Fair Housing: Funding and Activities Under the Fair Housing Initiatives
Program (Letter Report, 03/26/97, GAO/RCED-97-67).

Pursuant to a congressional request, GAO reviewed the Department of
Housing and Urban Development's Fair Housing Initiatives Program,
focusing on: (1) how funds are allocated among the program's four
initiatives or funding categories, what dollar amounts are made
available under each category, and what level of demand exists for funds
under each category; and (2) who receives program funds and how the
funds are being used.

GAO noted that: (1) from the program's inception through fiscal year
(FY) 1997, the Congress has appropriated $113 million to carry out the
Fair Housing Initiatives Program; (2) the Assistant Secretary for Fair
Housing and Equal Opportunity, the Department of Housing and Urban
Development, judgmentally determines how funds are allocated among the
four initiatives on the basis of the program legislation, the
administration's and the agency's priorities, and input from the housing
industry and fair housing groups; (3) the agency's budget requests to
the Congress set forth how it plans to divide the total program dollars
among the four initiatives; (4) the largest portion, more than $40
million, has been budgeted and made available for the private
enforcement initiative; (5) as measured by the amounts requested on
applications, for the 3 most recent years, fiscal years 1994 through
1996, there is also great demand for the private enforcement initiative;
(6) through FY 1996, 220 different organizations in 44 states and the
District of Columbia received program grants; (7) of all the funds
awarded, 26 organizations received about half; (8) the largest portion
of funds, about $41 million, was spent on the private enforcement
initiative for activities aimed at determining the existence of
discrimination in renting, sales, and lending, primarily testing to
investigate individual complaints and testing to investigate industry
practices; (9) grantees have used funds for a variety of other fair
housing activities, such as litigation, new fair housing organizations
and capacity building for existing organizations, pamphlets and
brochures, print, television, and radio advertisements, and conferences
and seminars for housing industry professionals; and (10) other funded
activities also have included special projects on mortgage lending and
insurance redlining.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-97-67
     TITLE:  Fair Housing: Funding and Activities Under the Fair Housing 
             Initiatives Program
      DATE:  03/26/97
   SUBJECT:  Civil rights law enforcement
             Grants-in-aid
             Discrimination
             Housing programs
             Locally administered programs
             Non-profit organizations
             Intergovernmental fiscal relations
             State governments
IDENTIFIER:  HUD Fair Housing Initiatives Program
             
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Cover
================================================================ COVER


Report to the Subcommittee on VA, HUD, and Independent Agencies,
Committee on Appropriations, House of Representatives

March 1997

FAIR HOUSING - FUNDING AND
ACTIVITIES UNDER THE FAIR HOUSING
INITIATIVES PROGRAM

GAO/RCED-97-67

HUD's Fair Housing Initiatives Program

(385648)


Abbreviations
=============================================================== ABBREV

  FHIP - Fair Housing Initiatives Program
  GAO - General Accounting Office
  HUD - Department of Housing and Urban Development
  VA -

Letter
=============================================================== LETTER


B-276176

March 26, 1997

The Honorable Jerry A.  Lewis
Chairman
The Honorable Louis Stokes
Ranking Minority Member
Subcommittee on VA, HUD,
 and Independent Agencies
Committee on Appropriations
House of Representatives

Fair housing legislation was first enacted as part of the Civil
Rights Act of 1968.  Under the 1968 act, limited enforcement powers
were available to the federal government, and, therefore, private
entities played the primary role of enforcing the law.  In 1988, the
Fair Housing Initiatives Program was established to assist all
parties in fighting housing discrimination.  These included private
nonprofit organizations such as civil rights organizations and local
fair housing groups; public entities such as colleges and
universities; and certain state and local fair housing agencies.  The
program funds activities designed to enforce fair housing laws and to
inform the public about their rights and obligations under such laws. 
It has four initiatives or funding categories--private enforcement
(for private nonprofit entities), the fair housing organizations
initiative (for private nonprofit entities), education and outreach
(for private and public entities), and administrative enforcement
(for state and local agencies). 

This report responds to your request that we review (1) how funds are
allocated among the program's four initiatives or funding categories,
what dollar amounts are made available under each category, and what
level of demand exists for funds under each category and (2) who
receives program funds and how the funds are being used.  As
requested, we are also providing background information on the
program's history and the activities eligible for funding. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

From the program's inception through fiscal year 1997, the Congress
has appropriated $113 million to carry out the Fair Housing
Initiatives Program.  The Assistant Secretary for Fair Housing and
Equal Opportunity, the Department of Housing and Urban Development,
judgmentally determines how funds are allocated among the four
initiatives on the basis of the program legislation, the
administration's and the agency's priorities, and input from the
housing industry and fair housing groups.  The agency's budget
requests to the Congress set forth how it plans to divide the total
program dollars among the four initiatives.  The largest
portion--more than $40 million--has been budgeted and made available
for the private enforcement initiative.  As measured by the amounts
requested on applications, for the 3 most recent years--fiscal years
1994 through 1996--there is also great demand for the private
enforcement initiative. 

Through fiscal year 1996, 220 different organizations in 44 states
and the District of Columbia received program grants.  Of all the
funds awarded, 26 organizations received about half.  The largest
portion of funds--about $41 million--was spent on the private
enforcement initiative for activities aimed at determining the
existence of discrimination in renting, sales, and lending--primarily
testing\1 to investigate individual complaints and testing to
investigate industry practices.  Grantees have used funds for a
variety of other fair housing activities, such as litigation; new
fair housing organizations and capacity building for existing
organizations; pamphlets and brochures; print, television, and radio
advertisements; and conferences and seminars for housing industry
professionals.  Other funded activities also have included special
projects on mortgage lending and insurance redlining. 


--------------------
\1 Testing programs involve the use of "testers" posing as renters,
purchasers, or borrowers in order to ascertain if a similarly
situated member of a protected class (based, e.g., on race, national
origin, or gender) has been subject to discrimination. 


   BACKGROUND ON THE FAIR HOUSING
   INITIATIVES PROGRAM'S HISTORY,
   FUNDING, AND ACTIVITIES
------------------------------------------------------------ Letter :2

The Fair Housing Act, title VIII of the Civil Rights Act of 1968,
prohibited discrimination in the sale, rental, and financing of
housing based on race, color, religion, or national origin.\2 The act
allowed the Department of Housing and Urban Development (HUD) to
investigate and conciliate complaints of housing discrimination and
authorized the Department of Justice to file suits in cases of a
pattern or practice of discrimination or in cases of public
importance.  HUD was not given any authority to administratively
remedy acts of discrimination against an individual, however. 

The Fair Housing Act also required HUD to refer housing
discrimination complaints to state and local agencies where the state
or local law provided rights and remedies substantially equivalent to
those provided by the federal law.  In 1980, HUD established the Fair
Housing Assistance Program to provide financial assistance to state
and local agencies to encourage them to assume a greater share of the
enforcement of their fair housing laws. 

The Fair Housing Initiatives Program (FHIP), administered by HUD, is
designed to provide a coordinated and comprehensive approach to fair
housing activities in order to strengthen enforcement of the Fair
Housing Act.  During the 1986 Senate hearings on its proposal to
establish the FHIP, HUD testified that enforcement activity,
particularly testing, by private nonprofit and other private entities
would be the principal focus and motivation of the program.  In
February 1988, the program was created as a 2-year demonstration
program by the Housing and Community Development Act of 1987. 

About 7 months later, the Fair Housing Amendments Act of 1988 was
signed into law, and it became effective in March 1989.  The 1988 act
attempted to remedy the enforcement shortcomings of the original
legislation.  It significantly strengthened federal fair housing
enforcement by, among other things, establishing an administrative
enforcement mechanism, allowing HUD to pursue cases filed by an
individual before an administrative law judge for disposition and
providing for civil penalties. 

In November 1990, FHIP was extended for 2 additional years,\3 and
with the enactment of the Housing and Community Development Act of
1992, it became a permanent program, effective fiscal year 1993.  The
1992 act also expanded the program to reflect significant legislative
changes in fair housing and lending that had taken place after the
program's creation in 1988.\4 It authorized FHIP to implement testing
programs whenever there was a reasonable basis for doing so;
establish new fair housing organizations or expand the capacity of
existing ones; conduct special projects to, for example, respond to
new or sophisticated forms of housing discrimination; undertake
larger, long-term enforcement activities through multiyear funding
agreements; and pay for litigation.  For fiscal years 1989 through
1997, the Congress appropriated $113 million for FHIP.  The permanent
program grew from an appropriation of $10.6 million in fiscal year
1993 to $26 million in fiscal year 1995 (see fig.  1). 

   Figure 1:  Fair Housing
   Initiatives Program's
   Appropriations, Fiscal Years
   1989 Through 1997

   (See figure in printed
   edition.)

Source:  HUD's fiscal years 1989 through 1997 appropriations
legislation. 

Funds for the program are distributed on the basis of competitive
grants through four program initiatives.  These initiatives or
funding categories generally define who is eligible to receive funds
and/or the focus of activities to be funded.  The initiatives are (1)
the private enforcement initiative--funding for private nonprofit
organizations to undertake testing and other enforcement-related
activities; (2) the fair housing organizations initiative--funding
for private nonprofit organizations to create new fair housing
enforcement organizations in those areas of the country that were
unserved or underserved by such organizations or expand the capacity
of existing private nonprofit fair housing organizations; (3) the
education and outreach initiative--funding for private and public
entities to educate the general public and housing industry groups
about fair housing rights and responsibilities; and (4) the
administrative enforcement initiative--funding for state and local
government agencies that administer fair housing laws certified by
HUD as substantially equivalent to federal law to help such agencies
broaden their range of enforcement and compliance activities. 
Private organizations that receive grants generally are nonprofit
entities and have experience in investigating complaints, testing for
fair housing violations, and enforcing legal claims or outcomes. 


--------------------
\2 In subsequent legislation, the Congress also prohibited
discrimination on the basis of gender, disability, and familial
status. 

\3 By the National Affordable Housing Act of 1990, Nov.  28, 1990. 

\4 In addition to the Fair Housing Amendments Act of 1988,
significant changes include the 1989 amendments to the Home Mortgage
Disclosure Act, which require certain lending institutions to provide
federal regulators and the public with additional information on
mortgage loan applicants and lending patterns.  Also, the 1991
amendments to the Equal Credit Opportunity Act require federal
banking regulatory agencies to make referrals to the Department of
Justice whenever the regulators have reason to believe that there has
been a pattern or practice of discrimination and referrals to HUD
when it appears that other violations under the act violate the Fair
Housing Act. 


