U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

WASHINGTON, DC: 20410-0500

JUL 2 9 2003

MEMORANDUM FOR: Carolyn L. Federoff, President, National Council of HUD Local, 222

THRU: Priscilla A. Lewis, Chief, Labor Relations Branch, ARHLL

FROM: Richard A. Hauser, General Counsel, C

SUBJECT: Realignment of the Office of General Counsel /Departmental Enforcement Center

The purpose of this memorandum is to notify the union of the next phase of the Office of General Counsel/Departmental Enforcement Center realignment. This proposed realignment will reassign the Departmental Enforcement Center (DEC) Satellite Office attorneys, now located in the five DEC Satellite Offices, to Regional Counsel Offices in the jurisdictions where they are located, and will consolidate all OGC/DEC headquarters administrative functions. Consistent with the initiatives of this administration, these changes will lead toward the strengthening enforcement capability of the Department and streamline the operations of OGC/DEC. Specifics of the new organization follow.

The Office of Program Enforcement satellite attorneys who are now part of the Field structure of the DEC will be reassigned to their respective offices of the Regional Counsel in each of the five Regional offices (New York, Chicago, Atlanta, Ft. Worth, and San Francisco). Please note: the DEC Los Angeles Satellite Office of Counsel will report to the San Francisco Regional Counsel Office. The location and duty station of the staff will remain in Los Angeles.

An Associate Regional Counsel for Program Enforcement and Litigation (GS-15) will be established in Regions 1,111, and VII, (Boston, Philadelphia, and Kansas City),

The Headquarters administrative, information technology, and training staff in OGC and DEC will be consolidated.

The DEC Mortgagee Review Board staff now located in the DEC, will be reassigned to the Office of Housing, DAS for Single Family, Office of Lender Activities and Program Compliance, Mortgagee Review Board Division.

The FOIA Division will be realigned to the Office of Litigation.

The Departmental Enforcement Center will report to the Office of Deputy General Counsel

(General).

Additionally, there is a proposed internal redeployment of attorneys within the Office of Finance and Regulatory Enforcement, which will be renamed to the Office of Program Compliance. The purpose of this redeployment is to a) consolidate the regulatory enforcement functions of the office into a single division, b) give the attorneys the opportunity to develop broad enforcement expertise concerning a variety of statutes, and c) enable the staff to devote legal resources to the Healthy Homes and Lead Hazard control area, which has grown in recent years.

The proposed OGC/DEC realignment will not impact the number of FTEs. The Office of General Counsel has identified eight new Associate Regional Counsel positions at the GS-15 level that will be filled internally from existing FTEs. There is a potential need for an Operating Plan change related to the individuals who are changing program offices, which will be addressed in HUD's Operating Plan.

In accordance with Article 5, Section 5.04 (3) - Reorganization, the requested information is attached. I would appreciate your immediate attention to this proposal. If additional information is needed, please contact Sinthea Kelly, Director, Management and Administrative Services Staff, at 202-708-0290.

Attachments

Cc: Edward Eitches, President, HUD AFGE Local 476

Perry Casper, Portland, Oregon

James Lee, Richmond, Virginia

Marinella Murillo, San Antonio, Texas

Lisa Lowery, Knoxville, Tennessee

John Noyes, Minneapolis,. Minnesota

Cliff Barnhill, Vice President, AFGE Local. 222

Article 5, Section 5.04 - (3) Reorganizations

a. See attached `To and From List'

b. No impact upon upward mobility and/or career ladder positions.

c. See the attached 'To-From List'.

d. No impact upon employee's receipt of performance ratings,

e. No bargaining unit position descriptions have been changed.

f. No employees have been detailed due to proposed reorganization.

g. No new bargaining unit positions were created.

h. No employees will be downgraded or separated as a result of the proposed reorganization.

i. At this time, management has not planned any physical moves of staff.

j. Organization charts are attached.

Attachment 1