Federal Housing Dollars in Lansing: The Network Around the LHC

LANSING, Mich. — The Lansing Housing Commission does not operate alone. Its public-housing portfolio, the roughly $200 million in federal Low-Income Housing Tax Credits flowing through its Lansing-area housing-development projects, and the federal voucher subsidies that pass through it move through a cluster of nonprofit, private, and law-firm entities and through a small group of individuals who hold multiple roles across those entities. The entities, the people in them, and the money flows between them are the subject of this third post in the LHC institutional series. The map is not comprehensive; it covers what the prior posts in this series, their underlying case-file briefs, and the Michigan and federal corporate, nonprofit, and political-finance records examined so far have surfaced.

The first two posts in this series covered the LHC board structure and the dual-role positions held by two of its five seated commissioners, and the LHC executive director's five private business entities and the August 2025 dual-signature transaction. This third post takes a wider view, placing those findings inside the broader Lansing-area network of housing-related entities and individuals around the agency. A money-flow diagram shows the federal dollars entering LHC and where they go. A table of named individuals shows who holds which role inside that flow.

The dollar amounts, board memberships, employment histories, registered-agent roles, and shared-address patterns documented here come from the Michigan LARA Corporate Division, IRS Form 990 nonprofit returns, IRS Form 8872 political-organization disclosures, Ingham County property records, the City of Lansing CivicClerk system, and the Lansing Housing Commission's own posted records at lanshc.org. The relationships described are contractual or governance facts on the public record. Whether any specific arrangement violates federal or state law is a question for the bodies authorized to decide it; the rules that apply to the LHC's role in this network are written up separately at Public Housing Commission Conflict-of-Interest Standards.

Key findings

• The LHC Executive Director signed an August 2025 housing deal as both LHC and the private company he personally owns. Doug Fleming signed the Oliver Gardens II project paperwork on behalf of both LHC and a private general-partner LLC he is the sole member of. That LLC controls a project the State of Michigan has now awarded $1,479,466 in federal tax credits, and the cash from selling those credits funds the project's developer fee, which Fleming's private company is positioned to receive (full detail in the second post in this series).
• The LHC Board Chair earns $123,787 a year from the nonprofit on the other side of LHC's joint housing partnerships. Emma Henry chairs the LHC board that approves Capital Area Housing Partnership (CAHP) partnership terms and oversees Fleming's employment contract and compensation. She is also the paid Executive Director of CAHP, which collected $1,250,000 in developer fees from LHC-partnership projects in fiscal year 2024 (year ending June 2024) per the IRS Form 990 for EIN 38-3099281. In 2024 she stepped aside on one vote (a project where CAHP was the named partner) out of 15+ votes across eight LHC board meetings.
• An LHC Commissioner is a paid Vice President at Cinnaire, the company that buys the tax credits from LHC's housing deals and provides the cash that funds them. Ashlee Barker votes on LHC matters concerning Cinnaire while drawing a salary from Cinnaire (per the Cinnaire team page), and Cinnaire is the standing tax-credit buyer on LHC's $200M Lansing-area housing-development pipeline.
• The same attorney serves as registered agent for the LHC executive director's prior employer, as a director on the nonprofit at which the LHC board chair is the paid executive director, and as the registered agent for the original Oliver Gardens entities the 2008 HUD Office of Inspector General (OIG) report flagged. Thomas L. Lapka of Mallory Lapka Scott & Selin PLLC is the registered agent for at least 22 active Michigan housing entities, and a member-owner of Capitol Ave Inv LC, the entity that owns the building at 605 S Capitol Avenue where Lapka's law firm, Watermark Management Group LLC (Fleming's pre-LHC employer), Cove Investments II LLC, and Sam Spadafore's SJS Consulting Group LLC are all registered. Registered-agent status is a ministerial function (the designated recipient of legal mail); the post does not infer active legal representation from the registered-agent role alone.
• The number of public-housing apartments LHC owns and operates dropped 92% between 2020 and 2025 (from 833 down to 66). Most of the loss came through two mechanisms: roughly 427 units exited via HUD's Rental Assistance Demonstration (RAD) program, which converts public-housing apartments into a different type of subsidized housing while keeping the federal rent subsidy attached to the building (defined in the glossary above); and 202 of the homes were sold to a private buyer (SK Lansing, organized in March 2022 and renamed six months before the sale closed; now managed by Evert Kramer's Michigan Asset Group LLC). Of approximately 40 SK-displaced households who wanted to buy their own homes, approximately 8 qualified, per City Pulse, May 19, 2022. The federal voucher subsidy that previously supported public-housing operations under LHC ownership now flows to a Florida-anchored private landlord, with no fixed end date.
• This map is not comprehensive. The post documents the clusters the public record establishes most clearly. Additional individuals and entities (other LIHTC partnership co-developers, MSHDA-side actors, additional contractors and property managers, City of Lansing planning and economic-development staff who process the LHC pipeline applications, and the Cinnaire equity-investor base) appear in the public record but are not fully documented here. Future work may extend the map.

Who sits on both sides of LHC's decisions

The same people and the same companies show up on both sides of the Lansing Housing Commission's contracting and governance decisions. The table below pairs each actor's LHC-side role (what they vote on, sign, or appoint) with what they personally receive on the other side: salary, contract revenue, sale proceeds, or political donations.