      ACTIVITIES ELIGIBLE FOR
      PROGRAM FUNDS
---------------------------------------------------------- Letter :2.1

The program provides considerable flexibility in the types of
activities that can be funded under each initiative.  Eligible
activities include education and outreach programs, testing based on
complaints and other reasonable bases, the recruitment of testers and
attorneys, special projects to respond to new or sophisticated forms
of discrimination, litigation expenses, and the creation of new fair
housing organizations in areas of the country underserved by fair
housing enforcement organizations.  The program is restricted from
funding two types of activities:  (1) settlements, judgments, or
court orders in any litigation action involving HUD or HUD-funded
housing providers and (2) expenses associated with litigation against
the federal government.  Appendix I provides additional details on
the types of activities eligible for funding under the program. 


      FHIP'S ROLE AS A KEY
      COMPONENT OF HUD'S FAIR
      HOUSING ENFORCEMENT
      ACTIVITIES
---------------------------------------------------------- Letter :2.2

FHIP is an integral part of HUD's fair housing enforcement and
education efforts that are concentrated within the Office of Fair
Housing and Equal Opportunity.  In addition to FHIP, this office is
responsible for the oversight of the Fair Housing Assistance Program,
investigation and processing of fair housing complaints, and referral
of complaints to Justice when appropriate.  FHIP links and extends
fair housing enforcement and education and outreach activities to
many state and local governments and communities across the
country.\5 The program makes it possible for HUD to look
comprehensively at fair housing problems and to work with the whole
spectrum of agencies that are involved in fighting housing
discrimination.  Taken together, FHIP and the Fair Housing Assistance
Program, form a national fair housing strategy through greater
cooperation between the private and public sectors.  In fiscal year
1996, FHIP accounted for about 22 percent of the Office of Fair
Housing and Equal Opportunity's $76.3 million budget (see fig.  2). 

   Figure 2:  Office of Fair
   Housing and Equal Opportunity's
   Budget for Fiscal Year 1996

   (See figure in printed
   edition.)

Source:  GAO's analysis of data from HUD. 


--------------------
\5 While HUD established the Fair Housing Assistance Program to
encourage state and local governments to assume more responsibility
in enforcing fair housing requirements, 18 state governments do not
qualify for financial assistance under the program because they lack
a fair housing law substantially equivalent to federal law, along
with the administrative capacity.  Also, few units of local
government (50) qualify for assistance. 


   HUD USES DISCRETION IN
   ALLOCATING FHIP FUNDS, AND
   ALLOCATIONS ARE GENERALLY AS
   PROPOSED IN BUDGETS TO THE
   CONGRESS
------------------------------------------------------------ Letter :3

HUD uses discretion in deciding how FHIP funds are allocated among
the four program initiatives.  Reflecting the program's principal
focus, HUD's budget requests to the Congress set forth how it plans
to divide the total amount of dollars requested for FHIP among the
four initiatives.  Notices of funding availability in the Federal
Register indicate the dollar amounts HUD makes available for
competition under each program initiative. 


      HUD'S ALLOCATION OF FHIP
      FUNDS
---------------------------------------------------------- Letter :3.1

According to the Acting FHIP Division Director, the Assistant
Secretary for Fair Housing and Equal Opportunity determines how funds
are allocated on the basis of legislation,\6 administration and
agency priorities, and input from the housing industry and fair
housing groups.  HUD's allocations for FHIP have consistently
reflected that enforcement activities are the principal focus of the
program.  In annual budget justifications to the Congress, HUD
discusses its emphasis for the year and indicates how much of FHIP's
total budget request it plans to allocate to each FHIP initiative. 
Table II.1 in appendix II shows by fiscal year the dollar amounts HUD
anticipated it would allocate to each initiative. 


--------------------
\6 For example, in the enacting legislation for the program, the
Congress specified that up to $3 million of the $5 million in
authorized appropriations (60 percent) could be used for the private
enforcement initiative in fiscal years 1988 and 1989. 


      DOLLAR AMOUNTS MADE
      AVAILABLE FOR EACH
      INITIATIVE
---------------------------------------------------------- Letter :3.2

The Congress has appropriated amounts equal to or greater than the
amounts HUD requested each fiscal year until 1996.\7 In accordance
with its budget plans, HUD has made the largest portion of FHIP
dollars available for the private enforcement initiative.  In 2
fiscal years (1993 and 1994) in which HUD received appropriated
amounts higher than its budget requests, the additional dollars
available resulted in the private enforcement initiative's receiving
significantly more money than initially planned.  Overall, HUD made
about 48 percent of FHIP funds available for the private enforcement
initiative (see table II.2). 

The relationship between HUD's proposed allocations for each
initiative and the funds made available indicates that the dollar
amounts were basically the same in 4 of the 8 years (fiscal years
1989 through 1991 and 1995).  For the remaining years, allocations
varied considerably from HUD's initial budget plans primarily because
appropriated amounts for FHIP overall were either higher or lower
than the budget requests.  The variations were as follows: 

  -- In fiscal year 1992, the amount appropriated for FHIP was the
     same as the budget request.  The private enforcement
     initiative's allocation was $1.3 million less than HUD initially
     anticipated; the administrative enforcement initiative's was
     $0.9 million more, and the education and outreach initiative's
     was $0.4 million more. 

  -- In fiscal year 1993, FHIP's appropriation was $3 million higher
     than the budget request.  The private enforcement initiative's
     allocation was $1 million more; the education and outreach
     initiative's, $0.5 million more.  The fair housing organizations
     initiative, which was authorized in late 1992, received a $2.6
     million allocation.  The administrative enforcement initiative's
     allocation was $1.1 million less than anticipated, however. 

  -- In fiscal year 1994, FHIP's appropriation was $3.6 million
     higher than the budget request.  Of this, HUD allocated $3
     million to the private enforcement initiative and $0.6 million
     to the fair housing organizations initiative. 

  -- In fiscal year 1996, FHIP's appropriation was 43 percent lower
     than the budget request.  While the budget request included
     funds for all initiatives, owing to the reduced appropriation,
     HUD did not allocate any funds to the administrative enforcement
     initiative.  Allocations to the other three initiatives ranged
     from 30 to 120 percent of the amount initially requested. 


--------------------
\7 For another fiscal year (1990), an appropriations reduction, which
was applicable to many federal accounts, resulted in FHIP receiving a
$93,000 decrease in its appropriation.  The appropriation was further
reduced through a sequestration of $68,000, to $5,839,000 (see table
II.2). 


      THE DEMAND FOR FHIP FUNDS
---------------------------------------------------------- Letter :3.3

From fiscal year 1989 through fiscal year 1996, HUD received 2,090
applications for FHIP grants and approved about one-quarter of these
applications for funding.  Historically, the demand for education and
outreach grants has exceeded that for the other three initiatives
each fiscal year except for 1996.  For the 3 most recent years
(fiscal years 1994 through 1996), the greatest demand, as measured by
the amounts requested on applications, has been for the private
enforcement initiative. 

In fiscal year 1996, the number of applications for grants decreased
from 300 in each of the 3 previous fiscal years to 91.  The most
significant decrease was for education and outreach grants, dropping
to 19 applications from over 200 the prior year (see table II.3). 
HUD told us that the significant drop in education and outreach
applications is primarily attributable to language in the 1996
appropriations law requiring applicants to meet the definition of a
qualified fair housing enforcement organization in order to be
eligible for FHIP funds.  According to FHIP legislation, a qualified
fair housing enforcement organization is a private nonprofit
organization that has at least 2 years of experience in complaint
intake, complaint investigations, testing, and enforcement of legal
claims.  HUD told us that the legislative requirement precluded many
previously eligible organizations from applying for an education and
outreach initiative grant.\8 Also, according to HUD, a one-third
reduction in FHIP's appropriation for that fiscal year discouraged
many organizations from applying for FHIP funding. 

On the basis of the dollar value of grant applications submitted to
HUD, the greatest demand has been for private enforcement initiative
grants.  Our analysis of the dollar amount of applications is based
on fiscal years 1994 through 1996 for which complete information is
readily available (see table II.4).  Of the total $175 million in
applications received for the 3-year period, $76 million, or about 43
percent, was for private enforcement initiative grants, and about 36
percent was for education and outreach initiative grants. 


--------------------
\8 Previously, eligible applicants for education and outreach grants
included, among others, housing associations, training organizations,
colleges and universities, and city and state governments.  The
requirement that all organizations meet the definition of a qualified
fair housing enforcement organization was removed in the fiscal year
1997 appropriations law. 


   FHIP GRANT RECIPIENTS AND
   ACTIVITIES ARE DIVERSE
------------------------------------------------------------ Letter :4

From the program's inception through September 1996, a total of 220
different organizations received FHIP grants in 44 states and the
District of Columbia; 26 organizations received about half of all
FHIP funds awarded.  The organizations are located in 15 states and
the District of Columbia. 

FHIP-funded activities have reflected the program's purpose as
described in the legislation.  That is, grantees have used FHIP
dollars to fund the kinds of activities intended, namely,
implementing fair housing testing programs and testing-related
activities; establishing new fair housing organizations; and
educating the public and housing providers about fair housing
requirements. 


      FHIP DOLLARS ARE
      CONCENTRATED AMONG A LIMITED
      NUMBER OF GRANTEES
---------------------------------------------------------- Letter :4.1

Through fiscal year 1996, HUD awarded 483 grants totaling $86 million
to support fair housing enforcement and education.\9 Of the 220
different organizations that received grants, 26 received about half
of the funds awarded.  These 26 organizations, located in 15 states
and the District of Columbia, received 179 of the 483 grants.  They
include state governments; national membership organizations; legal
aid organizations; and civil rights and advocacy groups.  Some have
grants that are national in scope, and some are involved in
establishing new fair housing organizations in states that were
unserved or underserved by fair housing enforcement organizations. 
Also, some organizations represent all protected classes, while
others focus on a specific target population, such as persons with
disabilities.  Table 1 identifies the 26 organizations and the number
and dollar value of grants received through fiscal year 1996.  (See
app.  III for a complete list of the grants awarded and the dollar
amount of each.)



