title
Presentation, discussion, and possible action on recommendation to adopt Final Orders of debarment for SRCJJC Lubbock Management LLC and associated responsible entities and individuals; THF Housing Development Corporation and associated responsible entities and individuals; The City of Lubbock Housing Initiatives and associated responsible entities and individuals, and to consider the timely filed appeals
end
RECOMMENDED ACTION
recommendation
WHEREAS, Estrada South I f/k/a Park Meadows I (HTC 03140 / CMTS 3354) (Estrada South I) was subject to an HTC Land Use Restriction Agreement;
WHEREAS, Estrada North f/k/a Stone Hollow Village (HTC 04057 / CMTS 4112) (Estrada North) was subject to an HTC Land Use Restriction Agreement;
WHEREAS, Estrada South II f/k/a Park Meadows II (HTC 060058 / CMTS 4371) (Estrada South II) was subject to an HTC Land Use Restriction Agreement;
WHEREAS, the three developments were foreclosed on August 6, 2024, terminating TDHCA’s HTC LURAs;
WHEREAS, SRCJJC Lubbock Management LLC, Chris Roberts, Peter Delfino, George Arau, Jennifer Joyce, THF Housing Development Corporation, Mark Mayfield, Susan Hamm, Griffith Morris, Johnny White, Nancy Jackson, Phil Woods, John Moman, and Dave Edwards either controlled Estrada South I, or had chosen to delegate their control authority, at the time of foreclosure;
WHEREAS, SRCJJC Lubbock Management LLC, Chris Roberts, Peter Delfino, George Arau, Jennifer Joyce, THF Housing Development Corporation, Mark Mayfield, Susan Hamm, Griffith Morris, and Johnny White, Nancy Jackson, Phil Woods, John Moman, and Dave Edwards either controlled Estrada North, or had chosen to delegate their control authority, at the time of foreclosure;
WHEREAS, SRCJJC Lubbock Management LLC, Chris Roberts, Peter Delfino, George Arau, Jennifer Joyce, The City of Lubbock Housing Initiatives, The Housing Authority of the City of Lubbock a/k/a the Lubbock Housing Authority, Mike Chapman, Toby Cecil, Ayda Chapa, Amanda Gray, Vecelia Mann, and Jerry Ramirez either controlled Estrada South II, or had chosen to delegate their control authority, at the time of foreclosure;
WHEREAS, Tex. Gov’t Code §2306.0504(b) states that the Department may debar a person from participation in a Department program on the basis of the person's past failure to comply with any condition imposed by the Department in the administration of its programs;
WHEREAS, 10 TAC §2.401 defines the violations that are eligible for debarment;
WHEREAS, controlling a multifamily Development that was foreclosed after April 1, 2021, where the foreclosure or deed in lieu of foreclosure terminates a subordinate TDHCA LURA is grounds for discretionary debarment under 10 TAC §2.401(a)(7);
WHEREAS, an informal conference was held on October 29, 2024, regarding the debarment referrals relating to the foreclosures of Estrada South I and Estrada North;
WHEREAS, on November 13, 2024, the TDHCA Executive Director issued a debarment determination notice recommending a one-year debarment term for THF Housing Development Corporation, Mark Mayfield, Susan Hamm, Griffith Morris, Johnny White, Nancy Jackson, Phil Woods, John Moman, and Dave Edwards, relating to the foreclosures of Estrada South I and Estrada North;
WHEREAS, an informal conference was held on November 21, 2024, regarding the debarment referrals relating to the foreclosure of Estrada South II;
WHEREAS, on December 11, 2024, the TDHCA Executive Director issued debarment determination notices recommending a ten-year debarment term for SRCJJC Lubbock Management LLC, Chris Roberts, Peter Delfino, George Arau, and Jennifer Joyce, and a one-year debarment term for The City of Lubbock Housing Initiatives, The Housing Authority of the City of Lubbock a/k/a the Lubbock Housing Authority, Mike Chapman, Toby Cecil, Ayda Chapa, Amanda Gray, Vecelia Mann, and Jerry Ramirez, relating to the foreclosure of Estrada South II;
WHEREAS, SRCJJC Lubbock Management LLC, Chris Roberts, Peter Delfino, George Arau, and Jennifer Joyce did not appeal their debarment determinations to the Board;
WHEREAS, THF Housing Development Corporation, Mark Mayfield, Susan Hamm, Griffith Morris, Johnny White, Nancy Jackson, Phil Woods, John Moman, Dave Edwards, The City of Lubbock Housing Initiatives, The Housing Authority of the City of Lubbock a/k/a the Lubbock Housing Authority, Mike Chapman, Toby Cecil, Ayda Chapa, Amanda Gray, Vecelia Mann, and Jerry Ramirez have appealed their debarment determinations to the Board;
WHEREAS, the appeals include evidence that supports removing the following board members from this debarment action because they are not board officers and did not have control as defined by the rule: Nancy Jackson, Phil Woods, John Moman, Dave Edwards, Amanda Gray, Vecelia Mann, and Jerry Ramirez;
WHEREAS, no further changes to the debarment determinations are recommended by staff based upon the appeals, and
WHEREAS, staff has based the above debarment term recommendations on the Department’s rules for debarment and an assessment of each and all of the material factors identified at 10 TAC §2.401(j) that are to be considered in determining a recommended period of debarment, applied specifically to the facts and circumstances present in this case.
