its grantees to make certain that this
    responsibility is carried out at the subrecipient level. We found that
    grantees generally had good management systems and controls in place to
    monitor their subrecipients and to ensure that they carried out their work
    plans, met their objectives, and used federal funds legally and
    responsibly. However, even with good controls, problems can still occur,
    as we found

    15U.S. General Accounting Office, HUD MANAGEMENT: Impact Measurement
    Needed for Technical Assistance, GAO-03-12 (Washington, D.C.: Oct. 25,
    2002).

    16Christopher Walker and Mark Weinheimer, "Community Development in the
    1990s" (Washington, D.C.: The Urban Institute, September 1998); and
    Weinheimer and Associates, "HUD Section 4: Building the Capacity of CDCs,"
    (Washington, D.C.: Assessment Report, June 2001).

    17Initiation refers to the first stage of growth, when a civic or church
    group forms to provide a social service or advocate on an issue. The group
    lacks staff or at least lacks staff trained in development. Demonstration
    occurs when an existing group assumes an initial program in community
    development. The new CDC lacks staff and relies on volunteers. In the
    third stage, professionalization, the CDC takes on larger projects (20-30
    units) or builds several homes and is able to secure funds for staff and
    more projects. When a CDC reaches the fourth stage, institutionalization,
    the staff has developed expertise and taps into public and private sources
    of support that is enabling it to do one large project after another. A
    CDC has reached maturation when it can maintain a consistent level of
    staff expertise, manage multiple projects simultaneously, and move into
    new programs that meet community needs.

    at one CDC. While HUD has overarching responsibility for detecting such
    internal control failures, the cost-effectiveness of adding additional
    federal controls at the subrecipient level must be weighed against the
    size of the program and the amount of federal funding involved. Given the
    relative size of the Section 4 program and the fact that similar problems
    should not recur if HUD and the grantees remain vigilant, we do not
    believe that additional controls are necessary at this time.

    Recommendation for 	We recommend that the Secretary of HUD take steps to
    recover the grant funds that one Section 4 grantee used to cover a bad
    debt.

    Executive Action

    Agency Comments

      Scope and Methodology

    In an e-mail dated August 7, 2003, HUD provided technical comments, which
    we incorporated into this report as appropriate.

    To accomplish our objectives, we reviewed public laws, federal
    regulations, HUD directives, budget documents and other material that
    described the Section 4 program, grantees' missions and organizational
    structures, and authorized and appropriated funding. To determine how
    Section 4 funding has evolved and expanded over the years and how grantees
    use Section 4 funding, we interviewed HUD, Living Cities, LISC,
    Enterprise, YBUSA, and HFHI officials in national, local, and rural
    offices, and subrecipients in Americus, GA; Baltimore, MD; Boston, MA;
    Cleveland, OH; Frederick, MD; Hughesville, MD; Kingston, RI; and
    Washington, D.C. We collected data from LISC, Enterprise, and YouthBuild
    USA showing the number of multiple grants and amounts provided to CDCs or
    affiliates. We selected five CDCs/affiliates from three grantees. For LISC
    and Enterprise, we chose the CDCs that had received the greatest number of
    grants and analyzed the purpose of each grant. For YBUSA, we selected the
    affiliates that had received the highest dollar amounts.18 To create the
    maps of subrecipients and cities that received Section 4 funding, we
    obtained city data from NCDI, LISC, Enterprise, YBUSA, HFHI, and CHAPA and
    used geographical information software (GIS) to create the maps. We used
    the same software to create the rural

    18The criteria differed for YBUSA because of the shorter grant time frame.
    Habitat for Humanity was not included in this analysis because it does not
    allow affiliates to receive multiple grants in any Section 4 grant cycle.

    county maps with data obtained from LISC and Enterprise that listed each
    CDC categorized as rural and the counties they served.

