During the November 20 meeting of the board of the Connecticut Housing Finance Authority (CHFA), Dr. Harold Foley, an Atlanta-based affordable housing developer with multiple projects in Connecticut, used the public comment period to address a number of concerns he has about how the Department of Housing (DOH), and particularly DOH Commissioner Seila Mosquera-Bruno, has awarded funding to affordable housing projects over the last five years.

Foley was asking the CHFA board, on which Mosquera-Bruno serves as chairman, to suspend its upcoming round of federal Low-Income Housing Tax Credit (LIHTC) awards “to allow for a comprehensive review of issues regarding the integrity and fairness of the state’s housing funding process.”

For the past several months, Foley has sent letters to practically every lawmaker and state agency with oversight of Connecticut’s housing department, including sending around a podcast outlining his allegations. The General Assembly’s Housing Committee, the CHFA Board, some members of the Finance, Revenue and Bonding Committee and members of the State Bond Commission, have all been sent emails and letters from Foley detailing his allegations that Mosquera-Bruno is unfairly awarding additional funding to developers with whom she is associated, particularly her previous employer. He has even flown up to Connecticut and met with lawmakers personally to discuss the matter.

“We have compiled extensive evidence suggesting the improper and non-competitive allocation of over $100 million in Department of Housing (DOH) funding. Much of this funding appears to have been directed to a select group of preferred developers with close ties to the current DOH Commissioner, who also serves as Chairman of the CHFA,” Foley wrote in his letter to the CHFA Board. “It is imperative that future funding rounds proceed only under conditions of restored transparency, fairness, and integrity.”

The letter goes on to show term sheets for various affordable housing projects that were updated multiple times, claiming DOH awarded additional money to these projects outside of competitive processes and in excess of the state agency funding “cap” of $4 million per project, while requiring other developers like his own company, HF3, to adhere to that same funding cap.

Foley’s claims and evidence in his letters comprise much of his petition to the Connecticut Office of the Claims Commissioner seeking permission to sue the state for $110 million. Foley claims DOH’s “wrongful conduct” has cost him and his company millions and subjected him to arbitrary and onerous requirements on properties he has developed in Connecticut. And, he claims, Commissioner Mosquera-Bruno has a conflict of interest.

“DOH has improperly and arbitrarily obstructed, rejected and/or underfunded Claimants’ projects, which has caused Claimants to suffer financial harm and detriment, including, but not limited to lost rental income, lost developer fees, lost development opportunities, and lost capital gains from the ultimate disposition of the subject properties,” Foley wrote in his petition to the claims commissioner. “During the same time period that DOH was underfunding or disqualifying Dr. Foley’s and HF3 projects, DOH was engaging in unlawful acts to provide an unfair advantage to competing developers by granting approval and supplemental funding for other projects, including projects that were being proposed by the DOH Commissioner’s former employer.”

Prior to being appointed commissioner in 2019, Mosquera-Bruno was the executive director of the Mutual Housing Association of South Central Connecticut, Inc.(MHASCC), which goes by NeighborWorks New Horizons, and a is member of the national umbrella organization NeighborWorks America.

MHASCC has developed and manages over 800 affordable housing units in Connecticut, according to their website, and at least five of MHASCC’s projects were approved for additional funding by DOH in letters signed by the commissioner, including two projects that Mosquera-Bruno initiated when she was head of MHASCC.

According to numbers presented in Foley’s petition to sue the state, his four development projects in Connecticut received funding that averaged out to $88,590 per unit. Under the so-called “cap,” DOH provides funding for up to $150,000 per unit with a “maximum” of $4 million per project. Foley compares his funding to that of several projects that received the entirety of their project costs from DOH – largely thanks to federal COVID dollars – that averaged $324,951 per unit.

“An increase in DOH funding equates to a project being more profitable with far less risk,” Foley’s attorney Scott Orenstein writes in the petition. “In light of the foregoing, Claimants suffered financial harm and detriment as a result of the State not providing equal protection of the laws.”