Quick glossary, in plain English

• Federal tax credits (LIHTC): a federal program that gives developers a tax break for building affordable apartments. The State of Michigan (through MSHDA) decides which projects get the credits. Developers sell the credits to companies for cash and use the cash to build the project.
• Tax-credit buyer (a "syndicator"): the company that buys those tax credits from the developer for cash. Cinnaire is the standing tax-credit buyer on LHC's housing pipeline.
• Developer fee: the cash the developer pockets when they put the project together. Typically 10–15% of the total project budget; MSHDA's Qualified Allocation Plan caps the fee per deal and the cap varies by deal structure.
• Housing voucher: a federal rent subsidy. The tenant pays a portion of rent and the federal government pays the rest directly to the landlord.
• 527 political fund: a political committee that raises money to support a candidate. The Schor Lansing Fund is one such committee that the Mayor of Lansing operates.
• Registered agent: the person designated to receive legal mail for a company. Useful as a tracer of which lawyer is associated with which entity, but it is a ministerial role; it is not the same as actively representing the company in legal matters.
• RAD (Rental Assistance Demonstration): a federal program that lets a public housing agency convert public-housing apartments into a different type of subsidized housing. The building's operational status changes, but the federal rent subsidy stays attached to the property. Tenants generally keep the right to stay; some public-housing protections (grievance procedures, certain eviction protections) do not transfer.

Actor	LHC SIDE: what they decide, vote on, sign, or appoint	OUTSIDE BENEFIT: what they (or the company they control) receive
Doug Fleming person LHC Executive Director	Signs LHC's housing-partnership agreements. In August 2025 he signed the Oliver Gardens II project paperwork on behalf of both LHC and the private company he personally owns: both sides of the same deal (the dual-signature transaction documented in the second post in this series)	Owns five private companies (four use the LHC office address as their business address). One of those companies controls a housing project that the State of Michigan awarded $1,479,466 in federal tax credits in August 2025. The cash from selling those credits is what funds the project's developer fee, which Fleming's company is positioned to receive
Emma Henry person LHC Board Chair	Chairs the LHC board that approves the partnership terms with CAHP and oversees Fleming's employment contract and compensation. In 2024 she stepped aside on one vote (a project where CAHP was the named partner) out of 15+ votes across eight board meetings	Earns $123,787 a year as paid Executive Director of CAHP, the nonprofit on the other side of LHC's joint housing partnerships. CAHP itself collected $1,250,000 in developer fees from those housing projects in fiscal year 2024 (year ending June 2024, per its IRS Form 990)
Ashlee Barker person LHC Commissioner	Votes on LHC matters concerning Cinnaire, the company that buys the tax credits from LHC's housing deals and provides the cash that funds them	Drawn a salary as Vice President, Innovation at Cinnaire (per the Cinnaire team page). Her salary amount is not publicly reported
Andy Schor person Mayor of Lansing	Appoints LHC commissioners (with City Council confirmation) under the City Charter; Henry's seat as LHC Board Chair is the Mayor's appointment	Operates the Schor Lansing Fund (IRS Form 8872, EIN 83-1577483; the IRS portal requires an EIN search). Reported receipts: $108,686 from 352 donors across 2019–2025. Network-adjacent line items are small in absolute terms: $100 from Cinnaire SVP Edmiston (March 2019, 0.09% of receipts), $3,000 from Kramer Management Group (2023 + 2025, 2.8% of receipts), and $1,090 in fundraiser-ticket payments to CAHP (2020–2025). Listed here as documented network connections, not as a personal financial benefit to the Mayor
Capital Area Housing Partnership entity (nonprofit) EIN 38-3099281	The nonprofit on the other side of LHC's joint housing partnerships. Its paid Executive Director (Henry) is the LHC Board Chair; its FY2023 Board Chair (Lapka) is the long-time registered agent (a ministerial role) for Fleming's previous employer	Took in $1,250,000 in developer fees from LHC-partnership housing deals in fiscal year 2024 (year ending June 2024); also received $1,090 from the Mayor's political fund between 2020 and 2025 (recorded as fundraiser-ticket and event-sponsorship payments)
Cinnaire entity (3 affiliated organizations) EINs 38-3126310, 38-3225995, 38-3666288	The standing tax-credit buyer on LHC's $200M housing-development pipeline. One of its Vice Presidents (Barker) sits on the LHC board and votes on LHC matters involving Cinnaire. One of its directors (Manuel) served as Vice Chair of CAHP in fiscal year 2023 while CAHP partnered with LHC on housing projects	Holds combined assets of about $269 million across its three affiliated organizations (Cinnaire Corporation, $72.2M; Cinnaire Solutions, $39.7M; Cinnaire Lending, $157.3M). CEO Mark McDaniel earned $950,737 in 2024. The fees Cinnaire collects on each LHC tax-credit deal are not separately disclosed
Fleming's five companies entity (private LLCs) incl. Oliver Gardens II GP, 220 Kalamazoo GP	Four of the five companies use the LHC office at 419 Cherry St as their business address. Their sole owner is the LHC Executive Director. They are the entities positioned to collect developer fees on LHC's tax-credit-funded housing projects	Oliver Gardens II, the housing project Fleming's company controls, was awarded $1,479,466 in federal tax credits by the State of Michigan in August 2025. The share of the project budget that ultimately becomes the developer fee is not publicly reported
Mallory Lapka Scott & Selin PLLC entity (law firm) 605 S Capitol Ave	Lapka chairs CAHP (Chair in fiscal year 2023; Director in fiscal year 2025). His law firm is the long-time legal contact (registered agent) for Fleming's previous employer Watermark, the original Oliver Gardens LDHA LP, and at least 22 other tax-credit-housing partnerships of the kind LHC participates in	Holds the long-time legal-contact role across Watermark Management Group LLC, the original Oliver Gardens LDHA LP, and at least 22 other tax-credit-housing partnerships of the kind LHC participates in; the registered-agent role itself is ministerial (it is the designated recipient of legal mail, not active legal representation), and any direct fee revenue to the firm from LHC-funded deals is not separately disclosed in public records reviewed for this post
SK Lansing / Kramer Management entity (private) Red Michigan Holdings LLC; Michigan Asset Group LLC	Bought 202 former public-housing homes from LHC in 2023 (the sale Fleming and the LHC board approved). Kramer Management now manages those homes. Principal Evert Kramer's firm donates to the Mayor's political fund, and the Mayor appoints LHC's commissioners	Paid $14,620,000 for the 202-home portfolio (2023; documented in the earlier post on the SK transaction). Receives an estimated $2,200,000 per year in federal rent-subsidy payments (housing vouchers) on those same homes (estimate from the federal voucher payment standard times the unit count, also documented in the earlier post). Kramer Management donated $3,000 to the Mayor's political fund in 2023 and 2025

