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I
·I
I
I
i
A 'DRAFT PROPOSAL
THE PURPOSES AND WORK PROGRAJ.'1 OF THE
TASK FORCE ON THE CITIES
Summary Statement
It is recorrrrnended that the concept and criteria underlying
Federal urban policy move fro m program to floo:
and that the Task
Force use its time an~ equity to mark this historical divide and to
begin detailing what it means and by what policies and procedures
it might be expressed.
Background
The l a st generation of Federal activity in urban affairs has
deve loped along two line s tha t l ead to growing frustration in a
pluralistic society of increa sing mas s and priva te initiativ e :
(1) the notion tha t for every urban problem the re should be a sp e cific
program which is to b e executed pr incipa lly t hrough a public bur e aucracy ;
(2) the d ef inition of urb an prob l em s and polici es in s ta tic (mainly
ge ograph i c ) t erms.
This ur ba n wor ld is two uni verse s ap ar t fro m the kind of ana l ysi s
on wh ich th e econom ic polici es of the U. S . during this s a~e period h ave
be en conc eived and e na ct ed.
Th e l a tter have derived f r om dynami c
ana l ysis expr e ssed in terms o f na tional a ggregat e s.
Th i s econo;-nic
mod e l ha s h ad at least s ome s embl a nce of internal consi stency , and lev e r s
0•
�2
I
have been designed which make it possible to effect changes in
national economi c behavior at relevant scale.
The urban model has not even the pre tense of int erna l consistency,
and with its tiny levers exerts a force on urban development so small
that even its local effects are barely visible.
What is worse, it
involves such a massive input of politica l and admi.nistrative t a l ent
that the nation's energies and equities are dissipat~d.
Despite some lingering prejudice, it is becoming evident to many
of us that the simple multiplication of pre sent efforts and redoubling
of budg ets will not produce e quiva l ent r esults.
In the us e of the
existing urban model, we have alre ady r ea ched the point of dimi nishing
returns:
Ten times the pr e sent urban r enewa l, we lfa r e and other programs
will more like ly produc e ten time s the pre s eni frustr a tions r a ther than
some multiple of the desired urban outcome .
To s ay that the pr e s ent urb an model h as been inadequate is not to
s ay th at th e more dy nam ic mode l o f na tiona l e conomi c policy h as been
idea l.
From many points o f view -- not l eas t the urb a n -- the na tiona l
ec onomic model h a s pr oduc ed s ome indi ffe r ent and some times disastT.ous
res ults.
For one , i t h a s b een ti ed to a singl e-entry bookkeeping of
na tiona l b e nef it:
a t a lly o f Gross Nationa l Produ ce whi ch r eg i sters
pr esumed social ga ins wi t hout of f s e tting measures of soci a l cost.
More impor tant, the r e cord er s and eng ineers of a ggrega t e economi c change
h ave omitt e d any cons id eration of area - except f or an occas i onal bow
to economic r eg ions wh e n a stray member of the peer group or a dr a~a tic
accid ent of history (like the TVA) have made it resp e cta bl e .
�3
In an age of urban concentration, the failure to include area
as one dimension of national economic policy has been folly.
And
'
i
with the prospect of peace being declared, and urban development
becoming the object of increas ed public and private spending, the
need for a major policy shift is all the more urgent.
Consider four examples:
1.
The flmv of effective consumer demand into areas of
"social deficit" - Bedford-Stuyvesant; North Philadelphia, the ghettoes
of our metropolitan areas; the abandoning small towns of the Jersey
Pines, the Appalachian chain, etc.
In these areas -it is b e coming
painfully obvious that pres ent public pro gr ams (renewal; ,ve lfare ;
job training and deve lo pment) are not producing much of an effe ctive
dema nd, and that until there is such a d er.iand, there won't b e induc ed
an adequ a te economic b ase .
Thus the growing cry for the nega tive
income t ax , the guarant eed minimum income , the fa mily allowanc e , and
the "welfare dollar" (of Lloyd's Bank Revi ew , ca. Octob er 1966 ) wh ich
giv e s the poor a choic e of expenditures among essential s e rvi ces .
The Task Force wi ll not h ave to inv ent propos a ls of this sort;
but we can ( a ) sh ow h ow th ey f it int o a more dynamic urb an model;
(b) do b ad ly-nee ded di gg ing into the ir pr obable e ff ec ts , relative
advantages, and adm inistra tiv e feasibility.
�,
4
2.
deficit.
The flow of investment and enterprise into areas of social
Public programs of renewal, housing, and economic opportunity
have had discouragingly weak leverage in stimulating the economic
development of ghettoed and other declining corrnnunities.
that tax policy offers a more promising lead:
It may be
declaring areas of socia l
deficit elig ible sites for Fede ral, st a te and local tax incentive s of
various sorts for spe cifi e d kinds o f inv e stment and enterpris e .
The proposal is not new; but again, the Task Force can develop
its rationa le and explore its fe a sibility.
3.
The f low of nat iona l t ax r e sourc e s to sta t e s and mun ic ipa l iti e s,
(and to othe r qua si-public instrumentaliti e s for corrnnunity action).
The r eadi es t exampl e is the He ller Pl an, which -- along with othe r
proposa ls like the sha r ed-t ax -- ba dly n eeds r e sha ping to f it a d e cl a r ed
schedul e o f urb an needs and r eforms.
It seems cl ear the pre s ent
structure of Fede r a l gr ants pr oduce s a flow of r ev enu e s to th e l e sser
jurisd ic t i on s which i s too sma ll, too c a t egoric a l, to o i ncoher ent , and
too much i n t he c ontro l of s pe cia li z ed t e chn ici ans .
It a l so conc entrate s
on the a rt of grant sman s hip r a t he r tha n on per formanc e ; and it exa cts
sma ll change s i n b ehav i or fro m t h e bur eau c r ac i e s ra ther than ma j or
ch ange s and c onc ess ions fr om gov ernors and l eg is l a tur e s , mayor s and
c ounci l s ( e.g . , to b e e li g ibl e for a ma jor b lock gra nt from the ~d er ai
governme nt, a Sta t e mi ght b e aske d to expand and r esh a pe it s own
r ev enue s y s t em , and mak e some f undament a l changes i n i ts admini stra t i v e
structure and procedur e s ) .
�5
The Task Force might declare for an increased flm~ of Federal
revenues to the States and local governments through more generalized
I
I
grants, and begin to detail some of the more promising ways, means
and conditions.
(And now that the "growth sector" of central citi e s
se ems to be public and non-profit in character (education, health,
government, etc.), we might explore the possibility of expanding in
lien payments to those municipalities as a major reve,nue source.)
4.
The flow of nationa l resources into housing in de cl a r ed areas.
This flow has been too sma ll, too erratic, and off the geogyaphical
targets of need.
The Task Force mi ght review in the persp e ctive of
thirty years the efficacy of curr ent devic e s and (e.g. FHA 1 s)
conventional wisdom:
subsidies; etc.
mortgage insuranc e ; below-ma rket-int er es t-rate s;
There may be more powe rful levers than these, with
more consist e nt effects and ge og raphical accuracy.









There are othe r flows to c ons ider:
most important, th e flm~s of
people to and within the country I s met ropolitan areas, wi th a sp e cial
eye to the forces, inc ent ive s, etc ., which sti mu l a t e and shape thos e
flows.
For example, a low airline fare from Puerto Rico to oth er
metropolitan area s than New York might have l essened "The Puerto Rican
problem".


.


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              <text>|
A DRAFT PROPOSAL

THE PURPOSES AND WORK PROGRAM OF THE

TASK FORCE ON THE CITIES

Summary Statement

It is recommended that the concept and criteria underlying
Federal urban policy move from program to flow: and that the Task
Force use its time and equity to mark this historical divide and te
begin detailing what it means and by what policies and procedures

it might be expressed.

Background

The last generation of Federal activity in urban affairs has
developed along two lines that lead to growing frustration in a
pluralistic society of increasing mass and private initiative:

(1) the notion that for every urban problem there should be a specific
program which is to be executed principally through a public bureaucracy;:
(2) the definition of urban problems and policies in static (mainly
geographic) terms. x

This urban world is two universes apart from the kind of suaipats
on which the economic policies of the U.S. during this same period have
been conceived and enacted. The latter have derived from dynamic
analysis expressed in terms of national aggregates. This economic

model has had at least some semblance of internal consistency, and levers
have been designed which make it possible to effect changes in
national economic behavior at relevant scale.

The urban model has not even the pretense of internal consistency,
and with its tiny levers exerts a force on urban development so small
that even its local effects are barely visible. What is worse, it
involves such a massive input of political and administrative talent
that the nation's energies and equities are dissipated.

Despite some lingering prejudice, it is becoming evident to many
of us that the simple multiplication of present efforts and redoubling
of budgets will not produce equivalent results. In the use of the
existing urban model, we have already reached the point of diminishing
returns. Ten times the present urban renewal, welfare and other programs
will more likely produce ten times the present frustrations rather than
some multiple of the desired urban outcome.

To say that the present urban model has been inadequate is not to
say that the more dynamic model of national economic policy has been
ideal. From many points of view -- not least the urban -- the national
economic model has produced some indifferent and sometimes disastrous
results. For one, it has been tied to a single-entry bookkeeping of -
national benefit; a tally of Gross National Produce which registers
presumed social gains without offsetting measures of social cost.

More important, the recorders and engineers of aggregate economic change
have omitted any consideration of area - except for an cccasional bow
to economic regions when a stray member of the peer group or a dramatic

accident of history (like the TVA) have made it respectable.
In an age of urban concentration, the failure to include area
as one dimension of national economic policy has been folly. And
with the prospect of peace being declared, and urban development
becoming the object of increased public and private spending, the
need for a major policy shift is all the more urgent.

Consider four examples:

1. The flow of effective consumer demand into areas of

 

"social deficit" - Bedford-Stuyvesant; North Philadelphia, the ghettoes
of our metropolitan areas; the abandoning small towns of the Jersey
Pines, the Appalachian chain, etc. In these areas it is becoming
painfully obvious that present public programs (renewal; welfare;

job training and development) are not producing much of an effective
demand, and that until there is such a demand, there won't be induced
an adequate economic base. Thus the growing cry for the negative
income tax, the guaranteed minimum income, the family allowance, and
the "welfare dollar" (of Lloyd's Bank Review, ca. October 1966) which
gives the poor a chaice of expenditures among essential services.

The Task Force will not have to invent proposals of this sort;

4

but we can (a) show how they fit into a more dynamic urban model;
(b) do badly-needed digging into their probable effects, relative

advantages, and administrative feasibility.
2. The flow of investment and enterprise into areas of social
deficit. Public programs of renewal, housing, and economic opportunity
have had discouragingly weak leverage in stimulating thé economic
development of ghettoed and other declining communities. It may be
that tax policy offers a more promising lead: declaring areas of social
deficit eligible sites for Federal, state and local tax incentives of
various sorts for specified kinds of investment and enterprise.

The proposal is not new; but again, the Task Force can develop
its rationale and explore its feasibility.

3. The flow of national tax resources to states and municipalities,
(and to other quasi-public instrumentalities for community action).

The readiest example is the Heller Plan, which -- along with other
proposals like the shared-tax -- badly needs reshaping to fit a declared
schedule of urban needs and reforms. It seems clear the present
structure of Federal grants produces a flow of revenues to the lesser
jurisdictions which is too small, £60 categorical, too incoherent, and
too much in the control of specialized technicians. It also pipsedewated:
on the art of grantsmanship rather than on performances; and it exacts
small changes in behavior from the bureaucracies rather than major
changes and concessions from governors and legislatures, mayors and
councils (e.g., to be eligible for a major block grant from the Federal
government, a State might be asked to expand and reshape its own

revenue system, and make some fundamental changes in its administrative

structure and procedures).
The Task Force might declare for an increased flow of Federal
revenues to the States and local governments through more generalized
grants, and begin to detail some of the more promising ways, means
and conditions. (And now that the "growth sector" of central cities
seems to be public and non-profit in character (education, health,
government, etc.), we might explore the possibility of expanding in
lien payments to those municipalities as a major revenue source.)

4. The flow of national resources into housing in declared areas.

 

This flow has been too small, too erratic, and off the geographical
targets of need. The Task Force might review in the perspective of
thirty years the efficacy of current devices and (e.g. FHA's)
conventional wisdom: mortgage insurance; below-market-interest-rates;3
subsidies; etc. There may be more powerful levers than these, with

more consistent effects and geographical accuracy.

There are other flows to consider: most important, the flows of
people to and within the eouatania metropolitan areas, with a special
eye to the forces, incentives, etc., which stimulate and shape those |
flows. For example, a low airline fare from Puerto Rico to other

metropolitan areas than New York might have lessened "The Puerto Rican

problem".
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                    <text>3/8/67
DRA}= FOR DISCUSSION
Staff paper on ~-,.o del Cities
The discussion which follows treats those problems and conflicts
which are li-ely to arise in the implementation of the Model Cities
program.
Most of them are built into the inte govenunental system in
which bdel Cities will operate without t he administrative instnnnents
to co ect or direct them.
By i mplicat ion, the questions raised in
this pape_ are suggestive of conceptual diff icul ties with the Model
Cities approach, and not of the effectiveness of those charged with its
administration.
The Model Cities prog~am is considered by many to be the most
useful instnu nt yet put int e hands of American cities by the Federal
goverrunent.
This program tests several notions:
one is that a multitude
of catego ical aids can be tied together in a single package and their
i mpact maximized in a slum neighborhood; al'lother being that a handful of
Americal'l cities can make imaginative and effective use of supplemental
fu1ds.
Model Cities represents an attractive departure from past Federal
efforts in sol ving urbal'l problems but it cannot be expected to overcome
t he barriers that those previous effor ts have helped to erect.
Consider the perspective of a well-intentioned mayor.
A relatively
small carrot has been he ld out by t he Federal government, which can be
taken and eaten if the mayor can do some things which t he Feder al government cannot:
coordinat e and maximize t he impact of a rultitude of
cat egorical aids.
He must correct a -s ituation in whi ch semi- autonomous
bureaucracies make decisions about resource allocat i on·, of t en with the
r • -· ,
�2
a1a and comfort of thei
F d -ral counterpartso
He must o;::,erate with a
b wilde.ing maze of state channeled programs whichv through rigidity and
reg essiv
id fonnulaeP eL ctivcly discriminat
.ere _re ot e
aga~nst his city.
easoi s \vhy few cities can b expected to come up
.·ith app_ications wlich, in factp meet the rigorous standards of the
guidelmes o Fi st, few cities h ve the talent:
person.riel who combine
sop: is:icated app eciation o the g antsman' s game with great p_ogrammatic
i rri.aginat ion ao not exist
be e_:pected to come
the city ov
~Tl
la ge numbers.
p wit. an application that will, favor one area of
all oth rs, someth.:.ng very unattractive to men who mus t
stm d fo _ el ction i.ri all neighborhoo So
notice
t·
~re t hey do exist they will
In additionp on very s .o t
e mayor may have to alter p iorities which have already been
set and to which his city 1s corrun ·ttedo
This is especial:y true where
ur an renewal activity has avoided hard core slum eighborhoods wh ich
now must be incorporated into a comprehensive rene.,ral effort.
Then
there is the obvious problem of having to compete for one of seventy
slots for which the fiscal rewards are not great.
Given constraints oft: is nature, it is not surprising that cities
would not involve all the important cowmunity-,~ide agencies and citizens'
groups in preparing the initial application as required in the guidelines.
There is not time (3-1/2 months between issuance of the guidelines and
final application date) and there is not the staff to deal with suggestions
and complaintso
The city might also wonder how HUD and other Federal
agencies are to review a large nur.iber of applications in a very short
time and realistically evaluate ,t he thoroughness and comprehensiveness of
�3
eac: •
T e incentives may be, the efore, on "wi nging it" like the college
stude t
w.10
stuc y at
substitutes reputation , s avvy P and testmanship for d:i.ligen-
xam time.
T e costs of not involving mai7.y elements of t he community
planning of t e initial appl · cation are substantial.
1n.
t1 e
Such a process
would be an efficient and effective mean!; of ed 1cating t he comrr.i.mi ty P
cr:!a::ing
ari
awar ness and gaining acceptance of s ignific ant inno .1at i ons
in l )cal government .
Even wh n the planners are favorab l y dispc!: :: J ·:o
t his approach it is doubtful that they wi\ l have the time or sta :f
support to institute it.
In a real s ensep the w2yor ' s troub-e begins when his city 1s selected
as a model.
He must conduct complex negotiations with alrr.ost as many
agenc ies as th re are catego i cal a ids in his application and hope they
will
11 fund h i m at r oughly t he s am time.
If truly innovat ive , he
must secure the unlikeliest kinds of changes from the unlikeliest agenc ies
in ' .is city and at the state and Federal level 9 e. g. ~ the welfare system,
educational establishment, mortgage bankersg etc.
He may have to convince
unsympathet ic l egislators t hat legislati ve revisions of sweeping import
should be made -- he may even ask for additional funds.
a great dea
We are asking
of a c lass of political animal who seeks always to avoid or
resol ve conflict.
None of this is t o say t hat t he Federal administr ators of th-=s
program will have an ea sy t ime.
The gr eatest obs tacle is t he dependence
on the categorica l grant progr ams of other Federal agencies for ~:upport
arid funding .' Spec ifically:
�4
a.
In this p_ogram
H
i ch e hasizes flexibility, c ities must
cl:oose amongst categorical prog ams Hhich more often than not hare rigid
s tancl,~r s O confus · ng jurisdictional relations a.i7.d mysterious r drr{u~.i stra -~i ve
To play a us ful om.sbudsrnan role for the cities vis ··a vis
prrcticc:s .
tr~ -!::.e
0
other Federal agencies, HUD rust persuade under-ftmd.ed l:· :rograrn
adm_;_,'1is'· rs.to s to make subst2..r1tial allocat · ns t o other t.hol1 tra ·!~ · ic,na l
recipie.. ts.
deally t_ese agencies would also review Model Cities
applications and be able to synch onize the grant approvals with those
of HUD.
b.
Many relevant categorical prog ams, especially m HEW P
are acirninistered thro gh state governrnents with an impressive variety
of pl211s
regulations, capacities, standards and fiscal strength.
It
is difficult to i~2gine that n cessary evis · ons in these arrangements
can be e_fected in time to assist model neighbor oods.
It is equally
difficult to envis·on HUD, two levels removed from the source of difficulty,
paying a too direct role in effecting such changes.
c.
Urban renewal is probably disproportionately attractive
to citie s planning model neighbo_hood programs .
For one thing there is
250 IP.illion dollars in ear-rnarked funds which may be used by these cities
and t he ir use is controlled by the same agency administering Mode l Cities .
If other programs are to be more competitivep then ear-marked moneys
ITU.lSt
be secured and simple administrative arr3Ilgcrnents substituted to attract
~·b del City planners to them.
The 1odel Cities approach is an introduction to "consumer al location
of resources. 11 This mzans that each city is allotted money with which


 ·• ,',


�5
to "buy" prog ·
lS
in the combination that it sees will have t ,e greate5t
in;pact on the problems of that city.
The change t o consumer aEocatio:1
is a radical one and the prob lems cannot be
lll1
ere stimated.
___ F derally-designed progran s, the c ity i s asked t o
accepting
__
,,. . . ..._,,.
.
In~;tead of
prep., re a.n
op .i mal mix of programs based on the effectiveness of a t,ernat iv,: sy_.t :mt.s.
The fi st atterr:pt at t his approach is understandably imperfect b eca.use,:
a.
cities still must choose Lorn among exi st ing programs in ·
combinations w ich are largely pre - detennined by funding levels and
ju_isdictio al rights;
b.
p emiu~s are still attached t o particular programs by
favorable matching ratios;
c.
the discretionary supplemental moneys are small in relation
to the total outlay involved thereby limiting new· programs indicated by
systematic analys is.
The 1odel Cities program will make its great contribution by
demonst_ati.Tlg t hat the flexibility needed for experimentation is not
provided by a one-shot grant Federal money, no matter how large it is
or how few stri.Tl.gs are attached.
If the applicat ions are prepared with
diligence~ the Federal government will have a central catalogue of the
obstacles that it must deal with before real innovation can be achieved.
This catalogue would be a systematic vote by seventy cities indicating
wher e Federal legislation~ admin·strative r egulations and inter-agency
operat ions are t o be revised to be made more relevant to the needs of
America~ cities.
,.. ... ,
The Federal goven1ment should be preparing itsel f for
�6
i.11:plementing a hos t of change s that 1-·Jill be suggested by Model Citie s
applica1 t s.
This may require a new institutionalized capacity in l-IUD~
HI::.lv, Labor and other agenc ies operating urban-related programs •
. •,
r • .•,
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              <text>3/8/67

DRAFT FOR DISCUSSION

Staff paper on Model Cities

The discussion which follows treats those problems and conflicts
which are likely to arise in the implementation of the Model Cities
program. Most of them are built into the intergovernmental system in
which Model Cities will operate without the administrative instruments
to correct or direct them. By implication, the questions raised in
this paper are suggestive of conceptual difficulties with the Model
Cities approach, and not of the effectiveness of those charged with its
administration. |

The Model Cities program is considered by many to be the most
useful instrument yet put in the hands of American cities by the Federal
government. This program tests several notions: one is that a multitude
of categorical aids can be tied together in a single package and their
impact maximized in a slum neighborhood; another being that a handful of
American cities can make imaginative and effective use of supplemental
funds. Model Cities represents an attractive departure from past Federal
efforts in solving urban problems but it cannot be expected to overcome
the barriers that those previous efforts have helped to erect.