DOH’s position is that there isn’t much to see here – that there are no “caps” but rather a “target investment” that “provides the development community with a starting point from which to seek other financing opportunities for their project,” according to DOH’s response to multiple questions sent by Inside Investigator.

Foley’s public comment to the CHFA board – and the letters he’s been sending around – apparently didn’t sit well with Michael Santoro, director of the Office of Policy, Research and Housing Support for DOH. 

In an unusual move, Santoro joined the public comment period to inform the board that Foley was in default of a subordinate loan for his Cherry Avenue apartment project in Waterbury, is currently facing a lawsuit, and the default “will necessarily result in any pending application of funds administered by DOH being placed on hold.” To which, Foley interjected, “what does that have to do with anything?”

The CHFA Board, apparently, also wondered what those comments had to do with the issue at hand and questioned why DOH elected to make this response in a public meeting, while not addressing the allegations.

“We had someone come in and make some pretty serious accusations and listening to it on the phone the response was to basically say that he was in bad standing.” said CHFA board member and Senior Vice President for M&T Bank Timothy Hodges. “The response that was given, not adequate. In my opinion there needs to be more.”

“Again, pretty serious accusations. If someone were to come back and say, what did you guys do or did you check into it, I don’t know that we have met that,” Hodges continued. “As board members if we don’t have a response or know what the response is, how do we do our jobs?”

The CHFA is a self-funded, quasi-public state agency that leverages private investment with public financing to get affordable, multifamily housing built in Connecticut, a prospect that has been a hot-topic at the Capitol as housing proponents, after five years of debate, finally pushed through a housing bill during a November 2025 special session that will purportedly make it easier to construct multifamily housing in suburban towns.

The state offers various incentives to developers looking to build affordable, multifamily projects, including millions in federal tax credits through its Low-Income Housing Tax Credit program (LIHTC). The LIHTC program awards a developer tax credits worth, for example, $10 million, which are then sold to private investors, thus leveraging public financing to get private dollars.

CHFA has a ceiling on how much they can award in low income housing tax credits annually, so they are awarded through a competitive process, and developers can only recoup a portion of that total per year.

Typically, affordable housing projects seeking state and federal funding will apply through this “highly competitive” process to CHFA for a 9% LIHTC tax credit award.  If selected, the project can then seek “subordinate funding” through Connecticut’s DOH to bridge financing gaps through loans or grants, along with several other incentive programs like federal subsidies, and energy rebates.

State statute gives the DOH commissioner fairly broad discretion in financing affordable housing projects, which the department does primarily through Connecticut’s FLEX funding, which offers 40-year loans that are more like grants, and the State Housing Trust Fund (HTF), which are both funded by state bonding. Despite DOH’s claim that there is no cap on agency funding, Dr. Foley and others could certainly be forgiven for thinking there is one based on DOH’s annual guidance for developers.

For instance, under DOH and CHFA’s Requirements and Instructions for the Fall 2022 Development Engagement Process, the “Limitation” section says, “Any future award of DOH state bond funding is limited to $100,000 per unit or $4,000,000 maximum per project,” which are the typical stated limitations, according to a review of CHFA’s past guidelines. 

According to DOH’s 2024 parameters for subordinate financing of CHFA approved projects, funding awards are limited to two projects per developer “due to limited resources,” and the state’s subordinate financing targets were between $100,000 and $150,000 per unit depending on whether the unit targets 50 percent of the area median income, and “a maximum of $4 million per project.”

And while DOH says these are merely “target investments,” Foley claims these figures were used as caps on his projects despite his requests for additional funding, while other projects did receive additional funding far surpassing $4 million and $150,000 per unit.

“Many developers were strictly held to this cap and denied additional funds based upon this rule,” Foley said to the CHFA Board.

