Report on the Implementation of the Russian Officer Resettlement Certificate Program

Participants Guide to Program Procedures 
This guide is designed as quick reference for program procedures, which were described during the briefing session. 
Keep this information to refer to as you progress through the steps to purchase your new home.
1.
Registration of Your Certificate.  Your first stop with your new certificate and funding form is the bank, or
the bank's representative at the briefing. In many cases you will be able to do this on the same day as the briefing. 
You must present your certificate and your bank funding information form to the bank and give the bank one copy of
each.  The bank will ask you to show your passport or military identification and will also verify your certificate
against the master certificate log.
2.
Bank Funding Letter.  The bank will also give you a letter stating:
-
The monthly value of your certificate for three months for new construction and three months for
existing housing
-
The Certificate issue date
-
The Certificate expiration date
3.
Terms and Conditions.  The Bank will give you a copy of the program terms and conditions which must be
met before the bank will release funding for your purchase.
4.
Return a Copy of the Bank Funding Letter.  The bank will ask you to return a form stating that you
understand the terms and conditions which must be met to obtain funding.
5.
The Search for Housing.  You will have one month to sign a presales agreement for purchase of a home.  If
the projected date of completion of the unit you plan to buy is more than three months past the issue date of your
certificate, plan to return to the bank after the first month to update the value of your bank funding commitment. You
will then know the maximum certificate value for the full four months of the certificate.
6.
Once You Have Found Housing You Would Like to Purchase.  You and the seller should prepare a presales
agreement for submission and review by the bank.  Upon receipt of this proposed agreement, the bank will schedule
a joint inspection by the bank's engineer, the municipal/oblast construction inspector (if applicable), the seller, and
you.  If the unit is under construction,  the bank's engineer will determine what needs to be done for the house to be
completed and receive a certificate of occupancy.  If the unit is not new, the bank engineer will complete an
inspection form for your information.
7.
Following the Inspection.  The bank's engineer will prepare an agreement for you, the seller, the
construction inspector, and the bank's engineer to sign showing all  have agreed on what must be done before the
unit will be completed.  This document will be attached to the presales agreement.  The bank will advise you in
writing if the engineer determines the house cannot be completed within three months.  An opinion by the bank that
the unit cannot be completed on time does not prevent you from signing a presales contract to purchase that unit, it
merely would advise against that course of action.
8.
During the Construction Period, you should contact the bank every 30 days to keep the bank informed as
to the likely date when the unit will be completed and closing of the sale can occur.
9.
Certificate of Occupancy.  When the house qualifies for a Certificate of Occupancy, the purchase can
proceed.
10.
If You Do Not Sign a Presales Agreement within one month, the bank will notify the municipality and your
certificate will expire unless the bank is still reviewing your presales agreement, but has not yet issued an opinion.  In
that case you will have an additional ten days following receipt of the bank's opinion to sign a presales agreement.

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11.
If You Find Already Completed Housing which has never been occupied, you may agree to purchase such
housing and the process will proceed much more quickly.
12.
Completing the Purchase.  In order to complete purchase, the bank will collect all substantiating program
documents and submit them to the program reviewer.  These include:  the papers you submitted to the municipality
to prove your eligibility; family size; intent to vacate your Baltic residence; if applicable the records of the bank's
actions; the Certificate of Occupancy; if applicable, proof that the seller has the legal right to sell the property to
your, and information of the funding needed to purchase the unit.
13.
Preparation for Closing.  You will be responsible for paying all taxes, notary fees, and fees associated with
the registration of the deed to the property.  The applicable fees and the amount of such fees vary from jurisdiction
to jurisdiction, but generally are based upon a percentage of the sales contract.  Once the bank has been notified
that the reviewer has approved the release of funding, the bank will assist you in providing the necessary
documents and undertaking the necessary activities associated with paying these taxes and fees. 
14.
Closing the Purchase.  When the bank receives approval from the reviewer, it will disburse funds.  The
bank will pay the seller the contracted cost of the unit or the value of the certificate, whichever is less.  If the cost of
the housing is greater than the value of the bank's funding, you must pay the difference to the seller at closing. The
seller must sign a document stating he has been paid all the funds he is entitled to. 