Consider the perspective of a well-intentioned mayor. A relatively
small carrot has been held out by the Federal government, which can be
taken and eaten if the mayor can do some things which the Federal govern-
ment cannot: coordinate and maximize the impact of a miltitude of
categorical aids. He must correct a situation in which semi-autonomous

bureaucracies make decisions about resource allocation, often with the

é
BS

aid and comfort of their Federal coumterparts. He must operate with a
bewildering maze of state channeled programs which, through rigidity and
recressive aid formulae, effectively discriminate against his city.

There are other reasons why few cities can be expected to come up
With applications which, in fact, meet the rigorous standards of the
guidelines, First, few cities have the talent: personnel who combine
sophisticated appreciation of the grantsman's game with great programmatic
imagination do not exist in large numbers. Where they do exist they will
be expected to come up with an application that will. favor one area of
the city over all others, something very unattractive to men who must
stand for election in all neighborhoods. In addition, on very short
notice the mayor may have to alter priorities which have already been
set and to which his city is committed. This is especially true where
urban renewal activity has avoided hard core slum neighborhoods which
now must be incorporated into a comprehensive renewal effort. Then
there is the obvious problem of having to compete for one of seventy
slots for which the fiscal rewards are not great.

Given constraints of this nature, it is not surprising that cities
would not involve all the important community-wide agencies and citizens’
groups in preparing the initial application as required in the guidelines.
Theré is not time (3-1/2 months between issuance of the guidelines and
final application date) and there is not the staff to deal with suggestions
and complaints, The city might also wonder how HUD and other Federal
agencies are to review a large number of applications in a very short

time and realistically evaluate the thoroughness and comprehensiveness of
each, The incentives may be, therefore, on “winging it" like the college
student who substitutes reputation, savvy, and testmanship for diligent
study at exam time.

The costs of not involving many elements of the community in the
planning of the initial application are substantial. Such a process
would be an efficient and effective means of educating the community,
creating an awareness and gaining acceptance of significant innovations
in local government. Even when the planners are favorably disposed to
this approach it is doubtful that they will have the time or stafi
support to institute it.

In a real sense, the mayor's trouble begins when his city is selected
as a model. He must conduct complex negotiations with almost as many
agencies as there are categorical aids in his application and hope they
will all fund him at roughly the same time. If truly innovative, he
must secure the unlikeliest kinds of changes from the unlikeliest agencies
in his city and at the state and Federal level, e.g., the welfare system,
educational establishment, mortgage bankers, etc. He may have to convince
unsympathetic legislators that legislative revisions of sweeping import
should be made -- he may even ask for additional fimds. We are asking
a great deal of a class of political animal who seeks always to avoid or
resolve conflict.

None of this is to say that the Federal administrators of this
program will have an easy time. The greatest obstacle is the dependence
on the categorical grant programs of other Federal agencies for support

and funding. Specifically: ey.
4

gram which emphasizes flexibility, cities must

o

a. In this pro
choosé amongst categorical programs which more often than not have rigid
standards, confusing jurisdictional relations and mysterious administrative
practices. To play a useful omsbudsman role for the cities vis-a-vis
these other Federal agencies, HUD must persuade under-funded program
administrators to make substantial allocations to other than traditional
recipients. Ideally these agencies would also review Model Cities
applications and be able to synchronize the grant approvals with those
of HUD.

b. Many relevant categorical programs, especially in HEW,
are administered through state governments with an impressive variety
of plans, regulations, capacities, standards and fiscal strength. It
is difficult to imagine that necessary revisions in these arrangements
can be effected in time to assist model neighborhoods, It is equally
difficult to envision HUD, two levels removed from the source of difficulty,
playing a too direct role in effecting such changes.

c. Urban renewal is probably disproportionately attractive
to cities planning model neighborhood programs. For one thing there is

250 million dollars in ear-marked funds which may be used by these cities
and their use is controlled by the same agency administering Model Cities.
If other programs are to be more competitive, then ear-marked moneys must
be secured and simple administrative arrangements substituted to attract
Model City planners to them.

The Model Cities approach is an introduction to "consumer allocation

of resources." This means that each city is allotted money with which
to “buy programs in the combination that it sees will have the sreatest
impact on the problems of that city. The change to consumer allocation

is a radical one and the problems cannot be underestimated. Instead of
accepting Federally-designed programs, the city is asked to prepare an
optimal mix of programs based on the effectiveness of alternativ: systons.
The first attempt at this approach is understandably imperfect because:

a. Cities still must choose from among existing programs in’
combinations which are largely pre-determined by funding levels and
jurisdictional rights;

b. premiums are still attached to particular programs by
favorable matching ratios;

c. the discretionary supplemental moneys are small in relation
to the total outlay involved thereby limiting new programs indicated by
systematic analysis.

The Model Cities program will make its great contribution by
demonstrating that the flexibility needed for experimentation is not
provided by a one-shot grant Federal money, no matter how large it is
or how few strings are attached. If the applications are prepared with
diligence, the Federal government will have a central catalogue of the
obstacles that it must deai with before real innovation can be achieved.
This catalogue would be a systematic vote by seventy cities indicating
where Federal legislation, administrative regulations and inter-agency
operations are to be revised to be made more relevant to the needs of

American cities. The Federal government should be preparing itself for

ety
6

implementing a host of changes that will be suggested by Model Cities

n

applicants. This may require a new institutionalized capacity in HUD,

HEW, Labor and other agencies operating urban-related programs,
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                    <text>,
3/8/67
A Proposal for Task Force Agenda
Part I
The staff of the Task Force has spent most of the past three
weeks attempting to outline future areas for investigation.
Our f~_ints
of departure have been based on Task - Force discussions concerning the
nature and location of urban ghettos; the definition and measurement of.
social deficit areas; the prospects for significant improvement in ghetto
job opportunities; the possibility of moving from programs to "flows"
(as defined in the Ylvisaker paper); and more focused research in such
areas a s housing and welfare programs.
These discussions, you will recall, were at a high level of
generality and implied further decisions about which areas should be
given intensive study- studies which hopefully would produce policy
recorrnnendations for the President.
In recent Task Force discussions and in interviews with a number
of government of~icials another, more general theme has emerged to
compete and, in a sense, out-flank the development of Task Force thinking
on the above issues.
It appears clear that this group believes that the time· has come
for a sharp break with previous Federal policy-making and prograunning
directed towards urban problems. *
The need for a new "laundry list" of
marginal adjustments and categorical .aid
programs is rejected.
,





It is
In fairness we might concede the Federal government has .only recent ly
b egun to look at....~ts role as solving urban problems as opposed to
providing welfare 'payments, more' housing etc. The fact that Feds feel
this way now is of course a mamor advance. The fact that they increasingly
a r e being held respon sible for what happens in urban areas provides some
assurance of the potential significance of our work.
�2
felt , instead, th a t
th e Pr e sid e nt mu s t a lt e r or g o outsid e t h e presen t
f r amework (or even create a new framework) for d~cision-making about
urb an problems to seek ways and means for achieving national goals in
urban areas.
The task force believes that present. activity and
predict able future activity can be reshaped and criticized productively,
but it also is convinced that such an approach offers faint promise as
a source of significant innovation in solving urban problems.
Ind eed,
the Task Force might go a step further and argue that the whole range of
ex isting Federal programs and institutions primarily des~gned to solve
urban problems have had a relatively minor impact on human and phy s ical
development in American cities.
This judgment (however qualified) is supported by the foll owi ng -admittedly over-simplified -- reasoning:
1)
While the range and size of Federal activity has increased rapidly
and while the institutions specifically charged with urban
responsibility have multiplied and grown, general economic, social
and physical trends have not altered significantly in any large city.
2)
It s eems therefore reasonable to assume th at the forces shaping thes e
t r ends a r e far more meaningful in affecting the quality of urban
1 i f e than i s th e sum total of Federal· programs focused on "urban ne eds".
3)
It appe ar s equa lly r ea s onable to conclude tha t the i nstitut i ons ,
mechanisms, and dolla rs now available for dev e l opi ng u r ban po licy
• ,'I /
at the Federal level ar e inad equa s~ ' or misori ent ed in t erms of
understanding and confronting some of the most important questions
in urban ' areas"·:· :
�3
The implications of all this for the Task Force include the
following:
1)
further infusions of Federal assistance through present or
predictable grant-in-aid programs offer little hope of significantly
altering major urban trends; therefore the Task Force should not
corrnnit a major portion of its limited resources to seeking new
devices for such increases.
Such devices, as well as adjustments
in present devices, should have a place in Task Force recommendations
only insofar as they spring from the kind of agenda ·suggested below.
2)
The search for more effective levers for influencing urban trends
is severely handicapped by the sorts of Federal apparatus and
information available for dealing with urban problems.
(E.g. see attached paper on social deficits.)
3)
The Task Force could most profitably allocate its time to assembling
some of the major social and economic questions relevant to ur ban
problems; indicating what kinds of institutions and/or devices for
policy formulation are in existence or might be created to deal with
such questions.
(It is even possible that the Task Force might
"solve" a question or two and have a basis for more specific _policy
recommendations.)
Questions might be modeled on the following:
1)
One obvious goal for Federal policy . is increasing income and, thus,
~ . .~ J
consumer demand in the ghetto.
,..,,,
' ... ~I


/


�4
(a)
Where in the Federal establishment (in HUD?).
Is there a
means for sorting out the various policy alternatives which
might be pursued to achieve this goal (e.g. negative income
tax, family allowance, jobs for the poor, etc.).
The answer to such a question would include surveying existing
sc atte red research and recorrnnendations on the several alternatives and
determining whether a basis exists already (though undiscovered) for
packaging a Federal approach to fulfilling this goal.
If this is so,
we migh t recommend some method of pulling together urban-oriented
pol icy-making on this questions.
If, as is more likely the case, there
is no sum total of effort which exhausts the alternative approach e s to
this problem our recommendations would include the need for same.
In short, the approach involves posing fundamental questions,
determining if a solution is now available, and if not, what is needed
to begin us down the road towards one.
One Task Force goal then becomes - at the most general level not simply to look for the "real" levers in this urban game (we have
neither staff, nor time, nor expertise t~ do a thorough job here) but
rath er to look for ways of elevating and . refining the level and nature
of urban policy-making.
• ·,
J
. ··. ·,.·V
I
/·
�5
It should not be difficult to start this process by agre e ing
on an initial list of questions.
We already have some.
1)
How can we increase consumer demand in the central city?
2)
Have we systematically located and defined urban ghettos?
3)
Wh a t is needed to create the capacity to calculate social defec t s
in urba n areas?
4)
Whe re in the Federal establishment is work going forward on the
possibilities to altering the flow of entreprenurial activity to
increase the share of central city.
5)
etc.
'
·. _.: v
,.
•·.,I
I
V
�6
?ar t II
The Task Force, it appears, is close to agreement on another
s e t of concerns which can be approached by more traditional methods,
and presumably would produce more traditional recommendations.
1)
Cha nges in Federal assistance systems
The Task Force is justified in looking at such proposals as
t ax sha ring, combining grant-in-aid programs etc., in terms o f
the ir r el a tive impace on cities.
It is clear that with a sma ll
i nput of staff resources we can contribute a city vie'W' to th i s
di a logue .
2)
Inc rea s i ng the flow and consistency of investment into lo'W'-income
housing in urban areas.
For wha t ever re ason there seems to be a "nea ter" problem.
We h ave
cons i derab le expertis e among Task Force members thems elv e s and
shou ld be abl e to a ssembl e a set o f recormnenda tions in th i s area.
I n add i t ion, wh il e there are manpower, education and other Task
f orces, our i s the only one which 'Wi ll - if it choose s - look a t
housing this year .
3)
Mode l cit ies
(a)
This program repres ents, i n a sense, the l atest in Wa shing t on
approa che s to urban pr oblems.
We mus t confr ont and ev en judge
it if we are t o justify a ma j or break with current approache s .
·. :U
.'
�If
7
(b)
This program also represents the latest Federal response to
the "ghetto" problem.
Given the political, social and moral
imperatives for doing something now about urban ghettos, the
Task Force should make some attempt to review and evaluate the
early directions of model cities.
(c)
This program also represents the boldest approach to altering
the system of Federal assistance and therefore is related
directly to item (1) above.
.
. ,;
· ; t
,;
'
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              <text>3/8/67
A Proposal for Task Force Agenda

Part I
The staff of the Task Force has spent most of the past three

weeks attempting to outline future areas for investigation. Our points
of departure have been based on Task: Force discussions concerning the
mature and location of urban ghettos; the definition and measurement of.
social deficit areas; the prospects for significant improvement in ghetto
job opportunities; the possibility of moving from programs to "flows"

(as defined in the Ylvisaker paper); and more focused research in such
areas as housing and welfare programs.

These discussions, you will recall, were at a high level of
generality and implied further decisions about which areas should be
given intensive study- studies which hopefully would produce policy
recommendations for the President.

In recent Task Force discussions and in interviews with a number
of government officials another, more general theme has emerged to
compete and, in a sense, out-flank the development of Task Force thinking
on the above issues.

It appears clear that this group believes that the time has come
for P sharp break with previous Federal policy-making and programming

. *
directed towards urban problems. The need for a new "laundry list" of

marginal adjustments and categorical aid programs is rejected. It is

 

* In fairmess we might concede the Federal government has only recently
begun to look at its role as solving urban problems as opposed to

providing welfare payments, more’ housing ete. The fact that Feds feel

this way now is of course a mamor advance. The fact that they increasingly
are being held responsible for what happens in urban areas provides some
assurance of the potential significance of our work.
Felt, instead, that the President must alter or go outside the present
framework (or even create a new framework) for decision-making about
urban problems to seek ways and means for achieving national goals in
urban areas. The task force believes that present activity and
predictable future activity can be reshaped and criticized productively,
but it also is convinced that such an approach offers faint promise as
a source of significant innovation in solving urban problems. Indeed,
the Task Force might go a step further and argue that the whole range of
existing Federal programs and institutions primarily designed to solve
urban problems have had a relatively minor impact on human and physical
development in American cities.

This judgment (however qualified) is supported by the following --

admittedly over-simplified -- reasoning:

1) While the range and size of Federal activity has increased rapidly
and while the institutions specifically charged with urban
responsibility have multiplied and grown, general economic, social
and physical trends have not altered significantly in any large city.
2) It seems therefore reasonable to assume that the forces shaping these
trends are far more meaningful in affecting the quality of urban
life than is the sum total of Federal programs focused on "urban needs".
3) It appears equally reasonable to conclude that the institutions,
mechanisms, and dollars now available for developing urban policy
at the Federal level are snadaguare’ of misoriented in terms of

understanding and confronting some of the most important questions

in urban areas. ' fst
The implications of all this for the Task Force include the

following:

1)

2)

3)

1)

Further infusions of Federal assistance through present or
predictable grant-in-aid programs offer little hope of significantly
altering major urban trends; therefore the Task Force should not
commit a major portion of its limited resources to seeking new
devices for such increases. Such devices, as well as adjustments
in present devices, should have a place in Task Force recommendations
only insofar as they spring from the kind of agenda suggested below.
The search for more effective levers for influencing urban trends
is severely handicapped by the sorts of Federal apparatus and
information available for dealing with urban problems.
(E.g. see attached paper on social deficits.)
The Task Force could most profitably allocate its time to assembling
some of the major social and economic questions relevant to urban
problems; indicating what kinds of institutions and/or devices for
policy formulation are in existence or might be created to deal with
such questions. (It is even possible that the Task Force might
"solve" a question or two and have a basis for more specific policy
recommendations.)

Questions might be modeled on the following:

One obvious goal for Federal policy,is increasing income and, thus,

|
vil

consumer demand in the ghetto.
(a) Where in the Federal establishment (in HUD?). Is there a
means for sorting out the various policy alternatives which
might be pursued to achieve this goal (e.g. negative income
tax, family allowance, jobs for the poor, etc.).

The answer to such a question would include surveying existing
scattered research and recommendations on the several alternatives and
determining whether a basis exists already (though undiscovered) for
packaging a Federal approach to fulfilling this goal. If this is so,
we might recommend some method of pulling together urban-oriented
policy-making on this questions. If, as is more likely the case, there
is no sum total of effort which exhausts the alternative approaches to
this problem our recommendations would include the need for same.

In short, the approach involves posing fundamental questions,
determining if a solution is now available, and if not, what is needed
to begin us down the road towards one.

One Task Force goal then becomes - at the most general level -
not simply to look for the "real" levers in this urban game (we have

neither staff, nor time, nor expertise to do a thorough job here) but

rather to look for ways of elevating and.refining the level and nature

of urban policy-making.
It should not be difficult to start this process by agreeing

on an initial list of questions. We already have some.

1)
2)

3)

4)

5)

How can we increase consumer demand in the central city?

Have we systematically located and defined urban ghettos?

What is needed to create the capacity to calculate social defects
in urban areas?

Where in the Federal establishment is work going forward on the
possibilities to altering the flow of entreprenurial activity to
increase the share of central city.

etc.
The Task Force, it appears, is close to agreement on another

set of concerns which can be approached by more traditional methods,

and presumably would produce more traditional recommendations.

1)

2)

3)

Changes in Federal assistance systems

The Task Force is justified in looking at such proposals as

tax sharing, combining grant-in-aid programs etc., in terms of

their relative impace on cities. It is clear that with a small

input of staff resources we can contribute a city view to this

dialogue.

Increasing the flow and consistency of investment into low-income

housing in urban areas.

For whatever reason there seems to be a "neater" problem. We have

considerable expertise among Task Force members themselves and

should be able to assemble a set of recommendations in this area.

In addition, while there are manpower, education and other Task

forces, our is the only one which will - if it chooses - look at

housing this year.

Model cities

(a) This program represents, in a sense, the latest in Washington
approaches to urban problems. We must confront and even judge

it if we are to justify a major break with current approaches.

wit
(b)

(ec)

This program also represents the latest Federal response to
the "ghetto" problem. Given the political, social and moral
imperatives for doing something now about urban ghettos, the
Task Force should make some attempt to review and evaluate the
early directions of model cities.