                                Table 1
                
                  Twenty-six Organizations Awarded the
                 Highest Amounts of FHIP Funds, Fiscal
                        Years 1989 Through 1996

                                                       Total amount of
Grantee                           Number of grants              grants
------------------------------  ------------------  ------------------
National Fair Housing Alliance                  11          $6,906,398
Lawyers' Committee for Civil                    12           3,120,927
 Rights Under Law of Boston
 Bar Association
Open Housing Center, Inc.                       11           3,053,568
Leadership Council for                          12           2,598,474
 Metropolitan Open Communities
Metropolitan Milwaukee Fair                      9           2,166,299
 Housing Council
Fair Housing Council of                          9           2,067,456
 Greater Washington
Council for Concerned Citizens                   8           1,811,874
Long Island Housing Services                     8           1,503,718
Project Sentinel                                 6           1,423,525
Fair Housing Congress of                         5           1,385,834
 Southern California
Fair Housing Council of                          6           1,368,267
 Northern New Jersey
Toledo Fair Housing Center                       5           1,271,258
Housing Opportunities Made                       7           1,268,215
 Equal of Richmond
Massachusetts Commission                         9           1,239,756
 Against Discrimination
Fair Housing Center of                           6           1,234,338
 Metropolitan Detroit
Housing Discrimination Project                   8           1,118,487
Cuyahoga Plan of Ohio                            7           1,037,033
Metro Fair Housing Services,                     4           1,025,843
 Inc.
Legal Aid Society of                             2           1,025,021
 Albuquerque
John Marshall Law School                         4           1,024,280
Fair Housing Council -                           9           1,022,120
 Kentucky
HOPE Fair Housing Center                         7             999,720
Asian Americans for Equality                     3             910,345
Arizona Fair Housing Center                      2             898,950
Austin Tenants' Council                          5             819,474
Arizona Attorney General's                       4             782,842
 Office
======================================================================
Total                                          179         $43,084,022
----------------------------------------------------------------------
Many of these organizations received grants in consecutive years as
well as grants under more than one FHIP initiative.  For example, the
National Fair Housing Alliance received at least one grant during
each fiscal year of FHIP funding, including two education and
outreach grants from 1991 funds, two private enforcement grants and
one fair housing organizations grant from 1994 funds, and a fair
housing organizations and an education and outreach grant from 1995
funds.\10 The Metropolitan Milwaukee Fair Housing Council also
received one grant each fiscal year and two grants in each of two
fiscal years--a private enforcement grant and an education and
outreach grant in 1990 and two private enforcement grants in 1994. 
The Open Housing Center, Inc., received three grants in 1994 and two
in 1995, but none in 1993.  Some of the 26 organizations received
grants that were awarded for multiyear projects, and these grants
were generally much larger than single-year grants. 


--------------------
\9 One grant awarded with fiscal year 1989 funds is not included
because HUD did not locate the necessary documentation in time for
our analysis.  We excluded 41 fiscal year 1996 grants because the
final statements of work and budgets had not yet been completed as of
September 1996.  As a result, our discussion of FHIP grant recipients
does not include the $12 million set aside for those 41 grants. 

\10 With one exception, the fiscal year 1996 solicitation for
applications specified that an organization cannot receive more than
one grant.  A successful applicant under the fair housing
organizations initiative is also eligible to receive one additional
award under either the private enforcement or education and outreach
initiative. 


      MOST FHIP FUNDS ARE USED FOR
      ENFORCEMENT
---------------------------------------------------------- Letter :4.2

FHIP grant awards reflect the program's emphasis on private
enforcement-related activities.  From fiscal year 1989 through 1996,
the largest percentage of FHIP dollars funded activities under the
private enforcement initiative--$40.5 million, or 47 percent. 
Another $15.8 million, or 18 percent, was awarded for the fair
housing organizations initiative (see fig.  3). 

   Figure 3:  Percentage of FHIP
   Dollars Awarded for Each
   Initiative, Fiscal Years 1989
   Through 1996

   (See figure in printed
   edition.)

Note:  $86 million awarded through September 1996, representing 483
grants. 

Source:  GAO's analysis of FHIP grant data. 

Overall, FHIP-funded activities consist predominately of testing
(complaint-based, systemic, or both) and other enforcement-related
activities.  Under the private enforcement initiative, in particular,
funded activities include, among others, testing to confirm
allegations of discrimination in the rental and sale of property,
litigating cases, organizing new fair housing offices, and developing
computer databases on complaints. 


      ACTIVITIES UNDER FHIP'S FOUR
      INITIATIVES ARE DIVERSE
---------------------------------------------------------- Letter :4.3

Seventy-nine different organizations received 202 private enforcement
initiative grants ranging from $10,000 to $1 million and averaging
about $200,500.\11 Of the 202 grants we reviewed, 181 were funded to
carry out testing and testing-related activities.  The remaining 21
grants were funded to engage in other enforcement-related activities,
such as litigating cases; recruiting and/or training attorneys;
developing fair housing databases; establishing a statewide attorney
network to handle complaints from member offices; and training
volunteers and community residents. 

In addition, private enforcement initiative grants funded special
projects that focus on high-priority issues such as mortgage lending
discrimination and insurance redlining.  Included among those awards
was a fiscal year 1992 grant for $1 million to support a large-scale
national testing program to assess mortgage lending discrimination. 
Information obtained from FHIP-funded projects can be used by either
public or private nonprofit organizations, or HUD, as the basis for a
formal complaint against individuals or lending institutions. 
Several FHIP-funded projects involving testing mortgage lenders and
insurance companies were completed in 1995, and as a result,
complaints have been filed with HUD against three of the largest home
insurance companies and five of the largest independent mortgage
companies in the country. 

Under FHIP's fair housing organizations initiative, 47 different
groups received 56 grants ranging from $30,000 to $1,859,000 and
averaging about $282,500.  While organizations with grants under the
fair housing organizations initiative may engage in many of the same
activities as the private enforcement initiative grantees, the fair
housing organizations initiative was established to create new fair
housing enforcement organizations in those areas of the country that
were unserved or underserved by these organizations or expand the
capacity of existing private nonprofit fair housing organizations. 
Of the 56 fair housing organizations initiative grants, 19 were used
to establish new organizations.  According to HUD, some grants funded
more than one new fair housing organization, and in total, 23 new
organizations have been established with FHIP grants.  The new
organizations are located primarily in the southern and western
United States--areas historically underserved by fair housing
enforcement programs, according to HUD.  Fair housing organizations
initiative grantees were also funded to recruit and train testers,
implement testing programs, and conduct community outreach to inform
the public about the services provided by newly established fair
housing organizations. 

One hundred and twenty-eight different organizations received 188
education and outreach initiative grants ranging from $6,500 to
$1,182,900 and averaging about $119,300.  A wide range of activities
were funded to provide education and outreach under this initiative's
three components--national, regional and local, and community-based. 
Overall, the principal activities for the 188 education and outreach
grants were developing pamphlets and brochures; preparing print,
television, and radio advertisements; producing video and audio
tapes; and providing conferences and seminars for other interested
parties, including the housing industry, consumers, and community
organizations. 

Twenty-two different organizations received 37 administrative
enforcement initiative grants ranging from $55,300 to $439,300 and
averaging about $197,200.  About two-thirds of those grants funded at
least one type of testing, that is, complaint-based or systemic. 
Other FHIP-funded activities include staff training, community
training, tester recruitment, and conciliation/settlement activities. 


--------------------
\11 Because this section focuses on grants and organizations by
program initiative, the number of different organizations that
received FHIP grants will total more than the 220 previously
discussed.  This is because many of the same organizations received
grants under more than one initiative. 


      FHIP FUNDS MAY NOT BE USED
      TO SUE THE FEDERAL
      GOVERNMENT
---------------------------------------------------------- Letter :4.4

To determine whether grantees used FHIP funds to sue the government,
we asked HUD's Office of General Counsel to identify FHIP grantees
involved in litigation with the government.  The General Counsel
identified 10 cases involving 7 grantees who had filed lawsuits
against the government since the inception of the program.  Of the 10
lawsuits, 4 (involving 3 grantees) were filed and resolved before a
FHIP grant was awarded to the fair housing organization.  For the
remaining six lawsuits (involving four grantees), pro bono legal
services or other resources were used to pursue the cases against the
U.S.  government, according to HUD. 


      HUD'S FINAL ASSESSMENTS
      INDICATE GENERAL
      SATISFACTION WITH GRANTEES'
      USE OF FUNDS
---------------------------------------------------------- Letter :4.5

HUD has generally been satisfied with grantees' use of funds.  During
the grant performance period and before closing out a grant, HUD
reviews quarterly reports and products provided by the grantee to
ensure that the organization's performance is consistent with the
grant agreement.  At the end of the grant period and after receipt of
the final performance reports and products, HUD completes a closeout
review.  For this final assessment, HUD determines whether the
grantee performed all grant requirements, indicates whether all work
is acceptable, and rates the grantee's performance. 

Our analysis of the available assessments of 206 grants that had been
closed out as of November 1996 indicates that HUD believes that the
grantees generally carried out the activities as agreed.  HUD rated
21 grantees as excellent, 150 as good, 27 as fair, and 6 as
unsatisfactory.\12 For the six grantees rated unsatisfactory, the
primary reason cited was a failure to complete all the expected work
requirements usually because of personnel changes within the
organization. 

According to HUD, these 206 grants did not represent the total of all
grants that should have been closed out and evaluated.  An additional
118 grants for which the work has been completed and final payments
have been made have yet to be closed out.  The Acting FHIP Division
Director told us that performing closeout reviews is an
administrative process and, as such, is a low-priority item. 
According to HUD's Office of Procurement and Contracts, neither
federal regulations nor HUD's guidelines include a specific time
frame for completing the reviews. 


--------------------
\12 Two of the assessments did not indicate a rating. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

We provided a draft of this report to HUD for review and comment.  We
discussed the draft report with HUD officials, including the Acting
FHIP Division Director.  In commenting, HUD said that the report
presents an accurate description of how FHIP funds are used.  HUD
also provided other comments consisting primarily of suggested
changes to technical information, and we incorporated these in the
report where appropriate. 


---------------------------------------------------------- Letter :5.1

We conducted our work between August 1996 and February 1997 in
accordance with generally accepted government auditing standards. 
Appendix IV describes our objectives, scope, and methodology. 