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Glossary of Terms: 
BTI:
Bureau of Technical Inventory:  Agency responsible for recording technical information of
housing (floor plans to sales records.)
IMC:
Interministerial Committee for the Implementation of the State Program “Housing”
ISB:
International Standard Bank, a term used by The World Bank, in assessing the quality of banks in
Russia.
LAU:
Local Administering Unit, or banks
MINSTROI:
State committee on architecture and Construction, formerly known as GOSSTROI.  It is the ministry
of construction 
MOU :
Memorandum of Understanding
MOD:
Ministry of defense
Oblast:
An administrative region in Russia (province)
Propiska:
A residential permit.  Russians during the Soviet period had to have a propiska to reside in any
city.  Officially only Moscow and St. Petersburg require propiskas.
PW:
Price Waterhouse Inc.
RFP:
Request for proposals
State AKT:
The certificate of occupancy, issued by a committee formed by and headed by the Oblast
department of construction
UI:
Urban Institute

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185
Program Description 
Russian Military Officer Resettlement Program
Housing Certificate Program
 
In response to agreements between the President of the United States of America and the President of the  Russian
Federation in April and July of 1993, the governments of the two countries have agreed to undertake a project
designed to provide up to 5,000 units of housing for Russian military officers demobilized from the Baltics or
elsewhere outside Russia, and to support reforms in the Russian housing sector.  The governmental agencies
responsible for implementing this project are the United States Agency for International Development (USAID) and
on the Russian side, the Interministerial Committee for the Implementation of the State Program "Housing" (IMC). 
Among the 21 members of the IMC,  the State Committee on Architecture and Construction (MINSTROI) has been
designated as the lead agency.  Of the project's five thousand housing units to be provided, 2,500 will be provided
through a direct construction program involving American and Russian building companies.  The remaining 2,500
units will be provided through a housing certificate program.
Under contract to USAID, Abt Associates is responsible for implementing  the main housing certificate program that
will deliver 2,000 housing certificates in approximately six Oblasts to demobilized Russian military officers and their
families currently living in the Baltic Republics of Latvia and Estonia.  (A pilot program involving 500 certificates has
been undertaken in Pskov and Yaroslavl, and is being managed by the Urban Institute and Quadel Consulting
Corporation).  Officers selected for the program may use their certificates to purchase either new or existing housing
units in selected municipalities.  The funding value of a certificate may not exceed $25,000, and may be less,
depending upon prevailing housing prices in the oblast and the size of the unit required.
Program Overview
The housing certificate project will select those Oblasts, that have sufficient capacity to supply housing units to
returning officers within the time and cost limits specified.  With the approval of the IMC, Abt Associates will
designate a local bank in each selected oblast for administration of the certificates and distribution of funds . The
housing certificate entitles an officer to a certain amount of money to be used only for the purchase of a new or
existing dwelling unit of the size to which his family is entitled. Upon his registration in the program, each officer is
provided a bank funding letter showing the certificate values for the unit size for which the officer qualifies.  These
values, for both new and existing housing, are projected for a period of three months, based on recent price trends.
Each municipality participating in the certificate program will be responsible for verifying officer eligibility, enrolling
them in the program, and for explaining how the selection and purchase of dwellings is to be carried out.   The
Program Reviewer, Price Waterhouse,  is under contract to Abt Associates to review and approve all required
program documentation prior to the disbursal of funds .
Eligibility Requirements
Participation in the Housing Certificate Program is strictly limited to officers demobilized and discharged from military
service in the Baltic republics or other countries outside Russia.  The eligible population is separated into the
following three categories:
1) 
At least 80 percent of the recipients must be Russian military officers who were demobilized and
departed from military service in the Baltics on or after January 28, 1992;  
2) 
No more than 10 percent of the recipients may be officers demobilized and departed in the Baltics
before January 28, 1992;  
3) 
No more than 10 percent of the recipients may be officers demobilized and departed from military
service in other countries besides the Baltics on or after April 2, 1993.

