City auditor urges outside review after staff says FEMA map document was altered; council debates next steps

The office of the city auditor told the City Council on Sept. 9 it had found a reasonable basis to be concerned that a Federal Emergency Management Agency (FEMA) mapping exhibit used in a previous tax‑incentive approval had been altered, and recommended an outside, independent investigation.

George Holland, city auditor, said his office began a review after receiving an allegation in August. Auditor staffer Amir Hussain, a Certified Fraud Examiner who led the probe, described a timeline that began with a June 2022 FEMA mapping release and followed regulatory steps, an incentive application, hearings and two council readings in early 2024. Hussain told council the auditor’s office found discrepancies between documents and versions and said testimony given under oath during litigation further raised concerns.

Holland and Hussain recommended the council authorize an external law firm or outside counsel experienced in public incentives to examine the evidence and determine whether fraud or other wrongdoing occurred. They said the city’s audit office lacks subpoena authority and the internal capacity to pursue a complex investigation that could require litigation support.

City attorney Miles Risley, Mayor Paulette Guajardo and council members questioned next steps. Several council members said the matter should be referred to law enforcement — the city attorney and auditors said the FBI has already been contacted earlier for consultation. Council members debated whether the city attorney’s office, the police department’s internal investigators, or an independent counsel appointed from outside the region would provide the most trustworthy, impartial review. Some council members said an outside firm would be the only way to avoid a perception of partiality because multiple parties in the litigation have social or professional ties to local officials.

Councilmembers asked whether the auditor’s office had reviewed both plaintiff and defense testimony; the auditor’s staff said the office had examined deposition transcripts and documentary evidence provided to the auditor during the inquiry but that the litigation was continuing and other depositions were still being taken. The city auditor’s memo to the council recommended an independent investigation by an external law firm with experience in tax‑incentive programs and public finance.

Council members discussed procedural options on the council floor. One motion to retain external counsel for a city investigation failed after a split vote; members proposed instead to forward the allegations to the Corpus Christi Police Department and to seek a status update from the FBI. Several council members said they would recuse themselves from any vote on an investigation if they are parties or witnesses in the related litigation.

Why it matters: City administration and legal staff are expected to vet material put before council for ordinance votes. The auditor’s statement that a federal‑agency exhibit was altered raised questions about vetting and whether that altered material influenced a prior incentive decision. The council must balance competing priorities — following the open litigation process, ensuring impartial review and preserving public trust — as it chooses where any additional inquiry should sit.

What’s next: Council voted against immediate hiring of outside counsel; several council members asked staff to provide status updates from law‑enforcement partners and to report back. The auditor’s office said it had already provided evidence to federal authorities for consultation and that it would share information with the police chief on request. The council’s audit committee will continue to follow the auditor’s recommendations and may revisit outside counsel if law‑enforcement review is judged incomplete.