When Foley requested $1.7 million in additional funding for his Cherry Avenue project in April of 2020 to help cover the costs of environmental remediation work imposed by DOH and the Department of Energy and Environmental Protection (DEEP), he was told there wasn’t enough money to go around. “Unfortunately, the Department does not have any additional funds at this time to assist you in filling this gap,” Santoro wrote in an April of 2020 email.

Foley’s projects all received tax credits through the CHFA and funding from DOH in amounts less than the stated guidelines for that year: his Brookside Commons project in 2022 received $3.8 million; his Rocky Neck project received $5.2 million in 2019 when the guidelines set agency funding at a maximum of $6 million; and his 2017 Cherry Avenue apartments received $3.2 million.

And it certainly appeared that other developers, including MHASCC, believed they could only get a maximum of $4 million for a project; it’s part of Foley’s critique of how DOH awards funding.

In 2021, MHASCC applied for CHFA’s 9% LIHTC round. Although typically only six to seven projects are selected through this process per year, this year CHFA expanded the number of projects to ten. CHFA is allowed to expand the number of projects awarded LIHTC by drawing down on the following year’s allocation.

After being denied the 9% LIHTC in the 2020 competitive process, MHASCC’s Linden Street Apartments project in Waterbury came in last place for the 2021 LIHTC awards. The organization then applied to DOH for $4 million in agency funding. According to the October 2022 term sheets, DOH provided $3.77 million in FLEX funding, $1.76 million from the State Housing Trust Fund, already putting the agency funds well over $4 million.

By April of 2024, however, the term sheets and funding amounts had been amended three times and DOH’s contribution to the project grew. DOH had added an additional line of FLEX funding for $874,000 and added $1.5 million from the State Housing Trust Fund. That put the total agency funding at $7.9 million or roughly $180,000 per unit in the 44-unit apartment building.

This pattern is repeated across multiple projects with multiple term sheet amendments in which DOH’s contribution continues to increase well past the per project “maximum” for that particular year, including for projects that DOH Commissioner Mosquera-Bruno originated when she was head of MHASCC.

In 2019, when the stated “maximum” was $6 million, MHASCC was approved for $5.8 million in DOH funding for their River Breeze Commons project following a successful bid for CHFA’s 9% LIHTC, according to a letter and term sheet sent from former DOH Commissioner Evonne Klein to then MHASCC Executive Director Mosquera-Bruno. 

In a term sheet amendment in 2022, DOH added an additional $1.2 million from the state’s HTF, according to a letter from now-Commissioner Mosquera-Bruno to her successor at MHASCC, Tom Cruess.

Similarly, MHASCC’s 2014 Spruce Meadows project, also launched under Mosquera-Bruno’s tenure, originally received $4.9 million in agency funds. Spruce Meadows was one of two planned apartment complexes in Pawcatuck, the other being Spruce Ridge, which was separately awarded $3.5 million in agency funds. Together, the two complexes would host 86 housing units.

However, the project and its funding went through multiple amendments between 2014 and 2024, and agency funding for Spruce Meadows grew from $4.9 million to $8.5 million through a combination of FLEX and HTF funds. Spruce Ridge had increased from $3.5 million to $8.3 million through the addition of federal HOME block funding and a National Housing Trust Fund grant. Part of those increased payments covered a $2.2 million settlement with the previous contractor and $300,000 for investor withdrawal, according to the budget sheets.

That puts agency directed funding for the total projects at roughly $195,000 per unit. DOH originally listed the complexes as containing 129 units in their 2024 Governor’s Report, even though MHASCC only listed 86 units online. When Foley questioned DOH about this in a July 2025 email, DOH insisted there were 129 units. The agency now says that figure was a “data entry error” that has since been corrected.

Lastly, in 2025, when DOH and CHFA guidelines indicated a “maximum of up to $4 million per project,” Eastern Connecticut Housing Opportunities, Inc. (ECHO) received $8.2 million from DOH FLEX funds to acquire two properties in Uncasville dubbed The Village, with no accompanying CHFA tax credits or other sources of funding listed on the term sheet.

