What Is the Lansing Housing Commission?

LANSING, Mich. — The Lansing Housing Commission (LHC) is the City of Lansing's public housing authority, a public corporation chartered in 1964 under the Michigan Housing Facilities Act, MCL 125.651, to administer federally subsidized housing for low-income residents in Lansing. As of 2025 LHC owns and operates 66 public-housing units (concentrated at Hildebrandt Park and Mt. Vernon), administers 2,252 federal Section 8 Housing Choice Vouchers and 253 project-based vouchers under HUD program rules, and acts as a development partner on a Low-Income Housing Tax Credit pipeline of more than $200 million in active project cost. The agency reports to HUD as Public Housing Agency MI058 and is governed by a five-member volunteer board appointed by the Mayor of Lansing.

Across the four years in which the agency's public-housing portfolio fell from 833 units to 66, the LHC board approved the Section 18 disposition plan that converted public-housing parcels to private ownership, the executive director's continued employment and annual bonuses, and a Low-Income Housing Tax Credit partnership pipeline that now generates the agency's operating revenue.

Three of the people sitting in LHC's governance structure are conflicted on deals the board approves. Board Chair Emma Henry is the paid Executive Director of Capital Area Housing Partnership ($123,787 in salary plus other compensation per CAHP's FY2025 IRS Form 990, EIN 38-3099281), the nonprofit named as partner on LHC LIHTC deals. The 2024 LHC board minutes record one Henry abstention out of fifteen-plus resolutions. Commissioner Ashlee Barker is paid Vice President, Innovation at Cinnaire, the financial institution the LHC executive director identified on the public record as the standing purchaser of LHC's tax credits. The 2024 minutes record zero Barker recusals across the eight 2024 board meetings. LHC Executive Director Doug Fleming is the registered agent and organizing member of the General Partner LLCs that collect developer fees on the LIHTC partnerships LHC enters; on August 22, 2025, Fleming signed the formation documents for Oliver Gardens II LDHA LP (LARA 900082911) both as agent of the General Partner LLC (which Fleming organized one day earlier, on August 21, 2025) and on behalf of LHC, the limited partner.

These are conflicts of interest in the textbook sense. The federal and Michigan rules that govern conflicts of interest on a public housing commission, and the bodies authorized to act on them, are documented at Public Housing Commission Conflict-of-Interest Standards. This post documents conditions present in the public record. Whether any matched rule has been violated, and whether a covered exception applies, is a determination for the body authorized to act.

The disposition itself, the four-closing $14.62 million sale of 202 scattered-site homes to an entity that became Red Michigan Holdings LLC, was documented in the previous post in this series; this post documents the body that approved it.

The reporting in this post draws on three sources of public record: the City of Lansing Boards and Commissions roster confirming the current LHC commissioner composition; the IRS Form 990 filings of the nonprofit organizations at which two of the commissioners hold paid positions; and the LHC board meeting minutes and packets archived in the Lansing CivicClerk system across 2024. The 2020 and 2021 LHC board resolutions that authorized the Section 18 disposition, identified in the City of Lansing's August 2022 Consolidated Plan filing to HUD, are not yet available in CivicClerk's archived packet record at a level of detail sufficient to publish individual commissioner roll-call votes, and that record is the subject of a pending FOIA inquiry to LHC.

Key findings

• The Lansing Housing Commission board is a five-member volunteer body appointed by the Mayor under MCL 125.651, with overlapping seven-year terms confirmed in the City of Lansing Boards and Commissions roster.
• Two of the five seated commissioners hold paid positions at organizations that earn fees from LHC's development pipeline. Board Chair Emma Henry is Executive Director of Capital Area Housing Partnership, which reported total revenue of $10,811,971 in CAHP's IRS Form 990 for the fiscal year ending June 2025, EIN 38-3099281, more than twelve times its FY2017 revenue of $839,575. Commissioner Ashlee Barker is Vice President of Innovation at Cinnaire, the Community Development Financial Institution that, on the record before the Lansing City Council on November 15, 2023, the LHC executive director identified as the standing purchaser of LHC's 9 percent Low-Income Housing Tax Credits.
• The board's 2024 voting record contains one abstention. Across at least fifteen substantive resolutions in eight 2024 LHC board meetings (civic_files 9428, 9430, 9432, 9434, 9436, 9438, 9440, and 9442), Henry abstained once, on Resolution 1373, a 9 percent LIHTC application for a Williamston project naming CAHP as partner. Henry voted on every other resolution and motioned the resolution approving the executive director's annual bonus.
• No commissioner abstentions are documented for any 2024 vote on a Cinnaire-syndicated LHC project. The same set of board minutes records no recusals from Commissioner Barker in any 2024 meeting, including the meetings at which the Riverview 220, Oliver Gardens II, and Grand Vista Place LIHTC pipeline was discussed.
• The CAHP nonprofit board, of which Lansing's LHC board chair is the executive director, includes the attorney who is registered agent for the LHC executive director's prior employer and for the original Oliver Gardens limited partnership. Thomas L. Lapka of Mallory, Lapka, Scott & Selin PLLC served as CAHP board chair in the FY2023 IRS Form 990 filing and remains a CAHP director in the FY2025 filing. The CAHP board has reorganized between FY2023 and FY2025, with Peter Kulick now chairing in place of Lapka and several FY2023 directors no longer serving.

Two terms used throughout this post

Low-Income Housing Tax Credit (LIHTC). A federal program created by Internal Revenue Code §42. The federal government issues tax credits, allocated to states (Michigan's allocation is administered by MSHDA), and a developer of affordable housing applies for an award. The developer does not use the credits directly; the credits are sold to a corporate investor through a "syndicator" (in Lansing, that role is played by Cinnaire), and the cash from that sale becomes upfront equity in the development partnership. In exchange the units must remain affordable for at least 30 years. The developer earns a "developer fee" (typically 10–15 percent of the project's total cost) on completion. LIHTC is the federal program that produces most new affordable housing in the United States today.