We will send copies of this report to congressional committees and
subcommittees interested in housing matters; the Secretary of Housing
and Urban Development; the Director, Office of Management and Budget;
and other interested parties.  We will also make copies available to
others upon request.  If you would like additional information on
this report, please call me at (202) 512-7631.  Major contributors to
this report are listed in appendix V. 

Lawrence J.  Dyckman
Associate Director, Housing and
 Community Development Issues


EXAMPLES OF ELIGIBLE ACTIVITIES
=========================================================== Appendix I

Type of initiative             Eligible activities
-----------------------------  ----------------------------------------------------------
Private enforcement            ï¿½ testing and other investigative activities to identify
initiative                     housing discrimination;
                               ï¿½ remedies for discrimination in real estate markets;
                               ï¿½ special projects, including the development of
                               prototypes to respond to new or sophisticated forms of
                               discrimination;
                               ï¿½ technical assistance to local fair housing
                               organizations;
                               ï¿½ the formation and development of new fair housing
                               organizations;
                               ï¿½ capacity building to investigate housing discrimination
                               complaints for all protected classes;
                               ï¿½ regional enforcement activities to address broader
                               housing discrimination practices; and
                               ï¿½ litigation costs and expenses, including expert witness
                               fees.

Fair housing organizations     ï¿½ staff training;
initiative/                    ï¿½ education and outreach to promote awareness of services
Continued development          provided by new organizations;
component                      ï¿½ technical assistance and mentoring services for new
                               organizations; and
                               ï¿½ activities listed above under the private enforcement
                               initiative.

Fair housing organizations     ï¿½ projects that help establish, organize, and build the
initiative/                    capacity of fair housing enforcement organizations in
New organizations component    targeted unserved and underserved areas of the country.

Education and outreach         ï¿½ media campaigns, including public service announcements,
initiative                     television, radio and print advertisements, posters,
                               pamphlets and brochures;
                               ï¿½ seminars, conferences, workshops and community
                               presentations;
                               ï¿½ guidance to housing providers on meeting their Fair
                               Housing Act obligations;
                               ï¿½ meetings with housing industry and civic or fair housing
                               groups to identify and correct illegal real estate
                               practices;
                               ï¿½ activities to meet state and local government fair
                               housing planning requirements; and
                               ï¿½ projects related to observance of National Fair Housing
                               Month.

Administrative enforcement     ï¿½ fair housing testing programs and other related
initiative                     enforcement activities;
                               ï¿½ systemic discrimination investigations;
                               ï¿½ remedies for discrimination in real estate markets;
                               ï¿½ technical assistance to government agencies
                               administering housing and community development programs
                               concerning applicable fair housing laws and regulations;
                               and
                               ï¿½ computerized complaint processing and the monitoring of
                               system improvements.
-----------------------------------------------------------------------------------------

DATA ON FUNDING FOR THE FAIR
HOUSING INITIATIVES PROGRAM AND
THE DEMAND FOR FUNDS
========================================================== Appendix II

The following four tables provide details on the Department of
Housing and Urban Development's (HUD) allocation of funds among the
Fair Housing Initiatives Program's (FHIP) four funding initiatives or
categories, the dollar amounts made available under each category,
and the level of demand for funds under each category.  The demand is
indicated by both the number of applicants and the dollars requested. 



                                        Table II.1
                         
                         HUD-Proposed Allocations, by Initiative
                                     and Fiscal Year

                                  (Dollars in millions)

                                                                               Total
                                                                           --------------
Initiativ                                                                  Dollar  Percen
e            1989    1990    1991    1992    1993    1994    1995    1996       s       t
---------  ------  ------  ------  ------  ------  ------  ------  ------  ------  ------
Administr       0       0       0    $1.6    $2.1   $ 1.5   $ 3.0   $ 4.0  $ 12.2      12
 ative
 enforcem
 ent
 initiati
 ve
Education    $2.0    $2.0    $2.0     2.1     2.5     3.0     7.0     6.0    26.6      25
 and
 outreach
 initiati
 ve
Fair           \a      \a      \a      \a      \a     6.4     7.0    10.0    23.4      22
 housing
 organiza
 tions
 initiati
 ve
Private       3.0     4.0     3.6     4.3     3.0     6.0     9.0    10.0    42.9      41
 enforcem
 ent
 initiati
 ve
=========================================================================================
Total        $5.0    $6.0    $5.6    $8.0    $7.6   $16.9   $26.0   $30.0  $105.1     100
-----------------------------------------------------------------------------------------
\a Not applicable. 

Source:  HUD's fiscal years 1989 through 1996 congressional budget
justifications. 



                                        Table II.2
                         
                         FHIP Funds Made Available, by Initiative
                                     and Fiscal Year

                                  (Dollars in millions)

                                                                               Total
                                                                           --------------
Initiativ                                                                  Dollar  Percen
e            1989    1990    1991    1992    1993    1994    1995    1996       s       t
---------  ------  ------  ------  ------  ------  ------  ------  ------  ------  ------
Administr       0       0       0    $2.5   $ 1.0   $ 1.5   $ 3.0       0   $ 8.0       8
 ative
 enforcem
 ent
 initiati
 ve
Education    $2.0    $1.9    $1.9     2.6     3.0     3.0     6.8   $ 2.0    23.2      24
 and
 outreach
 initiati
 ve
Fair           \a      \a      \a      \a     2.6     7.0     7.3     3.0    19.9      20
 housing
 organiza
 tions
 initiati
 ve
Private       3.0     3.9     3.8     3.0     4.0     9.0     9.0    12.0    47.7      48
 enforcem
 ent
 initiati
 ve
=========================================================================================
Total        $5.0    $5.8    $5.7    $8.1  $10.6\  $20.5\   $26.1   $17.0   $98.8     100
                                                b       c
-----------------------------------------------------------------------------------------
\a Not applicable. 

\b The amount appropriated in fiscal year 1993 exceeded the budget
request by $3 million. 

\c The amount appropriated in fiscal year 1994 exceeded the budget
request by $3.6 million. 



                                        Table II.3
                         
                         Number of Applications for FHIP Grants,
                              by Initiative and Fiscal Year

                                                                               Total
                                                                           --------------
Initiativ                                                                          Percen
e            1989    1990    1991    1992    1993    1994    1995    1996  Number       t
---------  ------  ------  ------  ------  ------  ------  ------  ------  ------  ------
Administr      \a      \a      \a      16      24      17      18      \a      75       4
 ative
 enforcem
 ent
 initiati
 ve
Education     183     178     150     218     201     187     216      19   1,352      65
 and
 outreach
 initiati
 ve
Fair           \a      \a      \a      \a      49      49      59      19     176       8
 housing
 organiza
 tions
 initiati
 ve
Private        58      50      48      58      72      85      63      53     487      23
 enforcem
 ent
 initiati
 ve
=========================================================================================
Total         241     228     198     292     346     338     356      91   2,090     100
-----------------------------------------------------------------------------------------
Note:  HUD was unable to provide data for one selection panel. 

\a Not applicable. 



                               Table II.4
                
                 Dollar Value of Applications for FHIP
                 Grants, by Initiative and Fiscal Year

                         (Dollars in millions)

                                                          Total
                                                    ------------------
                                                              Percent\
Initiative                1994      1995      1996    Dollar         b
--------------------  --------  --------  --------  --------  --------
Administrative            $2.2      $3.6        \a      $5.8         3
 enforcement
 initiative
Education and             23.5      37.5      $2.5      63.5        36
 outreach initiative
Fair housing              10.5      14.9       4.6      30.0        17
 organizations
 initiative
Private enforcement       18.8      34.1      22.6      75.5        43
 initiative
======================================================================
Total                    $55.0     $90.1     $29.7    $174.8       100
----------------------------------------------------------------------
\a Not applicable. 

\b Figures do not add to 100 percent because of rounding. 


LIST OF GRANTEES BY FHIP
INITIATIVE FOR FISCAL YEARS 1989
THROUGH 1996
========================================================= Appendix III

                                                                      Initiativ
Recipient                                         Location            e            Amount
------------------------------------------------  ------------------  ---------  --------
1989 grants
-----------------------------------------------------------------------------------------
Independent Housing Services                      San Francisco, CA   EOI         $45,020

National Association of Protection and Advocacy   Washington, DC      EOI          50,765
Systems

International Association of Official Human       Washington, DC      EOI          70,000
Rights Agencies

Metropolitan Washington Council of Governments    Washington, DC      EOI          26,954

National Fair Housing Alliance                    Washington, DC      EOI        1,182,94
                                                                                        1

National Association of Protection and Advocacy   Washington, DC      EOI          30,000
Systems

Massachusetts Commission Against Discrimination   Boston, MA          EOI          33,722

Boston Fair Housing Commission                    Boston, MA          EOI          35,112

State of New Jersey, Department of Law and        Trenton, NJ         EOI          29,661
Public Safety

New Mexico State Housing                          Santa Fe, NM        EOI          51,594

Metropolitan Phoenix Fair Housing Center\a        Phoenix, AZ         PEI          50,486

Fair Housing Congress of Southern California      Los Angeles, CA     PEI         140,000

Operation Sentinel                                Palo Alto, CA       PEI          66,263

Fair Housing Association of Connecticut, Inc.     Bridgeport, CT      PEI          10,000

Metro Fair Housing Services, Inc.                 Atlanta, GA         PEI         197,329

SER\JOBS for Progress, Inc.                       Waukegan, IL        PEI          29,933

Access Living of Metropolitan Chicago             Chicago, IL         PEI         135,948

Interfaith Housing Center of the Northern         Winnetka, IL        PEI          32,000
Suburbs

Leadership Council for Metropolitan Open          Chicago, IL         PEI          88,000
Communities

HOPE Fair Housing Center                          Wheaton, IL         PEI          38,000

South Suburban Housing Center                     Homewood, IL        PEI          36,498

Northwest Indiana Open Housing Center             Gary, IN            PEI          60,636

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         149,208
the Boston Bar Association

Housing Allowance Project, Inc.                   Springfield, MA     PEI         117,000

Suburban Maryland Fair Housing, Inc.              Rockville, MD       PEI          12,750

Fair Housing Center of Metropolitan Detroit       Detroit, MI         PEI         145,208

Legal Aid Society of Minneapolis                  Minneapolis, MN     PEI          60,000

Council for Concerned Citizens                    Great Falls, MT     PEI          97,509