This program also represents the boldest approach to altering
the system of Federal assistance and therefore is related

directly to item (1) above.
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                    <text>CCMMENTS ON THE AGENDA
Part I of the attached is an attempt to determine the
condition for a breakthrough in Federal policy-making on
urban problems.
priority.
The Task Force may wish to assign it top
Even if this is the case, I believe that ~art II
should remain in the agenda.
Agenda setting is, in a sense, a process of allocation
of scarce resources (Task Force and staff time).
The attached
agenda represents a rough estimate of all that can be taken
on in the time remaining.
Changes and/or additions will be ,
in effect, substitutions and should be based on altering the
implicit priorities in the present agenda.
Ri char d
.~\ I
. ,•
'I '
• .1 V
,I
.Ji
c.
Leone
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              <text>COMMENTS ON THE AGENDA

 

Part I of the attached is an attempt to determine the
condition for a breakthrough in Federal policy-making on
_ urban problems. The Task Force may wish to assign it top
priority. Even if this is the case, I believe that Part II
should remain in the agenda.

Agenda setting is, in a sense, a process of allocation
of scarce resources (Task Force and staff time). The attached
agenda represents a rough estimate of all that can be taken
on in the time remaining. Changes and/or additions will -be,
in effect, substitutions and should be based on altering the

implicit priorities in the present agenda.

Richard C. Leone
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                  <elementText elementTextId="41690">
                    <text>THE NATION.AL
PREPARED BY
CHICAGO • NEW YORK • WASHINGTON, D.C. • DALLAS • ST. LOUIS • OMAHA
LOS ANGELES • SAN FRANCISCO • MINNEAPOLIS-ST. PAUL
VOL. 21 - No. 11
MARCH 1967
$20.00 PER YEAR
"TREND, TREND, WHICH WAY'S THE TREND?" That's the absorbing question which is
being debated vigorously by the business and investment communities as the
economy feels its way cautiously into 1967.
The difficulties of a definitive answer to the question first stated above lie
in the apparent contradictions contained in the business· and financial news as
it unfolds day after day.
For example:
the rally in the stock and bond markets
in the month of January seemed to be saying that the doubts and uncertainties of
the year-end were really unfounded; that . 1967 was going to be another strong
year after all. And yet there was a nagging persistence to bearish bulletins
about business itself. Automobile production was down 18% in January and 21.5%
in the first half of February . Steel-making thus far in 1967 is off last year's
pace, with mills currently operating at only 70% of capacity. Durable goods
orders in January were down 5 . 1% from last year and business inventories were
disturbingly high .
Through it all the war in Viet Nam keeps requiring more and more money: President
AJohnson's messages to the Congress point up the urgency of expanding the
9perimeters of the Great Society; unemployment in January held at the low level
of 3.7% of the labor market (with many cities still below the "point-of-shortage");
and wages are continuing their trend of the past six months.
Although the rally in the bond and stock markets faltered in mid-February and
bad news once again seemed to capture the spotlight of the public's attention,
we have certainly not turned bearish. We still see no recession in the offing
(by our definition) and we still would put 1967 in the "plus" column as a whole.
BASICALLY, OUR FORECASTING FOCUS IS ON CONSUMERS. During most of the year 1966,
financial and capital factors were in bad trend. The stock markets were sagging,
the money markets were demoralized and the whole real estate sector of the
eco·nomy was dispirited.
Yet consumers were more numerous, more prosperous and
more fully employed. And business was good indeed!
In spite of the anomalous developments thus far in 1967, con~umers are in better
basic condition than they were a year ago!
In most metropolitan areas, employment
in this January was better than last year's.
In all such areas, the average
income of consumers is higher than it was at this time last year.
And it is
moving still higher!
It is true that about October 1, 1966, the chilling winds of doubt blew over the
consumers of the U.S. with the result that their willingness to spend (not their
capacity to spend) was momentarily curbed. While they waited to experience a
resurgence of their buying enthusiasm, they increased their savings.
In other
words, they rested their buying oars and took advantage of the biggest inventory
of their own goods in the history of the American family.
But they did not
chan e their fundamental habits! As spring comes --- and if their incomes hold
we think they will --- they'll get right back into the spending stream to take
~dvantage of the higher living standards which are within their grasp. And once
they do that, we'll forget about the dwindling profits in the last quarter of
1966 and the first of 1967.
COPYRIGHT 1967 •
Real Estate Research Corporation
•
73 West Monroe, Chicago, Ill inois 60603
•
Reproduction in whole or part prohibited .
�PAGE 2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___.._
~.at MARKET LETTER
REAL ESTATE ACTIVITY NOT ONLY FAILED TO TURN AROUND in the first month of 1967,
but i t s lipped f urther into the doldrums which had marked the last months of
1966. One of the reasons that the year-to-year comparisons with the first month
of 1966 look so bad is that --- if you remember accurately --- last year started
out impressively on the strong side, at least in the major· activity factors of
local real estate markets, with sales, mortgage lending and new construction
well ahead of the previous year, in most areas.
Here is how these activity factors performed in the latest month for which
complete national figures are available (January 1967):
Real Estate Sales
Off a little less than they were in December, sales for the nation were
down 14.7% in January, with the following regional comparison with the
same month last year:
Region
Northeast - - Great Lakes - South - Central Prairie
Pacific West -
Percent Change
- - - and
- -
- - - - - - - - - - - - - - - - Mountain - - - - - - - - - - -
8.0
15 . 7
6.2
18.4
20.1
The reasons for the slow selling pace were not much changed from those
which have prevailed in the past few months.
The sharp drop in new home
construction and completion was a major factor.
Normally the sale of a
new house results in from two to five sales of other dwelling units as
occupants play a game of "musical chairs" in the upgrading process. No
new houses; no occ~pancy shifts down the line.
In addition, the promise
of lower mortgage money rates (given
wide publicity, especially since
October) has caused many prospective
Selected NATIONAL Economic Indicators
buyers of existing houses to wait for
better terms.
VALUE OF DOLLAR (1939 = 100)
41. 54¢
INDICATOR
PRICES:
Wholesale Prices
Building Costs
Farm Product Prices
Consumer Prices
Dow Jones lndl's (as of· 2/23)
PRODUCTION, EMPLOYMENT,
INCOME:
Total Production
Manufacturing
Persons Employed
Persons Unemployed
Construction Employment
lr.dividual Income
Wages
MONETARY FACTORS:
Interest Rates
Currency in Circulation
Government Debt
Checks Cashed (Dollars)
Value of Dollar
·Data latost available for each fador.
% CHANGE
FROM A
YEAR AGO
1.5
4.2
2.7
3.3
-11.0
-
-
4.8
4.6
0.3
0.5
0.2
8.4
2.6
14.4
0.6
2.1
15.4
- 1.2
% CHANGE
FROM A
MONTH AGO
0 .3
o.o
1.2
- o.o
- 0.4
-
0.7
0.7
0.1
0.3
0.2
0.9
1.1
1.6
0.1
0.1
4.6
o.o
On the income property side, the rapid
drop in money rates acted to lower
realistic capit alization rates faster
than prospective buyers could adjust
their sights. Moreover, improved
market conditions in most space markets
(especiall y in the Northeast, Great
Lakes and South regions) caused potential sellers to scent higher occupancies and rentals --- thus causing them
to firm their ideas of value. Fina lly,
a rapidly rising stock market p roved a
lure to speculators looking fo r a f as t
return on investment.
We look for unfavor able y ear-to-ye ar
comparisons in t h e sa l es marke t s to
continue for the fi r s t q u a rt e r of this
year, after whi c h we e xpe ct me a s urable
improvement.
Mortgage Lending
The n a tiona l d e cline s ince last year in
mor tg a ge lend i ng for the late st month
�THE REAL ESTATE FORECAST AUTHORITY _ _ _ _ _ _ _ _ _ _ _ _ _ _ PAGE 3
(January) was 33.5% in the number of
total dollar volume of those loans.
tinued to improve, the actual volume
highly selective and cautious nature
mortgage loans closed and 42.4% in the
While mortgage money conditions conof lending was still low, due to the
of lenders returning to the markets.
Here are the regional comparisons between the mortgage business in the
latest month and that of the same month of 1966:
Northeast Great Lakes - South - Central Prairie
Pacific West -
Number of Loans
Percent Change
Dollar Volume
Percent Change
Region
- - - and
- -
- - - - - - - - - - Mountain
- - -
- - - - - - -
50.1
43 . 1
0.4
40.6
46 . 8
-
-
-
-
-
-
29.6
26.7
22.3
29 . 7
42.1
It is obvious from the above statistics that, through the month of January
at least, the improvement in mortgage money conditions was largely
theoretical and technical rather than actual --- as far as real estate
lenders and borrowers were concerned.
As noted above, the drop of interest rates in the basic money markets during
the month of January was a little less than remarkable.
However, at the
end of that month and all during February, these trends were reversed.
Yields on treasury bills, municipals and corporates were up steadily,
week-by-week in February.
This yo-yo action of money rates in the first eight weeks of 1967 was not
reflected in the mortgage money rate situation. Reason: the supply-demand
ratio in the mortgage money markets did not parallel that in the basic
money markets. Here were the differences:
1. The savings flow into real estate-oriented institutions was
greatly improved over a year ago. On the other hand, mortgage
demand (in the kind of loans scared lenders now consider acceptable)
was disappointing.
As a result, on balance, there was more money
than there were loans.
2. In the basic money markets, demand held high and supply was not
meaningfully improved. Money lenders found that they had underpriced their commodity and took a second look at their potentials.
We see no particular "threat" in the February developments to the long-term
tr e nd of mortgage money.
1967 will continue to score improvements in this
se ct o r .
New Construction
One o f the mu ch-touted "bullish" factors cited by those who are optimistic
about 1 967 is t he belief that the ailing home-building industry will stage
a come b ack i n t he year.
So- called building stocks have shown outstanding
str e n g th on t h e n ation's stock markets as speculators have hungrily snapped
th e m up in an t i c i patio n of higher sales and earnings.
These se ntime nts hav e not only been encouraged by the statistics of housing
construction in t h e past three months (January housing starts were at a
s e asona lly adjus t ed a nnual rate of 1 , 243,000 units --- up 14.6% from
De c e mbe r and up a whopping 47% from last October' s postwar low), but by
the longe r range pros p e c ts f or a d ramati c incr ease in t h e number of young
married coupl e s starting i n 1 968 .
�PAGE 4 _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ tk 1/4Uo,u,( MARKET LET.YER
Certainly (as this Letter has pointed out for several months), the
residential markets in most local areas have gained strength in virtually
all local areas --- and are postured for a burst of new supply in many.
In our opinion, the high expectations of the building industry (like
those which have pushed savings and loan stocks skyward since last fall)
tend to exaggerate the actual prospects for building profits --- either
on the part of the developer or the materials manufacturer . The reason:
the costs of money, materials, labor and land are such that development
profits must await a higher general rental market to encourage and
support a meaningfully higher volume of new construction.
The real profits are to be made in the purchase of good, sound, welllocated and well-designed existing property which will experience sharply
enhanced earning power before a new building boom can get started.
THE BIGGEST REAL ESTATE PROFITS IN THE PAST FIVE MONTHS· have been made in real
es t a t e s t ock s. Our read ers wi ll rememb er t h at we se t up a Real Estate Stock
Index in October of 1965. On that date we assigned the figure of 100.0 to
the prices of these securities which prevailed on October 1, 1965. Here is
the record of those values, monthly, since that date:
Month
1965
1966
1967
January - - - - - - February
- - - - - - - - March - - - - - - - - - - April - - - - - May - - - - - - - - - - - - - June - - - - - - - July
- - - - - - - - August - - - - September - - - - - October - - - - - - - - - November
- - - - - - December - - - - - Even if these real estate stocks had
owner would have done better than if
on the big board.
- - -
106.9
101.5
110.l
101.4
- 108.3
- 96 . 6
95.1
93 . 3
83 .4
- 79.7
100.0
75.2
106.9
80.8
105.1
84.4
been purchased - on October 1, 1965, their
he had bought the Dow Jones Industrials
REAL ESTATE TRENDS AT A GLANCE


% CHANGE fROM A YEAR AGO


fACTOR
NATIONAL
REAL EST A TE SALES
(Number of Transactions)
MORTGAGE LENDING
{Number of Loans Closed)
(Dollar Volume)
TOTAL BUILDING
(Dollar Volume)
RESIDENTIAL {NEW)
{No. of Projects Started)
(Dollar Volume)
NON°RESIDENTIAL {NEW)
{Dollar Volume)
MARRIAGES
EVICTIO NS
NORTH EAST
REGION I
GREAT LAKES
REGION 11
SOUTH
REGION Ill
PRAIRIE
MOUNTAIN
REGION IV
PACIFIC
WES·T
REGION V
17.2
14.0
18.1
9.6
14.8
21.6
33.9
38.0
33.1
42.6
28.4
34.7
19.7
15.9
31.9
46.8
42.1
42.6
7.3
11.4
35.0
24.3
22 . 9
26.1
35.2
45.5
37.2
20.3
43.6
47.6
19.7
28.2
44 . 2
55.1
48 . 3
60 . 0
10.0
7. 7
1.8
15.0
3. 7
8.8
102.5
6.9
0.9
25.8
11. 7
1.1
9 .8
12.8
40 . 7
9.4
3.5
o.o


Fi gures are based upo n extension to Nnti0nal and Regional Leve l s of act ual rates for QUARTER ending January 31, 1967 .


�THE REAL ·ESTATE FORECAST AUTHORITY _ __ _ __ _ _ _ _ _ _ _ _ PAGE 5
SPECIAL RESEARCH REPORT
A LOOK AT THE "MODEL CITIES" PROGRAM
Last year, Congress passed legislation authorizing a new urban program to be
administered by the Department of Housing and Urban Development (known as HUD).
Originally known as the "Demonstration Cities Program," it was recently renamed
the "Model Cities Program" to placate Congressmen who feared their constituents
would think the bill encouraged civil rights marches and other "demonstrations!"
Since this program may have important impacts upon big-city real estate markets,
we will explore certain key aspects of it in this month's Special Research Report.
The Model Cities Program was originally devised to counteract the following
undesirable tendencies which had appeared in the Federal government's attempts
to aid cities, especially large central cities:
h
1.
An enormous number of Federal programs were being administered by many
different Federal --- and city --- departments without much coordination. A recent Office of Economic Opportunity manual lists over 250
Federal aid programs, most of which are applicable in cities ,.
2.
Funds passed out under these programs tended to be widely dispersed
over the urban landscape.
Instead of really trying to upgrade a small
area by focusing a whole battery of urban renewal, health, antidelinquency, manpower training, education and other programs on it,
the Federal government was scattering its shots too broadly . Hence
each slum received too little assistance to counteract the forces
"naturally" dominant there.
3.
Each program assisted with Federal funds tended to be the same in all
parts of a city, and often all over the country, both because one set
of Federal rules governed it and because big-city bureaucracies wanted
to adopt "uniform and equal" policies in all neighborhoods. As a
result, specific programs were often badly adapted to the peculiar
needs of non-typica l neighborhoods, especially low-income ghettos.
4.
A great deal of urban renewal assistance was designed not so much to
eliminate blight or improve the living conditions of low-income
re sidents, but to bolster the sagging economies of big-city downtown
business districts.
Thus the wealthy were the biggest beneficiaries,
and the poor were merely shifted from one slum to another.
These complex maladies demanded a complex remedy --- and that is just what the
Model Cities Program is designed to produce.
In fact , the Guidelines describing
how t o apply for a gran t to plan (but not e xecute ) this program are over 50
pages long. Henc e we can only mention their most salient features here, before
a n a l yz i ng some of their major implications.
Part ic i pation in the program by any given city involves three stages. The
pr e - application stage lasts unti l an application for a planning grant is completed
a nd approved by HUD . No Fede r al financing is available for filling out an
a pplica ti o n .
Yet it is so complex that many cities have spent months at it and
only four h ave formally filed applications (as of February 25, 1967). HUD is
like l y t o disapprove of almost everyone's application at first until it is
adjus t e d t o r easonable conformance with the many criteria described below. After
HUD a ppr o v a l is obtained, the planning stage begins. This can last from si x
to twe l ve mo nths, a n d can be financed up to 80% by HUD g rants
(though the
total a utho r ized to HUD for such planning is only $24 mil lion over two years).
Fi n ally, for those few cities receiving final approval, the e x ecution stage
a rr ives .
In thi s s t age , each city will apply for normal Federal aid for specific
�PAGE 6 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ fk "1t,attu4t MARKET LETTER
programs in the Model
can get an additional
otherwise have to put
the Model Cities Area
assistance.
City Area (such as 2/3 financing for urban renewal), and
"block grant" for up to 80% of the local share it would
up. This bonus can be used for additional activities in
which would otherwise not be eligible for Federal
The myriad specific criteria which Model City plans must meet include the
following major ones summarized from HUD's Program Guide:
1.
The program must be comprehensive. Specifically, it should contain
the following components: physical improvement, housing, transportation, education, manpower and economic development, recreation and
cultural, crime reduction, health and social services and public
assistance.
2.
The program should provide for administrative machinery at the local
level to carry out all its aspects on a consolidated and coordinated
basis. Preferably, this means direct linkage to the mayor or other
chief executive.
3.
It should make a substantial impact on the physical, economic and
social problems in the model neighborhood area.
4.
It should remove or arrest blight and decay in the selected area or
areas of the city.
5.
It should be of sufficient magnitude to contribute to the sound
development of the entire city.
6.
It should make marked progress in reducing social and educational
disadvantages, ill health, underemployment and lack of social services
necessary to se·rve the poor and disadvantaged of the area.
7.
It should provide for widespread citizen participation.
8.
It should provide maximum opportunities for employing residents of the
area in all phases of the program and enlarged opportunities for
work and training~
9.
It should contribute to a well-balanced city with a substantial
increase in the supply of standard housing of low and moderate cost.
10.
It should contribute to a well-balanced city with maximum opportunities
in the choice of housing accommodations for all citizens of all
income levels.
11.
It should contribute to a well-balanced city with adequate public
facilities, commercial facilities a dequate to service the residential
ar eas , and ease of access between residential areas and centers of
employment.
12.
I t should provide for a comprehensive plan for the r elocation of
individuals, families, business concerns and nonprofit organizations.
In addition, eac h program should requir e re-examination of local laws, be
consis tent with comprehensive metropolitan-wide planning, be initiated within
a short period of time (under five years), embody high standards of urban design ,
maintain historic sites, make maximum use of new technology, use cost- benefit
analysis, conform to civil rights requir ements , encourage maximum private
enterprise, not reduce previous local spending in the Model City area , and be
backed by adequate local resources.
�THE REAL ESTATE FORECAST AUTHORITY _ _ _ _ _ _ _ _ _ _ __ __ PAGE 7
In setting out this extraordinarily ambitious set of requirements, HUD is like a
bachelor stating he will only marry a girl with Jacqueline Kennedy's poise,
Jayne Mansfield's figure, Grace Kelly's face, Elizabeth Taylor's allure and
Barbara Hutton's money!
In fact, he would be fortunate to get any one of these
charms, as HUD will be fortunate to get even a majority of its requirements
actually met by any given city.
Although each individual criterion seems
justified, the group taken together constitute too radical a departure from
present urban government practice to be fully achieved in any single city.
Specifically, we believe that HUD's program will encounter five major obstacles
and will have to compromise with them in many cases. These are as follows:
1.
All three of the major objectives of the Model Cities Program --coordination, innovation and specific adaptation of programs to ghetto
areas --- run counter to well-entrenched bureaucratic tendencies in
city governments. City --- and Federal --- departments used to
carrying out their own functions without much checking with each
other will resist intimate cooperation in planning their programs.
Moreover, innovation requires changing established behavior patterns,
and few things are more difficult for large bureaucracies. Finally,
the development of new programs tailored to the needs of ghetto
residents, and different from programs in the rest of the city, will
run counter to tendencies toward "equal treatment" and "uniformity"
long established in some city departments.
All three of these frictions will probably be greatest regarding bigcity schools. Many school boards are relatively free from direct
political control by city governments; hence it will be hard for
mayors to get them to change their ways to fit these criteria. Yet
schools are the most important single public institution in almost
all ghettos.
They alone have the potential power to make up for many
of the home deficiencies suffered by children from deprived families.
He nce if they are not effectively integrated into the Model Cities
Program in a city, and given part of its bonus "block grants," it
cannot really achieve its major goals. So one of the key tactics for
any city trying to make this program work must be convincing school
authorities of the need to create new programs specifically designed
for ghetto areas, including programs which use school buildings for
many kinds of non-educational activities (such as recreation, social
service distribution and adult vocational training) .
2.
Concentration of leadership efforts on one Model City neighborhood
will be necessary to make this program work; yet this contradicts the
fundam e ntal "Law of Over-Dispersion" sacred to politicians. The desire
to garn widespread political support naturally leads elected officials
t o spread the benefits of any program to all areas under their jurisdiction, even though this causes a loss of the economic benefits of
concentration. Hence city politicians will be sensitive to the charge
of focusing too much attention on the Model City neighborhood,
especially since it will be a low-tax-paying ghetto area. So they may
provide only h alf - hearted leadership in support of such concentration.
3.
Ev e n if local a r eas succeed in establishing coordination among th eir
own city departments and related agencies, there is no guarantee that
Fe d e r al age n cies will similarly cooperate in Washington. For example,
whe n a city as k s for a grant from the Department of Health, Education
and We l f ar e t hat is u r gently needed for its Model City Program, it may
find itse l f at th e e nd of the long " normal processing line" along
with a ll oth e r r equ ests, i ncludi n g those in no way associated with
Model Citi es .
�PAGE S_ _ _ __ _ __ _ _ _ _ _ _ _ _ _ _ fk ?tat«,,uzl MARKET LETT ER
4.
In large cities, it will be impossible to simultaneously meet the two criteria of significant impact on the city as a whole and intensive
impact in the Model City neighborhood .
If an area is large enough to
be a significant slice of the entire city, it will be too big for this
program to effect intensively, since total Model City funds are quite
limited.
5.
The housing requirement in the Guidelines is ambiguous. At one point,
it says that. the program must provide "a substantial increase in ·t11e
supply of standard housing of low and moderate cost . " But in the
next sentence, it says "The program should add to the overall supply
of low and moderate-income housing, not decrease it . " The latter
requirement is virtrially impossible, since any clearance of substandard and deteriorated units, or reduction in overcrowding, will
cause a decline in total supply of low-income housing. Even building
new public housing will probably not increase this total supply,
though it could easily increase the standard supply .
In spite of these drawbacks, the Model Cities Program is ' definitely a worthwhile experiment which could have significant long-run benefits
if it is
truly conceived of as a means of demonstrating techniques which will later be
applied on a much larger scale . Specifically, it may create an incentive for
at least some cities to do enough innovating, coordinating, concentrating
and adapting of programs to particular needs to give local governments a "shot
in the arm." But eventually this tiny shot must be followed by much larger
appropriations than those as yet made for Model Cities if the lessons learned
are to ·have any truly sizeable impact upon U.S . urban problems.
(The Special Research Report series on Change in Modern Society will be
continued in a later issue . )
-
NO QUOTATION W ITHOUT PERMISSION
-
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              <text> 