Section 18 disposition. The federal process under 24 CFR Part 970 by which a public housing authority requests HUD's permission to permanently remove public-housing units from its portfolio. Authorities apply by demonstrating that the units are physically obsolete, that rehabilitation cost would exceed replacement cost, or that disposition is in the public interest. HUD reviews and may approve, often conditioning approval on the issuance of Tenant Protection Vouchers to displaced residents. After disposition the units are typically either sold to a private buyer (as happened with the 202 SK Lansing scattered-site homes) or converted to project-based vouchers attached to a private LDHA-structured partnership.

How LIHTC dollars move from federal allocation through Cinnaire syndication to developer fees and tenant unitsU.S. Treasuryissues federal tax creditsunder IRC §42MSHDAMichigan housing finance agency;allocates state's LIHTC shareLHC + CAHPfile LIHTC application;create LP partnership;organize GP entitytax credits(awarded)Cinnaire(syndicator)buys tax credits;pays equity to LPcash equity(into project)corporateinvestorsInvestorsclaim creditsover 10 yearsagainst fed taxesLP Partnershipbuilds or rehabs units;must keep affordableat least 30 yearsdeveloper fee(10–15% of cost)GP entityorganized by Flemingat LHC office (per LARA);collects developer feeTenantspay rent (limited to 30 percent of income); federal voucher subsidy covers the restLIHTC dollar flow. The federal government issues tax credits; MSHDA allocates Michigan's share; LHC and CAHP file partnership applications; Cinnaire buys the awarded credits and pays cash equity into the partnership; the partnership builds or rehabilitates units; the General Partner entity (in LHC's recent deals, an LLC organized by Doug Fleming, the LHC executive director, at the LHC office at 419 Cherry Street) collects a developer fee, typically 10 to 15 percent of total project cost; tenants pay 30 percent of income with the federal voucher subsidy covering the balance. Three of the four people on the dual-roles table above sit at points on this flow where paid compensation is generated: Henry (Executive Director of CAHP, the joint developer), Barker (Vice President at Cinnaire, the syndicator), and Fleming (the LHC executive director who organizes and serves as registered agent of the GP entities that collect developer fees on the partnerships LHC enters). Sources: IRC §42; MSHDA; Cinnaire; LARA filings for Oliver Gardens GP, LLC and 220 Kalamazoo GP, LLC.

What the LHC does

The Lansing Housing Commission is the public housing agency for the City of Lansing. Per the HUD Picture of Subsidized Households dataset for PHA MI058 in 2025, LHC administers 66 public-housing units (the remaining stock at Hildebrandt Park and Mt. Vernon), 2,252 Housing Choice Vouchers (the federal Section 8 program for tenant-based rental assistance), and 253 project-based vouchers (subsidies tied to specific units, including approximately 209 of the SK Lansing scattered-site homes documented in the previous post in this series). The combined federal allocation across these programs is approximately 2,318 subsidized units in Lansing.

The households in those units are concentrated at the lowest income levels in the city. Per the HUD Picture of Subsidized Households dataset for PHA MI058 in 2025, the LHC-served population is 67 percent Black non-Hispanic, 79 percent female-headed, 38 percent disabled, and 79 percent of households earn below 30 percent of Area Median Income. The average annual household income across the LHC programs is $16,426. The annual HUD outlay across all LHC programs is approximately $24.9 million, computed as 2,318 units multiplied by an average HUD per-unit payment of $896 per month.

Beyond the existing portfolio, LHC is the limited partner or development sponsor on a Low-Income Housing Tax Credit pipeline that, per LHC board minutes and MSHDA award records, exceeds $200 million in total project cost. The active 2024-2025 pipeline named in LHC board minutes includes Riverview 220 (the 220 Kalamazoo project, $22.5 million estimated total cost, $1,497,000 in 9 percent LIHTC per MSHDA's 2023 LIHTC reservation list), Grand Vista Place ($19.8 million estimated total cost per LHC board packet, October 23, 2024 (civic_file_9440), 4 percent LIHTC plus project-based vouchers), Oliver Gardens II ($1,479,466 in LIHTC per MSHDA's 2025 LIHTC reservation list), and Washington Apartments ($1,650,000 in LIHTC per the same MSHDA list). LHC's 2024 board minutes also reference an additional $60 million in HUD-funded major complex renovations (per the executive director's report at the November 25, 2024 LHC board meeting (civic_file_9442)).

The LHC board's votes, the executive director's contracts, and the partnership structures the board approves determine which projects in this pipeline move forward, which private partners receive developer fees and syndication fees, and what tenant-protection terms apply to the units that result. The board does not decide individual tenant cases, but it does decide the program structure inside which those tenant cases play out. When LHC sells a public-housing unit and converts it to a project-based voucher under a private LDHA, federal voucher payments continue to flow but the tenant's protections under public-housing law (which include eviction limits, grievance procedures, and resident-council requirements under 24 CFR Part 966) are replaced by the weaker protections that apply to project-based voucher units, as documented in the eviction filings in the previous post in this series.

Person	Role at LHC (public housing authority)	Role at CAHP (private 501(c)(3) developer)	Role at Cinnaire ($269M CDFI; LIHTC syndicator)
Emma Henry	Board Chair (volunteer)	Executive Director ($123,787 in FY2025 IRS 990)	(none)
Ashlee Barker	Commissioner (volunteer)	(none)	Vice President, Innovation (paid; per Cinnaire's published team page)
Thomas L. Lapka	(none, but registered agent for Watermark Management Group LLC, the entity at which the LHC executive director was previously employed)	Board Chair in FY2023; Director in FY2025	(none)
Doug Fleming	Executive Director (paid staff position; contract approved by the LHC board)	(none directly, but joint-development partner with CAHP on multiple LIHTC projects)	(none directly, but Fleming is also the registered agent and organizing member of the General Partner LLCs that collect developer fees on LHC's LIHTC partnerships syndicated through Cinnaire; full structure covered in the next post in this series)