NOW, therefore, it is hereby
RESOLVED, that three Orders, including: (1) a Final Order of Debarment for a term of ten years for SRCJJC Lubbock Management LLC, Chris Roberts, Peter Delfino, George Arau, and Jennifer Joyce; (2) a Final Order of Debarment for a term of one year for THF Housing Development Corporation, Mark Mayfield, Susan Hamm, Griffith Morris, and Johnny White; and (3) a Final Order of Debarment for a term of one year for The City of Lubbock Housing Initiatives, The Housing Authority of the City of Lubbock a/k/a the Lubbock Housing Authority, Mike Chapman, Toby Cecil, and Ayda Chapa; substantially in the form presented at this meeting, and authorizing any non-substantive technical corrections, are hereby adopted as the order of this Board.
end
BACKGROUND
PROPERTY AND FINANCING INFORMATION:
1. Estrada South I: 2003 HTC award for new construction. 112 units in Lubbock, with 18 units at 40% AMI, 32 units at 50% AMI, and 50 units at 60% AMI, with the remainder at market rate. HTC LURA was signed in 2005. The 15-year federal Compliance Period ended on December 31, 2021. The Extended Use Period was set to terminate December 31, 2044. Owned by THF Housing Development Corporation as general partner and fee title owner, and SRCJJC Lubbock Management as limited partner.
2. Estrada North: 2004 HTC award for new construction. 140 units in Lubbock, with 13 units at 30% AMI, 4 units at 40% AMI, 28 units at 50% AMI, and 67 units at 60% AMI, with the remainder at market rate. HTC LURA was signed in 2006. The 15-year federal Compliance Period ended on December 31, 2021. The Extended Use Period was set to terminate December 31, 2046. Owned by THF Housing Development Corporation as general partner and fee title owner, and SRCJJC Lubbock Management as limited partner.
3. Estrada South II: 2006 HTC award for new construction. 120 units in Lubbock, with 32 units at 30% AMI, 34 units at 40% AMI, and 54 units at 50% AMI. HTC LURA signed in 2008. The 15-year federal Compliance Period ended on December 31, 2023. The Extended Use Period was set to terminate December 31, 2048. In addition to TDHCA’s restrictions, 32 of the units are also public housing units. Owned by The City of Lubbock Housing Initiatives, as general partner, and SRCJJC Lubbock Management as limited partner.
VIOLATIONS SUBJECT TO DEBARMENT:
1. Tex. Gov’t. Code 2306.0504(b) states, “(b) The department may debar a person from participation in a department program on the basis of the person's past failure to comply with any condition imposed by the department in the administration of its programs.”
2. 10 TAC §2.401(a)(7) states, “(a) The Department may debar a Responsible Party, a Consultant and/or a Vendor who has exhibited past failure to comply with any condition imposed by the Department in the administration of its programs. […] (7) Controlling a multifamily Development that was foreclosed after April 1, 2021, where the foreclosure or deed in lieu of foreclosure terminates a subordinate TDHCA LURA;”
All three properties were foreclosed on August 6, 2024, terminating the TDHCA LURAs, except for the three-year safe harbor period for existing low-income tenants.