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No more than 10 percent of the total number of beneficiaries across all three categories can be selected by local
authorities.
Guide to Program Procedures
Officers from Latvia and Estonia who are selected to receive housing certificates will be designated by the Office of
Social Assistance, Ministry of Defense, and will be grouped as much as possible according to their preferences
among the Oblasts selected for the program.  Each group of 30-50 officers will visit their selected oblast together, and
will have a designated Coordinating Officer who will be responsible for making the initial contact with the oblast to
which his group is assigned, for maintaining communications with the members of his or her group, and for
performing all necessary administrative tasks to ensure that documentation is in order and delivered promptly on
behalf of the officers.  A listing of required documentation is attached to this program description.
On the officers' first trip to the oblast, the group will participate in an informational seminar where they will be given
details of eligibility and other program requirements, and will be interviewed individually by municipal/oblast
housing officials.  When an individual's program application and documentation proving eligibility is complete,  he
will receive his housing certificate.  Each officer will then register his certificate with the local administering bank, and
will visit available housing units with other members of his group or by himself.  The bank will maintain all program
documentation and individual records for each officer.
Within one month of receiving their certificates, officers must find a housing unit, negotiate the price, and sign a
presales contract  with the offeror or owner of the unit. This contract will define the terms and conditions of the sale,
and will commit both the buyer and the seller to complete the purchase transaction within three months (or one
month if it is an existing unit).   The bank will assure that all contractual and program requirements have been met,
and the Program Reviewer, Price Waterhouse,  will verify that all documentation is complete before the final
disbursement of funds. 

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List of International Standard Banks 
BANKS
HEADQUARTERS
 ADDRESS/TELEPHONE
Baltiyiskiy Bank
St. Petersburg
Mr. A.E. Lovjagin  CEO
34 Sadovaya St.  St. Petersburg
Tel [phone] 
Fax [phone]
Bank St. Petersburg
St. Petersburg
Mr. Y.I. Lvov  CEO
70-72 Reki Fontanki Nab. St. Petersburg
Tel [phone]
Fax [phone]
Inkombank
Moscow
Mr. V.V. Vinogradov
  CEO
14 Nametkina St. Bldg. 7  Moscow
Tel [phone]
Fax [phone]
Menatep
Moscow
Mr. M. Khodorkovsky  CEO
4 Kolpachny Pereulok  Moscow
Tel [phone] 
Fax [phone]
Mosbusinessbank
Moscow
Mr. V.L. Bukato CEO
15 Kuznetsky Most  Moscow
Tel [phone] 
Fax [phone]
Petrovsky Bank
St. Petersburg
Mr. Y.V. Golovin  CEO
8 Ruzovskaya St.  St. Petersburg
Tel [phone] 
Fax [phone]
Tokobank
Moscow
Mr. V.K. Yakunin  CEO
7 Mashy Poryvaevoy St. Moscow
Tel [phone] 
Fax [phone]
Tveruniversal
Tver
Mrs. A.M.Kozyreva CEO
43 Volodarskogo St.
Tver
Tel [phone] 
Fax [phone]

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Sample Memorandum of Understanding: 
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE UNITED STATES AGENCY FOR INTERNATIONAL DEVELOPMENT
AND
THE INTERMINISTERIAL COMMITTEE ON THE REALIZATION OF
THE STATE PROGRAM HOUSING
OF THE RUSSIAN FEDERATION
AND 
THE MUNICIPALITY OF ST. PETERSBURG
FOR
ISSUANCE OF CERTIFICATES FOR OFFICER HOUSING
ARTICLE 1. PURPOSE
The United States Agency for International Development ("A.I.D."), the Interministerial Committee for Realization of
the State Program "Housing" of The Russian Federation ("IMC"), the of St. Petersburg ("Municipality") hereinafter
referred to as the Parties, wish to cooperate in a mutual effort to provide housing for demobilized Russian Officers
principally from the Baltic States through a housing certificate program.
This Memorandum of Understanding is entered into pursuant to the Project Grant Agreement between the
Government of The United States of America and the Government of the Russian Federation for an Officer Housing
Program dated July 29, 1994 ("Officer Housing Program Agreement"), and the Agreement Between the Government
of the United States of America and the Government of the Russian Federation Regarding Cooperation to Facilitate
the Provision of Assistance, dated April 4, 1992, and is governed by terms and conditions of those agreements.
In accordance with the Officer Housing Program Agreement, A.I.D. has agreed to provide housing certificates for
Russian military officers demobilized from the Baltics and elsewhere outside Russia, and to support reforms in the
Russian housing sector, and the IMC has agreed to coordinate and cooperate in the implementation of the Program. 
The purpose of this Memorandum of Understanding (hereinafter referred to as the "Memorandum") is to set forth
the agreed understandings and undertakings of the Parties named above with respect to the administration of the
Housing Certificate Program in St. Petersburg, Municipality. 
ARTICLE 2.
UNDERTAKINGS OF THE PARTIES
Section 2.1
 A.I.D.  will furnish technical assistance and administrative direction for the Housing Certificate
Program, according to which _____ housing certificates for the demobilized Russian officers are allocated to St.
Petersburg.  A.I.D. will supervise the distribution of housing certificates. 
A.I.D. assistance will be provided through a Housing Certificate Program management firm under contract
with A.I.D. (the "General Contractor") which, in turn, will negotiate with a bank to manage key aspects of the
Program and provide program manuals that specify certificate distribution procedures.
Section 2.2
The IMC will be responsible for coordinating the participation of all Russian Government entities
in the Program.  The IMC will:
(a)
In conjunction with Municipality authorities and the designated representatives of the Ministry of
Defense of The Russian Federation, and in accordance with the criteria for beneficiary selection set forth in the
Officer Housing Program Agreement as clarified in this Memorandum, identify the eligible officers to be provided
housing in accordance with Section 2.3 (b) of this Memorandum; and provide A.I.D. with the list of proposed
beneficiaries describing how each meets the above eligibility criteria;