The four publicly-documented dual roles. Two of the five LHC commissioners (Henry and Barker, highlighted) hold paid positions at organizations that earn fees from LHC's development pipeline: Henry as the executive director of CAHP, the nonprofit that co-develops LIHTC partnerships with LHC; Barker as a vice president at Cinnaire, the financial institution identified by the LHC executive director on the public record as the standing purchaser of LHC's 9 percent tax credits. Lapka, the CAHP chair in FY2023 and a director in FY2025, is also the registered agent for Watermark Management Group LLC, the entity at which LHC's current executive director was previously employed. The LHC executive director, Doug Fleming (highlighted), holds the agency's senior staff position while also serving as the registered agent and organizing member of the General Partner LLCs that collect developer fees on the LIHTC partnerships LHC enters; the full structure of Fleming's documented entity holdings is the subject of the next post in this series. Sources: City of Lansing Boards and Commissions roster (March 12, 2026); CAHP IRS Form 990, EIN 38-3099281, FY2023 and FY2025; Cinnaire's published team page for Ashlee Barker; LHC executive director's on-the-record statement to Lansing Committee on Development and Planning, Nov 15, 2023 (file 7246, "Minutes"). A fourth potential overlap (FY2023 CAHP Vice Chair Mary Manuel as a Cinnaire employee circa 2021) has been referenced in case-file research; the specific title and primary-source citation are pending re-verification and are not asserted here as established fact.

How the LHC works

The Lansing Housing Commission was incorporated in 1964 under the Michigan Housing Facilities Act, Act 18 of 1933, which authorizes a municipal housing commission to acquire, build, lease, and dispose of housing facilities for low-income residents within its jurisdiction. Under MCL 125.654, the housing commission is governed by a board of five members, who serve overlapping five-year terms (in Lansing's adopted ordinance, the terms are seven years), appointed by the Mayor and serving without compensation. Under MCL 125.655, the board has the authority to "elect such officers and adopt such bylaws, rules and regulations as it deems advisable," to enter into contracts on behalf of the commission, and to "appoint a director who shall not be a member of the commission."

The agency's day-to-day operations are run by the Executive Director, who serves at the board's pleasure under a contract the board approves and renews. LIHTC partnerships in which LHC is the limited partner, brownfield-tax-capture deals, and PILOT applications under MCL 211.7d all require board action before they reach Lansing City Council, as do the agency's annual budget and its annual plan to HUD (the document required of every public housing authority under 24 CFR Part 903) and any disposition of public-housing units (which under 24 CFR Part 970 requires HUD approval of the housing authority's Section 18 disposition application before the units may be transferred out of public ownership).

The five seats

As confirmed by the City of Lansing Boards and Commissions roster in effect on March 12, 2026, the five seated LHC commissioners are:

Commissioner	Seat type	Term expires	Outside paid affiliation
Heather Taylor	At-Large	June 30, 2026	Not documented in this record
Emma Henry (Chair)	At-Large	June 30, 2027	Executive Director, Capital Area Housing Partnership (EIN 38-3099281)
Ashlee Barker	At-Large	June 30, 2029	Vice President of Innovation, Cinnaire (EIN 38-3126310 and affiliates)
Loria Ann Hall	At-Large	June 30, 2030	Not documented in this record
Bryan Jones	Resident	June 30, 2028	Resident commissioner per MCL 125.654

The five seats are appointed by the Mayor of Lansing, with City Council confirmation, per the City Charter and the Lansing Boards and Commissions handbook posted on the City's website. The current Mayor is Andy Schor, who took office on January 1, 2018 and is in Schor's second term, and Schor was the Mayor in office at the time of the 2020 board approval of the Section 18 scattered-site disposition. The boards-and-commissions roster does not provide commissioner appointment dates, only term expiration dates, and from the term-expiration pattern, four of the five current commissioners would have been appointed under the Schor administration.

The current executive director

The Lansing Housing Commission is run day-to-day by an executive director who serves at the LHC board's pleasure under a contract the board approves and renews. The current LHC executive director is Doug Fleming. Fleming was appointed interim ED in September 2018 and has served continuously since. Per LHC board minutes, the LHC board approved Fleming's contract renewal on March 12, 2024 (CivicClerk event 7206) and approved an annual bonus on January 24, 2024 (CivicClerk event 7205) justified in the minutes as compensation "as in years past as stated in contract due to continued development, PHA standing with HUD etc."

Per LHC board minutes documenting Fleming's 2018 hire, Fleming was employed at Watermark Management Group LLC (LARA 801327067) for fifteen years before joining LHC. Watermark is a Lansing-area entity engaged in affordable-housing limited-partnership management. The same Watermark entity has Thomas L. Lapka, the FY2023 chair (and FY2025 director) of the CAHP nonprofit board, as its registered agent.

In addition to the LHC executive director role, Fleming is the registered agent and organizing member of at least five private business entities filed with LARA, four of which use the LHC office address (419 Cherry Street) as their registered address. Two of those entities are general-partner LLCs for Low-Income Housing Tax Credit partnerships in which LHC is the limited partner: Oliver Gardens GP, LLC (LARA 900082883, organized August 21, 2025) and 220 Kalamazoo GP, LLC (LARA 802983492, on which Fleming became the registered agent on November 6, 2023). The general-partner LLC structure, in LIHTC partnerships, is the entity that collects developer fees on the project's completion. The full structure of Fleming's documented entity holdings, the dual-signature transaction for Oliver Gardens II in August 2025, and the relationship of those entities to the federal LIHTC dollars flowing into LHC's pipeline are the subject of the next post in this series. The structural fact relevant to this post is that the LHC executive director's contract and bonuses are approved by the same LHC board on which Henry sits, and the developer fees that flow from LHC's LIHTC partnerships flow to GP entities that the LHC executive director personally organized.

How CAHP and LHC are connected

The Capital Area Housing Partnership and the Lansing Housing Commission are two legally distinct organizations that operate inside the same Low-Income Housing Tax Credit pipeline in Lansing. CAHP is a private 501(c)(3) nonprofit corporation, incorporated in 1992 (LARA 800854579) and exempt under Internal Revenue Code §501(c)(3). LHC is a public corporation chartered by the City of Lansing under the Michigan Housing Facilities Act, MCL 125.651, governed by the five-member volunteer board described above and accountable to HUD as a Public Housing Agency under 24 CFR Subtitle B, Chapter IX. CAHP raises private capital, applies for federal tax credits, and earns developer fees on the partnerships it sponsors. LHC administers federal public-housing funds and Section 8 voucher allocations, oversees the agency's owned units, and acts as a limited partner or development sponsor on the same kind of LIHTC partnerships CAHP develops.