Fair Housing Council of Northern New Jersey       Hackensack, NJ      PEI         250,000

Civic League of Greater New Brunswick             New Brunswick, NJ   PEI          97,664

Long Island Housing Services                      Islandia, NY        PEI          63,864

Open Housing Center, Inc.                         New York, NY        PEI         150,107

Westchester Residential Opportunities, Inc.       White Plains, NY    PEI          59,220

Legal Aid Society of New York                     New York, NY        PEI         112,774

Housing Opportunities Made Equal-Buffalo          Buffalo, NY         PEI          36,181

Fair Housing Contact Service                      Akron, OH           PEI          74,705

Toledo Community Housing Resource Board           Toledo, OH          PEI          67,000

Cuyahoga Plan of Ohio                             Cleveland, OH       PEI          89,566

Oregon Legal Services Corporation                 Portland, OR        PEI          93,365

Fair Housing Council of Delaware County           Media, PA           PEI          73,683

Housing Opportunities Corporation                 Memphis, TN         PEI          91,525

Housing Opportunities Made Equal of Richmond      Richmond, VA        PEI          91,521

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         164,774

=========================================================================================
Total                                                                 43         4,538,48
                                                                                        6


1990 grants
-----------------------------------------------------------------------------------------
Alaska Human Rights Commission                    Anchorage, AK       EOI          34,015

Magnolia Community Resource Board                 Magnolia, AR        EOI          30,591

City of Phoenix                                   Phoenix, AZ         EOI          75,000

Arizona Attorney General's Office                 Phoenix, AZ         EOI          42,036

Old Pueblo Community Housing Resource Board       Tucson, AZ          EOI          30,000

Fair Housing Council of San Diego                 San Diego, CA       EOI          28,456

Housing for All, Metro Denver Fair Housing        Denver, CO          EOI          75,000
Center

Colorado Department of Institutions               Denver, CO          EOI          20,280

Fair Housing Council of Greater Washington        Washington, DC      EOI          68,010

National Council of La Raza                       Washington, DC      EOI         249,864

Iowa Civil Rights Commission                      Des Moines, IA      EOI          75,000

Caldwell Community Housing Resource Board         Caldwell, ID        EOI          65,894

Leadership Council for Metropolitan Open          Chicago, IL         EOI          75,000
Communities

Chicago Area Fair Housing Alliance                Chicago, IL         EOI          47,795

NAACP-Illinois State Conference of Branches       Decatur, IL         EOI          12,436

Wyandotte County Community Housing Resource       Kansas City, KS     EOI          30,000
Board

Fair Housing Council-Kentucky                     Louisville, KY      EOI          42,192

Community Housing Resource Board of Lake Charles  Lake Charles, LA    EOI          36,090

Massachusetts Commission Against Discrimination   Boston, MA          EOI          65,393

Massachusetts Association of Realtors             Waltham, MA         EOI          13,528

York County Community Action Corporation          Sanford, ME         EOI          43,803

Legal Aid Society of Minneapolis                  Minneapolis, MN     EOI          46,903

Montana Human Rights Commission                   Helena, MT          EOI          75,000

Elizabeth City State University                   Elizabeth City, NC  EOI          72,500

Urban Housing Foundation, Inc.                    Omaha, NE           EOI          37,419

Camden County Community Housing Resource Board    Camden, NJ          EOI          74,480

New York State Division of Human Rights           New York, NY        EOI          74,880

National Urban League                             New York, NY        EOI         256,932

Long Island Housing Services                      Islandia, NY        EOI          74,972

Professional Housing Services, Inc.               Cleveland, OH       EOI           6,500

Cuyahoga Plan of Ohio                             Cleveland, OH       EOI          74,064

City of Tulsa, Department of Human Rights         Tulsa, OK           EOI          29,125

Multnomah County Community Development Division   Portland, OR        EOI          74,895

Booker T. Washington Center, Inc.                 Erie, PA            EOI          28,492

Chattanooga Community Housing Resource Board      Chattanooga, TN     EOI          25,175

City of El Paso                                   El Paso, TX         EOI          70,260

Virginia Polytechnic Institute and University     Blacksburg, VA      EOI          52,092

Fair Housing Council of Fox Valley                Appleton, WI        EOI           9,972

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       EOI          62,052

Metropolitan Phoenix Fair Housing Center          Phoenix, AZ         PEI          45,398

Marin Housing Center                              San Rafael, CA      PEI          87,828

Project Sentinel                                  Palo Alto, CA       PEI          98,969

Fair Housing Council of Greater Washington        Washington, DC      PEI         128,612

National Fair Housing Alliance                    Washington, DC      PEI         507,027

Mental Health Law Project                         Washington, DC      PEI          86,865

Housing Opportunities Project for Excellence,     Miami, FL           PEI          66,470
Inc.

Metro Fair Housing Services, Inc.                 Atlanta, GA         PEI         186,920

HOPE Fair Housing Center                          Wheaton, IL         PEI          49,777

Interfaith Housing Center of the Northern         Winnetka, IL        PEI          51,800
Suburbs

Leadership Council for Metropolitan Open          Chicago, IL         PEI         218,681
Communities

South Suburban Housing Center                     Homewood, IL        PEI          34,591

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         234,861
the Boston Bar Association

Fair Housing Center of Metropolitan Detroit       Detroit, MI         PEI         198,760

Council for Concerned Citizens                    Great Falls, MT     PEI          97,509

Fair Housing Council of Northern New Jersey       Hackensack, NJ      PEI         200,000

Truckee Meadows Fair Housing                      Reno, NV            PEI          65,040

Open Housing Center, Inc.                         New York, NY        PEI         154,338

Medger Evers College, Center for Law and Social   New York, NY        PEI         107,349
Justice

Long Island Housing Services                      Islandia, NY        PEI          95,688

Housing Opportunities Made Equal-Buffalo          Buffalo, NY         PEI          41,997

Monroe County Legal Assistance Corporation        Rochester, NY       PEI          71,640

Westchester Residential Opportunities, Inc.       White Plains, NY    PEI          64,390

Toledo Fair Housing Center                        Toledo, OH          PEI         108,283

Cuyahoga Plan of Ohio                             Cleveland, OH       PEI         156,233

Fair Housing Contact Service                      Akron, OH           PEI          73,849

Metropolitan Fair Housing Council of Greater      Oklahoma City, OK   PEI          98,337
Oklahoma City

Urban League of Pittsburgh, Inc.                  Pittsburgh, PA      PEI         118,161

Housing Opportunities Corporation                 Memphis, TN         PEI         115,973

Housing Opportunities Made Equal of Richmond      Richmond, VA        PEI          74,142

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         101,861

=========================================================================================
Total                                                                 70         6,047,44
                                                                                        5


1991 grants
-----------------------------------------------------------------------------------------
Alaska State Commission for Human Rights          Anchorage, AK       EOI          75,000

Arkansas Delta Housing Development Corporation    Forrest City, AR    EOI          75,000

Fair Housing Congress of Southern California      Los Angeles, CA     EOI          74,360

Housing for All, Metro Denver Fair Housing        Denver, CO          EOI          39,398
Center

International Association of Official Human       Washington, DC      EOI          40,000
Rights Agencies

Howard University                                 Washington, DC      EOI          99,573

National Fair Housing Alliance                    Washington, DC      EOI          25,000

Fair Housing Council of Greater Washington        Washington, DC      EOI          75,000

Neighborhood Federation for Neighborhood          Washington, DC      EOI          88,995
Diversity

National Fair Housing Alliance                    Washington, DC      EOI          75,000

Commission on Equal Opportunity                   Atlanta, GA         EOI          75,000

Leadership Council for Metropolitan Open          Chicago, IL         EOI          60,000
Communities

Fair Housing Council-Kentucky                     Louisville, KY      EOI          47,116

Community Action, Inc.                            Haverhill, MA       EOI          49,607

Massachusetts Rehabilitation Commission           Boston, MA          EOI         186,287

NAACP Special Contribution Fund                   Baltimore, MD       EOI          40,000

Maine Human Rights Commission                     Augusta, ME         EOI          70,574

Northern Bergen County Community Housing          Hackensack, NJ      EOI          58,200
Resource Board

Housing Help, Inc.                                Greenlawn, NY       EOI          34,930

Open Housing Center, Inc.                         New York, NY        EOI          75,000

Long Island Housing Services                      Islandia, NY        EOI          75,000

Cuyahoga Plan of Ohio                             Cleveland, OH       EOI          75,000

Fair Housing Council of Oregon                    Portland, OR        EOI          75,000

Tenants' Action Group of Philadelphia             Philadelphia, PA    EOI          73,249

Providence Housing Authority                      Providence, RI      EOI          37,115

State of South Carolina Human Affairs Commission  Columbia, SC        EOI          75,000

City of Dallas, Fair Housing Office               Dallas, TX          EOI          74,991

Austin Tenants' Council                           Austin, TX          EOI          43,500

Heartland Human Relations Association             La Mesa, CA         PEI          69,846

Project Sentinel                                  Palo Alto, CA       PEI         195,094

Fair Housing Congress of Southern California      Los Angeles, CA     PEI          56,926

Marin Housing Center                              San Rafael, CA      PEI          58,500

Housing for All, Metro Denver Fair Housing        Denver, CO          PEI          57,278
Center

Mental Health Law Project                         Washington, DC      PEI          90,000

Fair Housing Council of Greater Washington        Washington, DC      PEI         186,795

Housing Opportunities Project for Excellence,     Miami, FL           PEI          77,376
Inc.

South Suburban Housing Center                     Homewood, IL        PEI          55,000

HOPE Fair Housing Center                          Wheaton, IL         PEI          68,000

Interfaith Housing Center of the Northern         Winnetka, IL        PEI          61,260
Suburbs

Chicago Lawyers' Committee for Civil Rights       Chicago, IL         PEI          77,169
Under Law, Inc.