THE NATIONAL

PREPARED BY

JAMES C. DOWNS, JR.
Editor and Publisher

Author

ANTHONY DOWNS CHICAGO * NEW YORK * WASHINGTON, D.C. * DALLAS « ST. LOUIS * OMAHA
Special Research Reports LOS ANGELES * SAN FRANCISCO * MINNEAPOLIS-ST. PAUL

VOL. 21 —No. 11 $20.00 PER YEAR MARCH 1967

That's the absorbing question which is
being debated vigorously by the business and investment communities as the
economy feels its way cautiously into 1967.

The difficulties of a definitive answer to the question first stated above lie
in the apparent contradictions contained in the business and financial news as
it unfolds day after day. For example: the rally in the stock and bond markets
in the month of January seemed to be saying that the doubts and uncertainties of
the year-end were really unfounded; that.1967 was going to be another strong
year after all. And yet there was a nagging persistence to bearish bulletins
about business itself. Automobile production was down 18% in January and 21.5%
in the first half of February. Steel-making thus far in 1967 is off last year's
pace, with mills currently operating at only 70% of capacity. Durable goods
orders in January were down 5.1% from last year and business inventories were
disturbingly high.

 

Through it all the war_in Viet Nam keeps requiring more and more money: President
Johnson's messages to the Congress point up the urgency of expanding the
perimeters of the Great Society; unemployment in January held at the low level

of 3.7% of the labor market (with many cities still below the "point-of-shortage") ;
and wages are continuing their trend of the past six months.

Although the rally in the bond and stock markets faltered in mid-February and
bad news once again seemed to capture the spotlight of the public's attention,
we have certainly not turned bearish. We still see no recession in the offing
(by our definition) and we still would put 1967 in the "plus" column as a whole.

, During most of the year 1966,
financial and capital factors were in bad trend. The stock markets were sagging,
the money markets were demoralized and the whole real estate sector of the
economy was dispirited. Yet consumers were more numerous, more prosperous and
more fully employed. And business was good indeed:

In spite of the anomalous developments thus far in 1967, consumers are in better
basic condition than they were a year ago: In most metropolitan areas, employment
in this January was better than last year's. In all such areas, the average
income of consumers is higher than it was at this time last year. And it is
moving still higher!

It is true that about’October 1, 1966, the chilling winds of doubt blew over the
consumers of the U.S. with the result that their willingness to spend (not their
capacity to spend) was momentarily curbed. While they waited to experience a
resurgence of their buying enthusiasm, they increased their savings. In other
words, they rested their buying oars and took advantage of the biggest inventory
of their own goods in the history of the American family. But they did not
change their fundamental habits! As spring comes --~- and if their incomes hold
(we think they will) --- they'll get right back into the spending stream to take
dvantage of the higher living standards which are within their grasp. And once
they do that, we'll forget about the dwindling profits in the last quarter of
1966 and the first of 1967. e

 

 

COPYRIGHT 1967 © Real Estate Research Corporation @ 73 West Monroe, Chicago, Illinois 60603 © Reproduction in whole or part prohibited.
PAGE 2 the National MARKET LETTER

REAL ESTATE ACTIVITY NOT ONLY FAILED TO TURN AROUND in the first month of 1967,
but it slipped further into the doldrums which had marked the last months of
1966. One of the reasons that the year-to-year comparisons with the first month
of 1966 look so bad is that --- if you remember accurately --- last year started
out impressively on the strong side, at least in the major activity factors of
local real estate markets, with sales, mortgage lending and new construction
well ahead of the previous year, in most areas.

Here is how these activity factors performed in the latest month for which
complete national figures are available (January 1967):

Real Estate Sales
Off a little less than they were in December, sales for the nation were

down 14.7% in January, with the following regional compar teas with the
same month last year:

Region Percent Change
Northeast ------ +--+ +++ -°- 8.0
Great Lakes - =- - Ss -s © == = 5s 2s ss =&lt; == Lad
REAR oS CS ea Se te me ee a ese alee, ae | 6.2
Central Prairie and Mountain - -------- . 18.4
Pacific West ------2f fff fff 20.01

The reasons for the slow selling pace were not much changed from those
which have prevailed in the past few months. The sharp drop in new home
construction and completion was a major factor. Normally the sale of a
new house results in from two to five sales of other dwelling units as
occupants play a game of "musical chairs" in the upgrading process. No
new houses; no occupancy shifts down the line. In addition, the promise
of lower mortgage money rates (given
wide publicity, especially since

 

 

 

 

 

 

Selected NATIONAL Economic Indicators October) has caused many prospective
= buyers of existing houses to wait for
[VALUE OF DOLLAR (1939 = 100) 41.54¢ better terms.
INDICATOR HOM A On On the income property side, the rapid
drop in money rates acted to lower
PRICES: realistic capitalization rates faster
Wholesale Prices 1.5 0.3 than prospective buyers could adjust
Building Costs 4.2 0.0 their sights. Moreover, improved
Feat Eroci, Sree = Boe = a5 market conditions in most space markets
onsumer Frices e . j i
Dow Jones IndI’s (ds of 2/23) |-11.0|= 0.4 (especially in the Northeast, Great

Lakes and South regions) caused poten-
PRODUCTION, EMPLOYMENT, tial sellers to scent higher occupan-
INCOME: cies and rentals --- thus causing them

 

 

 

 

 

Total Production ae = hs to firm their ideas of value. Finally,
Menvfocyrisg be 0.3 = a a rapidly rising stock market proved a
hata Ueto 0.5 7 Res lure to speculators looking for a fast
Construction Employment a, . 2 0.2 return on investment.
Individual Income
Wages Ee ae We look for unfavorable year-to-year
7 SSA: tat comparisons in the sales markets to

emt ee 1a 4 1.6 continue for the first quarter of this

ee ; = Sry bays year, after which we expect measurable
Currency in Circulation 0.6 O.1 J ‘
Government Debt oT = D7 smprovement .
Checks Cashed (Dollars) 15.4 4.6 2
Value of Dollar =t.2 0.0 Mortgage Lending
Dats latest available for each factor. The national decline since last year in

 

mortgage lending for the latest month
THE REAL ESTATE FORECAST AUTHORITY PAGE 3

 

(January) was 33.5% in the number of mortgage loans closed and 42.4% in the
total dollar volume of those loans. While mortgage money conditions con-
tinued to improve, the actual volume of lending was still low, due to the
highly selective and cautious nature of lenders returning to the markets.

Here are the regional comparisons between the mortgage business in the
latest month and that of the same month of 1966:

 

Dollar Volume Number of Loans

Region Percent Change Percent Change
Northeast -------f-ffrccoc s0.1--+-+-+-- 29.6
Great Lakes - ------effef-e-o 43.l1---+e-+-- 2608
South - -----+--ff+f2f-+-77 0.4------ 22.3
Central Prairie and Mountain - - - 40.6 ----+-+- 29.7
Pacific West ----=---+ reece 46.8 ------ 42.1

It is obvious from the above statistics that, through the month of January

at least, the improvement in mortgage money conditions was largely
theoretical and technical rather than actual --- as far as real estate

lenders and borrowers were concerned.

 

As noted above, the drop of interest rates in the basic money markets during
the month of January was a little less than remarkable. However, at the

end of that month and all during February, these trends were reversed.
Yields on treasury bills, municipals and corporates were up steadily,
week-by-week in February.

This yo-yo action of money rates in the first eight weeks of 1967 was not
reflected in the mortgage money rate situation. Reason: the supply-demand
ratio in the mortgage money markets did not parallel that in the basic
money markets. Here were the differences:

1. The savings flow into real estate-oriented institutions was
greatly improved over a year ago. On the other hand, mortgage
demand (in the kind of loans scared lenders now consider acceptable)
was disappointing. As a result, on balance, there was more money
than there were loans.

2. In the basic money markets, demand held high and supply was not
meaningfully improved. Money lenders found that they had under-
priced their commodity and took a second look at their potentials.

We see no particular "threat" in the February developments to the long-term
trend of mortgage money. 1967 will continue to score improvements in this
sector.

New Construction

One of the much-touted "bullish" factors cited by those who are optimistic
about 1967 is the belief that the ailing home-building industry will stage
a comeback in the year. So-called building stocks have shown outstanding
strength on the nation's stock markets as speculators have hungrily snapped
them up in anticipation of higher sales and earnings.

These sentiments have not only been encouraged by the statistics of housing
construction in the past three months (January housing starts were at a
seasonally adjusted annual rate of 1,243,000 units --- up 14.6% from
December and up a whopping 47% from last October's postwar low), but by

the longer range prospects for a dramatic increase in the number of young
married couples starting in 1968.
PAGE 4 the Mational MARKET LETTER

Certainly (as this Letter has pointed out for several months), the
residential markets in most local areas have gained strength in virtually
all local areas --- and are postured for a burst of new supply in many.

In our opinion, the high expectations of the building industry (like
those which have pushed savings and loan stocks skyward since last fall)
tend to exaggerate the actual prospects for building profits --- either
on the part of the developer or the materials manufacturer. The reason:
the costs of money, materials, labor and land are such that development
profits must await a higher general rental market to encourage and
support a meaningfully higher volume of new construction.

The real profits are to be made in the purchase of good, sound, well-
located and well-designed existing property which will experience sharply
enhanced earning power before a new building boom can get started.

THE BIGGEST REAL ESTATE PROFITS IN THE PAST FIVE MONTHS: have been made in real
estate stocks. Our readers will remember that we set up a Real Estate Stock
Index in October of 1965. On that date we assigned the figure of 100.0 to

the prices of these securities which prevailed on October 1, 1965. Here is
the record of those values, monthly, since that date:

 

Month 1965 1966 1967
January ~---- cc ttt rt 106.9 101.5
February --c fcr rt 7 tT cfr 110.1
March = --- ffs 57 77-7 C? 101.4
Aprigiie scsi SereS She? TS See ee 108.3
May ----c fcc trtcrtr ttc cco 96.6
June -=s=]|= 2s, 5-2. 2 Pk eee eo 95.1
II yos) =o S505 SSeS Seer Sar Ss 93.3
AUugUSt, = == = =p" =) =e ee 83.4
September - ----- tr trr rr 77 CDeut
October = =|=---f-ftfrF-7+ 100.0 75.2
November’ .&lt;.2.6.20=-S\5,)&gt; Si53&gt; == 106.9 80.8
December -------+c 77777 105.1 84.4

Even if these real estate stocks had been purchased on October 1, 1965, their
owner would have done better than if he had bought the Dow Jones Industrials
on the big board.

 

 

 

 

 

 

 

 

 

 

 

 

*% CHANGE FROM A YEAR AGO -
FACTOR PRAI
warionar | NQEORT | SHECTONS | scSiow'in | MOUNTAIN | MEET
REAL ESTATE SALES

(Number of Transactions) 17.2 14,0 13.1 9.6 14.8 21.6
MORTGAGE LENDING

(Number of Loans Closed) 33.9 33.1 28.4 19.7 31.9 42.1

(Dollar Volume) 38.0 42.6 34,7 15,9 46.8 42.6
TOTAL BUILDING

(Dollar Volume) Tes 11.4 35.0 24.3 22.9 Zo)

RESIDENTIAL (NEW)
(No. of Projects Started) eke a7 ee 43.6 19.7 44,2 48.3
(Dollar Volume) 45.5 20.0 47.6 28.2 ee 60.0
NON-RESIDENTIAL (NEW)

(Dollar Volume) 10.0 15.0 102.5 25.8 9,8 40.7
MARRIAGES 7.7 3.7 6.9 | 11.7 12.8 9.4
EVICTIONS 1.8 8.8 0.9 Lak 0.0 ca ae
*Figures are based upon extension to National and Regional Levels of actual rates for QUARTER ending January 31, 1967.

 

 

 
THE REAL ESTATE FORECAST AUTHORITY PAGE 5

SPECIAL RESEARCH REPORT

A LOOK AT THE "MODEL CITIES" PROGRAM

Last year, Congress passed legislation authorizing a new urban program to be
administered by the Department of Housing and Urban Development (known as HUD).
Originally known as the "Demonstration Cities Program," it was recently renamed
the "Model Cities Program" to placate Congressmen who feared their constituents
would think the bill encouraged civil rights marches and other "demonstrations!"
Since this program may have important impacts upon big-city real estate markets,
we will explore certain key aspects of it in this month's Special Research Report.

The Model Cities Program was originally devised to counteract the following
undesirable tendencies which had appeared in the Federal government's attempts
to aid cities, especially large central cities: -

1. An enormous number of Federal programs were being administered by many
different Federal --- and city --- departments without much coordina-
tion. A recent Office of Economic Opportunity manual lists over 250
Federal aid programs, most of which are applicable in cities.

2. Funds passed out under these programs tended to be widely dispersed
over the urban landscape. Instead of really trying to upgrade a small
area by focusing a whole battery of urban renewal, health, anti-
delinquency, manpower training, education and other programs on it,
the Federal government was scattering its shots too broadly. Hence
each slum received too little assistance to counteract the forces
"naturally" dominant there.

 

3. Each program assisted with Federal funds tended to be the same in all
parts of a city, and often all over the country, both because one set
of Federal rules governed it and because big-city bureaucracies wanted
to adopt “uniform and equal" policies in all neighborhoods. As a
result, specific programs were often badly adapted to the peculiar
needs of non-typical neighborhoods, especially low-income ghettos.

4. A great deal of urban renewal assistance was designed not so much to
eliminate blight or improve the living conditions of low-income
residents, but _ to bolster the sagging economies of big-city downtown
business districts. Thus the wealthy were the biggest beneficiaries,
and the poor were merely shifted from one slum to another.

 

These complex maladies demanded a complex remedy --- and that is just what the
Model Cities Program is designed to produce. In fact, the Guidelines describing
how to apply for a grant to plan (but not execute) this program are over 50
pages long. Hence we can only mention their most salient features here, before
analyzing some of their major implications.

Participation in the program by any given city involves three stages. The
pre-application stage lasts until an application for a planning grant is completed
and approved by HUD. No Federal financing is available for filling out an
application. Yet it is so complex that many cities have spent months at it and
only four have formally filed applications (as of February 25, 1967). HUD is
likely to disapprove of almost everyone's application at first until it is
adjusted to reasonable conformance with the many criteria described below. After
HUD approval is obtained, the planning stage begins. This can last from six

to twelve months, and can be financed up to 80% by HUD grants (though the

total authorized to HUD for such planning is only $24 million over two years).
Finally, for those few cities receiving final approval, the execution stage
arrives. In this stage, each city will apply for normal Federal aid for specific
PAGE 6 the National MARKET LETTER

 

programs in the Model City Area (such as 2/3 financing for urban renewal), and
can get an additional "block grant" for up to 80% of the local share it would
otherwise have to put up. This bonus can be used for additional activities in
the Model Cities Area which would otherwise not be eligible for Federal
assistance.

The myriad specific criteria which Model City plans must meet include the
following major ones summarized from HUD's Program Guide:

1. The program must be comprehensive. Specifically, it should contain
the following components: physical improvement, housing, transporta-
tion, education, manpower and economic development, recreation and
cultural, crime reduction, health and social services and public
assistance,

2. The program should provide for administrative machinery at the local
level to carry out all its aspects on a consolidated and coordinated
basis. Preferably, this means direct linkage to the mayor or other
chief executive.

3. It should make a substantial impact on the physical, economic and
social problems in the model neighborhood area.

4. It should remove or arrest blight and decay in the selected area or
areas of the city.

5. It should be of sufficient magnitude to contribute to the sound
development of the entire city.

6. It should make marked progress in reducing social and educational
disadvantages, ill health, underemployment and lack of social services
necessary to serve the poor and disadvantaged of the area.

7.  #It should provide for widespread citizen participation.

8. It should provide maximum opportunities for employing residents of the
area in all phases of the program and enlarged opportunities for
work and training.

9. It should contribute to a well-balanced city with a substantial
increase in the supply of standard housing of low and moderate cost.

10. It should contribute to a well-balanced city with maximum opportunities
in the choice of housing accommodations for all citizens of all
income levels.

ll. It should contribute to a well-balanced city with adequate public
facilities, commercial facilities adequate to service the residential
areas, and ease of access between residential areas and centers of
employment.

12. It should provide for a comprehensive plan for the relocation of
individuals, families, business concerns and nonprofit organizations.

In addition, each program should require re-examination of local laws, be
consistent with comprehensive metropolitan-wide planning, be initiated within

a short period of time (under five years), embody high standards of urban design,
maintain historic sites, make maximum use of new technology, use cost-benefit
analysis, conform to civil rights requirements, encourage maximum private
enterprise, not reduce previous local spending in the Model City area, and be
backed by adequate local resources.
THE REAL ESTATE FORECAST AUTHORITY PAGE 7

In setting out this extraordinarily ambitious set of requirements, HUD is like a
bachelor stating he will only marry a girl with Jacqueline Kennedy's poise,
Jayne Mansfield's figure, Grace Kelly's face, Elizabeth Taylor's allure and
Barbara Hutton's money! In fact, he would be fortunate to get any one of these
charms, as HUD will be fortunate to get even a majority of its requirements
actually met by any given city. Although each individual criterion seems
justified, the group taken together constitute too radical a departure from
present urban government practice to be fully achieved in any single city.