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(b)
Assist A.I.D. in the prompt resolution of problems arising during the course of the program under
this Memorandum, including : resolution of any problems which might arise between the Parties to this
Memorandum; resolution of problems encountered with any agencies of the Russian national, regional or local
governments assistance with any problems with local banks or other private, local implementing agencies;
assistance to assure that vouchers and beneficiary officers and their families are exempt from all national, regional
and local taxation pursuant to the Officer Housing Program Agreement;
Section 2.3
Responsibilities of the Municipality.
(a)
The Municipality agree that they will:  
(1) take overall responsibility for the administration of the certificate program within The Municipality.  The
Municipality will assist in obtaining the participation of officials, developers, banks, and other parties needed for the
implementation of the program.  St. Petersburg municipality will also work with the responsible parties in the Ministry
of Defense to ensure effective administration of the program; 
(2) allocate certificates for the issuance (including the 10% of certificates for those officers to be selected
from the municipal waiting list and the 90% to be nominated by the Ministry of Defense) to municipal government;
(3) Guarantee the availability of the necessary housing units and provide housing recipients free resident
permits (propiskas).
(4) work to assist officers selected for the Program.  This includes:
(a) Assisting officers directly or indirectly by providing information to help them to reduce
housing costs, particularly if local housing prices exceed maximum provided through the program;
(b) Encourage builders to make newly completed units available for sale to the officers; 
(c) Assist officers with the information about new or existing housing available for purchase in the
city, to the extent possible and appropriate; and 
(d) Assist to make procedures effective for the officers, including the possibility of participating in
briefings for the demobilized officers or their families currently located in the Baltic States.
(5) provide assistance in obtaining the cooperation of local government officials and private persons in
providing the information on housing costs and sales prices needed to establish pricing values for the certificates. 
The Municipality will be responsible for conducting the pricing analysis using a the pricing methodology provided
by the General Contractor. 
(6) cooperate with the General Contractor's efforts to interview participating officers in order to evaluate
their eligibility for the certificate program;
(7) cooperate with the bank selected by the General Contractor to provide program processing;   
(8) provide propiskas and other required residence permits to all beneficiaries who receive housing under
this program and insure that any registration and notary fee relating thereto will not exceed the normal standards of
the Russian Law;
(9) not demand any additional forms or registrations of officers beyond those required by the Russian Law
and the program manuals;
(10) in conjunction with the IMC and the designated representatives of the Ministry of Defense of the
Russian Federation, determine which demobilized military officers will be eligible to receive housing units; and
ensure that the recipients of the housing units fall within the eligibility categories set forth in the section 2.3 (b) of
this Memorandum;