Watermark Management Group LLC (LARA 801327067), Doug Fleming's pre-LHC employer for 15 years, is part of this network through the personnel pipeline (Fleming joined LHC from Watermark in September 2018) and the shared registered-agent role (Lapka's firm is the long-time registered agent, a ministerial role, for both Watermark and the Oliver Gardens limited dividend housing association (LDHA) partnerships LHC participates in). Watermark is not in the table above because no current LHC contract is documented in the public record reviewed for this post.

Federal and Michigan rules on conflict of interest in public-housing governance are written up at Public Housing Commission Conflict-of-Interest Standards. Whether any specific arrangement above violates a rule is a determination for the bodies authorized to make it.

Federal money in, contractor and partnership payments out

The dollar amounts above are the personal salaries, developer fees, sale prices, and donations the public record makes visible. The diagram below shows the institutional money flow: federal dollars enter LHC from four documented sources on the left, and federal dollars leave LHC through payments to a small set of contractor, partnership, and equity-investor entities on the right. Documented dollar amounts appear inside each destination box where the public record discloses them; "amount not disclosed" appears where it does not. The diagram is not exhaustive; LHC also pays salaries, building maintenance, utility bills, insurance, and other ordinary operating expenses that do not flow to the network entities documented in this post.

Federal money in, contractor and partnership payments outDocumented LHC money flows. Dollar values where the public record discloses them; "amount not disclosed" where it does not.FEDERAL / STATE SOURCESLANSING HOUSING COMMISSIONRECIPIENTSHUD Housing Choice Vouchers2,252 vouchers administeredannual federal subsidy streamtotal annual $ not separately disclosedHUD Operating + Capital Fundspublic-housing operating subsidyCapital Fund for 66 remaining unitsdeclining with inventory contractionMSHDA LIHTC allocations~$200M LIHTC pipeline valuerouted through LIHTC partnershipsper-project reservations varyProperty dispositions$14,620,000 SK scattered-sitesale (2023; 202 homes / 235 units)one-time, not recurringLANSINGHOUSINGCOMMISSIONpublic housing authority5-commissioner board66 owned public-housing units2,252 vouchers administeredCinnaire (3 affiliated entities)LIHTC equity buyer / syndicator~$269M combined CY2024 assetssyndication fees on LHC pipeline not disclosedCapital Area Housing Partnership501(c)(3) co-developer / partner$1,250,000 developer fees FY2024Henry is paid CAHP ED + LHC chairFleming GP LLCs (5 entities)developer-fee recipients$1,479,466 LIHTC reservationon Oliver Gardens II alone (Aug 2025)Kramer Mgmt / SK Lansing chainvoucher payments to former-LHC homes~$2,200,000 / year (estimate)Kramer Mgmt also donates to Schor FundWatermark Management GroupFleming's prior employer (15 yrs)no current LHC contract documentedhistorical / personnel-pipeline tieLHC operations and overheadstaff salaries, building maintenance,utilities, insurance, debt serviceordinary operating expensesSchor Lansing Fund (527 political committee)EIN 83-1577483 · $108,686 total receipts (2019–2025)Mayor Schor's discretionary fund; he appoints LHC commissionersnetwork-adjacent line items: $100 Edmiston (Cinnaire); $3,000 Kramer; $1,090 to CAHPDocumented LHC money flows. Source amounts for HUD Housing Choice Voucher payments and HUD Operating + Capital Funds are not separately disclosed in the public record reviewed for this post; the per-LHC totals would require a HUD FOIA. The Cinnaire ~$269M combined-assets figure is the sum of CY2024 total assets across three affiliated Cinnaire entities: Cinnaire Corporation (EIN 38-3126310), $72.2M; Cinnaire Solutions Corporation (EIN 38-3225995), $39.7M; and Cinnaire Lending Corporation (EIN 38-3666288), $157.3M. CAHP $1,250,000 developer-fees figure is from the FY2024 IRS Form 990, year ending June 2024 (EIN 38-3099281). Fleming GP LLC $1,479,466 figure is the MSHDA LIHTC reservation for Oliver Gardens II LDHA LP (Aug 2025), as documented in the second post in this series; the developer-fee percentage on that reservation is not separately disclosed. Kramer / SK voucher payment is an estimate based on per-unit voucher payment standard times the unit count, as documented in the earlier post on the SK scattered-site transaction. Schor Lansing Fund line items are from the IRS Form 8872 disclosures for EIN 83-1577483 (the IRS Political Organization Disclosure portal at forms.irs.gov requires an EIN search to retrieve a specific organization's filings). Sources: Michigan LARA Corporate Division filings; IRS Form 990 (CAHP) and IRS filings for the three Cinnaire affiliated entities; IRS Form 8872 (Schor Lansing Fund); MSHDA LIHTC award database; HUD-administered voucher and operating subsidy program documentation; Ingham County property records.

The people who direct, sit on the board of, and contract with LHC

The federal money flows above are directed and approved by people. The table below lists the individuals the public record places in roles relevant to LHC's contracting, governance, and partnership decisions. Each row gives the LHC-side role, the outside affiliation that creates the network connection, and the source.

