Documents obtained by The Inquirer show that, from 2005 until 2010, Greene signed annual "Disclosure of Lobbying Activities" forms that omitted any mention of Urban or American Continental.
The failure to disclose lobbying activities - no matter what the source of funding - can be punished with fines of up to $100,000 for each incident, HUD warns on the document.
"If you didn't declare it, it's falsifying a federal form," said Jereon Brown, a spokesman for the U.S. Department of Housing and Urban Development. "It's against the law."
Greene also signed a separate "Certifications of Payment to Influence Federal Transactions" with HUD, vouching for his compliance with filing rules and swearing that federal dollars were not used to pay a lobbyist.
According to that document, "HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties."
Greene's attorney, Clifford Haines, who was provided with copies of the documents Greene signed, did not respond to requests for comment. Greene was fired in September 2010 after secretly settling sexual-harassment complaints against him for hundreds of thousands of dollars.
Ballard lawyers, including one of the main attorneys working on PHA matters, Sharon Geno, were called for comment, but none responded.
Urban said he and his firm take compliance obligations "very seriously."
While Greene was signing documents disclaiming any lobbying activity, American Continental registered with Congress as a PHA lobbyist starting in 2005. Urban actually began working for PHA in 2003, but said he was doing research and monitoring legislation - activities that didn't constitute lobbying.
His work changed to lobbying in 2005, he said. It was then that American Continental filed with Congress that it was a Ballard lobbyist working on PHA matters.
"There is clear registration that I filed that says I was lobbying on behalf of the PHA," Urban said.
American Continental had a direct lobbying contract with PHA from October 2005 until September 2008. The contract was approved by PHA's five-member board.
After that, it once again was paid its $10,000-a-month retainer through Ballard.
The $700,000 figure was calculated from payments made to American Continental from 2005 through August 2010, when Greene was ousted. Urban said he was also paid $10,000 a month from 2003 to 2004.
Barbara Adams, PHA's newly appointed general counsel, said the housing agency was reviewing invoices at The Inquirer's request to determine the source of the funds used to pay Urban's company.
She said that, so far, it appeared that the American Continental payments from 2006 through 2010 were not made with federal funds. The money, she said, came from a PHA account that included laundry fees, cable fees, wireless and vending-machine commissions, as well as proceeds from a home-ownership program.
Adams said that most of the invoices she reviewed from that period contained a Ballard notation that PHA should pay them with nonfederal funds.
But for invoices in 2003, 2004, and 2005 - as well as one from 2007 - the source of funds to pay Urban is less clear, Adams said. There was no notation that they should not be paid with taxpayer funds, she said.
Michael P. Kelly, PHA's executive director, said Greene's failure to report the lobbying of American Continental was "inconsistent."
"I don't know why it wasn't done before," Kelly said.
He also could not explain why PHA channeled payments for lobbyists through a law firm. "That's really puzzling," Kelly said. "You'd think they'd go through a simple procurement [process] and the candidate would rise to the top of that."
After questions from The Inquirer, HUD's regional counsel in Philadelphia, Sheryl L. Johnson, began an inquiry into money spent on lobbying.
She sent PHA a letter Jan. 13 about its lobbying activities. She reminded PHA that it "is constrained on the use of funds for lobbying."
Johnson urged Adams to review all legal invoices to ensure that the housing authority was in compliance with the law - both in terms of how it paid lobbyists and how it reported their activities.
"Lobbying is permissible only if nonappropriated funds are used and if accurate disclosure forms ... have been filed," Johnson said.
In a response Friday, Adams wrote that PHA had "just begun the process of researching the extent of any such lobbying activities and the accuracy and completeness of any disclosures made by PHA in the years prior to 2011."
HUD took over PHA in March and is scrutinizing its past payments to outside lawyers. From 2007 to 2010, PHA spent $38.5 million on law firms, more than any other housing authority in the nation.
Most of PHA's $376 million budget comes from HUD. Brown, the HUD spokesman, said that if PHA found that any federal money was used to finance its lobbying activities, "we'll try to recoup every dollar."
He said the fresh questions about PHA's lobbyists would become part of a broader investigation of its spending on outside law firms. "This is all part of the same audit - legal expenses and what payments were for," Brown said.
Whether any federal funds were used is a major question, said former federal prosector L. George Parry.
"If there was a lie told here about the use of federal funds, one place you may want to call is the U.S. Attorney's Office," Parry said. "There should be some kind of criminal investigation. This involves a lot of money."
Jeffrey Lindy, another former federal prosecutor, said it made no difference whether the funds were routed through Ballard or paid directly, because the beneficiary of the lobbying was PHA.
This is the second time PHA's payments made through law firms has become an issue with HUD.
In July, PHA was forced to reimburse $150,000 in federal funds that it paid to former city controller Jonathan Saidel to cultivate city officials, as well as U.S. Rep. Bob Brady, who is also Philadelphia's Democratic Party leader. The payments were made through the law firm Schnader, Harrison, Segal & Lewis, which said its PHA contract allowed it to hire outside experts.
With Urban and American Continental, PHA should have reported the relationship, even if the payments were going through Ballard, said PHA's Adams.
"It seems to me you can't avoid doing that by simply having an arrangement between a law firm and a lobbying firm," she said.
Urban - whose clients include Comcast, SEPTA, and Temple University - said no other public client made payments through a law firm.
Congress requires housing authorities - as federally funded agencies - to file lobbying-disclosure forms because it wants to make sure that federal dollars earmarked to build housing for the poor aren't being spent on lobbyists.
Taxpayers "should demand and expect to know where [housing authorities] are spending their money and how they are spending their money," said Mark Studdert, who ran HUD's congressional-relations office from 2005 to 2008.
Kelly said that, since the start of this year, PHA has had "no federal lobbyists working on ... anything to do with HUD."
Previously, Kelly headed housing authorities in Washington, New Orleans, and San Francisco. He is also president of the Council of Large Housing Authorities, a trade association that lobbies on behalf of public housing agencies in major metropolitan areas.
About the federal guidelines controlling lobbying activities, Kelly said: "It's not a system built to be unclear or to make it difficult to make these kinds of disclosures."
He said that in his previous work at other housing authorities, he did not rely on outside lobbyists. "I was my own lobbyist."
PHA paid outside lawyers to shadow federal auditors. HUD
is demanding that
the housing authority repay $726,400.
Contact staff writer Jennifer Lin at 215-854-5659, email@example.com,
or @j_linq at Twitter.