Operationally the two organizations overlap in three documented ways. First, they co-develop affordable-housing projects. CAHP's IRS Form 990 filings identify CAHP as the developer or sponsor on the Walter French Apartments redevelopment (Walter French LDHA LP, LARA 802336812; Walter French II, LARA 802436136; Walter French III, LARA 802571381) and on a second-phase Williamston project that the LHC board considered as Resolution 1373 in June 2024 (CivicClerk civic_file_9436). Second, CAHP and LHC pursue the same federal funding sources, including MSHDA-administered LIHTC reservations and HUD program funds. Third, the two organizations share a chair-and-executive arrangement: Emma Henry simultaneously serves as the Chair of the LHC board and as the Executive Director of CAHP, on opposite sides of joint deals between the two entities.

Financially, the two organizations have moved in opposite directions across the eight-year period covered by available filings. The chart in the next section shows the inverse trajectory in summary form. LHC's public-housing portfolio fell from 833 units to 66 between 2020 and 2025; LHC's total assets fell from approximately $14 million to approximately $3.5 million per the LHC executive director's own statement to the LHC board on June 26, 2024 (civic_file_9436). Across the same period, CAHP's IRS 990 filings show revenue growth from $839,575 in FY2017 to $10,811,971 in FY2025 and asset growth from $1,149,247 to $14,590,737. Some of the federal housing-program activity that LHC formerly conducted directly is now conducted through LIHTC partnerships in which CAHP is a developer or co-developer, including partnerships in which the LHC executive director personally organizes the general-partner entity that collects the developer fee.

The board chair and Capital Area Housing Partnership

LHC public-housing units and CAHP total assets, 2017–2025LHC public-housing unitsCAHP total assets ($M)9006003001000$16$12$8$4$020172018201920202021202220232024202583366$1.1M$14.6MAcross the period in which LHC's public-housing portfolio fell from 833 units to 66, CAHP's total assets grew from $1.1 million to $14.6 million.LHC public-housing units (left axis, calendar year) and CAHP total assets (right axis, fiscal year ending June). Sources: HUD Picture of Subsidized Households, PHA MI058, 2020–2025; CAHP IRS Form 990 filings, EIN 38-3099281, FY2017–FY2025, via ProPublica Nonprofit Explorer. The 2018 and 2024 CAHP filings are omitted from the chart for clarity.

Emma Henry chairs the LHC board. Henry's paid position is Executive Director of Capital Area Housing Partnership, a Lansing nonprofit incorporated in January 1992 (LARA 800854579) and exempt under IRC §501(c)(3). Henry succeeded Rawley Van Fossen, who departed CAHP in December 2023. Per CAHP's IRS Form 990 for the fiscal year ending June 2025 (the most recent filing on ProPublica Nonprofit Explorer), Henry's reported compensation was $115,538 in salary plus $8,249 in other compensation, for a total of $123,787.

CAHP's IRS Form 990 filings show a substantial expansion of the organization across the same period in which LHC's public-housing portfolio contracted. CAHP's reported revenue grew from $839,575 in FY2017 to a high-water mark of $36,115,951 in FY2022, then stabilized at $10,161,679 in FY2023 and $10,811,971 in the most recent FY2025 filing. The FY2022 revenue spike is attributable in significant part to Emergency Rental Assistance pass-through funds the organization administered during the pandemic, per the federal ERA program design and the substantial single-year increase that does not recur in FY2023 or FY2025. CAHP's total assets grew from $1,149,247 in FY2017 to $14,590,737 in FY2025, a more than twelvefold increase. CAHP's expansion across this period coincided with LHC's contraction from 833 public-housing units to 66 and from approximately $14 million in assets to approximately $3.5 million per the LHC executive director's own statement to the LHC board on June 26, 2024 (civic_file_9436).

CAHP annual revenue, FY2017–FY2025 (IRS Form 990 filings)Revenue ($M, IRS Form 990)$40$30$20$10$0$0.84MFY2017$1.22MFY2019$1.79MFY2020$9.03MFY2021$36.12MFY2022(ERA pass-through)$10.16MFY2023$10.81MFY2025CAHP reported annual revenue. The FY2022 high-water mark of $36.12 million is attributable in significant part to Emergency Rental Assistance pass-through funds CAHP administered during the pandemic. Revenue stabilized in FY2023 and FY2025 at roughly twelve times the FY2017 baseline. Source: CAHP IRS Form 990 filings, EIN 38-3099281, via ProPublica Nonprofit Explorer. The FY2018 and FY2024 filings are omitted from the chart for clarity.

CAHP holds eighteen subsidiary entities under Henry's name as registered agent, per LARA filings. Six of those entities, including Walter French LDHA LP (LARA 802336812), Walter French II LDHA LP (LARA 802436136), and Walter French III LDHA LP (LARA 802571381), were created to develop the Walter French Apartments project (formerly the Walter French school site) into mixed-use affordable housing. The most recent CAHP-formed entities, CAHP Midland Member LLC and CAHP Embassy LLC, were formed in May and September 2025 respectively.

CAHP board composition: FY2023 and FY2025

The CAHP nonprofit board has reorganized between the FY2023 and FY2025 IRS Form 990 filings, the two filings on ProPublica's Nonprofit Explorer that bracket the period in which the SK scattered-site disposition closed and the LIHTC pipeline was approved. The FY2023 board (year ending June 2023) was the board in place at the time the disposition closed and at the time most of the 2024 LHC board votes documented above were taken. The FY2025 board (year ending June 2025) is the most recent composition reported.

