Dr Cooper appeared before an ACT parliamentary inquiry into the agency's purchases of land at Glebe Park and West Basin in 2015, where she was quizzed about the detail of her highly critical audit of the four transactions.

Dr Cooper said the agency had been "loose with documentation".

"This whole thing ... opens up the opportunities for fraud, when you have a system this loose without documentation," she said. "There's no way that the agency can come back and show justification, which is why one of the principles of any government is to have that transparency through documentation ...

"Given loose systems like this, it provides the opportunity for [fraud] to occur and go undetected," she said.

As a result of the findings, she was now investigating the Land Development Agency's purchases of farmland.

That investigation "brings up similar issues or even different issues", she said.

"Again, this is a loose governance arrangement and loose management that poses risk for the territory, so we can't generalise from these few sites. But we quite clearly can say that for these few sites there are very significant problems."

Dr Cooper criticised the lack of documentation also for invoicing in the case of the Glebe Park and lake purchases.

"It was hard to find out who paid for what given the arrangements, in fact it was near impossible on some of it. That's why we asked "was this free advice?" "Yes, it was", or "We'd had a lot of services from Colliers and we clustered them". You just couldn't track, this came in and therefore that invoice covered that."

Dr Cooper said there were significant gaps in documentation with the boat hire business in particular, and she recommended the committee focus on that purchase.

The purchases at issue are:

Dr Cooper's audit found the purchases lacked transparency, accountability and rigour.

At Wednesday's hearing, she and the director of performance audits Brett Stanton also detailed the relationship between the Land Development Agency and consulting firm Elleven, which is associated former City to the Lake project director Tim Xirakis.

Mr Stanton said one executive moved from a financial job with the government to start work the next day as a consultant with Elleven, doing the same job. Another executive moved from working on the City to the Lake project in the land agency to starting work two days later on the same project but employed through Elleven as a consultant.

Elleven had told the audit office that "the CEO of the LDA came to them with the advice that these people are too valuable to lose, can you find an arrangement for them", a claim denied by the chief executive.

Dr Cooper detailed an interview under oath with a former project director for the City to the Lake project who ran Elleven. He told the auditor, "There was a profit in it for me … I'll be quite honest. I was making a profit on their employment but that was my business."

The audit office asked him whether it would have been cheaper for the agency to simply keep employing the second consultant directly, to which he said "well and truly".

Dr Cooper said the agency chef executive had exempted the Elleven contracts from going to tender, with $2.7 million paid to the consultants in all.

While nothing illegal happened, the arrangement went to the heart of integrity issues, with the need to comply not only with the law but with the intent of the procurement guidelines.

Asked about evidence from the Mr Spokes owners Jillian Edwards and Martin Shanahan that negotiations with the land agency were slow, confusing, contradictory, lacking in any detail, and marred by an unwillingness to communicate in writing, staff changes, and a contradictory approach, Dr Cooper told the committee that the description "does depict the communication and the management style in the organisation".