RESPONSIBLE PARTIES: At the time of foreclosures, the control structures were as follows:
1. THF Responsible Parties: THF Housing Development Corporation (THF) entered as the general partner and fee title landowner for Estrada South I and Estrada North on July 14, 2017. Mark Mayfield was THF’s CEO and President, and its board members included Susan Hamm (Board Chair), Griffith Morris (Board Vice Chair), Johnny White (Board Secretary), Nancy Jackson, Phil Woods, John Moman, and Dave Edwards. Mr. Mayfield is now retired, but was in a position of control at the time of the salient events herein.
2. Housing Authority Responsible Parties: The City of Lubbock Housing Initiatives, a nonprofit instrumentality controlled by the Housing Authority of the City of Lubbock a/k/a the Lubbock Housing Authority (the Housing Authority), was the general partner and fee title landowner for Estrada South II. It was the original general partner for all three phases, but sold Estrada South I and Estrada North in 2017, only retaining Estrada South II. Mike Chapman is the housing authority’s executive director, and its board members include Toby Cecil (Board Chair), Ayda Chapa (Board Vice Chair), Amanda Gray, Vecelia Mann, and Jerry Ramirez.
3. SRCJJC Responsible Parties: SRCJJC Lubbock Management, LLC (SRCJJC) controlled the limited partner of the owning entities for all three properties. It had primary control per the limited partnership agreements with both general partners noted above. Managers for SRCJJC are Chris Roberts, Peter Delfino, George Arau, and Jennifer Joyce.
DELEGATION OF AUTHORITY TO LIMITED PARTNER: In March 2019, an unrelated limited partner controlled by Alden Torch sold the limited partnership interests in all three properties to Lubbock Affordable Housing Group, LLC. The limited partnership interests were then sold to SRCJJC Lubbock LLC in 2021.
1. THF: Claims it was unaware of these LP transfers, and that it was required to sign documents after the LP interests were sold. THF alleges that Mark Mayfield, its former CEO / President, unilaterally agreed to extensive control delegation to the limited partner in an amended limited partnership agreement in 2019, over the objections of staff and legal counsel, and that the THF board was not aware. THF claims that it was then left powerless to make needed changes at the development as a result. THF alleges that SRCJJC intentionally excluded THF from all decisions, and did not keep THF informed. During an informal conference on October 29, 2024, THF staff confirmed that Mark Mayfield had full authority to sign off on binding documents on behalf of the nonprofit, and did not require board approval to do so.
2. Housing Authority: States that it signed an amended and restated limited partnership agreement in 2019, delegating its control authority to the limited partner, and that it has had essentially no involvement in the operation of Estrada II since that time, and it is only involved with providing the HUD subsidy for the 32 public housing units, and providing a property tax exemption due to its role as the general partner. However, Section 4.3(d) of its limited partnership agreement provided the Housing Authority the ability to exercise control authority in the event that the limited partner violated the purposes of the partnership. Section 4.4 of that agreement further stated that the general partner “shall not, by act or omission, permit the termination or disqualification […] as a qualified low-income housing project under Section 42 of the Code.”
FORECLOSED LOANS:
1. Estrada South I and Estrada North: $5,042,052.00 deed of trust for Estrada South I and $5,320,591.00 deed of trust for Estrada North, effective January 5, 2023, both signed by SRCJJC, with joinder/consents signed by THF as ground lessor. THF alleges it was forced to sign the joinder. TDHCA does not have complete loan information, however, we did receive copies of the settlement statements, which show that the payoff for the prior lien for Estrada South I was $3,776,452.28 and $1,106,892.00 was intended for construction, and the payoff for the prior lien for Estrada North was $4,119,768.29 and $1,033,348.00 was intended for construction. The remaining balances were divided among closing costs and fees.
2. Estrada South II: $3,605,000.00 deed of trust, effective 7/25/2023, signed by SRCJJC only. Maturity date 7/1/2024. Per the note, 11.49% interest, and interest-only payments.