FY2023 CAHP board (year ending June 2023):

Name	CAHP role	Other publicly identified affiliation
Thomas L. Lapka	Chair	Attorney, Mallory, Lapka, Scott & Selin PLLC; registered agent for Watermark Management Group LLC and the original Oliver Gardens LDHA LP, among 22 active entities (per LARA filings)
Mary Manuel	Vice Chair	Cinnaire affiliation referenced in case-file research; specific title and primary-source citation are the subject of pending re-verification
Dana Watson	Director	East Lansing City Council member
Peter Kulick	Director	Attorney, Dickinson Wright PLLC
Irene Cahill	Director	Forestry Department, City of Lansing
Michael Debri	Director	Lansing Community President, Huntington Bank
Kassie Rhodes	Director	Vice President, Dart Bank
Mark Meadows	Director	Former Mayor, City of East Lansing

FY2025 CAHP board (year ending June 2025):

Name	CAHP role	Carryover from FY2023?
Peter Kulick	Chair	Yes (Director in FY2023; promoted to Chair)
Nate Kirk	Vice Chair	No (new in FY2025)
Elvin Caldwell	Secretary	No (new)
Jim Deline	Treasurer	No (new)
Thomas L. Lapka	Director	Yes (formerly Chair in FY2023)
Irene Cahill	Director	Yes
Kassie Rhodes	Director	Yes
Mark Meadows	Director	Yes
Patricia Franklin Lindsey, Andrea Bailey, Liz Harrow, Rick Ballard, Larry Rosen, Daniel Bollman, Laura Blanding	Directors	No (all new in FY2025)

One structural point follows clearly from the FY2023 CAHP board: the chair was Thomas L. Lapka, the registered agent for Watermark Management Group LLC (LARA 801327067), the entity at which the LHC executive director was previously employed before joining LHC in September 2018, and for the original Oliver Gardens LDHA LP and 22 active limited partnerships in the Lansing affordable-housing space. Lapka chaired the CAHP board across the period in which the SK disposition was approved and closed; he remains a CAHP director in the FY2025 filing. A second potential overlap involves the FY2023 CAHP Vice Chair Mary Manuel, who has been referenced in case-file research as a Cinnaire employee circa 2021 (the same Community Development Financial Institution that LHC Commissioner Ashlee Barker serves as Vice President, Innovation per Cinnaire's published team page), but the specific title and the primary-source citation for the Manuel-Cinnaire link are the subject of pending re-verification and are not asserted in this post as established fact.

The second affiliation: Cinnaire

Commissioner Ashlee Barker is Vice President of Innovation at Cinnaire, a Community Development Financial Institution headquartered in Lansing. Cinnaire operates through three corporate entities: Cinnaire Corporation, the parent (EIN 38-3126310, $72,188,344 in total assets per its FY2024 IRS Form 990-PF on ProPublica Nonprofit Explorer); Cinnaire Lending Corporation (EIN 38-3666288, $157,269,428 in total assets per its FY2024 IRS Form 990); and Cinnaire Solutions Corporation (EIN 38-3225995, $39,701,010 in total assets per its FY2024 IRS Form 990). Combined assets across the three entities are approximately $269 million. Cinnaire's chief executive, Mark McDaniel, reported $950,737 in compensation plus $45,576 in other compensation on the FY2024 990-PF.

Commissioner Barker's employer is the entity on the buy side of LHC's tax-credit transactions. On November 15, 2023, the LHC executive director told the Lansing City Council Committee on Development & Planning, in the meeting minutes preserved on the City's CivicClerk system at event 5689 (file 7246, "Minutes"): "The LHC has been awarded a 9% tax credit over 15 years, they then take those credits and sell them to Cinnaire, a syndicating type of organization. Those dollars then go into the project; not a loan." That on-the-record statement establishes Cinnaire as the standing purchaser of LHC's 9 percent Low-Income Housing Tax Credits and the equity counterparty whose purchase converts the federal credit allocation into upfront cash for LHC's LIHTC partnerships. The LHC board votes to apply for the tax credits and to enter the LIHTC partnership; the choice of syndicator is implemented after that approval as part of the LIHTC program design. The conflict the board does directly create, by voting to enter LIHTC partnerships in which Cinnaire is the standing equity buyer, is the conflict the federal-award procurement standard and Michigan's public-servant contracts statute reach when a board member's outside paid employer is the financial counterparty on the deal before the board (see Public Housing Commission Conflict-of-Interest Standards). The 2024 LHC board minutes record no Barker recusals across the eight meetings, including the meetings at which the Riverview 220, Oliver Gardens II, and Grand Vista Place LIHTC partnerships were discussed.

Cinnaire's documented relationship with LHC extends beyond syndication. The Lansing City Council in September 2023 approved Resolution 2023-225 congratulating Cinnaire on its 30th anniversary, and Mayor Schor proclaimed August 1, 2023 as "Cinnaire Day in Lansing" (civic_file_11733). LHC purchase-agreement filings for individual scattered-site home sales in the CivicClerk system (including the agreement files documented in the case-file research underlying the previous post in this series) show Cinnaire Title Services performing escrow and title-insurance functions for LHC sales to long-tenured residents. The specific dollar value of Cinnaire's annual fee revenue from LHC across syndication and title services is not separately reported in Cinnaire's IRS Form 990-PF filings, which aggregate fee income at the entity level.

The 2024 voting record

The complete LHC board minutes for 2024 are publicly available on the City's CivicClerk system as civic_files 9428, 9430, 9432, 9434, 9436, 9438, 9440, and 9442. The full table of substantive resolutions and recorded votes is below.