LHC-side role	Name	Outside affiliation that creates the network connection	Source
Mayor (appoints LHC commissioners)	Andy Schor	Operates the Schor Lansing Fund (EIN 83-1577483), a 527 political committee with $108,686 total receipts (2019–2025); Cinnaire SVP Edmiston and Kramer Management Group are documented donors	City Charter; IRS Form 8872
LHC Executive Director (since Sept 2018)	Doug Fleming	Sole member / organizer / agent on five private LLCs; four of the five are registered at LHC's office at 419 Cherry St; previously Asset Manager at Watermark Management Group LLC for 15 years (registered agent: Lapka)	LARA; LHC Special Board Meeting, Sept 4, 2018; post 2 in this series
LHC Board Chair	Emma Henry	Paid Executive Director of Capital Area Housing Partnership (compensation $123,787 FY2025); CAHP earned $1.25M in developer fees on LIHTC projects in FY2024 (year ending June 2024); abstained from one vote in 2024 (Resolution 1373)	IRS Form 990 EIN 38-3099281; LHC Board Report June 26, 2024
LHC Commissioner	Ashlee Barker	Vice President, Innovation at Cinnaire (the standing tax-credit syndicator on LHC's LIHTC pipeline)	Cinnaire team page; lanshc.org/commissioners
LHC Commissioner	Loria Hall	Property Manager at Continental Management (an affordable-housing facility); member of the National Center for Housing Management; certified occupancy specialist	lanshc.org/commissioners
LHC Commissioner	Heather Taylor	Outside affiliations not researched for this post	lanshc.org/commissioners
LHC Commissioner	Bryan Jones	Outside affiliations not researched for this post	lanshc.org/commissioners
LHC "Special Projects" employee	Sam Spadafore	Sole member of SJS Consulting Group LLC, registered at 605 S Capitol Avenue (Lapka's law-firm building); organized 220 Kalamazoo GP, LLC at the LHC office in Feb 2023 and transferred it to Fleming nine months later	LARA; post 2 in this series
CAHP Board Chair (FY2023) → Director (FY2025)	Thomas L. Lapka	Attorney at Mallory Lapka Scott & Selin PLLC (605 S Capitol Ave); registered agent for at least 22 active Michigan housing entities including Watermark Management Group LLC and the original Oliver Gardens LDHA LP	LARA; IRS Form 990 EIN 38-3099281
CAHP Vice Chair (FY2023)	Mary Manuel	Director, Learning and Talent Development at Cinnaire	Cinnaire team page; IRS Form 990 EIN 38-3099281 FY2023
CAHP Board Chair (FY2025)	Peter Kulick	Attorney at Dickinson Wright	IRS Form 990 EIN 38-3099281
CAHP Vice Chair (FY2025)	Nate Kirk	Outside affiliations not researched for this post	IRS Form 990 EIN 38-3099281
CAHP Director (FY2023)	Dana Watson	East Lansing City Council member	IRS Form 990 EIN 38-3099281
Former CAHP Executive Director (departed Dec 2023)	Rawley Van Fossen	Prior: Lansing City Director of Economic Development & Planning (the department that processes PILOT, brownfield, and rezoning applications); $122,506 final partial-year compensation at CAHP per FY2024 990	IRS Form 990 EIN 38-3099281; post 1 in this series
Cinnaire CEO	Mark McDaniel	$950,737 compensation per CY2024 IRS 990-PF for Cinnaire Corporation	IRS Form 990-PF EIN 38-3126310
Cinnaire Senior Vice President	Tom Edmiston	Donated $100 to the Schor Lansing Fund on March 1, 2019	IRS Form 8872; Cinnaire team page
Organized SK Lansing buyer entity (March 2022)	Tzvi Koslowe	Southfield, Michigan resident; organized SK Investments Group LLC (renamed Red Michigan Holdings LLC), the entity that bought 202 LHC scattered-site homes for $14,620,000 in 2023	LARA 802830624; earlier post on the SK transaction
Manages SK scattered-site portfolio	Evert Kramer	Principal of Michigan Asset Group LLC (DBA Kramer Management Group), 1305 South Washington Avenue, Lansing; donated $3,000 to the Schor Lansing Fund across 2023 and 2025	LARA 801534229; IRS Form 8872

The Watermark–CAHP–LHC career pipeline

The strongest single thread in the people table is a career-and-affiliation pipeline that runs through three institutions and back through one attorney. Doug Fleming worked at Watermark Management Group LLC for fifteen years before becoming LHC interim executive director in September 2018. Watermark Management Group's registered agent is Thomas L. Lapka. Lapka is also a director on the CAHP board (chair in FY2023, director in FY2025) where Emma Henry is the paid executive director. Henry chairs the LHC board that hired Fleming and oversees Fleming's employment contract and compensation. The Lapka-Fleming professional adjacency through Watermark dates to the pre-2018 era; the Fleming-Henry overlapping-role relationship dates from December 2023, when Henry succeeded Van Fossen as CAHP ED while continuing to chair the LHC board. The continuous element across the longer time frame is Lapka's presence in mid-Michigan affordable-housing legal work, which the public record traces to 1979–1984 LDHA limited partnerships.