 

Specifically, we believe that HUD's program will encounter five major obstacles
and will have to compromise with them in many cases. These are as follows:

1. &lt;All three of the major objectives of the Model Cities Program ---
coordination, innovation and specific adaptation of programs to ghetto
areas --- run counter to well-entrenched bureaucratic tendencies in
city governments. City --- and Federal --- departments used to
carrying out their own functions without much checking with each
other will resist intimate cooperation in planning their programs.
Moreover, innovation requires changing established behavior patterns,
and few things are more difficult for large bureaucracies. Finally,
the development of new programs tailored to the needs of ghetto
residents, and different from programs in the rest of the city, will
run counter to tendencies toward “equal treatment" and "uniformity"
long established in some city departments,

All three of these frictions will probably be greatest regarding big-
city schools. Many school boards are relatively free from direct
political control by city governments; hence it will be hard for
mayors to get them to change their ways to fit these criteria. Yet
schools are the most important single public institution in almost
all ghettos. They alone have the potential power to make up for many
of the home deficiencies suffered by children from deprived families.
Hence if they are not effectively integrated into the Model Cities
Program in a city, and given part of its bonus "block grants," it
cannot really achieve its major goals. So one of the key tactics for
any city trying to make this program work must be convincing school
authorities of the need to create new programs specifically designed
for ghetto areas, including programs which use school buildings for
many kinds of non-educational activities (such as recreation, social
service distribution and adult vocational training).

2. Concentration of leadership efforts on one Model City neighborhood
will be necessary to make this program work; yet this contradicts the
fundamental "Law of Over-Dispersion" sacred to politicians. The desire
to gain widespread political support naturally leads elected officials
to spread the benefits of any program to all areas under their juris-
diction, even though this causes a loss of the economic benefits of
concentration, Hence city politicians will be sensitive to the charge
of focusing too much attention on the Model City neighborhood,
especially since it will be a low-tax-paying ghetto area. So they may
provide only half-hearted leadership in support of such concentration,

Even if local areas succeed in establishing coordination among their
own city departments and related agencies, there is no guarantee that
Federal agencies will similarly cooperate in n_ Washington. For example,
when a city asks for a grant from the Department of Health, Education
and Welfare that is urgently needed for its Model City Program, it may
find itself at the end of the long "normal processing line" along

with a11 other requests, including those in no way associated with
Model Cities.
PAGE 8 the National MARKET LETTER

4. In large cities, it will be impossible to simultaneously meet the two @
criteria of significant impact on the city as a whole and intensive
impact in the Model City neighborhood. If an area is large enough to
be a significant slice of the entire city, it will be too big for this
program to effect intensively, since total Model City funds are quite

limited.

5. The housing requirement in the Guidelines is ambiguous. At one point,
it says that the program must provide "a substantial increase in the

 

supply of standard housing of low and moderate cost."' But in the
next sentence, it says "The program should add to the overall supply
of low and moderate-income housing, not decrease it." The latter

requirement is virtually impossible, since any clearance of sub-
standard and deteriorated units, or reduction in overcrowding, will
cause a decline in total supply of low-income housing. Even building
new public housing will probably not increase this total supply,
though it could easily increase the standard supply.

In spite of these drawbacks, the Model Cities Program is definitely a worth-
while experiment which could have significant long-run benefits --- if it is
truly conceived of as a means of demonstrating techniques which will later be
applied on a much larger scale. Specifically, it may create an incentive for
at least some cities to do enough innovating, coordinating, concentrating

and adapting of programs to particular needs to give local governments a "shot
in the arm." But eventually this tiny shot must be followed by much larger
appropriations than those as yet made for Model Cities if the lessons learned
are to have any truly sizeable impact upon U.S. urban problems.

(The Special Research Report series on Change in Modern Society will be Ge
continued in a later issue.)