Access Living of Metropolitan Chicago             Chicago, IL         PEI         158,610

Leadership Council for Metropolitan Open          Chicago, IL         PEI          93,932
Communities

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         196,841
the Boston Bar Association

Housing Discrimination Project                    Holyoke, MA         PEI         149,530

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         277,408
the Boston Bar Association

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         325,000
the Boston Bar Association

Fair Housing Center of Metropolitan Detroit       Detroit, MI         PEI         166,810

Fair Housing Council of Northern New Jersey       Hackensack, NJ      PEI         134,825

Civic League of Greater New Brunswick             New Brunswick, NJ   PEI          75,107

Open Housing Center, Inc.                         New York, NY        PEI         224,184

Westchester Residential Opportunities, Inc.       White Plains, NY    PEI          79,940

New York Lawyers for Public Interest              New York, NY        PEI          46,000

Housing Opportunities Made Equal-Buffalo          Buffalo, NY         PEI          46,455

Toledo Community Housing Resource Board           Toledo, OH          PEI         114,259

Oregon Legal Services Corporation                 Portland, OR        PEI          99,997

Fair Housing Council of Suburban Philadelphia     Upper Darby, PA     PEI          99,340

Housing Opportunities Corporation                 Memphis, TN         PEI         221,094

Housing Opportunities Made Equal of Richmond      Richmond, VA        PEI          87,566

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         155,254

=========================================================================================
Total                                                                 59         5,698,29
                                                                                        1


1992 grants
-----------------------------------------------------------------------------------------
Arizona Attorney General's Office                 Phoenix, AZ         AEI         231,920

Connecticut Commission on Human Rights and        Hartford, CT        AEI         439,312
Opportunities

Indiana Civil Rights Commission                   Indianapolis, IN    AEI          82,387

Massachusetts Commission Against Discrimination   Boston, MA          AEI          76,376

Montana Human Rights Commission                   Helena, MT          AEI         148,767

North Carolina Human Relations Commission         Raleigh, NC         AEI         163,386

Nebraska Equal Opportunity Commission             Lincoln, NE         AEI         176,067

Ohio Civil Rights Commission                      Columbus, OH        AEI         250,056

Texas Commission on Human Rights                  Austin, TX          AEI         234,495

King County Office of Civil Rights and            Seattle, WA         AEI          55,340
Compliance

Greater Birmingham Fair Housing Center            Birmingham, AL      EOI          79,376

Independent Housing Services                      San Francisco, CA   EOI          55,442

Project Sentinel                                  Palo Alto, CA       EOI          78,417

Howard University                                 Washington, DC      EOI         116,788

Fair Housing Council of Greater Washington        Washington, DC      EOI         109,585

Iowa Civil Rights Commission                      Des Moines, IA      EOI          75,745

Latinos United                                    Chicago, IL         EOI          91,881

Interfaith Housing Center of the Northern         Winnetka, IL        EOI          80,000
Suburbs

John Marshall Law School                          Chicago, IL         EOI         200,418

Leadership Council for Metropolitan Open          Chicago, IL         EOI          50,000
Communities

Housing Coalition of the Southern Suburbs         Dolton, IL          EOI          63,000

Kansas Human Relations Association                Salina, KS          EOI          86,230

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          EOI         121,431
the Boston Bar Association

Massachusetts Housing Finance Agency              Boston, MA          EOI          53,043

Housing Discrimination Project                    Holyoke, MA         EOI          88,706

ARC of Massachusetts                              Waltham, MA         EOI         108,169

Greater Baltimore Board of Realtors, Inc.         Baltimore, MD       EOI          50,000

Portland West Neighborhood Planning Council       Portland, ME        EOI          73,098

Access Resources of Missouri                      St. Louis, MO       EOI          33,191

Council for Concerned Citizens                    Great Falls, MT     EOI          74,314

North Carolina State University, Office of        Raleigh, NC         EOI         189,218
Research, Outreach and Extension

Gloucester County                                 Glassboro, NJ       EOI          62,845

State of New Jersey, Department of Public         Trenton, NJ         EOI         147,309
Advocacy

Long Island Housing Services                      Islandia, NY        EOI         166,300

Legal Aid Society of New York                     New York, NY        EOI          92,000

Cuyahoga Plan of Ohio                             Cleveland, OH       EOI         118,115

Housing Consortium for Disabled Individuals       Philadelphia, PA    EOI          55,724

Austin Tenants' Council                           Austin, TX          EOI          50,000

City of Lynchburg                                 Lynchburg, VA       EOI          44,000

Housing Opportunities Made Equal of Richmond      Richmond, VA        EOI         107,747

Virginia State University                         Petersburg, VA      EOI         103,887

Madison Equal Opportunities Commission            Madison, WI         EOI          57,310

Project Sentinel                                  Palo Alto, CA       PEI          99,689

Housing Rights, Inc.                              Berkley, CA         PEI          14,000

Housing for All, Metro Denver Fair Housing        Denver, CO          PEI          95,000
Center

National Fair Housing Alliance                    Washington, DC      PEI        1,000,00
                                                                                        0

Fair Housing Council of Greater Washington        Washington, DC      PEI         187,812

Housing Opportunities Project for Excellence,     Miami, FL           PEI          90,002
Inc.

HOPE Fair Housing Center                          Wheaton, IL         PEI          66,640

Leadership Council for Metropolitan Open          Chicago, IL         PEI         110,777
Communities

South Suburban Housing Center                     Homewood, IL        PEI          55,000

Fair Housing Council-Kentucky                     Louisville, KY      PEI          49,923

Housing Discrimination Project                    Holyoke, MA         PEI         136,631

Fair Housing Center of Metropolitan Detroit       Detroit, MI         PEI         157,000

Council for Concerned Citizens                    Great Falls, MT     PEI          99,627

Fair Housing Council of Northern New Jersey       Hackensack, NJ      PEI         195,606

Housing Opportunities Made Equal-Buffalo          Buffalo, NY         PEI          50,420

Open Housing Center, Inc.                         New York, NY        PEI         282,387

Westchester Residential Opportunities, Inc.       White Plains, NY    PEI          88,494

Toledo Fair Housing Center                        Toledo, OH          PEI         128,470

Fair Housing Council of Oregon                    Portland, OR        PEI         104,098

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         147,029

=========================================================================================
Total                                                                 62         7,900,00
                                                                                        0


1993 grants
-----------------------------------------------------------------------------------------
Colorado Civil Rights Division                    Denver, CO          AEI         259,803

Illinois Department of Human Rights               Chicago, IL         AEI         130,514

Massachusetts Commission Against Discrimination   Boston, MA          AEI         429,197

Massachusetts Commission Against Discrimination   Boston, MA          AEI         160,500

City of Dallas, Fair Housing Office               Dallas, TX          AEI         141,497

King County Office of Civil Rights and            Seattle, WA         AEI         207,113
Compliance

Southern Arizona Housing Center                   Tucson, AZ          EOI          98,803

National Association of Protection and Advocacy   Washington, DC      EOI         126,028
Systems

National Puerto Rican Coalition                   Washington, DC      EOI         200,000

National Fair Housing Alliance                    Washington, DC      EOI         199,554

Fair Housing Council-Kentucky                     Louisville, KY      EOI         139,283

Massachusetts Housing Finance Agency              Boston, MA          EOI         186,126

City of Boston, Boston Fair Housing Commission    Boston, MA          EOI          49,980

City of Southfield                                Southfield, MI      EOI         130,000

Michigan Department of Civil Rights               Detroit, MI         EOI         117,435

Metropolitan St. Louis Equal Housing Opportunity  St. Louis, MO       EOI          98,624
Council

West Jackson Community Development Corporation    Jackson, MS         EOI          89,060

Council for Concerned Citizens                    Great Falls, MT     EOI         116,191

Durham Affordable Housing Coalition               Durham, NC          EOI          90,856

New York State Division of Human Rights           New York, NY        EOI          77,052

Housing Help, Inc.                                Greenlawn, NY       EOI          50,000

State University of New York Research Foundation  Amherst, NY         EOI         199,873

Toledo Fair Housing Center                        Toledo, OH          EOI         115,112

Pacific Nonprofit Training Center                 Portland, OR        EOI         199,990

Austin Tenants' Council                           Austin, TX          EOI          52,000

Prince William County                             Woodbridge, VA      EOI          56,662

Tacoma Human Rights Department                    Tacoma, WA          EOI         122,592

ACORN Fair Housing Organization-Arkansas          Little Rock, AR     FHOI        500,418

Arkansas Delta Housing Development Corporation    Forrest City, AR    FHOI        113,915

Arkansas Fair Housing Council                     Little Rock, AR     FHOI        197,256

Midpeninsula Citizens for Fair Housing            Palo Alto, CA       FHOI         42,522

Metro Fair Housing Services, Inc.                 Atlanta, GA         FHOI        502,542

Idaho Legal Aid Services, Inc.                    Boise, ID           FHOI        419,240

Chicago Lawyers' Committee for Civil Rights       Chicago, IL         FHOI         88,666
Under Law, Inc.

Fair Housing Council-Kentucky                     Louisville, KY      FHOI        121,773

ACORN Fair Housing Organization-Louisiana         New Orleans, LA     FHOI        500,000

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          FHOI        209,386
the Boston Bar Association

Legal Aid of Western Missouri                     Kansas City, MO     FHOI        155,398

Metropolitan St. Louis Equal Housing Opportunity  St. Louis, MO       FHOI        305,697
Council

Council for Concerned Citizens                    Great Falls, MT     FHOI        447,666

Billings Fair Housing Alliance, Inc.              Billings, MT        FHOI         30,000

Family Housing Advisory Services, Inc.            Omaha, NE           FHOI        366,372

Civic League of Greater New Brunswick             New Brunswick, NJ   FHOI         99,708

Fair Housing Partnership of Greater Pittsburgh    Pittsburgh, PA      FHOI        130,000

Northwest Fair Housing Alliance                   Spokane, WA         FHOI        472,045

Greater Birmingham Fair Housing Center            Birmingham, AL      PEI         150,742

Marin Housing Center                              San Rafael, CA      PEI         105,233

Project Sentinel                                  Palo Alto, CA       PEI         417,999

Fair Housing Congress of Southern California      Los Angeles, CA     PEI         312,728

Connecticut Housing Coalition                     Wethersfield, CT    PEI         285,117

ACORN                                             Washington, DC      PEI         754,228

HOPE Fair Housing Center                          Wheaton, IL         PEI          97,545

Access Living of Metropolitan Chicago             Chicago, IL         PEI         394,762

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         379,315
the Boston Bar Association

Council for Concerned Citizens                    Great Falls, MT     PEI         448,200

Fair Housing Council of Northern New Jersey       Hackensack, NJ      PEI         287,836

Legal Aid Society of New York                     New York, NY        PEI          92,500