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(11)
guarantee that the sites on which the housing units are located have not been conveyed,
transferred, or assigned to any person or legal entity other than the eligible beneficiaries and are not subject to any
claims or rights to ownership or use by any persons or legal entities other than the eligible beneficiaries and, in the
event such claims or rights arise, defend and hold harmless the beneficiaries against such claims or rights and pay in
full any judgments, settlements or compensation based on them;
(12)
take all necessary steps and actions within the Law of Russian Federation to resolve any and all
matters arising that would delay implementation of this activity in accord with the schedule for provision of units to
the beneficiary demobilized military officers; and
(13)
provide information required by A.I.D. and the IMC to evaluate the progress of the program as
well as to determine the results and impact of the officer housing program on the beneficiaries and others;
(14)  inspect completed housing units with particular attention to the quality of the finishing of the units
and certify that they comply with all national and local building and occupancy requirements, codes, and standards
of Russian Federation;
(15)   assure expeditious transfer of title to such units to eligible demobilized military officers in accordance
with the Law of the Russian Federation "On Housing Privatization in Russia".
(16)  Recipients of housing provided under this Memorandum will be exempt from payment of:
A) income taxes for a period of three years on an amount equivalent to the dollar price of the certificate distributed to
the recipient for the acquiring housing; and
B) state notary fee for the notary certification of the contract for acquiring private property rights in the housing.
 The housing maintenance fee for the purchased housing units under the Project will be established at the same level
as for the free-of-charge privatized state and municipal housing.
(b)  The beneficiaries of the housing will be strictly limited to officers demobilized from military service in
the Baltics and other countries outside of Russia and their families and percentage of beneficiaries in each oblast by
beneficiary category as follows:
(1)  Russian military officers who were demobilized and departed from military service in the Baltics on or
after January 28, 1992 - at least 80% of all beneficiaries of St. Petersburg;
(2)  Russian military officers who were demobilized and departed from military service in the Baltics prior to
January 28, 1992, - no more than 10% of all beneficiaries of St. Petersburg;
(3)  Russian military officers who were demobilized and departed from military service in other countries
besides the Baltics on or after April 2, 1993 - no more than 10% of all beneficiaries of St. Petersburg.
No more than 10% of the total number of beneficiaries across all three categories can be selected by local authorities.
(c)  Assumption of Claims.  The Municipality acknowledge and understand that, pursuant to the Officer
Housing Program Agreement, the Government of the Russian Federation may be required by the Government of the
United States to assume certain obligations of the Government of the United States and/or any United States
Government contractor in the event that any Russian government national, regional, or local government agency or
any Russian private firm should fail to meet its obligations under any agreement with the Government of the United
States.  Should the Government of the Russian Federation be required to do so, the Municipality agree to accept the
Government of the Russian Federation as a full successor in interest to the Government of the United States and
agree that all terms and conditions of this Memorandum shall continue in full force and effect with regard to those
activities for which the Government of Russian Federation has assumed responsibility.
(d)  Taxation.  The Municipality agree that:

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191
(1)  all persons and their families (except citizens or permanent residents of the Russian Federation) who are
present in the Russian Federation in connection with the Officer Housing Program and who are employed by the
General Contractor or its subcontractors or other public or private organizations under contract with A.I.D., and the
employers of such persons, will be exempt from payment of:
    
(i)  all taxes on income received by such persons under the Officer Housing Program; and pension, medical,
employment and other social security taxes relating thereto; and
(ii) all value added, customs, personal effects, personal property or other taxes and charges upon personal
and household goods (including automobiles, equipment and materials) imported into, used in, or exported from the
Russian Federation for the personal use of such persons or members of their families.
(2)  all persons or organizations under contract with or financed by the Government of the United States or
the Government of the Russian Federation and providing goods and services for activities undertaken under this
Memorandum will be exempt from:
(i)  all taxes on profits received in connection with activities and transactions undertaken under this
Memorandum;
      (ii)  all taxes and similar charges on funds brought into, used in or taken out of the Russian Federation, including
the territory of the Municipality, in connection with activities undertaken under this Memorandum;
     (iii)  all taxes on property(including leases of property) used in connection with implementation of activities under
this Memorandum;
      (iv)  all value added and other similar taxes on purchases of goods and services required to implement activities
undertaken under this Memorandum;
       (v)  all special taxes supporting the most important sectors of the national economy of the Russian Federation
and on financing of construction, reconstruction, repair, and maintenance of highways, and other taxes, fees and
duties.
ARTICLE 3.  GENERAL PROVISIONS
Section 3.1.
Consultation.
The Parties will cooperate to assure that the purpose of this Memorandum will
be accomplished.  To this end, the Parties, at the request of either, will exchange views on the progress of the
performance of obligations under this Memorandum, the performance of contractors implementing activities under
this Memorandum, and other matters relating to the implementation of this Memorandum.
Section 3.2.
Utilization of Commodities, Funds, Certificates and Services.  Unless otherwise agreed by A.I.D.
and the IMC, all commodities, funds, certificates and services provided under this Memorandum and financed by
A.I.D. will be used only for the housing certificate program as specified in this Memorandum.
Section 3.3.
Reports, Accounting Records, Audits and Inspections. The Municipality will furnish to A.I.D. and
the IMC such information and reports relating to assistance provided under this Memorandum as A.I.D. or the IMC
may reasonably request.
The Municipality shall maintain, or cause to be maintained, as appropriate, records relating to the assistance
adequate to show use and receipt of assistance furnished to the Municipality pursuant to this Memorandum and
that the Municipality has taken actions as required under this Memorandum.  Records shall be maintained for a
period of three years after completion of assistance by A.I.D. under this Memorandum.
The Municipality shall afford representatives of A.I.D. and the IMC, or their designees, the opportunity at all
reasonable times to inspect locations where activities related to the Housing Certificate Program are taking