NO QUOTATION WITHOUT PERMISSION

 
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                    <text>I
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Reprinted from Federal Register - 31 F. R. p 8781-85
June 24, 1966
Title 24-HOUSING AND:HOUSING
CREDIT
Subtitle A-Office of the Secretary,
Department of Housing an~ Urban
Development
PART 0-STANDARDS OF CONDUCT
Pun,uant to and in accordance with
sections 201 through 209 of Title 18 of
~he United States Code, Executive Orqer
11222 of May 8, 1965 (30 F.R. 6469), and
Title 5, Chapter I, Part 735 of the Code
of Federal Regulations, Part O is a dded
to Subtitle A of Title 24 of the Code of
Federal Regulations, reading as follows:
Subpart A-Ger. •nt Provisions
0
Sec.
Purpose.
Definitions.
Interpretation and advisory service.
0 .735-104 Notification to employees and
special Government employees.
0.735-105 Remedial action.
0.735-106 Interest of employee's or special
Government employee's relatives.
0 .735-101
0 .735-102
0.735-103
Subpart Ii-Conduct and Responsibilities of
Employees
!l.735-201 Basic principle.
o·.'735- 202 Gifts, enterta.!nment, a nd favors.
Outsid e activity.
Financial Interests.
Personal real esta te tra n sactions.
Use of Inside information.
Intermediaries and product recommendations.
0.735-208 Membership In organization.~.
0.735-209 Use of Government property.
0 .735-210 Indeb tedness.
0.735- 211 Gambllng, betting, and lotteries.
0.735-212 Gener al conduct; and conduct
prejudicial to the Government.
0.736- 203
0 .735-204
0.735-205
0.735-206
0.735-207
Subpart C-Conducl and Responsibilities of
Special Government Employees
0.735-301 Use of Government employment.'
0.735-302 Use of Inside information.
0 .735-303 Coercion.
0 .735-304 Gifts, entertainment, and favors.
0.735-305 Applicability of other provisions.
Subpart D-Miscellaneous Statutory Provisions
0.735-401
Applicable statutory provisions.
Subpc:rt E-Statements of Employment and
Financial Interests
0 .735- 501 Submission of statements.
0 .735-502 Supplementary statements.
0.735-503 I nformation not known by em-
ployees.
Information prohibited.
Review of statements.
Confidentiality of statements.
Effect or employee's statements
on other requirements.
0.735-5-08 Specifl'C provisions !or special
Government employees.
Appendix-List of Positions Subject to
Subpart E.
0.735-504
0 .735- 505
0.735-506
0 .735- 507
this part. He ~hall be responsible for
coordinating the Department's counseling&gt; services and for assuring that counseling and interpretations on questions
Subpart A-Gener~I Provisions
of conflicts of interest and other matters
§ 0.735-101 Purpose.
covered by this part are available to desThe maintenance of unusually high ignated depnty counselors. He may
standards of honesty, integrity, impar- form ad hoc committees to evaluate the
tiality, and conduct by Government em- effe&lt;;JJveness of the standards, or to conployees and special Government em- sider any new or unusual question arisployees is essential to assure the proper ing from their application.
performance of the Government busi,oess
and the maintenance of public . confi(b) Dep_yty fOUns~lors. Such de~tY
dence. The avoidance of misconduct
and conflicts of interest on the -part of counselors as, maY; be requj.red . shall be
Government employees and special Gov- design!\ted to gi;ve llj_\,lthoritative advice
ernment employees through informed andNUidance to current ang, prospective
judgment is indispensable to the main- employees and special Goverrwient emtenance of these standards. To accord ployees on questions of confl,icts of-interwith these concepts, this part sets forth est and on other matters covered by .this
the Department's regulations prescrib- part.
ing standards of conduct and responsibilities, and governing statements of
Notification to employees
employment ahd financial interests for § 0.735-104
attd . special Gove~ment employees.
employees and special Government
The provisions of this part and all reemployees.
visions thereof shall be brought to the
§ 0.735-102 Definitions.
attention of and made available to:
(a) Each employee and special Gov(a) "Department" means the Department of Housing and Urban Develop- ernment employee at the time of issuance and at least annually thereafter ;
ment. ..
(b) Each new employee and special
(b) "Employee" means an officer or
employee of the Department, but does Government employee at the time of em·
not include a special Government em- ployment.
ployee.
(c) "Special Government employee"
means an officer or employee of the De- § 0.735-105 Remedial action.
partment appointed to serve with or
A violat·on of this part by an employee
without compensation, for not more than or special Government employee may be
130 consecutve days during any period of cause !or remedial or disciplinary action.
365 days, ori a full-time, part-time, or Such action may include, but is not limintermittent basis, and who is retained, ited to:
design ated, appointed, or employed as a
(a) Changes in assigned duties;
special Government employee under the
(b) Divestment by the employee or
provisions of section 202 of Title 18 of special Government employee of his conthe United States Code.
flicting interest;
(d) "Person" means an individual, a
(c) Disciplinary action, including
corporation, a company, an association, separation, which may be in addition to
a firm, a partnership, a society, a joint any penalty prescribed by law; or
stock company, or a ny other organiza(d) Disqualification for a particular
tion or institution.
assignment.
(e) "outside employment" · means all
gainful employment other than the per- Remedial action, whether disciplinary or
formance.. of official duties. It includes, otherwise, shall be effected in accordance
but is not limited to, working for another with any applicable laws, Executive oremployer, the management or operation ders, and regulations.
of a private business for profit &lt;including personally owned businesses, partnerships, corporations, and other business § 0. 735-106 Interests of employee's or
special Government employee's relaentities), and other self-employment.
AUTHORITY: The provisions of this Part O
issued under E.O. 11222 of May 8, 1965, 39
F .R. 6469, 3 CFR, 1965 Supp.; 5 CFR 785.10.f.
tives.
§ 0. 735- 103
service,
Interpretation and advisory
(a) Department counselor. The General Counsel is design ated ·counselor for
the Department and shall serve as the
Department's designee to the Civil Service Commission on matters covered b:v
For the purposes of this part, the int erest of a spouse, minor child, or a blood
relative who is a full-time resident of an
employee's or special Government employee's immediate household is considered to be an interest of the employee or
- ~ J l l l ( I M ! l l ~ ~ e• . 4.ifi..,,.;11 ..
�Subpart 8 -,-C'QRd\Jct and Responsibil.,i_ties of Employees
§ ~35- 201' Basic'principle.
(a) Each e'i'nployee must realize that
the --Government's basic and controlling
purpose in employing him is the public
interest, rather than his private or personal interest, and that he can never
have a right of tenure that transcends
the public good. He can properly be a
Government employee only as long as it
remains in the public ,interest for him
to be one. Public trust and confidence
in the integrity of the Government are
para.mount.
(b) (1) This basic principle applies
with special force and effect in the Department of Housing and Urban Development, which deals directly with important segments of the public, and whose
success depends upon public trust and
confidence in its actions. The official
actions of the Department often··have a
direct bearing upon the financial and
other interests of individuals, firms, and
institutions with which it does business.
Furthermore, the effective accomplishnient"oftnebepartmeWs ~sion is "si.gnifioa.ntly dependent u'pon a pubt\c image
that engenders confidence in the Department's integrity. Accordingly, the avoidance of any involvement that tends to
damage that image is a responsibility of
exceptional importance for all employees
who participate in or influence official
operating determinations that affect the
interests of those with whom the Department does business.
(2) If there is knowledge of an employee's involvement in or association
with circumstances reasonably construed
to reduce public confidence in the acts
or determinations of the Department,
such knowledge may be sufficient cause
for the initiation of action adverse to
the employee. Employees, therefore, are
alerted to the gravity with -which the
Department will view. any such involvement, especially if it has to do with conflicts of interest or the compromise of
integrity-whether real or only appar.ent.
§ 0.735-202
Gifts, entertain ment, and
f avors.
(a) Except as provided in paragraph
(b) of this section, an employee shall not
solicit or accept, directly or indirectly,
any gift, -gratuity, favor, entertainment,
loan, cir any other thing of monetary
value, from a person who:
(1) Has, or is seeking to obtain, cont r actual or other business or finan cial
rela tions with the Department ;
(2) Conducts operations or activities
tha t a re regula ted by the Denartment: or
(3) Has interests t h at m ay be substantially affect ed by the performance or
nonperformance of the employee's official
duty.
(b) The prohibitions of p a ragraph (a )
of t his section do not apply t o:
(1 ) The acceptance of customary business services fr om banks or other financial institutions if such services are obt ained under terms and conditions available to the general public;
&lt;2) Obvious family or personal relationships, such as those· between the employee __aµd his _parents, children, or
spouse;· when the "circunistances make it
clear that it i~ those relationships rather
than , the busmess of the persons concerned which are the motivating factors;
(3) The acceptance of food and refreshments of nominal value on infrequent occasions in the ordinary course of
a luncheon or dinner meeting or other
meeting or on an inspection tour where
an employee may properly be in attendance;
(4) The acceptance of unsolicited advertising or promotional. material, such
as pens, pencils, note pads, calendars,
and other items of nominal intrinsic
value.
(c) An employee_ shall avoid any
action, whether or not specifically prohibited by the regulations in this part,
which might result in, or create the appearance of:
&lt;1) Using public office for private
gain;
(2) Giving preferential treatment to
any person;
(3) Impeding Government efficiency
or economy;
(4) Losing complete independence or
impartiality; or
(5) Making a Government decision
outside official channels.
(d) An employee sha.11 not solicit contributions from another employee for a
gift, or make a donation as a gift, when
such gift is for an employee in a superior
official position. An employee in a superior official position shall not accept
a gift presented as a contribution from
employees receiving less salary than
himself.
(e) An employee shall not accept a
gift, present, decoration, or uther thing
from a foreign government unless authorized by law.
·
§ 0.73 5-20 3
Outs ide activity.
(a ) An employee shall not engage in
outside employment or other outside activity not compatible with the full a n d
proper discharge of his duties and responsibilities as an employee of the Depar tment. Incompatible activities in clude but are not limited to:
(1 ) Acceptan ce of a fee, compensa tion, gift, p a ym ent of expense, or any
other thing of m onetary value in circumsta n ces in which acceptance may result
in, or create t he appea ra nce of, a conflict of interest;
&lt;2) Employment which tends to impair his men tal or physical capacit y to
perform h is official duties a nd responsibilities in a n acceptable manner ;
(3) Activities that may be construed
by t he p ublic to be t he official a cts of the
Department;
'
(4) Activities that establish relationships or propert y interests that may result in a conflict between his private inWl(e.s~ !l,nd ~ offici!l,l quti~I !qd,_t;J ,i-,t
2
1 -~ ~~::l!fuii&gt;loyine~t taa.t,.rnr,y involve--'he
· use of _information secured as a resuJ.t.
· of employment in the Department to
the detriment of the Department or the
I public interest, or that may give prefer · ential treatment to any person , corpora.tiori, public agerfcy, or group.
(b) An employee shall not receive a ny
salary or anything of monetary value
from a private source as compensa tion
for his services- to the Government (18
U.S.C. 209).
(c) Full- ti.me employees and par t time employees with a regularly scheduled tour of duty must obtain the prior
approval of a designated personnel officer
before engaging in outside employment
in the following categories:
-(1) Employment related to or similar
to the substantive programs conducted
· by any part of ·the Department. This
includes but is n ot limited to the broad
· fields of real estate, mortgage lending,
property insurance, construction, construction financing, and land and real
estate planning.
(2 ) Employment tn the same professional field as t hat of t he individual's
official position.
(3 ) Employment with any person,
. firm, or other private orga nization having business eit h er directly or indirectly
with the Depe,rtment.
(4) Employment by S tate, local, or
other governmental body.
(d) No f ull-time employee or parttime employee with a regularly'scheduled
tour of duty shall maintain a publicly
listed place of business without the prior
approval of a designated personnel
officer.
(e) Except for employees subject to
the r equirements of Subpart E of this
part, approvals r equired by paragraphs
(c ) a nd (d ) of this section shall be
request ed on F orm HUD-843, Request
f or Auth orization to Engage in Outside
Employment and / or Statement of Fin ancial Interests. All . pertinent facts
regardin g t h e proposed employment,
such as the name of the employer, the
n ature of the work to be performed, and
the · amount of t ime involved, shall be
set forth .
(f) (1 ) Employees are encouraged to
engage in teaching, lecturing, and writing thm 1s n ot prohibited by law, Executive order, or this part. However,
an employee shall n ot, either for or
without compensation, engage in teaching, lecturing, or writing that is dependent on -information obtained as a result
of his employment by the Department,
except when that information has been
made available to the general public or
will be made available on request, or
when the Secretary or his designee gives
written authorization for the use of nonpublic information on the basi...; that the
use is in the public · interest.
&lt;2) An employee may use his name
and title in connect\on with articles for
publication which b'ear upon his work
in the Department only if he obtains
the approval of a designated personnel
officer.
�(g) This section does not preclude an
employee from:
(1) Accepting bona fide reimbursem&lt;.int, unless prohibited by law, for
actual expenses for travel and such other
necessary subsistence as is compatible
with this part for which no Government
p ayment or reimbursement is made.
However, an employee may not be reimbursed, and payment may not be made
on his behalf, for excessi\Te personal
living expenses, gifts, entertainment or
other personal benefits.
(2) Participating in the affairs of or
accepting an award for a meritorious
public contribution or achievement given
by a charitable, religious, professional,
social, fraternal, nonprofit educational
and recreational, public service, or civic
organization.
(3) Participating in the activities of
National ·or State political parties not
proscribed by law.
§ O. 735-204
Financial interests.
(a) An employee shall not :
(1) Have a direct or indirect financial
interest that conflicts, or appears to
conflict, with his official duties and responsibilities.
(2) Engage in, dfreetly or indirectly,
a financial transaction as a result of, or
prima.r ily· relying on, information ob~
taihed tgrpugh .bl~ emplo~ent by the
Dep,11.rtment.
(3) Acquire se~:urtties issued by thE:
Feder&amp;) National Mortgage Association.
&lt;4) Acquire ownership of. stock . or
other interest in a rental project financed
with an FHA insured mortgage as long
as the insura.nce is in force.
(5) Acquire ownership of FHA debentures or certifl.cates:of claim.
(6) Acquire interest in a cooperative
or condominium housing project financed under the National Housing Act
if the interest is not for obtaining a
home for himself or his family.
&lt;7) · Be an' officer or · director of any
organization which is an FHA approved
mortgagee or lending institution or which
services mortgages or other securities for
the Department. An employee may hold
stock or shares in such organizations
provided his official duties are such that
the holding will not create or tend to
create a conflict of interest. The prohi-bitions of this paragraph do not apply
to Federal Credit Unions that have been
approved as Title I lending institutions.
(8) Participate directly or indirectly in
any real estate activities for speculative
purposes as distinguished from bona fl.de
investment purposes.
&lt;b, This section does not preclude an
employee from having a financial interest or engaging in financial transactions
to the same extent as a private citizen
not employed by the Department so long
as it is not prohibited by law, Executive
Order 11222, or this part.
§ 0. 735-205
actions.
Personal real estate ll·ans-
(a) Because the OP.erations of the Department are directly· related to individual real estate transactions, all Department employees must exerci~_the utmost
care ,iJ:l the. handlµ11r..of~tmMr.Jeuons,l
real estate activitits ...."E~i:&gt;19'.$7~ rtful
therefore .rewrt ,to a desighated ,tiersonnel offl,cer-the' folloWl,ng tiJ&gt;es ~ tifrs~na.1
re~l esta~ transaction§ (~ the ~l'.,811Sac-·
ti6I} involves FHA md.ttga'ge l n$.Urapce,
the · report shall be fl.led at the tline the
application for such insurance is fl.led~
other types of transactions shall" be:re.:
ported at the time of cons~a,J;iah of
the-transaction) :
(1) Any purchase or sale of real property 1n which an employee has ari
interest.
·c2) Any Title I property improvement
loa~ obtained by the employee or in
which he h as a financial ihter'est. In
such case the employee must report 'the
name of the lending institutlon and ·a
description of .t he im_grovements being
financed.
(3). Any interest in a cooper.a,tive or
condominium- housing "project financed
under the National Housing. Act if jt
involves a home for himself or.Jtls".family.
(b)
a ddition to ~he repor:ting:_ re-:
quirements of paragrap)'l. Ca) of Uus, see"!{
t ion, employees shall , report ;all ·reru
estate holdings other than those held
person al residences.
Cc) Except for employees subject to
the requirements of SubPQrt E of 'this
part, reports required 'tl\'V paragraphs
(a) and (b) of this section shall be fl.led
on Form HUD-843, Request for Authorization to Engage in Outside Employment
and/or Statement of Financial Interests.
In
(b).rAn;emplqtee may~ designated to
serve as, a liaison fepreseht4tiv1:. of the
De,par.tment to a non-Federa1 or private
organization provided ·that:
0) Th'e activity ·relates 'to the work M
the Department.
.
(2) The employee does not participate
by vote in the policy determinations of
the organ~tion.
(3) The Department Is in no way
bound by any vote or action taken by the
organization.
§'°O. 735-209 Use of Government prop. erty.
An employee shall not directly or In-
directly use, or allow the use of Department property of any kind, including
property leased to the Department, for
other than officially approved activities.
An employee has a positive duty to protect and conserve Govern,ment property,
including equipment, supplies, and other
property entrusted or issued to him.
§ 0.735-210
·Indebtedness.
An' employee shall pay each just finan-
cial. obligation in a proper and ,timely
m anner , especially one imposed by law,
such as Federal, State, and local t axes.
For the purpose of this section, "just financial obligation" means one acknowledged by the employee or reduced to
judgment by a court, and "in a proper
a nd timely manner" means in a manner
which the Department determines does
not, under the circumstances, reflect adveraly..loll&gt; tmt, C]pvernmenff as his- amS 0.di'35.:..206 Use of idlide. irdormation. }Noyar.
1J:rotthe event· of a dispute. be• Excl!pt as provided _tp §"0 .,n5..:203 (f}, t;Jv.een aru employee anll. an aJ.!Egled credino employee shall giv~ pr 'use jnside· in- tor, this sootion ckles · riot · require · the
formatio~ acquired by means of his posi~ Department to determine the l'Widity or
tion to advance any private interest, the-. amount of the disputed debt.'
particularly the priv·a te interests of himself, his family, associates, or friends. ·§ 0.'135:-211 Gambling, belting, and lotteries.
For the purpose· of this section "inside
information" means information ob- . An employee shall not participate,
tained under Government authority but while on Government -owned or leased
which has not become part of the body o! property or while on duty for the Departpublic information.
ment, in any gambling activity includ§ ·o .735-207 Intermediaries and product ing the operation of a gambling device, in
conducting a lottery or pool, in a game
recommendations.
for money or property, or in selling or
No employee shall recommend or sug- purchasing a number slip or ticket.
gest the use of any particular or identified nongovernmental intermediary to § 0.735-212 General conduct; and condeal with the Department nor shall he
duct prejudicial to the Government,
recommend any device or product tested
Ca)
Each employee shall conduct himby or for, or used by, the Department,
self in a manner that facilitates the ef- ,
except as required by his official duties.
fective accomplishment of the work of
§ O. 735-208 Membership in organiza- the Department, observing at all times
tions.
the requirements of courtesy, considera(a) An employee may not, in his offi- tion. and promptness in dealing with the
cial capacity as an officer or employee of public and with persons or firms having
the Department, serve as a member of business with the Department;
Cb) An employee shall not engage in
a non-Federal or private organization
except where express statutory authority criminal, infamous, dishonest, Immoral,
exists, or statutory language n-ecessarily or notoriously disgraceful conduct, or
implies such authority. -However, 'an other conduct prejudicial to the Governemployee may serve in an individual ca- ment.
pacity as a member of a non-Federal or
Subpart C--Conduct and Responsibilprivate organization, provided that:
ities of Special Government Em(1) His membership does not violate
the restrictions noted in § 0.735-203; and
ployees
(2) His official title or organization
connection 1s not shown on any listing § O. 735-301 Use of Government employment.
or presented in a.ny activity of the orgaA special Government employee shall
nizatior1 in such a manner as to im.,ply
tQAt 9e Ii actin&amp; In, h~ offlci~ capa.city. not use his Government employmeo.li!M
as
3
�a purpose that is, or gives the appearance of being, motivated by the desire for
private gain for himself or another person, particularly one with whom he has
family, business, or financial ties.
§ 0. 735-302 . Use of inside information.
(a) A special Government employee
shall not use inside information obtained
as a result of his Government employment for private gain for himself or
another person either by direct action on
his part or by counsel, recommendation,
or suggestion to another person, particularly one with whom he has family, business, or financial ties. For the purpose
of this section, "inside information"
means information obtained under Government authority which has not become
part of the body of public information.
(b) Special Government employees
may teach, lecture, or write in a manner
consistent with the provisions of § 0.735203(!).
§ 0. 735-303 Coercion.
A special Government employee shall
not use his Government employment to
coerce, or give the appearance of
coercing, a person to provide financial
benefit to himself or another person,
particularly one with whom he h as
family, business, or financial ties.
§ 0. 735-304 Gifts, entertainment, and
favors.
(a ) Except as provided in paragraph
(b) of this section, a special Government
empfoyee;-w hile so employed or in- connection with his employment, .shall not
receive or solicit from a person having
'business with the Department anything
of monetary value as a gift, gratuity,
loan, entertainment, or favor for himself
or another person, particularly one with
whom he has family, business, · or
financial ties.
(b) The exceptions of § 0.735- 202(b),
which are applicable to employees, are
also applicable to special Government
employees.
§ 0. 735-305 Applicability of o ther provisions.
and conflicts of interest, as appropriate
to the employees concerned.
(c) The prohibition against lobbying
with appropriated funds (18 U.S.C. 1913).
(d) The prohibitions against disloyalty and striking (5 U.S.C. 118p, 118r).
(e) The prohibition against the employment of a member of a Communist
organization (50 U.S.C. 784).
(f) The prohibitions against (1) the
disclosure of classified information (18
U.S.C. 798, 50 U.S .C. 783); and (2) the
disclosure of confidential information
(18 u.s.c. 1905).
(g) The provision relating to the
habitual use of intoxicants to excess (5
u.s.c 640).
Ch) The prohibition against the mis).lSe of a Ooverriment vehicle (5 u.s.c.
78(c)).
m The prohibition against the misuse of the franking privilege (18 U.S.C.
1719).
(j) The prohibition against the use of
deceit in an examination or personnel
action in connection with Government
employment (5 U.S.C. 637).
(k) The prohibition against fraud or
false statements in a Government matter
(18 u .s.c. 1001).
(l) The prohibition against mutilating or destroying a public record (18
u.s.c. 2071).
'
(m) The prohibition against counterfeiting and forging transportation requests 08 U.S.C. 508).
(n) The prohibitions against (1) embezzlement of Government money or
property (18 U.S.C. 641); (2) falling to
account for public money (18 U.S.C.
643); and (3) ·embezzlement of the
money or. property of another person in
the possession of an emplo~ee by reason
of his employment (18 U.S.C. 654).
(o) The prohibition- against unauthorized use of documents relating to claims
from or by the Government (18 U.S.C.
285).
(p) The prohibition against proscribed political activities-The Hatch
Act (5 U.S.C. 1181), and 18 U.S .C. 602,
603, 607, and 608.
(a) Each special Government employe1 is subject to the provisions of Subpart E-Statements of Employ§§ 0.735-201, 0.735-208 through 0.735-212,
ment and Fina ncial Interests
and 0.735-508.
(b) Each special Government em- § 0.735-501 Submission of statements.
ployee shall acquaint himself with each
(a) Not later than 90 days after the
statute listed in Subpart D of this part. effective date of this part, each employee
occupying a position designated in the
Appendix shall submit to the reviewing
Subpart D-Miscellaneous Statutory official specified in § 0.735-505, Form
Provisions
HUD-844, Statement of Employment and
§ 0.735-40_
1 Applicable statutory provi- Financial Interests.
(b) Each employee who enters on duty
sions.
after the effective date of this part in a
Each employee shall acquaint himself position
designated in the Appendix shall
with each statute that relates to his
ethical and other conduct as an employee submit to the reviewing official specified
of ·t he Department and of the Govern- in § 0.735-505 a statement not later than
ment. The attention of each employee 30 days after his entrance on duty or
is directed to the following statutory 90 days after the effective date of this
part, whichever is later.
provisions:
(c) Additions to, deletions from, and
Ca) House Concurrent Resolution 175,
85th Congress, 2d Session, 72 Stat. Bl2, other amendments of the list of positions
the "Code of Ethics for Government in the Appendix may be made from time
to time as necessary to carry out the
Service".
'(b) Chapter 11 of Title 18, United purpcse of the law, Executive Order
States Code, relating to bribery, gra.ft, 11222, and Part 735 of the Civil Service
4
Commission Regulations (5 CFR •Part
735). Such amendments are effective
upon actual notification to the incumbents. The amended Ii.st shall be supmitted at least annually for publicatidn
in the FEDERAL REGISTER.
§ 0.735-502
Supplementary statements.
(a) Changes in, or additions to, the
information contained in an employee's
statement shall be repcrted to the appropriate reviewing official in a supplementary statement at the end of the quarter
in which the change occurs. Interim
memoranda reports shall be filed if required to meet the prior approval provisions of § 0.735-203 (c) and (d). or the
requirements of § 0.735-205(a) concerning the timely reporting of real estate
transactions. Financial interests or employment acquired during a quarter, but
dispcsed of or terminated before the end
of such quarter, shall constitute changes
or additions to be repcrted at the end
of such quarter. ·Q uarters end March 31,
June 30, September 30, and December 31.
If there are no changes or additions in
a quarter, a negative report is not required.
However, for the purpcse of
annual review, a supplementary statement, negative or otherwi&amp;.e, is required
as of June 30 of each year.
(b) A supplementary statement shall
be submitted on Form HUD-844, and
shall be designated "Supplem entary;'.
A supplementary statement shall furnish all information required by an initial
statement and by appropriate notation,
shall indicate any changes. in, or a dditions to the information set out in the
employee's initial statement or la.st supplementary statement.
§ 0.735-503 Information not known by
e mployees.
If any information required to be in-
cluded on a statement or supplementary
statement, including holdings placed in
trust, is not known to the employee but
is known to another person, the employee shall request that other person
to submit infonnation in his behalf.
§ 0.735-50 4 Information prohibited.
This subpart does not require an employee to 1'eport information relating to
his connection with, or interest in, a
professional society or a charitable, religious, social, fraternal, r ecreational, public service, civic, or political organization
or a similar organization not conducted
as a business enterprise. For the purpose of this section, educational and
other institutions doing research and development or related work involving
grants of money from or contracts with
the Government are deemed "business
enterprises" and a.re required to be included in an employee's statement.
§ 0.735-505 Review of statements.
(a) Employees reporting directly to
the Secretary shall submit their statements directly to the Secretary for review; employees reporting directly to
the Under Secretary shall submit their
statements directly to the Under Secretary for review.
(b) Employees reporting directly to
A(lsistant Secretaries shall submit their
�I
statements directly , to ~he · appropr1~e
Assist.ant Secretary for revie-yl'; em,pJoyjes
r eporting directly to the General ~ou·~ ei
shall sut&gt;mit their statements directJy W
th~ general Counsel for review.
·
(c ) Employees not included, "in .p aragraph (a ) .or (b) of this section shall
submit· their _statements directly to the
appropriate Deputy Counselor.
(d ) When a statement submitted under paragraph (b) or (c) of this section,
or information from other sources, indicates a conflict between the interest of
an employee and the performance of his
official duties, and when the conflict or
appearance of conflict cannot be resolved
by the r eviewing official, he shall report
the information concer ning t he conflict
or appearance of conflict to the Secretary through the Counselor. The employee concerned shall be given an opportunity to explain the: conflict· or
appearance of conflict before · any required remedial action is initiated.
(c) The Secretary or his designee may
waive the provisions of this sectioo in the
case of a special Government employee
who is not a consultant or an expert when
it is determined that the duties'. of the
position held by the special Gov~mment
employee are of a nature and at such
level of responsibility that the submission of a statement is not necessary to
protect the integrity of the Government.
For the purpose of this-parag1&amp;p~ "81G!'s'tllt:ant..,, and '"expert" have the melmings
given those terms by Chapter -~04 pf'the
Federal Personnel Manual.
This part was approved by the· Civil
Service Commission on May 17; 1966.
Effective date. This part shall be
effective as of June 24, 1966.
§ 0. 735-506
ments.
Officers a nd employees in the following
positions are subject to the provis!,Pns of
Subpart E of this p art :
(a ) Employees p aid a t a level of the Federal
Executive Sa lary Schedule est ablished by the
Federal Executive Sa l ary Act of 1964, aa
amended, except the Secretary,_who is subj ect to sep arate reporting requirements under
section 401 of Executive Order 11222;
(b) Employees in grade GS-16 or a bove of
t he G enera l Schedule established by the
Classiftc;:a tlon Act of 1949, rui amended, Of in
com parable or high er p ositions not s ubject to
t h at Act; and
(c ) Employees in the followtng positions:
Confide ntiality
of - 81.!lte-
After the review process has been completed, the statements submitted under
§ 0. 735-505 shall be promptly forwarded
to the personnel office having custol of
the employee's official personnel file .
The statements shall be held In onfidence and retained, in) 1i.Iilitecl accef;S
files.:· Information from a sfaU!ment
may n ot be disclosed exc~t as t~e Secretary or his designee , or the c ivlr Service
Commission may determine for good
cause shown.
·
§ 0.735-507 Effect of employee's statements on other requirements.
The statements and supplementary
statements required of employees are in
addition to, and not in substitution for,
or in derogation of, any similar requirement imposed by law, order, or regulation. The submission of a statement or
supplementary statement by an employee
does not permit him or any other per son
to participate in a matter in which h is
or the other person's participation is
prohibited by law, order or regulation.
§ 0 :735-508
Specific provis ions for special Government employees.
(a) Except as provided in p~ragraph
(c) of this section, each special G overnment employee shall submit to, the reviewing official specified in § 0.735-505,
Form HUD-844-A, Statement of Employment and Financial Interests, qot later
than the time of his employment. He
shall keep his statement current throughout his employment with the Department
by the submission of supplementary
sta-tem,ents.
Cb) The provisions of §§ 0.735-503,
0.735-504, 0.735-506, and 0.735--=001 are
applicable to a special GovemmJlht employee who is required to file a statement.
ROBERT
C.
WEAVER,
Secretary of Housing and
Urban Development.
APPENDIX-LIST OF POSITION S SUBJECT TO
SUBPART E
OFFICE OF T HE SECRETARY
Deputy Director, Northwest Operations·.
Regional Counsel.
Chief, Rea l Estate Disposition, Division of
Urba n Renewal.
CJiiet, Rea l Esta t e Acquisition, Division of
Urba n Renewal.
ASSISTANT SECRETARY FOR MORTGAGE CREDIT
A:i,JD F EDERAL HOUSING COM MISSIONER
Federal Hou si n g Admi n is tration
Departmental:
Director of Complia nce Coordina tion.
Director of Examination a nd Audit.
Director, Audit Division.
Director, Division of Genera l Services.
Deputy . Director, DI vision of General
Services.
Chief, Procurement a nd Property Section,
Division of Genera l Services.
Director, Community Disposition Staff.
Deputy Director, Community Disposition
Staff .
Fleid -Office Director, Community Disposition Staff.
Seici:
.
Multifa mily Housing Representf!ti~.
Director, Insuring Office.
Deputy Director, .Insuring Office.
Assistant Director (Chief of Opera tions)-.
Chief Underwriter.
Sta te Director (New York).
Assistant State Dlrec:tor.
F ederal N_aticmal M ortgage Association
Departmental :
Vice President.
Loan Ma n a ger.
Secretary- Treasurer.
Controller.
Director of Exa mina tion a nd Audit.
Field :
Agency Ma n ager.
Assista nt Agency Man a ger.
ASS I S TANT SECRETARY FOR METROPOLIT AN
DE VELOPMENT
Departmental:
Departmental:
_
Administrative Assistant ~ tl;le ~ Director, Urban
Planning Assistance
Dlrector, Low-Jnc~q,,11ow1n11, Dffi'fl!ltt'a-· Bra nch, Office of Pla nning Standards and
tlon Staff, Office 9! ptog:r,m Polfcy.
Coordina tion.
Director , Dlvisic:q at Research DevelopDirector, Division of Aca d emic Facilities,
ment, Office of Program Policy.
Office of T echnica l Services.
'
'Director, Eq'Ual Opportunity Standard s a nd
La nd and Facilities Development Adm,...ils Regulations Staff .
t ration:
Deputy Director, Compliance Divis ion.
Director, Division of Senior Citizens HoueField Sup ervisory I n vestigators, Complia n ce
lng.
Division.
Director, Division of Public F acilities
Director, Audit D ivision, Office of AdminisGrants.
tration.
Direc t or, Division of Public Fac111tles
Deputy .Director, Audit Division, Office of
Loans.
Administration.
Dlr.ector, Division of Land Development.
Field Supervisory Auditors, Audit Division,
Director, Division of College Housing.
Office of Adm).nistratlon.
Director, Fin ance Standard s Sta ff .
'D irector, n t'illslon of F inan ce and Accounts,
Deputy Director, Finance Stand ards Staff .
Office of Admlnishation. ·
Urban Tra n spor t ation Admlnlst ra tlon :
Dep uty Director, Division of F ina n ce and
Positions a t GS-15 .
Accounts, Office of Ad ministration.
Director, Division of Gen eral Services, Office
URBAN REN E WAL ADM INISTRATION
of Admlnls.tratlon.
Departm en tal :
Director, Property Managemen t and ProDirector , Demonstr ation P rogra m Branch .
curement Branch, Division of Gener a l ServDeput y Assistan t Comm issioner , Reh a biliices, Office of Administration.
t
a
tion a nd Codes.
Field:
PUBLIC HOUSING ADMIN I S TRATION
Deputy, Regional Administrator.
, Reglonai Director of Administration.
D ep artmen tal :
Director, Division of Communit y F ac111tles.
Director , Office Ser vices Branch .
Deputy Director, Division of Commu nity
Financin g Officer.
FacU!tles/
.l"!eld :
Director, Division of Urban Renewal.
Regional Director.
DeRuty_ Director, Division of Urban Re[F .R. Doc. 66---6930; F iled , J une 23, 1966;
newat,
8 :48 a .m .J
Director, Northwest Opera tlons .
5
U. S. GOVERNMENT PRINTING OFF ICE : 1966 0-223-092
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              <text>DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Reprinted from Federal Register - 31 F.R. p 8781-85

June 24,

Title 24—HOUSING AND HOUSING
CREDIT

Subtitle A—Office of the Secretary,
Department of Housing and Urban
Development

PART O—STANDARDS OF CONDUCT

Pursuant to and in accordance with
sections 201 through 209 of Title 18 of
the United States Code, Executive Order
11222 of May 8, 1965 (30 F.R. 6469), and
Title 5, Chapter I, Part 735 of the Code
of Federal Regulations, Part 0 is added
to Subtitle A of Title 24 of the Code of
Federal Regulations, reading as follows:

Subpart A—Ger=rol Provisions

Purpose.

Definitions.

Interpretation and advisory serv-
ice.

Notification to employees and
special Government employees.

Remedial action.

Interest of employee's or special
Government employee's rela-
tives.

Subpart B—Conduct and Responsibilities of
Employees

Basic principle.

Gifts, entertainment, and favors.

Outside activity.

Financial interests.

Personal real estate transactions.

Use of inside information.