ECHO is another housing nonprofit whose CEO Julie Savin has at least a passing relationship with Mosquera-Bruno, having worked as MHASCC’s director of real estate development between 2008 and 2017. ECHO, like MHASCC, was also the beneficiary of COVID taxpayer funds that were used to pay for the entirety of some of their projects, despite claims by the agency that state funding draws in private funding.

Part of the reasoning behind setting a target investment for DOH funding is to encourage developers to seek additional sources of funding, including private investment. A DOH press release touting the State Bond Commission’s approval of $140 million for DOH FLEX funding claims every dollar of state investment generates another five dollars in investments.

That private investment comes through LIHTC and the CHFA, so funding a project that has not qualified for LIHTC, or fully funding a project with only DOH money, essentially leaves millions in private investment dollars on the table.

As the state was flooded with federal COVID dollars, state agencies officials began to offload the money quickly by dumping one-time funds into projects. DOH was no different when it came to some affordable housing projects, fully funding developments that were rejected for CHFA’s 9% LIHTC, and, naturally, skyrocketing the cost per unit well above the target investment of between $100,000 and $150,000.

According to the latest DOH Governor’s report, when only accounting for FLEX funding, the average award per project is roughly $3 million with a median award of $2.9 million. When accounting for all funding sources, including federal COVID relief money sent to Connecticut through the American Rescue Plan Act (ARPA), the average jumps to $6.3 million per project, but the median remains the same, meaning a small subset of projects received much higher funding rates, driving up the average as DOH pushed to get projects completed with one-time funds.

“Total DOH investment in some projects comes from a variety of state and federal sources, including some onetime and/or time-limited funding which when leveraged, accelerate affordable housing opportunities to completion,” DOH wrote in response to Inside Investigator questions, noting that the ARPA funds were meant to provide affordable rental housing and services for vulnerable populations. “These were first-of-its-kind direct investments through the US Treasury. These funds were time sensitive to commit.”

Jack’s Farm, for instance, is a MHASCC project in Cheshire that applied for LIHTC funding for their 2023 round but did not receive an award. Nevertheless, DOH in 2024 funded the entirety of the project through a combination of $6 million in FLEX funding, $5.9 million in federal ARPA funds, and $8.9 million in State and Local Fiscal Recovery Funds, which were also under ARPA.

Although the FLEX funds are technically loans, the federal dollars were grants. Although the project wasn’t successful in their bid for LIHTC funding, DOH says that doesn’t mean the project isn’t worth financing. Those ARPA funds boosted the investment to over $500,000 per unit for the 45 new units of housing.

ECHO similarly received $5.1 million in FLEX funding and $6 million in ARPA funds in 2024 for construction of 64 units in New London, at a price of $187,442 per unit. The Chrysalis Center Housing Development Corporation received nearly full funding for two projects – the acquisition and redevelopment of an unoccupied building in New Britain at a cost of $5.6 million and construction of new affordable units at a cost of $11.1 million, a combination of $4 million in FLEX funding and $7 million in ARPA.

Lastly, there was Park City Place in Bridgeport, a project in which a former Holiday Inn was converted into apartments by developer John Guedes, who said in a Connecticut Post article that he “knows Mosquera-Bruno well and the topic of a possible sale had come up in ‘off the cuff’ conversations.” 

Guedes is the founder of Primrose Companies, Inc, which is listed as one of MHASCC’s largest contractors on their 2023 tax forms. Mosquera-Bruno is quoted on Primrose’s website as executive director for NeighborWorks praising the company’s expertise and stating that NeighborWorks “chose Primrose Companies Inc as preferred developer for three properties.”

DOH awarded the full cost of $22 million to the Mutual Housing Association of Southwestern Connecticut, also known as Connecticut Housing Partners (CHP), to purchase the property and maintain it as affordable housing. Of note, CHP is also a member of the national umbrella organization NeighborWorks America.