Resolution	Date	Subject	Henry's vote	CAHP referenced?
1361	Jan 24	LSJ Land Purchase	Yes	No
1362	Jan 24	Baryames Land Purchase (LIHTC)	Yes	No (CCA partner)
1363	Jan 24	Annual Plan Amendment	Yes	No
(motion)	Jan 24	Executive Director annual bonus	Motioned by Henry; seconded by Barker	N/A
(contract)	Mar 12	Executive Director contract renewal	Yes (Hall motioned; Barker seconded)	N/A
1364	Mar 12	Parking lot purchase ($25K)	Yes	No
1365–1366	Mar 12	HUD CoC grants	Yes	No
1367	Apr 24	Van donation to GAPs	Yes	No
1368–1371	Jun 26	Budget, utilities, HCV, procurement	Yes	No
1372	Jun 26	Purchase 405 S Grand	Yes	No
1373	Jun 26	9% LIHTC application, Williamston, with CAHP as partner	Abstain	Yes
1374–1375	Aug 28	SEMAP, Utility Allowance	Yes	No

Across the eight 2024 board meetings, Henry abstained on a single resolution: Resolution 1373, which explicitly named Henry's nonprofit CAHP as the LIHTC partner. On the executive director's annual bonus, justified in the January 24 minutes as "as in years past as stated in contract due to continued development, PHA standing with HUD etc.," Henry made the motion and Commissioner Barker seconded it. On the executive director's contract renewal in March, the contract had expired on December 31, 2023, and Henry voted yes while Commissioner Hall made the motion and Commissioner Barker seconded. The board's procedural choice on these executive-employment matters, in which the board chair's outside paid affiliation depends on the development pipeline that the executive director runs, did not result in either Henry or Barker recusing from the vote.

The 2024 LIHTC pipeline discussed across these eight meetings, by name, included Riverview 220 (the 220 Kalamazoo project, in which the LHC executive director is the registered agent of the general-partner LLC since November 2023, per LARA 802983492), Grand Vista Place (a 4 percent LIHTC project with project-based vouchers), and the Williamston project that prompted the lone abstention. Oliver Gardens II, the partnership in which the LHC executive director signed the certificate of limited partnership both as agent of the general partner and on behalf of LHC on August 22, 2025, was not yet before the board in 2024. The complete table of LIHTC partnerships and the developer-fee flows that they generate is the subject of a forthcoming post in this series.

What the 2020 and 2021 record shows

Two public documents establish that the Section 18 disposition authorizing the SK scattered-site sale was approved at the LHC board level, even though the CivicClerk LHC packet record for the meetings in question does not yet contain the individual commissioner roll-call votes at a level of detail sufficient to publish here. The City of Lansing's Consolidated Plan 2022–2026 and Annual Action Plan 2022 (the document filed with the United States Department of Housing and Urban Development under 24 CFR Part 91 and available through the City's Documents and Resources page) states on page 44 that "through HUD's Section 18 Disposition program, the Lansing Housing Commission is selling off approximately 220 scattered sites, thereby reducing the overall amount of affordable housing stock under the jurisdiction of the public housing authority." The LHC's own Annual Plan posted on its public website identifies the Section 18 disposition as a planned action in the agency's 2020 Annual Plan and reaffirms it in the 2021 Annual Plan.

The individual board resolutions under which the disposition and successive stages were approved, and the recorded roll-call votes on each, are not reflected in CivicClerk packets archived for those meetings. The LHC commissioner roster in seat at the time of those approvals, including any individuals no longer serving, would be necessary to attribute the disposition decision at the individual level, and that roster is the subject of pending FOIA inquiry to LHC. Until that record is produced, this post documents only what is on the public CivicClerk record at the level of individual votes and what the City of Lansing has filed with HUD on the disposition as a whole.

The "perplexing" comment

The earliest documented elected-official skepticism about the SK transaction in the public record came from Lansing City Council Member Adam Hussain (Third Ward). On May 19, 2022, in a City Pulse article covering the disposition, Hussain said it was "perplexing" that the LHC executive director was proposing that LHC would continue managing the scattered-site homes after they had been sold to a private buyer, "namely because the 'headache' of managing the properties was an impetus for the sale." That observation, made on the public record by the Council member who later chaired the body that approves PILOT applications from the buyer's eventual LDHA structure, was not followed by a Council resolution requesting LHC reconsideration, and the disposition itself closed in four phases between April 2023 and February 2025 across the four-closing $14.62 million sale documented in the previous post in this series.

The 2008 record

The current governance pattern at LHC has a documented antecedent. In HUD Office of Inspector General Report 2008-CH-1008, "Lansing Housing Commission Failed to Follow HUD's Requirements," HUD OIG found that LHC, between approximately 2005 and 2007, created two limited-liability and limited-partnership entities (the original Oliver Gardens, L.L.C., and Oliver Gardens LDHA LP) without HUD's prior written approval, and pledged approximately $1.4 million in federal assets as guarantees on those entities' obligations. The 2008 report identified the same legal-instrument category (privately controlled limited partnerships in which a public housing commission is a participant or guarantor) that subsequent LHC executives, including the current executive director, have used at scale across the 2018-to-2025 period. The 2008 report's findings were not the subject of further OIG enforcement against LHC after the corrective-action period closed.

The 2008 report named the prior LHC executive director and the prior LHC board. The current LHC board includes no commissioner who served at the time of the 2008 OIG findings, per the current Boards and Commissions roster. The institutional pattern documented in the 2008 report (public housing authority entry into private LP structures with material federal asset commitments, without HUD prior approval) is the subject of a forthcoming post in this series, which examines the active LIHTC partnership entity inventory and the documented use of dual-signature transaction structures.

The political-money context

Mayor Andy Schor operates an IRS §527 political organization, the Schor Lansing Fund (EIN 83-1577483). A 527 organization can raise unlimited contributions outside the limits that apply to candidate committees, and reports its receipts and expenditures to the IRS twice a year on Form 8872 schedules. Tom Edmiston, identified in the Schor Lansing Fund's contributor records as Cinnaire's Senior Vice President, contributed $100 to the fund on March 1, 2019 per the IRS Form 8872 schedule for the 2019 first-half reporting period. The Schor Lansing Fund has also made five donations to Capital Area Housing Partnership across 2020–2025 totaling $1,090, all in the $90–$250 range and all categorized in the 8872 schedules as fundraiser tickets or event sponsorships. The full donor base, expenditure pattern, and the LHC-adjacent line items in the Schor Lansing Fund's seven-year 8872 record are documented in the third post in this series, "Federal Housing Dollars in Lansing: The Network Around the LHC".