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192
place(including housing units purchased by officers receiving certificates under the Program) and all records relating
to the assistance provided under this Memorandum. 
Section 3.4.
Information. The Municipality will give appropriate publicity to the activity undertaken under this
Memorandum as a project to which the United States of America has contributed.
Section 3.5
Amendment and Modification.  This Memorandum may be amended or modified by written
agreement of the Parties. 
Section 3.6
Suspension and Termination.
(a)
Suspension. In the event that:
(1)
the IMC or the Municipality fails to comply with any material provision of this
Memorandum;
(2)
A.I.D. and IMC determine that an extraordinary situation has occurred which makes it
improbable either that the purpose of this Memorandum will be attained or that the
Municipality will be able to comply with provisions of this Memorandum; or
(3)
A.I.D. assistance is suspended or terminated pursuant to the terms of the Officer Housing
Program Agreement;
A.I.D. may, at its option, take steps to suspend, in whole or in part, provision of assistance under this
Memorandum and provide written notice of its actions to the IMC, the Municipality.  In the event of partial
suspension, such notice shall specify affected activities.  If, after sixty (60) days from the date of such notice, A.I.D.
determines that the cause or causes for the suspension have not been corrected, A.I.D. may, notwithstanding the
provisions Section 3.6(b), immediately terminate assistance and provide written notice of this action to the IMC and
Municipality.
(b)
Termination.
(1)
This Memorandum may be terminated if:
(i)
the Officer Housing Program Agreement is terminated;
(ii)
A.I.D., the IMC, or the Municipality jointly determine that any other party has failed to
meet its obligations under this Memorandum; provided that, the party seeking to
terminate has provided written notice to all other parties of the alleged default and
allowed thirty (30) days from the date of such notice for such default to be remedied;
Termination of this Memorandum will terminate any obligations of the Parties to provide financial or other resources
as required by this Memorandum, except for payment which they are committed to make pursuant to noncancellable
commitments entered into with third parties prior to the termination of this Memorandum. 
Section 3.7.
Refunds. If any failure on the part of the  Municipality to comply with any of its obligations under
this Memorandum has the result that commodities, funds, certificates or services financed by A.I.D. are not used in
accordance with this Memorandum, A.I.D. or the IMC may require the Municipality to refund all or part of any
amount of the financing provided by A.I.D. for such commodities, funding, certificates or services in U.S. Dollars
within sixty (60) days after the request for refund is made.
Section 3.8.
This Memorandum is prepared in both English and Russian, the texts in both languages being
equally authentic.  In case of difference between the two versions, the English language version will be used for the
purposes of interpretation.

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Section 3.9.
This Memorandum is effective on the date of signing by all Parties.
The Parties, each acting through their duly authorized representatives, have caused this agreement to be signed in
their names and delivered as of this        day of _______, 1995.
THE AGENCY FOR INTERNATIONAL
THE MUNICIPALITY OF
DEVELOPMENT
ST. PETERSBURG
_________________________
_______________________
THE INTERMINISTERIAL COMMITTEE        
FOR REALIZATION OF THE STATE          
PROGRAM "HOUSING"
___________________________

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