Housing Opportunities Made Equal-Buffalo          Buffalo, NY         PEI         183,774

New York Lawyers for Public Interest              New York, NY        PEI         225,757

Westchester Residential Opportunities, Inc.       White Plains, NY    PEI         297,262

Long Island Housing Services                      Islandia, NY        PEI         572,832

Tenants' Action Group of Philadelphia             Philadelphia, PA    PEI         164,999

Fair Housing Council of Suburban Philadelphia     Upper Darby, PA     PEI         196,947

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         305,511

=========================================================================================
Total                                                                 64         14,219,7
                                                                                       36


1994 grants
-----------------------------------------------------------------------------------------
Arizona Attorney General's Office                 Phoenix, AZ         AEI         177,078

Iowa Civil Rights Commission                      Des Moines, IA      AEI         116,998

Kentucky Commission on Human Rights               Louisville, KY      AEI         106,336

Massachusetts Commission Against Discrimination   Boston, MA          AEI         133,000

Pennsylvania Human Relations Commission           Harrisburg, PA      AEI         287,306

Texas Commission on Human Rights                  Austin, TX          AEI         231,845

Industrial Commission of Utah, Anti-              Salt Lake City, UT  AEI         117,718
Discrimination Division

Catholic Community Services of Southern Arizona   Tucson, AZ          EOI          77,448
(dba the Direct Independent Living Center)

Mental Health Advocacy Project                    San Jose, CA        EOI          63,520

Independent Living Resource Center of San         San Francisco, CA   EOI          70,991
Francisco

Conference of Mayors, Research and Education      Washington, DC      EOI         236,593
Foundation

Access Video Fund                                 Washington, DC      EOI         224,487

Howard University                                 Washington, DC      EOI         220,319

National Community Reinvestment Coalition         Washington, DC      EOI         242,494

Iowa Citizens for Community Improvement           Des Moines, IA      EOI          22,704

John Marshall Law School                          Chicago, IL         EOI         184,607

Leadership Council for Metropolitan Open          Chicago, IL         EOI         875,787
Communities

Massachusetts Rehabilitation Commission           Boston, MA          EOI         103,000

Housing Discrimination Project                    Holyoke, MA         EOI          87,825

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          EOI          94,163
the Boston Bar Association

Baltimore Neighborhoods, Inc.                     Baltimore, MD       EOI          90,173

Legal Aid Bureau of Southwestern Michigan         Kalamazoo, MI       EOI          99,969

North Carolina State University, Center for       Raleigh, NC         EOI         191,640
Accessible Living

New Mexico State Housing                          Santa Fe, NM        EOI          82,871

Asian Americans for Equality                      New York, NY        EOI          99,350

Northern Manhattan Improvement Corporation        New York, NY        EOI          88,782

YWCA of Salem                                     Salem, OR           EOI         156,153

ACORN Housing Corporation, Inc.                   Philadelphia, PA    EOI         220,000

Booker T. Washington Center, Inc.                 Erie, PA            EOI          56,972

Housing Opportunities Made Equal of Richmond      Richmond, VA        EOI         178,625

Champlain Valley Office of Economic Opportunity   Burlington, VT      EOI          76,997

Legal Aid Society of Santa Clara County           San Jose, CA        FHOI        239,965

Fair Housing Council of San Diego                 San Diego, CA       FHOI         98,297

Center for Legal Advocacy (dba the Legal Center   Denver, CO          FHOI        285,244
Serving Persons With Disabilities)

National Fair Housing Alliance                    Washington, DC      FHOI       1,858,63
                                                                                        1

Fair Housing Continuum                            Cocoa, FL           FHOI        479,812

Iowa Protection and Advocacy Services, Inc.       Des Moines, IA      FHOI        150,702

Housing Discrimination Project                    Holyoke, MA         FHOI        120,996

Neighborhood Legal Services, Inc.                 Lynn, MA            FHOI        114,774

Legal Aid Society of Minneapolis                  Minneapolis, MN     FHOI        268,589

Civil Rights Consortium                           Kansas City, MO     FHOI        365,685

North Mississippi Rural Legal Services            Oxford, MS          FHOI        146,068

University of Mississippi Law Center              University, MS      FHOI        244,901

North Carolina Client and Community               Raleigh, NC         FHOI        461,083

Community Health Law Project                      East Orange, NJ     FHOI        199,425

New Mexico Fair Housing Organization              Albuquerque, NM     FHOI        481,892

Legal Aid Society of Albuquerque                  Albuquerque, NM     FHOI        425,021

Nevada Legal Services                             Las Vegas, NV       FHOI        694,897

Open Housing Center, Inc.                         New York, NY        FHOI        260,675

Long Island Housing Services                      Islandia, NY        FHOI        218,646

Medger Evers College, Center for Law and Social   New York, NY        FHOI        198,411
Justice

Lorain County Urban League, Inc.                  Elyria, OH          FHOI        158,324

Protection and Advocacy for People With           Columbia, SC        FHOI        122,180
Disabilities

Austin Tenants' Council                           Austin, TX          FHOI         82,283

Pierce County Community Action Agency             Tacoma, WA          FHOI        442,328

North East Wisconsin Fair Housing Council, Inc.   Appleton, WI        FHOI        153,592

Greater Birmingham Fair Housing Center            Birmingham, AL      PEI         344,249

Southern Arizona Housing Center                   Tucson, AZ          PEI         205,741

Arizona Fair Housing Center                       Phoenix, AZ         PEI         342,319

Fair Housing Congress of Southern California      Los Angeles, CA     PEI         801,820

Fair Housing Council of San Diego                 San Diego, CA       PEI         139,806

Inland Mediation Board                            Ontario, CA         PEI         184,626

Sentinel Fair Housing                             Oakland, CA         PEI         189,196

Housing Rights, Inc.                              Berkeley, CA        PEI          80,831

Housing for All, Metro Denver Fair Housing        Denver, CO          PEI         216,000
Center

National Fair Housing Alliance                    Washington, DC      PEI         127,133

Fair Housing Council of Greater Washington        Washington, DC      PEI         378,792

National Fair Housing Alliance                    Washington, DC      PEI         299,981

Housing Opportunities Project for Excellence,     Miami, FL           PEI         324,121
Inc.

Metro Fair Housing Services, Inc.                 Atlanta, GA         PEI         139,052

South Suburban Housing Center                     Homewood, IL        PEI          35,000

John Marshall Law School                          Chicago, IL         PEI         400,000

HOPE Fair Housing Center                          Wheaton, IL         PEI          83,658

Leadership Council for Metropolitan Open          Chicago, IL         PEI         147,889
Communities

Lawyer's Committee for Better Housing, Inc.       Chicago, IL         PEI         155,830

Leadership Council for Metropolitan Open          Chicago, IL         PEI         192,733
Communities

Interfaith Housing Center of the Northern         Winnetka, IL        PEI          78,998
Suburbs

Fair Housing Council-Kentucky                     Louisville, KY      PEI         229,210

New Orleans Legal Assistance Corporation          New Orleans, LA     PEI         141,468

Housing Discrimination Project                    Holyoke, MA         PEI         349,018

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         373,415
the Boston Bar Association

Baltimore Neighborhoods, Inc.                     Baltimore, MD       PEI         140,935

Fair Housing Center of Metropolitan Detroit       Detroit, MI         PEI         151,400

Fair Housing Center of Metropolitan Detroit       Detroit, MI         PEI         415,160

Legal Aid Bureau of Southwestern Michigan         Kalamazoo, MI       PEI         105,944

Council for Concerned Citizens                    Great Falls, MT     PEI         430,858

Western Montana Fair Housing                      Missoula, MT        PEI         279,010

Fair Housing Council of Northern New Jersey       Hackensack, NJ      PEI         300,000

Housing Coalition of Central New Jersey           New Brunswick, NJ   PEI          80,000

Truckee Meadows Fair Housing                      Reno, NV            PEI         131,644

Long Island Housing Services                      Islandia, NY        PEI         236,416

Brooklyn Legal Services Corporation               Brooklyn, NY        PEI         397,200

Open Housing Center, Inc.                         New York, NY        PEI         208,798

Legal Services of Central New York                Syracuse, NY        PEI         127,668

Open Housing Center, Inc.                         New York, NY        PEI         590,150

Housing Advocates, Inc.                           Cleveland, OH       PEI         200,000

Toledo Fair Housing Center                        Toledo, OH          PEI         299,947

Fair Housing Contact Service                      Akron, OH           PEI         165,684

Housing Opportunities Made Equal Committee of     Cincinnati, OH      PEI          92,264
Cincinnati

Toledo Fair Housing Center                        Toledo, OH          PEI         619,446

Cuyahoga Plan of Ohio                             Cleveland, OH       PEI         194,069

Fair Housing Council of Oregon                    Portland, OR        PEI         246,380

Fair Housing Council of Suburban Philadelphia     Upper Darby, PA     PEI         339,426

West Tennessee Legal Services                     Jackson, TN         PEI         123,900

Housing Opportunities Made Equal of Richmond      Richmond, VA        PEI         528,380

Housing Opportunities Made Equal of Richmond      Richmond, VA        PEI         200,234

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         283,044

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         346,774

=========================================================================================
Total                                                                 108        26,483,7
                                                                                       90


1995 grants
-----------------------------------------------------------------------------------------
Arizona Attorney General's Office                 Phoenix, AZ         AEI         331,808

Iowa Civil Rights Commission                      Des Moines, IA      AEI         273,326

Indiana Civil Rights Commission                   Indianapolis, IN    AEI         135,420

Massachusetts Commission Against Discrimination   Boston, MA          AEI         174,246

Massachusetts Commission Against Discrimination   Boston, MA          AEI         108,615

Maryland Commission on Human Relations            Baltimore, MD       AEI         142,543

Montana Human Rights Commission                   Helena, MT          AEI         235,846

Ohio Civil Rights Commission                      Columbus, OH        AEI         274,200

Pennsylvania Human Relations Commission           Harrisburg, PA      AEI         414,600

Rhode Island Commission for Human Rights          Providence, RI      AEI         123,370

Fort Worth Human Relations Commission             Fort Worth, TX      AEI         109,231

Texas Commission on Human Rights                  Austin, TX          AEI         124,966

Washington State Human Rights Commission          Olympia, WA         AEI         394,516

Tacoma Human Rights Department                    Tacoma, WA          AEI          97,639