FACTORS CONTRIBUTING TO FORECLOSURE:
1. Per THF: THF representatives attended an informal conference on October 29, 2024, and stated that the reason for the foreclosure was because SRCJJC barred THF from receiving financials, THF was unable to cure the defaults, and THF had no knowledge of the loan terms. THF further alleged that SRCJJC contributed to the property’s failure when SRCJJC: failed to maintain acceptable occupancy rates; failed to properly repair the apartments after casualty losses; failed to properly account for insurance proceeds from casualty losses; failed to properly account for refinance proceeds or utilize them for the purpose of making needed repairs required by TDHCA; failed to keep vacant apartments secured; hired management companies without THF’s consent or input; failed to provide THF sufficient information to monitor progress at the apartments; changed the complex names without THF’s knowledge (THF learned about it after the property was renamed in CMTS); listed the properties for sale in October 2022 without THF’s knowledge (THF learned of the listing from third parties); refinanced the properties on January 4, 2024 without THF’s knowledge input or consent (except a last minute notice and threat of litigation if estoppel certificates were not signed); failed to provide sufficient information for THF to materially participate in operation and management; failed to pay vendors and management agents, filed lawsuits against the apartments and THF. THF claims they were powerless to prevent the foreclosures due to overreaching delegation provisions in the 2019 partnership agreement.
2. Per Housing Authority: Housing Authority representatives attended an informal conference on November 21, 2024, but did not provide any information responsive to this section.
3. Per SRCJJC: SRCJJC includes four managing members: Chris Roberts, Peter Delfino, George Arau, and Jennifer Joyce. Mr. Roberts and Ms. Joyce attended informal conferences on October 29, 2024 for Estrada South I and Estrada North, and on November 21, 2024 for Estrada South II. They stated that Mr. Arau proposed the acquisition in 2022, and connected the various partners for SRCJJC. The February 2021 winter storm had caused significant damage to Estrada South I and Estrada North, which had a two-year casualty loss restoration period with TDHCA. SRCJJC anticipated receiving approximately $3M in insurance proceeds to make necessary casualty loss repairs. Mr. Roberts and Ms. Joyce then alleged that associates of George Arau, including Mark Shapiro, had misappropriated funds invested by the partners, along with insurance proceeds of approximately $2.7M relating to the freeze damage claim. Mr. Roberts and Ms. Joyce also claim that financial statements were withheld from them, and they had no knowledge of the misappropriation until the third quarter of 2023, when other (unnamed) partners at SRCJJC notified them that they were out of money and needed to sell the property immediately. Ms. Joyce states that she started to investigate at that time, including a property inspection when she discovered that funded repairs had not been performed at the site as intended. Mr. Roberts and Ms. Joyce further allege that SRCJJC’s financials that were eventually disclosed had been manipulated by their partners.
ACTIONS TAKEN TO AVOID FORECLOSURE:
1. Per THF: States that it tried to get access to financials and the other matters outlined at Section V above, but alleges that SRCJJC refused to cooperate. THF then attempted to exit the partnership, but that requires permission of the SRCJJC, which was denied. THF filed a lawsuit against SRCJJC on August 9, 2023, alleging the matters outlined above, and claiming that SRCJJC was unjustly enriched by the refinance and casualty loss insurance proceeds, which THF alleges were not properly applied to property repairs. The lawsuit is ongoing.
2. Per Housing Authority: None. The Housing Authority chose not to perform any monitoring activities for Estrada South II, and did not intervene when appropriate under its partnership agreement.
3. Per SRCJJC: Mr. Roberts and Ms. Joyce state that they demanded financial statements and investigated the alleged mismanagement. They further state that there is pending litigation and a pending FBI investigation, but no written materials were provided to substantiate those statements. Both stated that they invested significant personal funds into the development, but there was nothing they could do to prevent foreclosure due to the financial mismanagement, and that the lender cut off communications. They mentioned that $8M was invested by SRCJJC between 2021 and 2024, but was unclear how much was part of the purchase price and how much was advanced for repairs and operating expenses. Mr. Arau and Mr. Delfino were not present during the informal conferences. There are no written submissions.
DEBARMENT IS DISCRETIONARY: Debarment is discretionary for this violation per the above referenced statute and rule.