DOH says that despite the high price tag, the terms of the 40-year loan to CHP make Park City Place a net overall gain for the state and that it saved time and money because it was a conversion rather than a new construction.

“Although this is a larger than standard outlay of funds, the Department has structured this transaction as a net cash flow loan that, unlike many of the LIHTC opportunities, will result in annual payments to the Department based on 75% of the NET operating income,” DOH wrote in its response. “It is anticipated that this financing will be fully repaid over the 40-year life of the project.”

Part of Foley’s argument, however, is that if the state of Connecticut is counting on getting five dollars of private investment for every one dollar of state support, fully funding projects without LIHTC support is essentially forfeiting millions in potential private investment and eating up a diminishing pool of bonded money that could be used to fund even more affordable housing. He claims that fully funding these projects is essentially leaving hundreds of millions in private investment on the table.

Indeed, DOH’s October 30, 2025, press release touts tens of millions in private investments for affordable housing projects through the 9% and 4% LIHTC awards. DOH indicated agency support of $16.5 million for 150 new units of affordable housing in New Haven, along with LIHTCs “that will attract $29.6 million in private investment.” 

“The Department utilizes a variety of state and federal resources that are available at the time of application,” DOH wrote to Inside Investigator. “Additionally, developers will seek other funding sources such as the Federal Home Loan Bank, Syndicators, CHFA and the other private resources.” 

Central to Foley’s petition to sue the state and his allegations against DOH and Commissioner Mosquera-Bruno is his Cherry Avenue Apartment project in Waterbury, a development for which Foley and his partners received 9% LIHTC funding and $3.2 million in DOH funding in 2015. 

Foley is claiming in his lawsuit that after receiving approval and funding for the project, DOH and DEEP then placed onerous and unnecessary environmental remediation requirements to remove contaminated soil, costing far more money than budgeted. 

Foley had provided an environmental assessment for the Cherry Avenue project by the engineering firm Fuss & O’Neill to both DOH and CHFA that indicated the environmental remediation could be handled with a $58,000 barrier and would not require the removal of contaminated material. According to the petition, “DOH and CHFA allowed the project to move forward to the next phase without raising any objections or requesting any clarification regarding the contaminated materials and/or the course of action that Fuss & O’Neill had proposed.” 

Foley claims it was only after the approvals and the contracts were signed that DOH required the Cherry Avenue project to enter the DEEP’s Brownfield Remediation and Revitalization Program. DEEP said all the contaminated soil would have to be removed at a far greater cost that, had Foley known this ahead of time, would have “made the project financially unfeasible.”

Foley says at that point he couldn’t back out of the deal “without incurring significant contractual liabilities,” and “had no other option” than to move forward. He was then denied additional funding by DOH and other state agencies to help mitigate the cost under the guise there wasn’t enough money to go around while DOH simultaneously awarded extra funds to projects like MHASCC’s Linden project.

Foley claims the losses his company sustained because of DOH officials’ treatment of the Cherry Avenue apartment development caused further problems down line, leading to projects having to be abandoned or delayed for years. He developed two more projects with LIHTC and DOH funding but states those projects could have been more financially successful had he been provided the additional funding given to other similar projects.

Then in 2020, Foley claims another proposed project in Simsbury was rejected because DOH said it was located on a floodplain, despite an engineering report indicating that the location was neither in a 100-year nor 500-year floodplain, according to Foley’s petition, and asserts the real reason for his denial “was far more nefarious.”

Then, in 2021, as the COVID pandemic drove up costs, Foley and his partners were awarded LIHTC funding and DOH funding for a proposed project in Terryville called Oak Wood Apartments. According to the petition, DOH indicated that it would be able to provide additional funding to help cover the escalating construction costs at a time of record high inflation.

However, when Foley and his partners reached out to DOH for an additional $650,000 to cover “COVID cost increases,” they were denied due to the “non-compliant status of the Cherry Avenue project.” Foley was being sued for defaulting on his loan to buy the property.

