We audited the Philadelphia Housing Authority’s compliance with the U.S. Department of Housing and Urban Development’s (HUD) conflict-of-interest and financial disclosure requirements as a result of the Authority’s initial failure to comply with an Office of Inspector General (OIG) subpoena during a previous American Recovery and Reinvestment Act of 2009 audit. (HUD OIG audit report number 2011-PH-1010, “The Philadelphia Housing Authority, Philadelphia, PA, Failed To Support Payments and Improperly Used Funds From the American Recovery and Reinvestment Act of 2009,” dated May 17, 2011). This audit was needed to evaluate information we later obtained from the Authority as a result of the United States District Court’s summary enforcement of the subpoena. The audit objective addressed in this report was to determine whether there were any apparent conflicts of interest involving responsible Authority employees and contractors that performed Recovery Act-funded rehabilitation of the Authority’s scattered site housing units and whether the Authority complied with mandatory financial disclosure reporting requirements.

The information we obtained from enforcement of the OIG subpoena did not indicate the existence of any apparent conflicts of interest involving Authority employees and the contractor or subcontractors that completed Recovery Act-funded rehabilitation of the Authority’s scattered site housing units. The audit did show, however, that the Authority did not comply with provisions in its Moving to Work Demonstration program agreement with HUD that required it to comply with State and local laws because it failed to comply with financial disclosure provisions in the Pennsylvania Public Official and Employee Ethics Act.

We recommend that HUD require the Authority (1) take immediate action to ensure that appropriate employees and board members file the required financial disclosures for calendar year 2010 and for the year following their termination of service and (2) fully implement and enforce the financial disclosure statement policies and procedures approved by its board on July 22, 2011.