Intermediaries and product rec-
ommendations.

Membership in organizations.

Use of Government property.

Indebtedness.

Gambling, betting, and lotteries.

General conduct; and conduct
prejudicial to the Government,

Subpart C—Conduct and Responsibilities of _
Special Government Employees

0.725-301 Use of Government employment.
0.735-302 Use of inside information.
0.735-303 Coercion,

0.735-304 Gifts, entertainment, and favors.
0.735-305 Applicability of other provisions.

Sec,

0.735-101
0.735-102
0.735-103

0.735-104

0.735-105
0.735-106

0.735—201
0.735-202
0.785-203
0.735-204
0.735-205
0.735-206
0.735-207

0.735-208
0.735—-209
0.735—210
0.735—-211
0.735-212

Subpart D—Miscellaneous Statutory Provisions
0.735-401 Applicable statutory provisions.

Subpart E—Statements of Employment and
Financial Interests

Submission of statements,

Supplementary statements.

Information not known by em-
ployees.

Information prohibited.

Review of statements.

Confidentiality of statements,

Effect of employee’s statements
on other requirements.

Specific provisions for special
Government employees.
Appendiz—List of Positions Subject to

Subpart E.

0.735501
0.735—502
0.735-503

0.735-504
0.735-505
0.735—506
0.735-507

0.735-508

1966

Avurnoniry: The provisions of this Part 0
issued under E.O. 11222 of May 8, 1965, 39
F.R. 6469, 3 CFR, 1965 Supp.; 5 CFR 735. 10%,

Subpart A—General Provisions
§ 0.735-101 Purpose.

The maintenance of unusually high
standards of honesty, integrity, impar-
tiality, and conduct by Government em-
ployees and special Government em-
ployees is essential to assure the proper
performance of the Government business
and the maintenance of public confi-
dence. The avoidance of misconduct
and conflicts of interest on the part of
Government employees and special Gov-
ernment employees through informed
judgment is indispensable to the main-
tenance of these standards. To accord
with these concepts, this part sets forth
the Department’s regulations prescrib-
ing standards of conduct and responsi-
bilities, and governing statements of
employment and financial interests for
employees and special Government
employees.

§ 0.735-102 Definitions.

(a) “Department” means the Depart-
ment of Housing and Urban Develop-
ment.

(b) “Employee” means an officer or
employee of the Department, but does
not include a special Government em-
ployee.

(ec) “Special Government employee”
means an officer or employee of the De-
partment appointed to serve with or
without compensation, for not more than
130 consecutve days during any period of
365 days, on a full-time, part-time, or
intermittent basis, and who is retained,
designated, appointed, or employed as a
special Government employee under the
provisions of section 202 of Title 18 of
the United States Code.

(d) “Person” means an individual, a
corporation, a company, an association,
a firm, a partnership, a society, a joint
stock company, or any other organiza-
tion or institution.

(e) “Outside employment” means all
gainful employment other than the per-
formance. of official duties. It includes,
but is not limited to, working for another
employer, the management or operation
of a private business for profit (includ-
ing personally owned businesses, partner-
ships, corporations, and other business
entities), and other self-employment.

§ 0.735-103 Interpretation and advisory
service.

(a) Department counselor. The Gen-
eral Counsel is designated Counselor for
the Department and shall serve as the
Department's designee to the Civil Serv-
ice Commission on matters covered by

this part. He shall be responsible for
coordinating the Department’s counsel-
ing services and for assuring that coun-
seling and interpretations on questions
of conflicts of interest and other matters
covered by this part are available to des-
ignated deputy counselors. He may
form ad hoc committees to evaluate the
effectiveness of the standards, or to con-
sider any new or unusual question aris-
ing from their application.

(b) Depyty counselors. Such depyty
counselors as,may be required. shall be
designated to give authoritative advice
and guidance to current and prospective
employees and special Government em-
ployees on questions of conflicts of-inter-
est ey on other matters covered by this
part.

§ 0.735-104 Notification to employees
atid. special Government employees.

The provisions of this part and all re-
visions thereof shall be brought to the
attention of and made available to:

(a) Each employee and special Gov-
ernment employee at the time of issu-
ance and at least annually thereafter;

(b) Each new employee and special
Government employee at the time of em-
ployment.

§ 0.735-105 Remedial action.

A violation of this part by an employee
or special Government employee may be
cause for remedial or disciplinary action.
Such action may include, but is not lim-
ited to:

(a) Changes in assigned duties;

(b) Divestment by the employee or
special Government employee of his con-
flicting interest;

(c) Disciplinary action, including
separation, which may be in addition to
any penalty prescribed by law; or

(d) Disqualification for a particular
assignment.

Remedial action, whether disciplinary or
otherwise, shall be effected in accordance
with any applicable laws, Executive or-
ders, and regulations.

§ 0.735-106 Interests of employee's or
special Government employee’s rela-
tives.

For the purposes of this part, the in-
terest of a spouse, minor child, or a blood
relative who is a full-time resident of an
employee's or special Government em-
Dloyee’s immediate household is consid-
ered to be an interest of the employee or
eminence rane tamplopecs . Gili «
Subpart B—Copduct and Responsibil-
ities of Employees
§ 6735-201 Basie‘principle.

(a) Each employee must realize that
the--Government’s basic and controlling
purpose in employing him is the public
interest, rather than his private or per-
sonal interest, and that he can never
have a right of tenure that transcends
the public good. He can properly be a
Government employee only as long as it
remains in the public interest for him
to be one. Public trust and confidence
in the integrity of the Government are
paramount.

(b) (1) This basic principle applies
with special force and effect in the De-
partment of Housing and Urban Develop-
ment, which deals directly with impor-
tant segments of the public, and whose
success depends upon public trust and
confidence in its actions. The official
actions of the Department often-have a
direct bearing upon the financial and
other interests of individuals, firms, and
institutions with which it does business.
Furthermore, the effective accomplish-
mient of the Department’s mNsion is sig-
nificantly dependefit upon a public image
that engenders confidence in the Depart-
ment’s integrity. Accordingly, the avoid-
ance of any involvement that tends to
damage that image is a responsibility of
exceptional importance for all employees
who participate in or influence official
operating determinations that affect the
interests of those with whom the Depart-
ment does business.

(2) If there is knowledge of an em-
ployee’s involvement in or association
with circumstances reasonably construed
to reduce public confidence in the acts
or determinations of the Department,
such knowledge may be sufficient cause
for the initiation of action adverse to
the employee. Employees, therefore, are
alerted to the gravity with avhich the
Department will view. any such involve-
ment, especially if it has to do with con-
flicts of interest or the compromise of
integrity—whether real or only apparent.

§ 0.735-202 Gifts, entertainment, and

favors.

(a) Except as provided in paragraph
(b) of this section, an employee shall not
solicit or accept, directly or indirectly,
any gift, gratuity, favor, entertainment,
loan, or any other thing of monetary
value, from a person who:

(1) Has, or is seeking to obtain, con-
tractual or other business or financial
relations with the Department; _

(2) Conducts operations or activities
that are regulated by the Department: or

(3) Has interests that may be substan-
tially affected by the performance or
nonperformance of the employee's official
duty.

(b) The prohibitions of paragraph (a)
of this section do not apply to:

(1) The acceptance of customary busi-
ness services from banks or other finan-
cial institutions if such services are ob-
tained under terms and conditions avail-
able to the general public;

(2) Obvious family or personal rela-
tionships, such as those between the em-
ployee. and his parents, children, or
spouse, when the circumstances make it
clear that it is those relationships rather
than:the business of the persons con-
cerned which are the motivating factors;

(3) The acceptance of food and re-
freshments of nominal value on infre-
quent occasions in the ordinary course of
a luncheon or dinner meeting or other
meeting or on an inspection tour where

an employee may properly be in attend- |

ance;

(4) The acceptance of unsolicited ad-
vertising or promotional material, such
as pens, pencils, note pads, calendars,
and other items of nominal intrinsic
value.

(c) An employee shall avoid any
action, whether or not specifically pro-
hibited by the regulations in this part,
which might result in, or create the ap-
pearance of:

(1) Using public office for private
gain;

(2) Giving preferential treatment to
any person;

(3) Impeding Government efficiency
or economy;

(4) Losing complete independence or
impartiality; or

(5) Making sa Government decision
outside official channels.

(d) An employee shall not solicit con-
tributions from another employee for a
gift, or make a donation as a gift, when
such gift is for an employee in a superior
official position. An employee in a su-
perior official position shall not accept
a gift presented as a contribution from
employees receiving less salary than
himself.

Ce) An employee shall not accept a
gift, present, decoration, or other thing
from a foreign government unless au-
thorized by law.

§ 0.735-203 Outside activity.

(a) An employee shall not engage in
outside employment or other outside ac-
tivity not compatible with the full and
proper discharge of his duties and re-
sponsibilities as an employee of the De-
partment. Incompatible activities in-
clude but are not limited to:

(1) Acceptance of a fee, compensa-
tion, gift, payment of expense, or any
other thing of monetary value in circum-
stances in which acceptance may result
in, or create the appearance of, a con-
flict of interest;

(2) Employment which tends to im-
pair his mental or physical capacity to
perform his official duties and responsi-
bilities in an acceptable manner;

(3) Activities that may be construed
by the public to be the official acts of the
Department; vi

(4) Activities that establish relation-
ships or property interests that may re-
sult in a confilct between his private in-
texests and his official duties; ang. ia 4t

2

, GS im ployment that,may involve he
use of information secured as a resuli.
of employment in the Department to
the detriment of the Department or the
public interest, or that may give prefer-

' ential treatment to any person, corpora-

-tion, public agericy, or group.

(b) An employee shall not receive any
salary or anything of monetary value
from a private source as compensation
for his services to the Government (18
U.S.C. 209). :

, (ce) Full-time employees and part-
time employees with a regularly sched-
uled tour of duty must obtain the prior
approval of a designated personnel officer
before engaging in outside employment
in the following categories:

‘(1) Employment related to or similar
to the substantive programs conducted
‘by any part of the Department. This
includes but is not limited to the broad
fields of real estate, mortgage lending,
property insurance, construction, con-
struction financing, and land and real
estate planning.

(2) Employment in the same profes-
sional field as that of the individual’s

official position.

(3) Employment with any person,

.firm, or other private organization hav-
ing business either directly or indirectly
with the Department.

(4) Employment by State, local, or
other governmental body.

(a) No full-time employee or part-
time employee with a regularly'scheduled
tour of duty shall maintain a publicly
listed place of business without the prior
approval of a designated personnel
officer.

(e) Except for employees subject to
the requirements of Subpart E of this
part, approvals required by paragraphs
(ec) and (d) of this section shall be
requested on Form HUD-—843, Request
for Authorization to Engage in Outside
Employment and/or Statement of Fi-
nancial Interests. All .pertinent facts
regarding the proposed employment,
such as the name of the employer, the
nature of the work to be performed, and
the amount of time involved, shall be
set forth.

(f) (1) Employees are encouraged to
engage in teaching, lecturing, and writ-
ing that is not prohibited by law, Ex-
ecutive order, or this part. However,
an employee shall not, either for or
without compensation, engage in teach-
ing, lecturing, or writing that is depend-
ent on.information obtained as a result
of his employment by the Department,
except when that information has been
made available to the general public or
will be made available on request, or
when the Secretary or his designee gives
written authorization for the use of non-
public information on the basis that the
use is in the public interest.

(2) An employee may use his name
and title in connection with articles for
publication which bear upon his work
in the Department only if he obtains
the approval of a designated personnel
officer.
(g) This section does not preclude an
employee from:

(1) Accepting bona fide reimburse-
ment, unless prohibited by law, for
actual expenses for travel and such other
necessary subsistence as is compatible
with this part for which no Government
payment or reimbursement is made.
However, an employee may not be re-
imbursed, and payment may not be made
on his behalf, for excessive personal
living expenses, gifts, entertainment or
other personal benefits.

(2) Participating in the affairs of or
accepting an award for a meritorious
public contribution or achievement given
by a charitable, religious, professional,
social, fraternal, nonprofit educational
and recreational, public service, or civic
organization.

(3) Participating in the activities of
National or State political parties not
proscribed by law.

§ 0.735-—204 Financial interests.

(a) An employee shall not:

(1) Have a direct or indirect financial
interest that conflicts, or appears to
conflict, with his official duties and re-
sponsibilities.

(2) Engage in, direetly or indirectly,
2, financial transaction as a result of, or
primarily relying on, information ob-
tained through his. employment by the
Department.

(3) Acquire securities issued by the
Federal National Mortgage Association.

(4) Acquire ownership of. stéck or
other interest in a rental project financed
with an FHA insured mortgage as long
as the insurance is in force.

(5) Acquire ownership of FHA deben-
tures or certificates:of claim.

(6) Acquire interest in a cooperative
or condominium housing project fi-
nanced under the National Housing Act
if the interest is not for obtaining a
home for himself or his family.

(7) Be an’ officer or director of any
organization which is an FHA approved
mortgagee or lending institution or which
services mortgages or other securities for
the Department. An employee may hold
stock or shares in such organizations
provided his official duties are such that
the holding will not create or tend to
create a conflict of interest. The prohi-
bitions of this paragraph do not apply
to Federal Credit Unions that have been
approved as Title I lending institutions.

(8) Participate directly or indirectly in
any real estate activities for speculative
purposes as distinguished from bona fide
investment purposes.

(b) This section does not preclude an
employee from having a financial inter-
est or engaging in financial transactions
to the same extent as a private citizen
not employed by the Department so long
as it is not prohibited by law, Executive
Order 11222, or this part.

§ 0.735-205 Personal real estate trans-

actions,

(a) Because the operations of the De-
partment are directly related to individ-
ual real estate transactions, all Depart-
ment employees must exercige the utmost
care in the. handling ef ‘Wey Dersonal

real estate activitits.“* teh
therefore report to a designated

nel officer the following types df Sera a
real estate transactions (if the transaé-
tidn involves FHA mdrtgage ingtrance,
the'report shall be filéd at the tine the
application for such insurance is filed;
other types of transactions Shall be re-
ported at the time of corisummation of
the transaction) :

(1) Any purchase or sale of real prop-
erty in which an employee has an
interest.

(2) Any Title I property improvement
loan obtained by the employee or in
which he has a financial interest. In
such case the employee must report the
name of the lending institution and a
description of the improvements being
financed.

(3). Any interest in a cooperative or
condominium housing project financed
under the National Housing. Act if it
involves a home for himself orhis family.

(b) In addition to the reporting. re-
quirements of paragraph (a) of this sees
tion, employees shall. report jall rea}
estate holdings other than those held as
personal residences.

(c) Except for employees subject to
the requirements of Subpart E of this
part, reports required by paragraphs
(a) and (b) ‘of this section shall be filed
on Form HUD-843, Request for Authori-
zation to Engage in Outside Employment
and/or Statement of Fmancial Interests.

§ 0:735-206 Use of intide informwnation.

“ Excépt as provided ip §°0.735-203(f),
no employee shall give or’‘use inside in-
formation acquired by means of his posia
tien to advance any private interest,
particularly the private interests of him-
self, his family, associates, or friends.
For the purpose of this section “inside
information” means information ob-
tained under Government authority but
which has not become part of the body of
public information.

§ 0.735-207 Intermediaries and product
recommendations,

No employee shall recommend or sug-
gest the use of any particular or identi-
fied nongovernmental intermediary to
deal with the Department nor shall he
recommend any device or product tested
by or for, or used by, the Department,
except as required by his official duties.

§ 0.735-208 Membership in organiza-
lions.

(a) An employee may not, in his offi-
cial capacity as an officer or employee of
the Department, serve as a member of
a non-Federal or private organization
except where express statutory authority
exists, or statutory language necessarily
implies such authority. However, ‘an
employee may serve in an individual ca-
pacity as a member of a non-Federal or
private organization, provided that:

(1) His membership does not violate
the restrictions noted in § 0.735-203; and

(2) His official title or organization
connection is not shown on any listing
or presented in any activity of the orga-
nization in such a manner as to imply
taat he is acting in, his official capacity,

(b), -An.emplqyee may be designated to
serve as a liaison representative of the
Department to a non-Federal or private
organization provided that:

(1) The activity relates to the work 6f
the Department. ;

(2) The employee does not participate
by vote in the policy determinations of
the organization.

(3) The Department is in no way
bound by any vote or action takén by the
organization.

§ 0.735-209 Use of Government prop-
erty.

An employee shall not directly or in-
directly use, or allow the use of Depart-
ment property of any kind, including
property leased to the Department, for
other than officially approved activities.
An employee has a positive duty to pro-
tect and conserve Government property,
including equipment, supplies, and other
property entrusted or issued to him,

§ 0.735-210 ‘Indebtedness.

An employee shall pay each just finan-
cial obligation in a proper and timely
manner, especially one imposed by law,
such as Federal, State, and local taxes.
For the purpose of this section, “just fi-
nancial obligation’’ means one acknowl-
edged by the employee or reduced to
judgment by a court, and “in a proper
and timely manner” means in a manner
which the Department determines does
not, under the circumstances, reflect ad-
verselyiom tha.@overnment as his. an-
Pioyer. fInhthe event of a dispute be-
tween amemptoyee and an alleged credi-
tor, this seetion dpes. not require the
Department to determine the walidity or
the. amount of the disputed dabt.

§ 0.735-211 Gambling, betting, and lot-

teries.

An employee shall not participate,
while on Government-owned or leased
property or while on duty for the Depart-
ment, in any gambling activity includ-
ing the operation of a gambling device, in
conducting a lottery or pool, in a game
for money or property, or in selling or
purchasing a number slip or ticket.

§ 0.735-212 General conduct; and con-
duct prejudicial to the Government,

(a) Each employee shall conduct him-
self in a manner that facilitates the ef-,
fective accomplishment of the work of
the Department, observing at all times
the requirements of courtesy, considera-
tion, and promptness in dealing with the
public and with persons or firms having
business with the Department;

(b) An employee shall not engage in
criminal, infamous, dishonest, immoral,
or notoriously disgraceful conduct, or
gener conduct prejudicial to the Govern-
ment,

Subpart C—Conduct and Responsibil-
ities of Special Government Em-
ployees

§ 0.735301

ployment.

A special Government employee shall
not use his Government employmensise®

Use of Covernment em-
a@ purpose that is, or gives the appear-
ance of being, motivated by the desire for
private gain for himself or another per-
son, particularly one with whom he has
family, business, or financial ties.

§ 0.735-302 Use of inside information.

(a) A special Government employee
shall not use inside information obtained
as a result of his Government employ-
ment for private gain for himself or
another person either by direct action on
his part or by counsel, recommendation,
or suggestion to another person, particu-
larly one with whom he has family, busi-
ness, or financial ties. For the purpose
of this section, “inside information”
means information obtained under Gov-
ernment authority which has not become
part of the body of public information.

(b) Special Government employees
may teach, lecture, or write in a manner
cons sient with the provisions of § 0.735-
203(f).

§ 0.735-303 Coercion.

A special Government employee shall
not use his Government employment to
coerce, or give the appearance of
coercing, a person to provide financial
benefit to himself or another person,
particularly one with whom he has
family, business, or financial ties.

§ 0.735-304 Gifts, entertainment, and
favors.

(a) Except as provided in paragraph
(b) of this section, a special Government
employee, while so employed or in con-
nection with his employment, shall not
receive or solicit from a person having
‘business with the Department anything
of monetary value as a gift, gratuity,
loan, entertainment, or favor for himself
or another person, particularly one with
whom he has family, business, or
financial ties.

(b) The exceptions of § 0.735-202(b),
which are applicable to employees, are
also applicable to special Government
employees.

§ 0.735-305 Applicability of other pro-
visions.

(a) Each special Government em-
ploye? is subject to the provisions of
§§ 0.735-201, 0.735—-208 through 0.735—212,
and 0.735-508.

(b) Each special Government em-
ployee shall acquaint himself with each
statute listed in Subpart D of this part.

