Dori Garmeiser

Overview

About Dori Garmeiser

“While HUD compliance is always desired, issues invariably arise and sometimes even lead to HUD enforcement, and it is my goal to achieve the best outcome for my client should the need arise.”

I represent sponsors, owners, and managers of affordable housing regarding HUD regulatory compliance and administrative enforcement, including:

• Debarment, Suspension, and Limited Denial of Participation (LDP)
• Office of Inspector General (OIG) Investigations and Audits
• Civil Money Penalties (CMPs)
• Program Fraud Civil Remedies Act (PFCRA)
• 2530 Previous Participation Review
• Physical condition inspection, including Real Estate Assessment Center (REAC) inspection
• Management and Occupancy Review (MOR)
• Annual Financial Statements (AFS)
• Freedom of Information Act (FOIA)
• Fair Housing and Section 504
• Lead-Based Paint (LBP)

Credentials

Bar Admissions

• District of Columbia
• New York

Education

• JD, Georgetown University Law Center
• BA, State University of New York at Binghamton

Representative Matters

• Represented a large developer in preventing debarment of the company based on certification statements made by a member of the executive team in connection with applying for a HUD-insured loan.
• Represented multiple clients in HUD OIG Audits, including with regard to responding to OIG findings of noncompliance with tenant eligibility and subsidy calculation requirements, and closing out OIG recommendations with HUD’s Office of Multifamily Housing.
• Represented numerous clients in responding to HUD Departmental Enforcement Center (DEC) notices concerning potential CMPs or PFCRA penalties and assessments, including successfully defending against the imposition of penalties and successfully negotiating reductions in penalty and assessment amounts.
• Represented numerous clients in reducing the level of, or resolving 2530 flags, as well as achieving 2530 approval despite the presence of flags.
• Represented various clients in successfully appealing failing REAC inspection scores to passing or otherwise significantly improving scores to extend time until next inspection.
• Represented numerous clients in responding to Notices of Default of Housing Assistance Payments Contract and/or Notices of Violation of Regulatory Agreement due to failing REAC inspection scores.
• Represented multiple clients in successfully appealing Unsatisfactory or Below Average MOR ratings to Satisfactory.
• Represented numerous clients in responding to HUD inquiries triggered by compliance issues raised during HUD review of AFS filings.
• Represented multiple clients in successfully objecting to the disclosure of commercial or financial information under FOIA Exemption 4.
• Represented multiple clients in responding to Fair Housing and Section 504 complaints, including negotiation of Voluntary Compliance Agreements.
• Represented multiple clients in responding to HUD Office of Lead Hazard Control and Healthy Homes (OLHCHH) compliance reviews.