    To determine the importance of Section 4 funding to private sector
    involvement in community development initiatives, we reviewed public laws,
    federal regulations, HUD directives, budget documents, and other
    materials. We obtained 1994 through 2001 private contribution data from
    LISC and Enterprise and 1997 through 2001 data from YBUSA and HFHI. We
    obtained matching policy information from HUD and the grantees and
    interviewed private funders that had provided either grants or loans to
    each of the grantees and subrecipients we visited in Boston, MA;
    Baltimore, MD; Frederick, MD; and Kingston, RI. We based our selections on
    the subrecipients' proximity to our offices in Washington D.C., and
    Boston, MA, and the amount of Section 4 funding they received.

    To determine how HUD and Section 4 grantees controlled the management and
    measured the impact of Section 4 programs, we reviewed and analyzed HUD
    and grantee criteria, processes and procedures for monitoring,
    controlling, and measuring performance and tested grantee monitoring and
    control procedures at seven subrecipients. In addition, we reviewed
    reports prepared by Living Cities and the Urban Institute that discussed
    NCDI's history and accomplishments.

    We conducted our work from September 2002 through April 2003 in accordance
    with generally accepted government auditing standards.

    As agreed with your offices, unless you publicly announce the contents of
    this report earlier, we plan no further distribution of this report until
    30 days from the report date. At that time we will provide copies of this
    report to the Chairman and Ranking Minority Members, Senate Committee on
    Banking, Housing, and Urban Affairs; the Chairman and Ranking Minority
    Member, House Committee on Financial Services; and the Ranking Minority
    Members of its Subcommittees on Oversight and Investigations and Housing
    and Community Opportunity. We will also send copies to the Secretary of
    Housing and Urban Development and the Director of the Office of Management
    and Budget. In addition, the report will be available at no charge on
    GAO's Web site at http//:www.gao.gov.

    Please contact me at (202) 512-8678 if you have any questions about this
    report. Key contacts and contributors are listed in appendix I.

    Thomas J. McCool Managing Director, Financial Markets and Community
    Investment

    Appendix I: Contact and Staff Acknowledgments

    GAO Contact Andy Finkel (202) 512-6765

    Acknowledgments 	In addition, Emily Chalmers, Nadine Garrick, Diana
    Gilman, John McGrail, John Mingus, Frank J. Minore, and Marc Molino made
    key contributions to this report.

      GAO's Mission

    Obtaining Copies of GAO Reports and Testimony

    The General Accounting Office, the audit, evaluation and investigative arm
    of Congress, exists to support Congress in meeting its constitutional
    responsibilities and to help improve the performance and accountability of
    the federal government for the American people. GAO examines the use of
    public funds; evaluates federal programs and policies; and provides
    analyses, recommendations, and other assistance to help Congress make
    informed oversight, policy, and funding decisions. GAO's commitment to
    good government is reflected in its core values of accountability,
    integrity, and reliability.

    The fastest and easiest way to obtain copies of GAO documents at no cost
    is through the Internet. GAO's Web site (www.gao.gov) contains abstracts
    and full-text files of current reports and testimony and an expanding
    archive of older products. The Web site features a search engine to help
    you locate documents using key words and phrases. You can print these
    documents in their entirety, including charts and other graphics.

    Each day, GAO issues a list of newly released reports, testimony, and
    correspondence. GAO posts this list, known as "Today's Reports," on its
    Web site daily. The list contains links to the full-text document files.
    To have GAO e-mail this list to you every afternoon, go to www.gao.gov and
    select "Subscribe to e-mail alerts" under the "Order GAO Products"
    heading.

    Order by Mail or Phone 	The first copy of each printed report is free.
    Additional copies are $2 each. A check or money order should be made out
    to the Superintendent of Documents. GAO also accepts VISA and Mastercard.
    Orders for 100 or more copies mailed to a single address are discounted 25
    percent. Orders should be sent to:

    U.S. General Accounting Office 441 G Street NW, Room LM Washington, D.C.
    20548

    To order by Phone: 	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
    512-6061

    Contact:

    To Report Fraud, Web site: www.gao.gov/fraudnet/fraudnet.htm

      Waste, and Abuse in E-mail: fraudnet@gao.gov

    Federal Programs Automated answering system: (800) 424-5454 or (202)
    512-7470

    Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800

    Public Affairs 	U.S. General Accounting Office, 441 G Street NW, Room 7149
    Washington, D.C. 20548
    *** End of document. ***