Each segment of the pipeline is documented in the public record:

Period	Organization	Fleming's role	Lapka connection	Henry connection	Source
~2003–2018	Watermark Management Group LLC	Asset Manager (15 years)	Lapka is registered agent (LARA 801327067)	none documented	LARA; LHC board minutes documenting Fleming's hire
prior to 2018	Capital Area Housing Partnership (overlap not separately documented in this post)	unknown	Lapka served on CAHP board (FY2023 chair)	none documented for this period	CAHP IRS Form 990
Sept 2018–present	Lansing Housing Commission	Executive Director	Lapka is agent for original Oliver Gardens LDHA LP and 22+ other housing entities Fleming's GP LLCs interface with	Henry is LHC board chair	LARA; LHC Special Board Meeting, Sept 4, 2018 and Sept 26, 2018 board meeting; Lansing City Pulse, Sept 4, 2018

The pipeline produces a structural condition: the attorney whose firm appears as registered agent on the legal entities, the nonprofit executive who partners with LHC on development deals, and the public housing director who executes those deals operate in adjacent roles within a small specialized field. The Lapka-Fleming professional adjacency (through Watermark) dates to Fleming's pre-2018 career; the Fleming-Henry overlapping-role relationship dates from December 2023. New entrants to the network are visible through the same physical addresses and the same legal-instrument categories: Sam Spadafore as LHC "Special Projects" employee with a personal LLC registered at 605 S Capitol Avenue, and Ashlee Barker as Cinnaire VP and LHC commissioner whose connection to the network runs through Cinnaire's role as the LHC pipeline's standing tax-credit syndicator (her personal address is not separately documented as part of the 605 S Capitol Ave cluster).

Two physical addresses anchor the network: 605 S Capitol Ave and 419 Cherry St

605 South Capitol Avenue is the address of Lapka's law firm, Mallory Lapka Scott & Selin PLLC. The building is owned by Capitol Ave Inv LC (LARA 801126643), an entity for which Lapka is a Member per the founding LARA Articles of Organization (Ingham County property records, parcel 33-01-01-16-384-002). Other entities registered at 605 S Capitol Ave include Watermark Management Group LLC (Fleming's prior employer for fifteen years), Cove Investments II LLC (LARA 802396715, a LIHTC co-developer on outside deals), and SJS Consulting Group LLC (the personal consulting LLC of Sam Spadafore, the LHC "Special Projects" employee who organized 220 Kalamazoo GP, LLC at the LHC office in February 2023 before transferring it to Fleming nine months later). The building is the physical anchor of the pre-LHC side of the network: the law firm that has structured affordable-housing limited partnerships in mid-Michigan for forty-five years, the management entity Fleming worked at, and the personal consulting LLC of an LHC staff member who organized one of the LHC pipeline's general-partner entities.

419 Cherry Street is the address of the Lansing Housing Commission. Four of the five private LLCs Doug Fleming has organized or serves as agent for (Oliver Gardens LLC, Oliver Gardens GP LLC, 220 Kalamazoo GP LLC, Oliver Gardens II LDHA LP) use 419 Cherry Street as their registered address. The fifth, Fleming Consulting LLC, is registered at Fleming's personal home in DeWitt. The detail of those five entities and the August 2025 dual-signature transaction is in the second post in this series; the pattern relevant to the network diagram is that the LHC office address has become the registered address for the private LLCs that collect developer fees on LHC's LIHTC partnerships.

The CAHP board across years

Capital Area Housing Partnership is the nonprofit closest to LHC in the network. Henry serves as its paid executive director (compensation $115,538 plus $8,249 in other compensation for the fiscal year ending June 2025, per the IRS Form 990 for EIN 38-3099281) and concurrently chairs the LHC board. In 2024, Henry abstained from one vote: Resolution 1373, the LHC board's vote on a 9% LIHTC application for a Williamston project with CAHP as named partner (LHC Board Report, June 26, 2024). Henry participated in all other LHC board discussions and votes across eight 2024 meetings. CAHP has reorganized its board between FY2023 and FY2025:

Position	FY2023 (year ending June 2023)	FY2025 (year ending June 2025)
Chair	Thomas L. Lapka (attorney; Watermark agent; agent for 22+ housing entities)	Peter Kulick (attorney)
Vice Chair	Mary Manuel (Director of Learning and Talent Development at Cinnaire per the Cinnaire team page)	Nate Kirk
Director	Dana Watson (East Lansing City Council member); additional directors	Lapka (continuing as a director); additional directors
Executive Director	Rawley Van Fossen*	Emma Henry (succeeded Van Fossen Dec 2023; LHC board chair)

Sources: CAHP IRS Form 990, EIN 38-3099281, FY2023 and FY2025; Cinnaire team page (Mary Manuel). ^*Van Fossen reported $122,506 in compensation on the FY2024 IRS Form 990 (year ending June 2024), his final partial year at CAHP; he departed in December 2023.

Van Fossen's prior role as the City of Lansing's Director of Economic Development and Planning (the department that processes rezoning applications, PILOT requests, and brownfield-tax-capture applications, including the LHC and CAHP applications that come before Council) is documented in the first post in this series. Van Fossen's transition from City Director to CAHP ED, and Henry's subsequent transition from CAHP staff to CAHP ED to LHC board chair, are the personnel side of the institutional relationship between LHC and CAHP.

The SK Lansing scattered-site sale and the property-management network

The Lansing Housing Commission sold 202 scattered-site public-housing homes (235 units) to an entity now named Red Michigan Holdings LLC for $14,620,000 in 2023, as documented in the earlier post on the SK Lansing scattered-site transaction. The buyer was created six months before the sale closed: SK Investments Group LLC was organized by Tzvi Koslowe in Southfield, Michigan in March 2022 and renamed to Red Michigan Holdings LLC in November 2022, eight months before the LHC sale closed. The Florida corporate chain behind the buyer is cross-held: Amnon Zakay owns Yard Holdings LLC, which owns Figtree Holdings LLC, which operates under the "SK Investments Group" brand and is managed by Yanir Hadan. Koslowe is the Michigan-side operator. The formal ownership link between Figtree Holdings (Florida) and Red Michigan Holdings LLC (Michigan) is established by brand-name evidence and the SK Investments Group website's listing of the LHC purchase as "SFR (single-family rental) Portfolio 3," not by a corporate filing in either Michigan or Florida. A nonprofit staging entity, SK Affordable Housing Company (LARA 802464667), was organized approximately 22 months before the acquisition LLC (June 2020 versus March 2022) by Koslowe's attorney William Freeman; the nonprofit has never filed an IRS Form 990.