DOH’s denial forced Dr. Foley to withdraw as developer in the Oak Woods project, which then moved on without him, but it cost him three years of development work and money. Foley claims that DOH’s citation of the Cherry Avenue issues is “egregious” because of the extra and unnecessary environmental costs imposed on him by DOH and their refusal to help him cover those costs. 

He then began to demand funding commensurate with other, similar projects that had received more support, including COVID funds, and when that didn’t happen, he began doing the research that would eventually lead to his petition to sue the state for financial losses due to disparate treatment.

“From the very first time that I heard about this and looked at this, it seemed pretty clear there was disparate treatment between Harold and other people seeking the grants and funding,” said attorney Scott Orenstein, who is representing Dr. Foley in his petition. “It certainly seemed like there is something there that could be actionable so we got into it, did the research, and we felt that there was a legally cognizable claim we could pursue.”

Cherry Avenue is central to DOH’s rebuttal that Dr. Foley is essentially a scorned developer who is angry over being denied funding for additional developments because he is “being sued by a creditor for a project that DOH previously funded.”

“Mr. Foley was told several times verbally and in writing that he needed to pay off his debt yet in more than two years he had failed to act,” said DOH Director of Marketing and External Affairs Maribel La Luz in an email. “While we understand some developers may not agree with our decision to deny their application for funding, and may even be unhappy, running to media, making false claims to try and bully us is both unprofessional and inappropriate. DOH takes its responsibility as a fiduciary and administrator of government funds seriously. Despite all of this, as we have communicated to him on several occasions, Mr. Foley is welcome to reapply for DOH funding once he resolves his debt and is back in compliance.”

According to the lawsuit against Foley, filed in March of 2023, he allegedly owes roughly $300,000 to BPS Realty LLP for the remaining principal and additional fees for the original purchase of the Cherry Avenue property. Foley counters in court documents that BPS “failed to properly disclose that the subject property was contaminated and required remediation,” and that he was “not made aware of the contamination and required remediation until shortly before the scheduled closing.”

According to a January 30, 2023 letter from Mosquera-Bruno to Foley, however, the DOH commissioner indicates that brownfield remediation “appears to have been contemplated from the onset,” and that there was a $600,000 line item in the term sheet, and that enrolling the property in DEEP’s brownfield program was “memorialized in a letter,” from the Department of Economic and Community Development “more than 2 months prior to the closing of the DOH funding.”

“While I recognize that the Borrower has faced challenges in developing housing at the Property, including financial challenges due to the environmental condition of the property, DOH does not currently administer any funding programs for such environmental activities,” Mosquera-Bruno wrote. “Please be advised that the existence of an outstanding Event of Default will necessarily result in any pending applications for funds administered by DOH being placed on hold, until such outstanding Event of Default has been cured.”

Foley’s case is set to go to trial, and after these issues are fully resolved, DOH says Foley can again start submitting projects for approval.

However, while Foley was being denied additional funding and forced to walk away from projects due to this court case, the same was not true for the MHASCC, which not only received additional funding but also received awards fully funding their projects while facing a similar lawsuit.

In 2021, MHASCC was awarded $3.9 million in DOH assistance to rehabilitate their Richard Street project, which encompassed nine buildings and 23 housing units in New Haven — what is called “preservation funding.” MHASCC did not, however, apply for, nor receive, LIHTC through CHFA, which reserves tax credits every year to rehabilitate affordable housing units.

In May of 2023, just two months after the lawsuit was filed against Foley, Key Bank filed a lawsuit against MHACC, also naming DOH, for allegedly defaulting on a $350,000 mortgage signed by Mosquera-Bruno in 2011 for their Richard Street development. MHASCC claimed in court documents that it had been making payments and that Key Bank was at fault for not recording those payments. The matter was eventually settled in June of 2025, according to court records.