The same individuals and institutions that appear in LHC's governance structure also appear in the political-finance record of the Mayor who appoints the LHC commissioners: Cinnaire executive money flows into the Mayor's 527 fund, the 527 fund makes recurring fundraiser-ticket donations to the nonprofit (CAHP) at which the LHC board chair is the paid executive director, and the LHC executive director's contract and bonuses are approved by an LHC board on which the CAHP executive director is the chair. The dollar values on the LHC-adjacent line items of the Schor Lansing Fund are small in absolute terms ($100 from a Cinnaire executive in, $1,090 in CAHP fundraiser donations out across five years); the structural relationships those line items document are an additional point at which the same set of entities appears across LHC governance and the Mayor's political-finance record. The full Form 8872 review is in the third post in this series.

What the rules say about these arrangements

The federal and Michigan rules that govern conflicts of interest on a public housing commission, the conduct each rule prohibits, and the body authorized to act when conditions covered by the rule are present in the public record are documented at Public Housing Commission Conflict-of-Interest Standards. The standards page covers the HUD mixed-finance development rule, the federal-award procurement standard, the Section 8 voucher conflict-of-interest rule, the Michigan public-servant contracts statute, the IRS Form 990 disclosure rules that run in place of the repealed Michigan nonprofit conflict-of-interest section, and the 2008 HUD OIG report on this same agency.

The conditions documented in this post match the conditions those rules were written to cover. The 2024 LHC board minutes record one disclosed conflict, the Henry abstention on Resolution 1373 (the Williamston LIHTC application that named CAHP as partner), and no other written disclosures of the kind the Michigan public-servant statute requires before a public servant participates in a contract with the public entity served. The 2024 minutes do not document a two-thirds supermajority vote of the kind that statute conditions any excepted contract on. The 2024 minutes do not document a HUD-approved alternative procurement plan covering Fleming's General Partner LLC arrangement. The 2024 minutes do not document the written standards-of-conduct policy that the federal-award procurement rule requires every federal-award recipient to maintain. This post documents conditions present in the public record. A finding of violation requires fact-finding by the body the rule names; that body is identified for each rule on the standards page.

How this affects Lansing renters

The structural facts above translate into specific outcomes for the Lansing residents who depend on LHC for housing. The 92 percent contraction of LHC's public-housing portfolio (from 833 units in 2020 to 66 in 2025) is not just an accounting change. It is 767 fewer Lansing households living under the tenant protections that public-housing law provides, including the eviction limits, grievance procedures, and resident-council rights set out in 24 CFR Part 966.

The 202 scattered-site homes that LHC sold to SK Lansing now operate as project-based voucher units under a private LDHA structure. Tenants in those homes are still federally subsidized, but the legal protections that applied to them as public-housing tenants no longer apply, because the units are no longer public housing. The result, documented in the previous post in this series, is twenty-nine eviction cases filed against tenants in the former public-housing scattered-site homes between June 2025 and February 2026, including a fourteen-case mass filing on January 29, 2026. The annual federal voucher payment to the SK-owned former-LHC properties is approximately $2.2 million per LHC board minutes for November 25, 2024 (civic_file_9442), none of which is conditioned on the eviction filing rate or on tenant retention.

The 2,252 Housing Choice Vouchers that LHC continues to administer in 2025 are useful only when a Lansing landlord agrees to accept them. As LHC's owned-stock portfolio has shrunk and as scattered-site units have moved to private ownership, the supply of voucher-eligible units in Lansing has shrunk with it. A voucher holder in 2025 enters a search-and-match process with fewer guaranteed-acceptance units than a 2020 voucher holder did. The HUD-reported demographics of the LHC-served population, including 67 percent Black non-Hispanic households, 79 percent female-headed households, 38 percent disabled-headed households, and 79 percent below 30 percent of Area Median Income, are the population most exposed when voucher search times lengthen.

The LHC board's procedural choices touch this situation in two specific ways. First, the executive director's annual bonus, which the LHC board approved at its January 24, 2024 meeting, was justified in the minutes as compensation "as in years past as stated in contract due to continued development, PHA standing with HUD etc." The compensation tied to "continued development" creates a financial incentive aligned with adding new LIHTC partnerships to the pipeline rather than with maintaining the 66 remaining public-housing units, the 2,252 vouchers, or the 209 SK-administered project-based-voucher units. Second, the LIHTC partnerships that the board approves and that generate the developer fees on which the agency now operates are, by program design, affordable for a fixed term (typically 30 years) rather than permanently. The units the board adds today have a federally-defined affordability expiration date; the public-housing units the board has disposed of did not.

The cumulative effect, for a Lansing renter at or below 30 percent AMI, is a smaller pool of strongly-protected federally-subsidized housing in the city, a larger pool of weakly-protected voucher-supported housing in the city, and a development pipeline that is producing units whose affordability is contractually time-limited. The LHC board did not create the federal program structure that produces this pattern; the board does, however, decide which deals inside that program structure move forward in Lansing and on what tenant-protection terms.

Who's supposed to fix this

The Lansing Mayor. The Mayor appoints LHC commissioners with City Council confirmation under the City Charter, and the Mayor in office across the period documented in this post is Andy Schor. The Mayor has prospective authority to nominate commissioners with development-finance independence from the deals the board is asked to approve, and to direct the City's planning, economic-development, and law offices to weigh that independence in advancing LIHTC PILOT applications and brownfield-tax-capture deals before Council.

The Lansing City Council. 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 hold confirmation hearings on individual nominees, to require disclosure of outside paid affiliations as a condition of confirmation, and to require, as a condition of any future PILOT approval involving LHC, CAHP, or Cinnaire-syndicated structures, public disclosure of the developer-fee flows generated by the underlying partnership.

HUD's Detroit Field Office and HUD's Office of Inspector General. The Detroit Field Office is the HUD office of jurisdiction for Michigan public housing agencies, the body that approves PHA Annual Plans and Section 18 disposition applications, and the body authorized to receive PHA officer disclosures and grant or deny conflict-of-interest waivers under the rules listed at Public Housing Commission Conflict-of-Interest Standards. HUD OIG authored the 2008 report on LHC's prior unauthorized-entity activities and is positioned to revisit the agency's current LIHTC partnership structure, including the conflict-of-interest record of the seated board.