The properties are managed today by Evert Kramer's Michigan Asset Group LLC, headquartered at 1305 South Washington Avenue in Lansing. The federal voucher payment to the SK-owned former-LHC properties was estimated at approximately $2,200,000 per year in the earlier post on the scattered-site transaction, computed from the per-unit federal voucher payment standard times the unit count; that figure is an estimate, not a HUD-published total. The subsidy stream flows to a private entity controlled by a Florida-anchored corporate chain through Kramer's Lansing-based property-management firm.

The Schor Lansing Fund as one node in the network

The Mayor of Lansing operates a discretionary 527 political fund, the Schor Lansing Fund (EIN 83-1577483; IRS Form 8872 disclosures). The fund reports $108,686 in receipts from 352 donors across 2019–2025. Three of its IRS Form 8872 line items connect to entities in the network diagrams above. The contributions from network-adjacent donors are: $100 from Tom Edmiston, Cinnaire's Senior Vice President, on March 1, 2019 (0.09% of fund receipts); and $3,000 from Kramer Management Group across two contributions ($500 on March 10, 2023 and $2,500 on December 12, 2025; combined 2.8% of fund receipts). The fund's expenditures into the network are: $1,090 in donations to Capital Area Housing Partnership across 2020–2025, all in the $90–$250 range, all categorized in the IRS Form 8872 schedules as fundraiser tickets or event sponsorships.

The Mayor of Lansing, Andy Schor, appoints the LHC commissioners with City Council confirmation under the City Charter. The dollar amounts on the Schor Lansing Fund's network-adjacent line items are small in absolute terms; the structural relationships those line items document are that a Cinnaire executive, the principal of the firm that manages the SK scattered-site portfolio, and the nonprofit at which the LHC board chair is the paid executive director are all present in the public record of the Mayor's discretionary political-finance vehicle. The Mayor's appointment authority over the LHC board is not conditioned on the donor base of the fund; the donor base is information for voters at the next mayoral election and for City Council during LHC commissioner confirmation hearings. The full Schor Lansing Fund record (donor base composition, expenditure pattern, the $32,400 paid to Grassroots Midwest in lobbying-related fees per the IRS Form 8872 schedules for EIN 83-1577483 (the IRS Political Organization Disclosure portal requires a manual EIN search to retrieve the Schor Lansing Fund filings), and the recurring administrative payments to the fund administrator's firm Capitol Fundraising Associates) is described at the case-file level in the first post in this series.

Lansing tenants, taxpayers, and the housing market bear the cost

The 92% reduction in the number of public-housing apartments LHC owns and operates between 2020 and 2025 (from 833 units down to 66, as documented in the earlier post) is the single largest impact on Lansing tenants. The reduction came through two main mechanisms with different consequences for the tenants involved: roughly 427 units exited the LHC portfolio in 2020–2021 through HUD's Rental Assistance Demonstration (RAD) program, which converts public-housing apartments into a different type of subsidized housing while keeping the federal rent subsidy attached to the building (defined in the glossary at the top of this post); 202 homes (235 unit-equivalents) in the SK Lansing scattered-site sale (2023–2024) converted to private-landlord ownership with the federal rent subsidy now flowing through tenant-held vouchers to the new owner; and the remaining unit losses came from smaller intermediate dispositions in 2021–2022 and a small number of individual resident purchases in 2024–2025. The network described above is the structure that produced both. The cost falls on seven groups.

The 202 households whose homes LHC sold to SK Lansing in 2023. These households went from public-housing residents (rent capped at 30% of household income, federal grievance and eviction protections, public-housing inspection rights) to voucher holders renting from a private landlord (the Kramer-managed, Florida-anchored SK Lansing chain). Of the approximately 40 households that expressed interest in purchasing the unit they were living in, approximately 8 qualified to buy (per City Pulse, May 19, 2022). Approximately 32 wanted-to-buy households did not get the chance. How many of the displaced households successfully used their replacement-housing voucher to find a new place in Lansing, and how many ended up displaced or homeless, is not in the public record yet. Public records requests are ready to file with HUD and LHC asking for those tracking records.

Federal taxpayers, who now subsidize a private landlord in place of the public-housing operation that previously held these homes. The 202 SK-owned former-LHC homes were federally subsidized when LHC owned them (HUD operating subsidy plus voucher payments) and they remain federally subsidized today (housing-voucher payments to the new private landlord). The federal expenditure level on these units did not start with the 2023 sale; what changed is the recipient and the tenant-protection terms. The recipient of the federal voucher payments is now a private Florida-anchored landlord through Kramer Management; the tenants no longer have public-housing grievance and eviction protections. Twenty-nine eviction cases have been filed against tenants of the former public-housing scattered-site homes since June 2025 (including 14 cases on a single day, January 29, 2026), as documented in the earlier post on the SK transaction. At the estimated $2,200,000 per year in voucher payments to the SK-owned former-LHC properties, the cumulative federal voucher subsidy to the new private owner reaches the 2023 sale price ($14,620,000) in roughly six to seven years and continues thereafter, with no fixed end date in the public record reviewed for this series.

People on LHC's public-housing waitlist. Anyone applying for LHC public housing today is competing for 66 slots; five years ago they would have been competing for 833 slots, a 92% reduction in the stock available to applicants. Public housing is the lower-rent, stronger-protection tier of the affordable-housing market; the alternatives waitlisted households get pushed toward (vouchers in the private market, tax-credit apartments) cost more for the household and offer fewer protections.

