Carson Jr. put people he'd invited in touch with his father's deputies, joined agency staff on official conference calls about the listening tour and copied his wife on related email exchanges, according to emails.
"I expressed my concern that this gave the appearance that the Secretary may be using his position for his son's private gain," Linda M. Cruciani, HUD's deputy general counsel for operations, wrote in a July 6 memo, describing her reaction upon learning of Carson Jr.'s involvement from other staff members.
The two-page memo, obtained by The Washington Post under the Freedom of Information Act (FOIA), details conference calls and meetings that Cruciani and her colleagues had with Carson, his son and other senior HUD officials to urge that Carson Jr. not be involved in the listening tour, an event intended to give the secretary a chance to see federally supported housing projects firsthand and to convey his policy vision to the public.
The warnings highlight the extent to which Carson has relied on close family members since joining the Cabinet. His wife, Candy Carson, son Carson Jr. and daughter-in-law Merlynn Carson have attended official meetings, according to current and former HUD officials. Early last year, Candy Carson accompanied her husband around the building and to official meetings both inside and outside HUD, officials said.
Carson Jr. has continued to attend official HUD events with his father and other elected officials, including during the secretary's October trip to Baltimore's Helping Up Mission, a faith-based group that helps men facing addiction and homelessness.
Cruciani wrote that, in a meeting on June 26, two days before the listening tour was to begin, Carson initially said "it would be difficult" to have the tour in Baltimore without his son's involvement because Carson Jr. is a large employer in the region. Carson Jr. is chairman of Interprise Partners, a private equity firm that invests in and manages companies in the Mid-Atlantic.
Even so, Cruciani wrote, she and her colleagues were left believing that Carson Jr. would not be involved in the two-day tour, with the possible exception of a community event about lead exposure.
Yet all three of Carson's family members attended multiple events during the Baltimore tour, including a closed-door session on housing policy, according to a person with knowledge of the matter who spoke on the condition of anonymity.
Jereon Brown, a HUD spokesman, confirmed that Carson Jr.'s role was not limited to the community event but declined to be more specific. He said no one was dropped from the list of invitees after the ethics warning. He did not respond to questions about what steps, if any, the secretary took to address the issues raised by the department lawyers.
In a statement Tuesday, Carson said his goal in conducting the tour was to "help the people of Baltimore have access to safe affordable housing."
"In my role as HUD Secretary, I try to be as inclusive as possible and talk with a wide variety of people because when it comes to increasing access to affordable housing, no rock should remain unturned," he said. "My family, or people with relationships with my family, have never influenced any decision at HUD."
In an interview with The Post in early January, Carson dismissed news reports that his family was involved in HUD business. "They can FOIA everything, and they have been," he said. "There's nothing to find. It's ridiculous."
Carson Jr. did not respond to an email seeking comment or to a message left at Interprise. Cruciani did not return a call seeking comment, referring the matter to HUD's press office.
The two-day event in Baltimore was part of a nationwide listening tour Carson conducted last year, one that also took him to Miami; Jacksonville, Fla.; Dallas; and Detroit. The Baltimore leg drew attention from officials concerned about ethics.
On June 14, Cruciani wrote, HUD officials Mason Alexander and Lynne Patton — both Trump administration political appointees — raised concerns that Carson Jr. and his wife had asked that more than half a dozen people be invited to the Baltimore tour. The list included Under Armour chief executive Kevin Plank; Genesis Rehab Services co-chief operating officer Dan Hirschfeld; former Enterprise Foundation chairman Frederick "Bart" Harvey III; and members of the Paterakis family, which owns a major real estate development and bakery business in Baltimore.
Patton said Carson Jr. and his wife "may be doing business with these entities or may be interested in doing business with these entities," Cruciani wrote.
When contacted this week, several of the guests said they had been invited but had no business relationship with Carson Jr. A spokeswoman for Plank said he declined the invitation.
The officials also told Cruciani that Carson Jr. and his wife asked that Seema Verma, administrator of the Centers for Medicare and Medicaid Services, be invited.
A little less than three months later, according to federal records, CMS awarded a $485,000 contract to the consulting company Myriddian, whose chief executive is Merlynn Carson. Carson Jr. identifies himself online as one of Myriddian's board members. The contract was awarded without a competitive bidding process, federal records show, although a CMS spokesman said multiple minority-owned firms were considered.
The spokesman said the contract was for career-development services for the agency's large contacting staff. He added that Verma did not attend the Baltimore tour and said CMS has no record of her receiving an invitation.
Merlynn Carson did not immediately respond to an email seeking comment.
On June 23, according to the memo, Cruciani met with Alexander and Beth Zorc, then HUD's acting counsel, to discuss concerns that "Ben Carson Jr. continued to be involved" in planning the tour and that some of his business associates would be present.
HUD lawyers and top officials agreed to a conference call with Carson Jr. on June 26, the memo states, two days before the tour was to begin.
On the call, Cruciani wrote, Carson Jr. said that "he had invited associates 'who work with us but [who] advance HUD initiatives' " and that it was "helpful for us to get the right people in the room" to establish privately funded community centers the secretary has dubbed "EnVision Centers."
Carson Jr. said that "nothing we would do would be near a conflict." He emphasized his desire to "help his father ask the right questions" and ensure that there was follow-up on what attendees might say to the secretary, Cruciani wrote.
"I explained that he might have staffed his father during the campaign this way, but that the follow-up from official meetings would be the responsibility of HUD staff," Cruciani wrote.
At Carson Jr.'s request, Cruciani sent him a primer on federal ethics laws under the header, "Misuse of Position: Regulations applying to SOHUD," shorthand for secretary of Housing and Urban Development.
Carson Jr. told Cruciani that he did not want to create unnecessary concern and that he would speak to his father, Cruciani wrote.
Later that day, Cruciani, Alexander and Zorc discussed the matter with the secretary themselves.
"The Secretary said that it was difficult to have a Listening Tour in Baltimore without his son's involvement as his son was the largest employer in Maryland," Cruciani wrote. "I said that I understood his frustration, but explained that the rule that he avoid any actions that might create the appearance of violating the law was broad."
Carson Jr. told HUD lawyers that he has "three law firms and 2,600 employees," the memo states.
Brown, the HUD spokesman, said Carson was speaking as "a proud father" and realizes that there are bigger employers in Maryland.
In the days before the listening tour, Carson Jr. used a company with which he is affiliated to invite a prominent local chief executive, Calvin G. Butler Jr. of Baltimore Gas and Electric Co., and then personally connected Butler's chief of staff with senior agency officials. The email exchange was obtained by the Democratic-leaning group American Oversight and provided to The Post.
The invitation came from Mark Powell, the chief executive of Argo Systems. Carson Jr.'s firm's website lists Argo as an "Interprise company" and says he serves on its board.
On June 15, Powell wrote to Butler: "One of my business partners, Ben Carson Jr., asked if I could extend an invitation to you or one of your senior team members to join Secretary Carson" on the tour.
Powell did not respond to an email seeking comment.
A BGE spokeswoman confirmed that Butler was invited but said he did not attend.
Carson Jr. also personally shaped the itinerary for the listening tour, adding a stop at a large mixed-use development project in West Baltimore.
"Thank you for working us in," Carson Jr. wrote to the developers, La Cité Development, on June 25.
Dan Bythewood, a partner in the project, said in an email that neither he nor his company has any business ties to Carson Jr.
"We were honored by their interest in our vision," he said.
Aaron C. Davis and Ben Terris contributed to this report.