Greater Birmingham Fair Housing Center            Birmingham, AL      EOI         147,624

Southern Arizona Housing Center                   Tucson, AZ          EOI         225,000

National Center for Youth Law                     San Francisco, CA   EOI         197,718

Protection and Advocacy, Inc.                     Sacramento, CA      EOI         309,225

City and County of San Francisco                  San Francisco, CA   EOI         151,891

Colorado Coalition for the Homeless               Denver, CO          EOI         108,894

National Community Reinvestment Coalition         Washington, DC      EOI         411,238

National Neighbors, Inc.                          Washington, DC      EOI         430,812

National Fair Housing Alliance                    Washington, DC      EOI        1,131,30
                                                                                        1

Iowa Citizens for Community Improvement           Des Moines, IA      EOI          62,047

John Marshall Law School                          Chicago, IL         EOI         239,255

Leadership Council for Metropolitan Open          Chicago, IL         EOI          88,000
Communities

Mayor's Office for People With Disabilities       Chicago, IL         EOI         146,838

Kansas Human Relations Association                Salina, KS          EOI          95,122

Fair Housing Council-Kentucky                     Louisville, KY      EOI          97,534

Fair Housing Council-Kentucky                     Louisville, KY      EOI         130,251

Massachusetts Commission Against Discrimination   Boston, MA          EOI          58,707

ARC of Massachusetts                              Waltham, MA         EOI         149,625

Housing Discrimination Project                    Holyoke, MA         EOI          99,139

West Jackson Community Development Corporation    Jackson, MS         EOI         139,570

North Carolina State University, Center for       Raleigh, NC         EOI         221,242
Universal Design

State University of New York Research Foundation  Amherst, NY         EOI         199,543

New York State Division of Human Rights           New York, NY        EOI         110,000

Westchester Residential Opportunities, Inc.       White Plains, NY    EOI          55,952

Black River Housing Council, Inc.                 Watertown, NY       EOI          50,000

Open Housing Center, Inc.                         New York, NY        EOI         261,499

Asian Americans for Equality                      New York, NY        EOI         310,995

Cuyahoga Plan of Ohio                             Cleveland, OH       EOI         329,986

Pacific Nonprofit Training Center                 Portland, OR        EOI         350,130

Eugene/Springfield/Cottage Grove (et al.)         Eugene, OR          EOI         131,316
Community
Housing Resources Board

Golden Triangle Radio Information Center          Pittsburg, PA       EOI          85,366

Tennessee Association of Legal Services, Legal    Nashville, TN       EOI          90,060
Aid Projects

Fair Housing Council of Greater Washington        Washington, DC      FHOI        332,850

National Fair Housing Alliance                    Washington, DC      FHOI        499,830

Chicago Lawyers' Committee for Civil Rights       Chicago, IL         FHOI        176,310
Under Law, Inc.

Fair Housing Council-Kentucky                     Louisville, KY      FHOI        164,838

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          FHOI        160,803
the Boston Bar Association

Housing Discrimination Project                    Holyoke, MA         FHOI         86,642

Legal Aid Society of Minneapolis                  Minneapolis, MN     FHOI        179,253

Legal Aid of Western Missouri                     Kansas City, MO     FHOI        210,578

North Carolina Fair Housing Center                Raleigh, NC         FHOI         37,348

New Hampshire Legal Assistance                    Concord, NH         FHOI        113,540

Open Housing Center, Inc.                         New York, NY        FHOI        246,430

Asian Americans for Equality                      New York, NY        FHOI        500,000

Fair Housing Partnership of Greater Pittsburgh    Pittsburgh, PA      FHOI        137,859

Fair Housing of Marin, Inc.                       San Rafael, CA      PEI         557,419

Housing for All, Metro Denver Fair Housing        Denver, CO          PEI          93,953
Center

Connecticut Housing Coalition                     Wethersfield, CT    PEI         353,328

HOPE Fair Housing Center                          Wheaton, IL         PEI         596,100

Lawyers' Committee for Civil Rights Under Law of  Boston, MA          PEI         599,096
the Boston Bar Association

Legal Aid Society of Albuquerque                  Albuquerque, NM     PEI         600,000

Legal Aid Society of New York                     New York, NY        PEI         105,445

Housing Opportunities Made Equal Committee of     Cincinnati, OH      PEI         214,657
Cincinnati

Tenants' Action Group of Philadelphia             Philadelphia, PA    PEI         195,000

Metropolitan Milwaukee Fair Housing Council       Milwaukee, WI       PEI         600,000

=========================================================================================
Total                                                                 69         16,317,4
                                                                                       85


1996 grants
-----------------------------------------------------------------------------------------
National Puerto Rican Coalition                   Washington, DC      EOI         443,484

Massachusetts Housing Finance Agency              Boston, MA          EOI         361,658

Arizona Fair Housing Center                       Phoenix, AZ         PEI         556,631

Project Sentinel                                  Palo Alto, CA       PEI         533,357

Fair Housing Council of Greater Washington        Washington, DC      PEI         600,000

Jacksonville Area Legal Aid                       Jacksonville, FL    PEI         592,915

Leadership Council for Metropolitan Open          Chicago, IL         PEI         597,675
Communities

Open Housing Center, Inc.                         New York, NY        PEI         600,000

Austin Tenants' Council                           Austin, TX          PEI         591,691

=========================================================================================
Total                                                                 9          4,877,41
                                                                                        1

=========================================================================================
Total grants                                                          484        $86,082,
                                                                                      643
-----------------------------------------------------------------------------------------
Legend

EOI = Education and outreach initiative

PEI = Private enforcement initiative

AEI = Administrative enforcement initiative

FHOI = Fair housing organizations initiative

dba = doing business as

\a This grant was not part of our file review as HUD did not locate
the necessary documentation in time for our analysis. 


OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================== Appendix IV

As requested, we reviewed (1) how funds are allocated among the four
FHIP initiatives, the dollar amounts made available for each
initiative, and the level of demand for funds under each initiative
and (2) who receives FHIP funds and how the funds are being used.  We
are also providing background information, as you requested, on the
history of FHIP and activities that can be funded under the program. 

To obtain information on FHIP, its funding, and eligible activities,
we reviewed the program's legislative history, regulations, policies,
procedures, and Federal Register notices that solicited applications
from eligible fair housing agencies and organizations.  We also
reviewed HUD's annual reports to the Congress on fair housing
programs for 1993 and 1994 and obtained descriptions and budgets for
other HUD-administered fair housing activities.  We interviewed the
Director, Office of Fair Housing Initiatives and Voluntary Programs
(who also is the Acting FHIP Division Director); FHIP's government
technical representatives; the Deputy Assistant Secretary,
Enforcement and Investigations; and the Director, Office of
Investigations, Fair Housing and Equal Opportunity. 

We also interviewed FHIP officials at the HUD's Southwest and Midwest
Regions in Fort Worth, Texas and Chicago, Illinois, respectively, as
well as officials of six organizations that received FHIP grants.  In
addition, we held discussions with the National Association of
Realtors and the Mortgage Bankers Association and attended the 1996
New England and Mid-Atlantic Fair Housing Conference. 

To determine how HUD allocates funds among the four program
initiatives, we reviewed and analyzed FHIP congressional budget
justifications for fiscal years 1989 to 1997.  We also reviewed
memorandums and correspondence regarding funding allocations and
HUD's priorities for FHIP since its inception.  To determine the
amounts available for award, we reviewed FHIP's notices of funding
availability as published in the Federal Register for fiscal years
1989 through 1996. 

To determine the demand for funds, we reviewed and analyzed the
available selection results, including technical evaluation panels'
reports, which contained lists of grant applicants and the panels'
recommendations to the Assistant Secretary for Fair Housing and Equal
Opportunity.  We reviewed technical evaluation reports to compile
data on the number of applications by fiscal year and by program
initiative.  We also analyzed the dollar value of applications for
those years for which complete information was readily
available--fiscal years 1994 to 1996.  Additionally, we reviewed
program guidance on the selection process and interviewed HUD
government technical representatives involved in the selection
process. 

To identify the recipients of FHIP funds and the amount of dollars
received, we obtained a copy of the FHIP funding and contract
tracking system's database, which contained 486 grant listings as of
October 1996.  Many grant numbers were not accompanied by the grantee
organizations' names and locations.  To develop a more complete list,
we compared the listed grant numbers to other HUD-provided reports
and added names and locations to the database where possible.  We
used this database as a control for our review of the FHIP grant
files.  During our review of the files, we filled in the missing
names and locations and verified all other grantees' names and
locations, as well as the grant amounts and year of appropriation. 

To determine how FHIP dollars are being used, we developed a data
collection instrument to record data from grant files on the
activities organizations agreed to carry out under the program.  In
developing the instrument, we interviewed program officials, reviewed
FHIP legislation and regulations, notices of funding availability,
and a sample of FHIP grant files.  HUD program officials reviewed and
commented on the data collection instrument, and we incorporated
their suggested changes.  For grants awarded through fiscal year
1996, we reviewed the available grant files (483) and recorded on the
data collection instrument the activities each grantee agreed to
carry out.  We used the information to develop a database from which
we analyzed the number and dollar value of the grants awarded to
organizations and the kinds of activities funded under each FHIP
initiative.  We also reviewed the available final performance
assessments (206) to determine whether grantees completed work as
agreed and how HUD rated their overall performance.  We did not
independently verify the accuracy of the final performance
assessments.  In addition, we interviewed HUD Inspector General
officials in each HUD region regarding their reviews of FHIP
grantees. 

To determine whether any grantees have used FHIP funds to pay
expenses associated with litigation against the U.S.  government, we
interviewed officials in HUD's Office of General Counsel, namely, the
Assistant General Counsel, Fair Housing Enforcement Division, and
Managing Attorney, Litigation Division.  At our request, HUD's
General Counsel contacted agency attorneys in each region to
determine whether they had knowledge of any lawsuits filed by FHIP
grantees against the government.  We interviewed the Acting FHIP
Division Director, responsible government technical representatives,
and government technical monitors about their knowledge of the cases
identified.  We also reviewed correspondence from grantees concerning
whether FHIP funds were used to pursue litigation. 


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION

Patricia D.  Moore
Jeannie B.  Davis
Michael L.  Mgebroff
Vondalee R.  Hunt
Alice G.  Feldesman
John T.  McGrail


*** End of document. ***