Voucher holders citywide. LHC administers 2,252 federal Housing Choice Vouchers. The agency's daily operational priorities (payment standards, recertification timelines, inspection enforcement, hearing rights when something goes wrong) are set by the same executive director who is positioned to collect developer fees on the side and the same board chair who is paid by the nonprofit on the other side of LHC's partnership deals. HUD administrative fees that fund voucher operations are also declining; Fleming acknowledged this on the record at the June 26, 2024 LHC board meeting: admin fees on managed properties have dropped from $785,000 to $200,000, with the gap "being replaced by developer fees."

Tenants of the new tax-credit apartments LHC helps build. The tax-credit projects LHC participates in (Riverview 220, Grand Vista, Oliver Gardens II, Washington Apartments, Williamston) charge what is called a "below-market" rent: a fixed rent set against the local median income, typically pegged so that a household earning 50 to 60 percent of the local median can afford it. That is cheaper than market-rate rent in Lansing, but it is not the same as public-housing rent, which is set at 30 percent of the actual household's income. A tax-credit apartment can still be unaffordable to the lowest-income households in Lansing. Lease protections are also weaker in tax-credit apartments than in public housing: no formal grievance process, narrower protections against eviction without cause, and a recertification process that can require a household to move out if income later rises above the cap. The 767 public-housing units LHC has lost since 2020 (across the RAD conversions and the SK sale together) do not come back when these tax-credit projects open.

Other affordable-housing developers in mid-Michigan. Every joint LHC housing deal runs through the same set of in-house partners: CAHP as the nonprofit on the other side of the partnership, Cinnaire as the company that buys the tax credits, Lapka's law firm as the long-time registered agent (a ministerial role) for the standard housing-partnership entities, and Fleming's own five LLCs as the entities positioned to collect the developer fees. A different developer who could build more apartments per dollar of federal money has no realistic way to bid on this work, because no competitive solicitation for a development partner is documented in the LHC board minutes reviewed for this series (HUD's mixed-finance development rules at 24 CFR (Code of Federal Regulations) Part 905 do not require a public housing agency to issue a competitive request for proposals (RFP) for partnership selection). The absence of a competitive bid process removes the normal pressure that holds fees down; whether LHC's developer fees actually exceed the fees paid by peer Michigan public housing agencies on comparable deals would require a comparator study that this post does not provide.

Lansing taxpayers and city services. LHC's tax-credit housing projects regularly ask the Lansing City Council for two things at the same time. The first is a PILOT (a sharply reduced annual property-tax bill, sometimes as low as 5 cents on the dollar of what a comparable building would owe, for as long as 40 years; "PILOT" is short for "payment in lieu of taxes"). The second is the larger development deal itself, which routes federal tax credits to a network of partners who collect millions of dollars in developer fees from the cash those credits raise. The PILOT side transfers decades of property-tax revenue away from Lansing schools, the fire department, police, and street repairs. The developer-fee side, on the roughly $200 million in federal tax credits flowing through LHC's Lansing-area housing-development projects (Riverview 220, Grand Vista, Oliver Gardens II, Washington Apartments, the Williamston project), works out to roughly $20 million to $30 million in private developer pay over the life of the projects (typical 10 to 15 percent of project budget across the affordable-housing tax-credit field, per the underlying case-file briefs in this series; the per-project cap is set by MSHDA's Qualified Allocation Plan and varies by deal type, and the actual fee on any given LHC partnership is not separately disclosed in the public record reviewed for this post). None of that developer pay lowers the rent the tenants pay. On September 30, 2024, Lansing City Council rejected one such PILOT request unanimously, by a 0 to 7 vote: a 5-percent PILOT for 40 years on the Riverview 220 and Grand Vista projects (Fleming acknowledged the rejection on the record at the October 23, 2024 LHC board meeting). The same network entities (CAHP as partner, Cinnaire as tax-credit buyer, Fleming's GP LLCs as fee recipients) continue to be positioned as the partners on the next tax-credit deals coming through the LHC pipeline.

Why this continues: the oversight gap

The same network structure that produces the harms above also blocks the corrective mechanisms. Conflict-of-interest review of a CAHP-LHC partnership term, of a Cinnaire syndication fee structure, or of a long-standing legal-firm relationship across the standard tax-credit-housing entities cannot reasonably be expected from a board member who holds the corresponding role on the other side of the relationship. Conflict-disclosure rules exist for that reason. Independent oversight in this network sits with HUD's Detroit Field Office, HUD OIG, MSHDA, the Michigan Attorney General, the Internal Revenue Service, and the Lansing City Council, and none of those bodies has, in the public record reviewed for this series, conducted a documented review of the network's current arrangement, an oversight gap that is what allows the structure to continue.

LHC's mission and the documented record

The Lansing Housing Commission's stated mission, posted on its own website at lanshc.org:

"The Lansing Housing Commission (LHC) is committed to the development and management of quality, affordable, and fair housing options in a compassionate, healthy, and safe way. LHC will deliver impactful resident services while maintaining the highest performance standards and outcomes."

Four documented gaps between the mission language and the record this post documents:

• "Quality, affordable, and fair housing options" versus the PILOT and developer-fee structure. The PILOT side transfers decades of property-tax revenue away from Lansing schools, fire, police, and street repairs, services LHC's low-income tenants disproportionately depend on. The developer-fee side routes roughly $20 million to $30 million in private pay to the same network entities that govern and contract with LHC, and none of it reduces the rent the tenants pay. Both flows move public money in directions that do not improve tenant housing quality or affordability.
• "Impactful resident services" versus the documented funding shift. Fleming told his board on the record at the June 26, 2024 LHC board meeting that admin fees on the managed properties had dropped from $785,000 to $200,000, with the gap "being replaced by developer fees." Resident-services funding is shrinking while developer-fee revenue is growing.
• "Highest performance standards and outcomes" versus the public-housing inventory loss. LHC's owned public-housing apartments dropped 92% in four years (from 833 to 66). Tenants of the SK-sold scattered-site homes lost public-housing grievance and eviction protections, and 29 eviction cases have been filed against those tenants since June 2025, including 14 cases on a single day (January 29, 2026), as documented in the earlier post on the SK transaction.
• "Fair housing options" versus the resident purchase-option gap. Of approximately 40 SK-displaced households who wanted to buy the unit they were living in, approximately 8 qualified, per City Pulse, May 19, 2022. Approximately 32 wanted-to-buy households did not get the chance on the largest disposition LHC executed.