However, between May of 2023 and June of 2025, during which the lawsuit was pending, MHASCC received an additional $874,000 in FLEX funding for its Linden Street project, and $21.6 million for their Jack’s Farm project. Additionally, as indicated before, in 2022 DOH provided $2.1 million in additional funding to MHASCC whose budget included covering the organization’s settlement costs with a previous contractor and investor withdrawal.

According to state statute, eligible costs for DOH financing means “costs relating to the planning, implementation and completion of an eligible project.” DOH, however, says the settlement and investor withdrawal costs constituted “legal fees” and other “soft expenses,” which they say are allowable expenses.

“We feel, obviously, that there were things done that certainly lead to potential causes of action that we felt should be adjudicated,” Orenstein said. “If we get by the claims commission, we’ll sue the state and a court will decide.”

If the $4 million per project “maximum” is indeed a cap, DOH certainly doesn’t hide the fact that they regularly fund projects over that amount. In just their latest press release, six projects received funding over that amount, including the $22 million Park City Place purchase and the $8.2 million in funding for ECHO to purchase the Village in New London. Still, the language contained on CHFA’s website certainly lends itself to interpretation as a cap.

The press release about newly financed affordable housing projects from July of 2025 contained five projects with more than $4 million in DOH funding, including, ironically, the Oak Woods project in Terryville that Foley was forced to walk away from due to his ongoing court case. According to the press release, Oak Woods received the 9% LIHTC and $6.3 million from DOH for 47 affordable units.

While DOH claims the “maximum” is instead a target investment that can be adjusted depending on the size and scope of the project, Orenstein says that is something a court should have the opportunity to weigh in on: “If that’s what they want to claim it is, the plain language would seem to be the opposite of that.”

The cost to build housing in Connecticut isn’t going down, and following the inflationary pressures of the COVID era, building affordable housing to be rented out at below-market rates is not feasible without state and federal subsidies. The State Bond Commission allocates roughly $800 million toward affordable housing funding every two years, so there is plenty of money to go around, but there are only so many projects the market can support in a given year because there is a limited number of developers and these deals take years to finalize.

CHFA Board member Timothy Hodges had asked for a better response from DOH, and, in response to Inside Investigator’s questions, DOH officials stated that there are no financial ties between Mosquera-Bruno and any of the organizations that receive funding and therefore no ethical violation.

“Regarding [Foley’s] suggestion that there is a conflict of interest, per State Ethics that would mean DOH and/or our commissioner have financial ties to a partner organization (e.g. stock ownership, continuing employment, or other current financial interest, etc.,) none of that is the case and is easily verifiable,” La Luz wrote in an email. “DOH provides resources to nonprofits all over the state, it’s central to our work and mission to provide high quality affordable housing to our most vulnerable residents who need it.”

With housing proponents arguing the state needs 100,000 new units of affordable housing to help lower the overall cost of living in the state, including rent, they claim now is the time to turbo-charge the state’s affordable housing investments. Foley, instead, is asking the State Bond Commission to suspend allocating any more bonded funds to DOH for affordable housing until an investigation is completed.

“I have uncovered evidence of inappropriate funding practices by the DOH involving a select group of developers with professional ties to the current Commissioner. These actions appear to constitute significant conflicts of interest and cronyism,” Foley wrote in his November 28 email to members of the Finance, Revenue and Bonding Committee. “I believe an immediate investigation into these matters is required to protect state resources.”

According to agenda for the December 18 State Bond Commission meeting — which was delayed by a week — DOH is drawing down on funds for several programs, including $37 million for FLEX funding out of a $100 million allocation, and $42.5 million from the $1 billion set aside for the Housing Trust Fund.

“These funds will provide financing for new construction and or rehabilitation of over 100 housing units and for immediate needs in existing housing projects, including those in the Connecticut Housing Finance Authority State Housing Portfolio,” the agenda item states. “Funds may be allotted to and disbursed by the Connecticut Housing Finance Authority as directed by the Department of Housing.”

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