Advisory Opinion request from CSRS, Inc. in connection with a subcontract for the Office of Community Development - Disaster Recovery Unit.

FAQ#: 115 published 4-1-2019

On November 14, 2017, Pan American Engineers, LLC ("Pan American") entered into a Professional Services Contract with the Louisiana Office of Community Development - Disaster Recovery Unit ("OCD"). On January 24, 2018, Pan American entered into a subcontract with CSRS to assist with grant management services in connection with OCD's Community Development Block Grant ("CDBG") Disaster Recovery Programs related to Hurricanes Katrina, Rita, Gustav, and Ike, the floods of 2016, and future disasters.

On May 3, 2018, Revision 1 to the Pan American subcontract with CSRS required CSRS to provide executive staff augmentation services and such personnel as necessary to provide executive staff services to OCD. Stacy Bonnaffons, an employee of CSRS, was assigned as temporary Chief of Staff for OCD until July 15, 2018, when her service was discontinued and the chief of staff position was abolished through the hiring of a Chief Operations Officer by OCD. Ms. Bonnaffons remains an employee of CSRS as a Program Manager in connection with the disaster recovery programs, in particular, the 2016 flood recovery program, "Restore Louisiana."

In October of 2018, OCD entered into an unrelated contract with The Compass Group Affordable Housing, LLC ("Compass Group") to provide policy and finance advisory services related to affordable, multi-family housing in support of the investment of CDBG funds into various multifamily rental housing programs, including the Piggyback Program, which combines CDBG loans with Low Income Housing Tax Credit equity. The Compass Group provides OCD with advisory services related to government regulations, financing structures, and housing policy issues, including affordability, disaster resilience, and other key outcomes.

Compass Group seeks to engage CSRS to supplement their services to OCD. These affordable housing services have no connection to the disaster recovery services provided by CSRS to Pan American and CSRS had no involvement in preparing the Request for Proposal which led to the contract between Compass Group and OCD. Additionally, Ms. Bonnaffons did not participate in the contract between Compass Group and OCD and Ms. Bonnaffons provided no services to OCD as interim Chief of Staff in connection with the affordable housing services to be provided in the potential subcontract between CSRS and Compass Group. Finally, Ms. Bonnaffons is not rendering the same services to CSRS as a Program Manager as the services she rendered to OCD as interim Chief of Staff.

Research Resource: Louisiana Ethics Agenda Item Docket No. 18-1283

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