FACTORS CONSIDERED TO DETERMINE RECOMMENDED DEBARMENT TERM: The TDHCA Executive Director issued multiple debarment determination notices, including (1) a ten-year debarment term for the SRCJJC Responsible Parties; (2) a one-year debarment term for the THF Responsible Parties; and (3) a one-year debarment term for the Housing Authority Responsible Parties. The THF Responsible Parties and Housing Authority Responsible Parties have appealed their debarment determinations (see Exhibits 2 and 3). There is no required minimum or maximum debarment term, and the Board may increase or decrease the recommended terms. Pursuant to 10 TAC §2.401(j), the recommended period of debarment was based upon the following material factors:
1. Repeated occurrences: There are no prior foreclosure occurrences for any of the Responsible Parties.
2. Seriousness of underlying issues: Foreclosure is among the most serious potential debarment violations because it removes affordable housing that was intended to benefit low-income Texans for many years to come. In this case, the Department lost 20 years of affordable housing for 212 collective units due to mismanagement by both THF and SRCJJC for Estrada South I and Estrada North. Both are also responsible for the mismanagement relating to the physical condition and delayed casualty loss restoration. For Estrada South II, the Department lost 24 years of affordable housing and 120 units due to mismanagement by both the Housing Authority and SRCJJC. There are also serious allegations relating to fraud and misappropriation by unknown third party, actions that both THF and SRCJJC agree impacted the physical conditions of Estrada South I and Estrada North due to delayed casualty loss restoration. One of the purposes of debarment is to give the Responsible Parties time to regroup and fix their internal policies and mechanisms to show that they can responsibly administer TDHCA properties and funding. Even a brief pause is vitally important to ensure that all eyes of the ownership of an affordable development are on its financial functioning to prevent this absolute worst outcome for the foundational, statutory, public policy of this Department to create and preserve decent, safe, and affordable housing: the loss of affordable units through foreclosure.
3. Presence or absence of corrective action: There is no way to correct a foreclosure after it occurs, but the Committee considered actions taken to prevent the foreclosure.
THF: Filed a lawsuit against SRCJJC in August 2023, attempting to recover funds and regain some control over the developments. That lawsuit remains ongoing.
SRCJJC: Mr. Roberts and Ms. Joyce stated that they demanded financial statements and investigated the mismanagement from their own partners. They further state that there is pending litigation and a pending FBI investigation, but did not provide supporting evidence to substantiate such claims. Mr. Roberts and Ms. Joyce also indicated that they tried to talk to some buyers prior to foreclosure, but those potential sales fell through.
Housing Authority: The Housing Authority had essentially no involvement in the operation of Estrada South II, except their 32 public housing units. It admits it was in the dark about all aspects of business operations. However, the Housing Authority is trying to negotiate with the lender-affiliate that purchased Estrada South II at foreclosure. The Housing Authority states that it has offered to become the general partner for the new owner, thereby restoring the property tax exemption, if the new owner agrees to reinstate the TDHCA HTC LURA. Unfortunately, representatives for the Housing Authority do not think the lender is interested.
4. Other material factors:
THF: THF was the fee title landowner for Estrada South I and Estrada North at the time of foreclosure. The Committee did not understand THF’s arguments regarding being forced to sign limited partnership agreements and loan documents. It was unclear how they were forced to sign.
THF is a nonprofit organization and controls nearly fifty developments that are monitored by TDHCA. THF claims that it participated in these developments as part of its charitable purpose, and that it should not be subject to debarment since it was not in a position of control at the time of foreclosure. Indeed, THF delegated extensive control authority to its limited partners, signing a new limited partnership agreement in 2019, and then signing TDHCA Control Forms in 2023 to formalize the control structure from a TDHCA compliance monitoring perspective. However, the Control Form explicitly states that such delegation does not negate accountability with respect to debarment proceedings. THF’s limited authority at the time of foreclosure is a direct and foreseeable consequence of its poor business decision to delegate its control authority. It would not be a reasonable result to reap the rewards and tax benefits of having a nonprofit in the general partner position while avoiding all potential responsibilities and consequences by voluntarily ceding control to another party and failing to adequately vet its business partners. THF made a poor business decision in ceding control, and the result was misappropriation of funds by its partners, failure of the developments, and ultimately foreclosure. Delegating all meaningful control authority is inconsistent with its role as general partner. THF did attempt to regain some control by filing a lawsuit against SRCJJC in 2023.
SRCJJC: The developments were financially distressed due to water damage from the February 2021 winter storm, and subsequent mismanagement of funds. SRCJJC entered the partnerships in 2022, after the first winter storm occurred. Significant fraud allegations are noted above. While SRCJJC focused on financial mismanagement during its informal conferences, THF also alleged that SRCJJC failed to maintain acceptable occupancy rates, failed to properly repair the apartments after casualty losses, failed to keep vacant units secured, and hired a replacement property management company without prior affordable experience without THF’s input, factors that all contributed to the financial difficulties that eventually culminated in foreclosure. It is unclear who is responsible for the alleged misappropriations since only Chris Roberts and Jennifer Joyce participated in the informal conferences. Both blamed unnamed affiliates of their partner, George Arau, but he did not attend the informal conferences. The fourth member of SRCJJC, Peter Delfino, also did not attend. SRCJJC’s mismanagement of the three developments is a primary cause of the foreclosures.