The LHC board itself. The board has the authority under MCL 125.655 to adopt bylaws and rules. Among the rules a board may adopt is a written conflict-of-interest policy, with documented recusal procedures and a requirement that members with outside affiliations affected by a vote disclose those affiliations on the record before the vote, not after. The current board's published 2024 minutes do not document a written conflict-of-interest policy or a documented recusal protocol; the absence of such documentation in the public record is itself the subject of FOIA inquiry to LHC.

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Sources

LHC enabling statute: Michigan Housing Facilities Act, MCL 125.651–125.696c (Act 18 of 1933), particularly MCL 125.654 (board composition and appointment) and MCL 125.655 (board powers, including authority to enter contracts and appoint a director). Federal program rules: 24 CFR Part 903 (PHA Annual Plan) and 24 CFR Part 970 (Section 18 demolition and disposition of public housing). Michigan PILOT statute: MCL 211.7d. The federal and Michigan conflict-of-interest rules cited throughout this post (24 CFR §905.604, 2 CFR §200.318(c), 24 CFR §982.161, MCL 15.321 through 15.323) are documented at Public Housing Commission Conflict-of-Interest Standards.

Commissioner roster: City of Lansing Boards and Commissions roster, in effect on March 12, 2026, identifying the five seated LHC commissioners by name, seat type, and term-expiration date.

CAHP financial and governance data: Capital Area Housing Partnership IRS Form 990 filings via ProPublica Nonprofit Explorer (EIN 38-3099281), specifically the FY2017 filing (revenue $839,575, assets $1,149,247), the FY2022 filing (revenue $36,115,951, the high-water mark attributable in significant part to Emergency Rental Assistance pass-through), the FY2023 filing (revenue $10,161,679, assets $6,322,558, and the board including Lapka as Chair, Manuel as Vice Chair, and the additional directors named in the FY2023 table above), and the FY2025 filing (Henry's compensation $115,538 in salary plus $8,249 in other compensation totaling $123,787; revenue $10,811,971; assets $14,590,737; and the reorganized board including Kulick as Chair, Kirk as Vice Chair, and the directors named in the FY2025 table above). CAHP entity inventory: Michigan LARA Corporate Division filings for the eighteen CAHP-affiliated entities listed in the underlying case-file research.

Cinnaire financial data: IRS Form 990 and 990-PF filings for Cinnaire Corporation (EIN 38-3126310, FY2024, $72,188,344 in total assets, McDaniel's $950,737 in compensation plus $45,576 in other compensation), Cinnaire Lending Corporation (EIN 38-3666288, FY2024, $157,269,428 in total assets), and Cinnaire Solutions Corporation (EIN 38-3225995, FY2024, $39,701,010 in total assets), via ProPublica Nonprofit Explorer.

2024 LHC board voting record: City of Lansing CivicClerk system, LHC board meeting packets and minutes at civic_file_9428 (Jan 24, 2024), civic_file_9430 (Mar 12, 2024), civic_file_9432 (Apr 24, 2024), civic_file_9434 (May 22, 2024), civic_file_9436 (Jun 26, 2024), civic_file_9438 (Aug 28, 2024), civic_file_9440 (Oct 23, 2024), and civic_file_9442 (Nov 25, 2024). Resolution numbers, subjects, and Henry's recorded votes are taken directly from the minutes pages of those packets. The motion-and-second pattern on the executive director's annual bonus and contract renewal is from the same source.

LHC executive director's on-the-record statement identifying Cinnaire as the syndicator that purchases LHC's 9 percent tax credits: City of Lansing CivicClerk system, Committee on Development and Planning meeting of November 15, 2023 (event 5689, file 7246, "Minutes"), p. 1, verbatim quote. Resolution 2023-225 congratulating Cinnaire on its 30th anniversary and Mayor Schor's "Cinnaire Day in Lansing" proclamation: City Council Proceedings of September 11, 2023 (event 5052, file 6934, "Minutes"). Ashlee Barker as Vice President, Innovation at Cinnaire: Cinnaire's published team page for Ashlee Barker, retrieved 2026-04-26. Mary Manuel as CAHP Vice Chair (FY2023): CAHP IRS Form 990, EIN 38-3099281, FY2023; Manuel's Cinnaire title and the primary-source citation are referenced in case-file research and are the subject of pending re-verification.

Disposition documentation: City of Lansing Consolidated Plan 2022–2026 and Annual Action Plan 2022 (filed with HUD under 24 CFR Part 91, available via the City of Lansing's Documents and Resources page), page 44. LHC Annual Plan filings on the agency's public website for 2020 and 2021.

Hussain "perplexing" quotation: City Pulse, "Few tenants qualify to buy homes amid public housing shakeup," May 19, 2022 (Kyle Kaminski).

2008 HUD OIG findings: HUD Office of Inspector General Report 2008-CH-1008, "Lansing Housing Commission Failed to Follow HUD's Requirements," identifying the original Oliver Gardens, L.L.C. and Oliver Gardens LDHA LP, the unauthorized creation of those entities by the prior LHC administration, and the pledge of approximately $1.4 million in federal assets as guarantees on the entities' obligations.

Schor Lansing Fund 527: IRS Form 8872 schedules for EIN 83-1577483 (2019 H1 through 2025 H2) at forms.irs.gov. The Tom Edmiston ($100, March 1, 2019; Cinnaire Senior Vice President) contribution and the five donations to Capital Area Housing Partnership across 2020–2025 ($1,090 total) are documented from the IRS schedules in the third post in this series, "Federal Housing Dollars in Lansing: The Network Around the LHC". Earlier coverage of the fund: Lansing City Pulse, "Mayor's 'Schor Lansing Fund' swells to over $110K."

Cinnaire Title Services in LHC scattered-site sales: documented in case-file research underlying the previous post in this series, drawn from LHC purchase-agreement files in the City of Lansing CivicClerk system.