Who's supposed to fix this

HUD's Detroit Field Office is the federal regulatory office of jurisdiction for Michigan public housing agencies. Its review authority covers public housing agency (PHA) Annual Plans, mixed-finance development proposals, Section 18 disposition applications, and the conflict-of-interest disclosures that LHC officers and commissioners are required to file. The Detroit Field Office is the body that approved the LHC scattered-site disposition and that would receive any executive-director or commissioner conflict disclosures filed under the federal rules. The federal and Michigan rules that apply to public-housing-commission conflicts of interest, the conduct each rule prohibits, and the specific records each rule requires a public housing agency to maintain are documented at Public Housing Commission Conflict-of-Interest Standards, the methodology page for this series.

HUD's Office of Inspector General previously audited LHC's prior administration and issued Report 2008-CH-1008, finding that LHC had created the original Oliver Gardens entities without HUD prior approval and pledged $1.4 million in federal assets as guarantees. The legal-instrument category that report addressed is the same category through which the current LHC LIHTC pipeline is organized. A 2026 follow-up audit on the same agency is within OIG's published mandate.

The Internal Revenue Service Tax Exempt and Government Entities Division administers the IRS Form 990 disclosure rules that govern Capital Area Housing Partnership's reporting of insider transactions, executive compensation, and conflict-of-interest policies. CAHP's Form 990 Schedule L Part IV reporting (Business Transactions With Interested Persons) is the primary disclosure point for any compensated arrangement between CAHP and a director, officer, or person with substantial influence over the organization.

MSHDA administers Michigan's federal LIHTC allocation. MSHDA's Qualified Allocation Plan governs the development-team scoring criteria, the conflict-of-interest disclosures required of applicants, and the set-aside categories under which credits are awarded. Any LHC LIHTC partnership that receives a MSHDA reservation passes through MSHDA's review process; that process is the state-side oversight layer for the partnership structures the network uses.

The Michigan Attorney General is the state-level enforcement body for several statutes that reach the relationships the diagrams document, including the Michigan public-servant contracts statute at MCL (Michigan Compiled Laws) 15.322 and MCL 15.323, the Michigan Open Meetings Act at MCL 15.261, and the Michigan Nonprofit Corporation Act at MCL 450.2101 and following.

The Lansing City Council confirms LHC commissioner appointments and approves the PILOT, brownfield-tax-capture, and land-disposition resolutions through which the LIHTC partnerships funded by Cinnaire and developed by LHC and CAHP reach the public-subsidy stage. Council has the authority to require, as a condition of any future LHC commissioner confirmation, public disclosure of the nominee's outside paid affiliations and any contractual relationships with entities in the network. Council also has the authority to require, as a condition of any future PILOT or brownfield-capture approval, public disclosure of the developer-fee flow and the GP-entity ownership structure for the underlying partnership.

Who reviews the network's arrangements on behalf of the Lansing tenants and voucher-holders the LHC was created to serve?

---

Sources

The Lansing Housing Network diagrams and prose draw on case-file research compiled across the prior two posts in this series and several issue briefs. The institutional and personnel data is taken from the Michigan LARA Corporate Division (corporate filings for Mallory Lapka Scott & Selin PLLC, Watermark Management Group LLC, Capitol Ave Inv LC, Cove Investments, SJS Consulting Group LLC, and the five Fleming LLCs documented in the second post); the IRS nonprofit filings system at ProPublica Nonprofit Explorer for CAHP (EIN 38-3099281) and for the Cinnaire entities; the IRS Political Organization Disclosure system at forms.irs.gov for the Schor Lansing Fund (EIN 83-1577483); the City of Lansing CivicClerk system for LHC board minutes; the LHC staff contact list at lanshc.org/contact-list; Ingham County property records for the 605 S Capitol Ave parcel; and prior reporting in Lansing City Pulse, "Turnover continues at Housing Commission," September 4, 2018, documenting Fleming's appointment as LHC interim executive director.

The SK Lansing entity chain is documented in the earlier Rhinoceros post on the scattered-site transaction, drawing on Michigan LARA filings for SK Investments Group LLC / Red Michigan Holdings LLC (LARA 802830624), Florida SunBiz filings for Yard Holdings LLC and Figtree Holdings LLC, the SK Investments Group website's confirmation of the LHC purchase as "SFR Portfolio 3," and the SK Affordable Housing Company filing (LARA 802464667).

The federal and Michigan rules that apply to the network's relationships are documented at Public Housing Commission Conflict-of-Interest Standards.

This post is the third in a series on the Lansing Housing Commission's institutional structure. Earlier posts: "What Is the Lansing Housing Commission?" (April 26) and "LHC Executive Director's Five LLCs" (April 26). The methodology page "Public Housing Commission Conflict-of-Interest Standards" documents the federal and Michigan rules cited across the series. Work expected to follow in this series may include a piece tracing the developer-fee flows on specific LHC LIHTC partnerships, and a piece on the Section 18 disposition compliance picture (FOIA-pending HUD records).

The map this post documents is not comprehensive. The Lansing housing network includes additional individuals and entities the investigation has not yet fully documented. Subsequent posts may extend the map.