Housing Authority: The Housing Authority and its nonprofit instrumentality do not control any other developments that are monitored by TDHCA. Like with THF above, the Housing Authority also delegated extensive control authority for Estrada South II to the limited partner in 2019. The Housing Authority’s limited authority at the time of foreclosure is a direct and foreseeable consequence of its poor business decision to delegate that authority. Furthermore, the Housing Authority did not participate enough in business operations to even know whether there was an issue to trigger its authority under Section 4.3(d) of the partnership agreement. It was within their power to exercise that section of the agreement, and they chose not to do so. Delegating all meaningful control authority and not maintaining any level of oversight is inconsistent with its role as general partner. It would not be a reasonable result to reap the rewards and tax benefits of having a housing authority in the general partner position while avoiding all potential responsibilities and consequences by voluntarily ceding control to another party and failing to adequately vet its business partners. The Housing Authority made a poor business decision in ceding control, and the result was failure of the developments, and ultimately foreclosure. However, despite the foreclosure, thirty-two units at Estrada South II will remain affordable since they are public housing units. Additionally, the possibility of restoring the HTC LURA is a significant factor, and would mitigate the seriousness of the foreclosure if it came to fruition.
DEBARMENT APPEALS: SRCJJC did not appeal. Written appeals for THF and the Housing Authority are at Exhibits 2 and 3. The appeals by THF and the Housing Authority focus on control authority delegation, and the role that nonprofits and housing authorities play in the Housing Tax Credit Program. They argue that debarring the nonprofits / housing authorities would disincentivize qualified nonprofits from joining post-15 to preserve a property, and that their involvement is needed for a property tax exemption to make the developments viable. They further argue that debarment would exacerbate preservation challenges for post-15 properties, and cause earlier foreclosures.
TDHCA staff reiterates that both organizations chose to abdicate their control authority, a significant factor that is relevant to this debarment decision. Indeed, THF provided an example in its appeal demonstrating how it had control authority for another distressed property in its portfolio, and it funded that development to avoid foreclosure when the limited partners refused to provide additional capital. It stated that it did not do the same for Estrada South I or Estrada North because it did not have control authority. But this is a circular dilemma of its own making, because THF only lacked control because it voluntarily chose to delegate control. TDHCA staff is uncertain how many other ownership structures are similarly adversely impacted.
The appeals included evidence that supports removing the following board members from this debarment action because they are not board officers and did not have control as defined by the rule: Amanda Gray, Vecelia Mann, and Jerry Ramirez for the Housing Authority, and Nancy Jackson, Phil Woods, John Moman, and Dave Edwards for THF. The recommendation below has been adjusted accordingly.
RECOMMENDATION: Accordingly, after consideration of all appropriate factors, including those set out in TEX. GOV’T CODE §2306.0504 and 10 TEX. ADMIN. CODE §2.401, the Enforcement Committee and Executive Director recommend the following:
1. A Final Order of Debarment for a term of ten years for SRCJJC Lubbock Management LLC and its managers, Chris Roberts, Peter Delfino, George Arau, and Jennifer Joyce;
2. A Final Order of Debarment for a term of one year for THF Housing Development Corporation, former chief executive officer Mark Mayfield, and officers for THF’s Board of Directors, Susan Hamm, Griffith Morris, and Johnny White; and
3. A Final Order of Debarment for a term of one year for The City of Lubbock Housing Initiatives, the Housing Authority of the City of Lubbock a/k/a the Lubbock Housing Authority, executive director Mike Chapman, and officers for the Housing Authority’s Board of Directors, Toby Cecil and Ayda Chapa, but with the possibility to remove the debarment if the Housing Authority, or an affiliate, joins the ownership structure of the new owner and reinstates the full term of the TDHCA HTC LURA.
Exhibits:
1. Rule Excerpts
2. Debarment Appeal for THF
3. Debarment Appeal for Housing Authority