Subpart D—Miscellaneous Statutory
Provisions

§ 0.735-401 Applicable statutory provi-
sions.

Each employee shall acquaint himself
with each statute that relates to his
ethical and other conduct as an employee
of the Department and of the Govern-
ment. The attention of each employee
is directed to the following statutory
provisions:

(a) House Concurrent Resolution 175,
85th Congress, 2d Session, 72 Stat. B12,
the “Code of Ethics for Government
Service”.

(b) Chapter 11 of Title 18, United
States Code, relating to bribery, graft,

and conflicts of interest, as appropriate
to the employees concerned.

(c) The prohibition against lobbying
with appropriated funds (18 U.S.C. 1913).

(d) The prohibitions against disloyal-
ty and striking (5 U.S.C. 118p, 118r).

(e) The prohibition against the em-
ployment of a member of a Communist
organization (50 U.S.C. 784).

({) The prohibitions against (1) the
disclosure of classified information (18
U.S.C. 798, 50 U.S.C. 783); and (2) the
disclosure of confidential information
(18 U.S.C. 1905).

(¢) The provision relating to the
habitual use of intoxicants to excess (5
U.S.C 640).

(h) The prohibition against the mis-
use of a Government vehicle (5 U.S.C.
T8(c)).

(i) The prohibition against the mis-
use of the franking privilege (18 U.S.C.
1719).

(j) The prohibition against the use of
deceit in an examination or personnel
action in connection with Government
employment (5 U.S.C. 637).

(k) The prohibition against fraud or
false statements in a Government matter
(18 U.S.C. 1001).

(1) The prohibition against mutilat-
ing or destroying a public record (18
U.S.C. 2071). ‘

(m) The prohibition against counter-
feiting and forging transportation re-
quests (18 U.S.C. 508).

(n) The prohibitions against (1) em-
bezzlement of Government money or
property (18 U.S.C. 641); (2) failing to
account for public money (18 U.S.C.
643); and (3) embezzlement of the
money or, property of another person in
the possession of an employee by reason
of his employment (18 U.S.C. 654).

(o) The prohibition against unauthor-
ized use of documents relating to claims
from or by the Government (18 U.S.C.
285).

(p) The prohibition against pro-
scribed political activities—The Hatch
Act (5 U.S.C. 118i), and 18 U.S.C. 602,
603, 607, and 608.

Subpart E—Staftements of Employ-
ment and Financial Interests

§ 0.735-501 Submission of statements,

(a) Not later than 90 days after the
effective date of this part, each employee
occupying a position designated in the
Appendix shall submit to the reviewing
official specified in § 0.735-505, Form
HUD-844, Statement of Employment and
Financial Interests.

(b) Each employee who enters on duty
after the effective date of this part in a
position designated in the Appendix shall
submit to the reviewing official specified
in § 0.735-505 a statement not later than
30 days after his entrance on duty or
90 days after the effective date of this
part, whichever is later.

(ec) Additions to, deletions from, and
other amendments of the list of positions
in the Appendix may be made from time
to time as necessary to carry out the
purpose of the law, Executive Order
11222, and Part 735 of the Civil Service

4

Commission Regulations (5 CFR Part
735). Such amendments are effective
upon actual notification to the incum-
bents. The amended list shall be sub-
mitted at least annually for publication
in the FEDERAL REGISTER.

§ 0.735-502 Supplementary statements.

(a) Changes in, or additions to, the
information contained in an employee’s
statement shall be reported to the appro-
priate reviewing official in a supplemen-
tary statement at the end of the quarter
in which the change occurs. Interim
memoranda reports shall be filed if re-
quired to meet the prior approval provi-
sions of § 0.735-203 (c) and (d), or the
requirements of § 0.735-205(a) concern-
ing the timely reporting of real estate
transactions. Financial interests or em-
ployment acquired during a quarter, but
disposed of or terminated before the end
of such quarter, shall constitute changes
or additions to be reported at the end
of such quarter. Quarters end March 31,
June 30, September 30, and December 31.
If there are no changes or additions in
a quarter, a negative report is not re-
quired. However, for the purpose of
annual review, a supplementary state-
ment, negative or otherwise, is required
as of June 30 of each year.

(b) A supplementary statement shall
be submitted on Form HUD~—844, and
shall be designated “Supplementary”.
A supplementary statement shall fur-
nish all information required by an initial
statement and by appropriate notation,
shall indicate any changes. in, or addi-
tions to the information set out in the
employee's initial statement or last sup-
plementary statement.

§ 0.735-503 Information not known by
employees.

If any information required to be in-
cluded on a statement or supplementary
statement, including holdings placed in
trust, is not known to the employee but
is known to another person, the em-
ployee shall request that other person
to submit information in his behalf.

§ 0.735-504 Information prohibited.

This subpart does not require an em-
ployee to report information relating to
his connection with, or interest in, a
professional society or a charitable, reli-
gious, social, fraternal, recreational, pub-
lic service, civic, or political organization
or a similar organization not conducted
as a business enterprise. For the pur-
pose of this section, educational and
other institutions doing research and de-
velopment or related work involving
grants of money from or contracts with
the Government are deemed “business
enterprises” and are required to be in-
cluded in an employee's statement.

§ 0.735-505 Review of statements.

(a) Employees reporting directly to
the Secretary shall submit their state-
ments directly to the Secretary for re-
view; employees reporting directly to
the Under Secretary shall submit their
statements directly to the Under Secre-
tary for review.

(b) Employees reporting directly to
Assistant Secretaries shall submit their
statements directly to the apenoprge
Assistant Secretary for review; employges
reporting directly to the General Counse
shall submit their statements directly
the General Counsel for revigw. —

(c) Employees not included, in para-
graph (a) or (b) of this section shall
submit their statements directly to the
appropriate Deputy Counselor.

(d) When a statement submitted un-
der paragraph (b) or (c) of this section,
or information from other sources, indi-
cates a conflict between the interest of
an employee and the performance of his
official duties, and when the conflict or
appearance of conflict cannot be resolved
by the reviewing official, he shall report
the information concerning the conflict
or appearance of conflict to the Secre-
tary through the Counselor. The em-
ployee concerned shall be given an op-
portunity to explain the conflict or
appearance of conflict before amy re-
quired remedial action is initiated.

§ 0.735-506 Confidentiality of. state-

ments.

After the review process has been com-
pleted, the statements submitted under
§ 0.735-505 shall be promptly forwarded
to the personnel office having eusony, of
the employee's official personnel /file.
The statements shall be held in ¢on-
fidente and rétained: in? limited access
files. Information from a statement
may not be disclosed except as the Secre-
tary or his designee, or the Civil Service
Commission may determine for good
cause shown.

§ 0.735-507 Effect of employee's state-
ments on other requirements.

The statements and supplementary
statements reauired of employees are in
addition to, and not in substitution for,
or in derogation of, any similar reauire-
ment imposed by law, order, or regula-
tion. The submission of a statement or
supplementary statement by an employee
does not permit him or any other person
to participate in a matter in which his
or the other person's participation is
prohibited by law, order or regulation.

§ 0:735—-508 Specific provisions for spe-
cial Government employees.

(a) Except as provided in paragraph
(c) of this section, each special Govern-
ment employee shall submit to: the re-
viewing official specified in § 0.735-505,
Form HUD-844-A, Statement of Employ-
ment and Financial Interésts, not later
than the time of his employment. He
shall keep his statement current through-
out his employment with the Department
by the peas of supplementary

ents.

(b) The provisions of §§ 0.735—503,
0.735-504, 0.735-506, and 0.735-507 are
applicable to a special Government ém-
ployee who is reauired to file a statement.

(c) The Secretary or his designee may
waive the provisions of this section in the
case of a special Government employee
who is not a consultant or an expert when
it is determined that the dutieg of the
position held by the special Govérnment
employee are of a nature and at such
level of responsibility that the submis-
sion of a statement is not necessary to
protect the integrity of the Government.
For the purpose of this-paragrapi® “én
sultant” and “expert” have the meanings
given those terms by Chapter 304 of the
Federal Personnel Manual.

This part was approved by the Civil
Service Commission on May 17, 1966.

Effective date. This part shall be
effective as of June 24, 1966.

RoserT C. WEAVER,
Secretary of Housing and
Urban Development.

APPENDIX—LIsT oF PosITIons SUBJECT TO
Suppart E

Officers and employees in the following
positions are subject to the provisions of
Subpart E of this part:

(a) Employees paid at a level of the Federal
Executive Salary Schedule established by the
Federal Executive Salary Act of 1964, as
amended, except the Secretary, who is sub-
ject to separate reporting requirements under
section 401 of Executive Order 11222;

(b) Employees in grade GS-16 or above of
the General Schedule established by the
Classification Act of 1949, ag amended, or in
comparable or higher positions not subject to
that Act; and

(c) Employees in the following positions:

OFFICE OF THE SECRETARY

Departmental:

Administrative Assistant te the Seoretary.

Director, Low-Incomg Mowing Demepetta-
tion Staff, Office 9f Program Poljcy.

Director, Division of Research Dévelop-
ment, Office of Program Policy.

Director, Equal Opportunity Standards and
Regulations Staff.

Deputy Director, Compliance Division,

Field Supervisory Investigators, Compliance
Division.

Director, Audit Division, Office of Adminis-
tration.

Deputy Director, Audit Division, Office of
Administration.

Field Supervisory Auditors, Audit Division,
Office of Administration.

Director, Division of Finance and Accotints,
Office of Administration.

Deputy Director, Division of Finance and
Accounts, Office of Administration.

Director, Division of General Services, Office
of Administration.

Director, Property Management and Pro-
curement Branch, Division of General Serv-
ices, Office of Administration.

Field:

Deputy Regional Administrator,

, Regional Director of Administration.
Director, Division of Community Facilities.
Deputy Director, Division of Community

Facilitiesi

Director, Division of Urban Renewal.

Deputy. Director, Division of Urban Re-
newal,

Director, Northwest Operations.

 

Deputy Director, Northwest Operations.

Regional Counsel.

Chief, Real Estate Disposition, Division of
Urban Renewal.

Chief, Real Estate Acquisition, Division of
Urban Renewal.

ASSISTANT SECRETARY FOR MORTGAGE CREDIT
AND FEDERAL HOUSING COMMISSIONER

Federal Housing Administration

Departmental:
Director of Compliance Coordination.
Director of Examination and Audit.
Director, Audit Division.
Director, Division of General Services.
Deputy .Director, Division of General
Services.
Chief, Procurement and Property Section,
Division of General Services.
Director, Community Disposition Staff.
é Deputy Director, Community Disposition
taf.

Field Office Director, Community Disposi-
tion Staff.

Bield: :

Multifamily Housing Representatiyp.

Director, Insuring Office.

Deputy Director, Insuring Office.

Assistant Director (Chief of Operations).

Chief Underwriter.

State Director (New York).

Assistant State Director.

Federal National Mortgage Association

Departmental:

Vice President.

Loan Manager.
Secretary-Treasurer.

Controller.

Director of Examination and Audit.
Field:

Agency Manager.

Assistant Agency Manager.

ASSISTANT SECRETARY FOR METROPOLITAN
DEVELOPMENT

Departmental:

Director, Urban Planning Assistance
Branch, Office of Planning Standards and
Coordination.

Director, Division of Academic Faci"ties,
Office of Technical Services.

Land and Facilities Development Admuuais-
tration:

Director, Division of Senior Citizens Hous-
ing.

Director, Division of Public Facilities
Grants.

Director, Division of Public Facilities
Loans,

Director, Division of Land Development.

Director, Division of College Housing.

Director, Finance Standards Staff.

Deputy Director, Finance Standards Staff.

Urban Transportation Administration:

Positions at GS-15.

URBAN RENEWAL ADMINISTRATION

Departmental:

Director, Demonstration Program Branch.

Deputy Assistant Commissioner, Rehabili-
tation and Codes.

PUBLIC HOUSING ADMINISTRATION

Departmental:

Director, Office Services Branch.
Financing Officer.

Field:

Regional Director.

{F.R. Doc. 66-6930; Filed, June 23, 1966;
8:48 a.m.]

U.S. GOVERNMENT PRINTING OFFICE : 1966 0—223-092
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                    <text>DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
66-77
June 27, 1966
STAND.ARDS OF CONDUCT
Several days ago you
Standards of Conduct
Reg ister on June 24,
It is important that
become familiar with
received summary informat i on on the Department's revi sed
regulatj_ons. The ret;ulatj_ons were published in the Federal
and are reproduced in the i r ent i rety in the att achment.
each employee carefully read all of the re5ulat ions and
them.
Informat i on concernj_ng reporting procedures and ot her i:mplementine; i nst ructions,
i ncluding the designation of Deputy Counselors, will be issued shortly. In
the meantime employees should give particular attent i on to the provisions of
Sections 0.735-203 through 0,735-205, and be prepared t o file a report on any
outside employment or other outside activity that requires author i zat i on, or
financ i al or other :Lnterest that i s subject to disclosure. Unless you are
occupy i ng a position subject to the provi si ons . of Subpart E of the regul at i ons,
a report will be required upon rece i pt of implement i ng instructions if you - are engaged i n any outside employment or other outside act j_v i ty that
i s subject to the prior approval provisions of Sect j_on o. 735-203( c)
and (d), and such act i vity has not been reported previ ously.
- have any unreported financial or other interests that are subject to the
disclosure requi rements of Secti on O. 735-205(a).
Employees subject to Subpart E will be given special i nstructions concerning
t he f iling of the statements of employment and financ i al j_nterests required by
o. 735-501.
If an employee ( i nclud i ng an e mployee subject to Subpart E) is engag ed i n any
outside employment or other outside act i vity or has a financial or othe r
i.nterest that now i.s prohi bited by Sect j_ ons 0,735-203(a ) and (b) and 0,735-204(aY,
and he cannot or doe s not termi nate such act i vi ty or interest by August 1, 1966,
a report on or before that date i s required, desc r ibing the steps that he ha s
taken t o conf orm with the referenced ·sections.
The attent i on of all employee s i s called to Sect i on 0.735-106, whic h provide s
that t he i nter e st of a spouse, minor child, or a blood relative who is a fulltime re sident of an employee's i mmed i ate househol d i s c ons id ered to be an
i nterest of t he employee .
Attachment
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              <text> 

 

 

 

 

 

 

 

 

 

 

 

Se staff BULLETIN

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

 

 

 

66-77 June 27, 1966
STANDARDS OF CONDUCT

Several days ago you received summary information on the Department's revised
Standards of Conduct regulations. The regulations were published in the Federal
Register on June 2, and are reproduced in their entirety in the attachment.

% is important that each employee carefully read all of the regulations and
become familiar with them.

Information concerning reporting procedures and other implementing instructions,
including the designation of Deputy Counselors, will be issued shortly. In

the meantime employees should give particular attention to the provisions of
Sections 0.735-203 through 0.735-205, and be prepared to file a report on any
outside employment or other outside activity that requires authorization, or
financial or other interest that is subject to disclosure. Unless you are
occupying a position subject to the provisions of Subpart E of the regulations,
a report will be required upon receipt of implementing instructions if you -

- are engaged in any outside employment or other outside activity that
is subject to the prior approval provisions of Section 0.735-203(c)
and (d), and such activity has not been reported previously.

- have any unreported financial or other interests that are subject to the
disclosure requirements of Section 0.735-205(a).

Employees subject to Subpart E will be given special instructions concerning
the filing of the statements of employment and financial interests required by

0.735-501.

If an employee (including an employee subject to Subpart E) is engaged in any
outside employment or other outside activity or has a financial or other .
interest that now is prohibited by Sections 0.735-203(a) and (b) and 0.735-20hk(a),
and he cannot or does not terminate such activity or interest by August 1, 1966,

a report on or before that date is required, describing the steps that he has
taken to conform with the referenced ‘sections.

The attention of all employees is called to Section 0.735-106, which provides
that the interest of a spouse, minor child, or a blood relative who is a full-
time resident of an employee's immediate household is considered to be an
interest of the employee.

Attachment
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                    <text>ATLANTA , GEORGIA
PH ON E JA. 2•4463
Ivan All e n ,
Jr. , Mayo r
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                    <text>ATLANTA,GEORGIA
PHONE JA. 2•4463
Ivan All en , Jr. , Mayor
Bttadd
lo.di, f tJ/4
j)~u-z
4ri
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              <text>ATLANTA, GEORGIA

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ATLANTA,GEORGIA

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Ivan Allen, Jr., Mayor
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                    <text>UP" EST OC 25 66


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MCINOMBU IYM ALLEK, MAYOR
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                    <text>HUD-28
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
(11 -65)
TRANSMITTAL SLIP
NAME
ROUTE TO:
ROOM


1.
BUILDI NG
Mr. Allen
2.
3.
4.
5.
6.
0
Action
D
As requl)8ted
0
Sunlmne
D
Approval
D
Signalnrc
D
Your information
0
Prepare reply for signature of
REMARKS:
Attached is the travel voucher for your
trip to Washington 10/28 .
Please sign,
retain your carbon and return the origi nal
t o me.
Also att ached is a per diem claim s heet on
which you may record any time devoted to this
assignment duri ng the period 11/6- 19.
I hope the personne 1 d ocument s arrived on schedu=e.
FROM (Name)
Mary Re Carlsen
.
FPI- LK- 3-22-66- 9M P ads-6007
I
DATE
11/11
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

HUD-28
(11-65)

 

 

 

 

 

 

 

 

 

 

 

TRANSMITTAL SLIP
ROUTE TO: NAME ROOM BUILDING
iL
Mr, Allen

2.
3.
4.
5.
6.

| Action (i) As requested (ma Surname

UJ Approval O Signature CJ Your information

LJ Prepare reply for signature of

 

 

REMARKS:

Attached is the travel voucher for your

trip to Washington 10/28. Please sign,

retain your carbon and return the original

to mee

Also attached is a per diem claim sheet on

which you may record any time devoted to this

assignment during the period 11/6-19.

I hope the personnel documents arrived on schedu]

 

 

FROM (Name)

Mary Ro Carlsen

 

DATE

ley elt

 

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FPI--LK—3-22-66—9M Pads—6007
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To:
ArDEE AMES
Members of Task Force
For your infonnation there
are further clippings on
the UDC proposal.
1/9/67
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To:

ArDEE AMES

Members of Task Force

For your information there
are further clippings on

the UDC proposal.

1/9/67
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                    <text>@l f l b d ~ ~ ~



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ATLANTA,GEORGOA
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                    <text>TELEPHONE
MESSAGE
/
To _ _~-~
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'--__,._-y"'--"___
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-\ +---Telephone No._ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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Wants you to call
Returned your call
Left the following message:








Is here to s ee you
Came by to see you
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Da te :_ __ __ _
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By---- - - -- - - - - - - - - - -- - - -F0RM 25•5
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              <text>Office of the’ Mayor

TELEPHONE MESSAGE

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To et BL 3k

Name

+ L| a nd ~

 

Telephone No.

 

[_] Wants you to call [_] Is here to see you
[_] Returned your call [_] Came by to see you

[_] Left the following message:

 

2 4p Bec’

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Date: Time

By

a.m. /p.m.

 

FORM 25-5
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                    <text>_UNION .
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COVT PP VUX TK[ Rlff ROUSE V.ASKINGTOff DC 3 NJT
ROKOP.ABLE lV'Ml ALt.EN, MAYOR OF A1'LAHTA
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ATLANTA '"
PLEASJ: CORFIR.M YOUR ATTENDAl'fCt AT TAS?: FORCE MaTlll~S ON 'ff.BRUARY
9 l 10. dJtsTS VILL JNCLJ.n}E FRAlllt RtCSSMAN N'V c;ARTH. KAN&lt;:UM
__ AS VELL ltS REPR.ESDITATiffS Of T1I'£' COUNCIL ECOIIOMlC ADVISERS
AND OTHl:R AC:DfCIES. MI:EnHc 'l:IEC:tlfS te-ioo A.N., Ollf TJn:JRS!&gt;AT
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