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 � testing and other investigative activities to identify
initiative housing discrimination;
� remedies for discrimination in real estate markets;
� special projects, including the development of
prototypes to respond to new or sophisticated forms of
discrimination;
� technical assistance to local fair housing
organizations;
� the formation and development of new fair housing
organizations;
� capacity building to investigate housing discrimination
complaints for all protected classes;
� regional enforcement activities to address broader
housing discrimination practices; and
� litigation costs and expenses, including expert witness
fees.
Fair housing organizations � staff training;
initiative/ � education and outreach to promote awareness of services
Continued development provided by new organizations;
component � technical assistance and mentoring services for new
organizations; and
� activities listed above under the private enforcement
initiative.
Fair housing organizations � 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 � media campaigns, including public service announcements,
initiative television, radio and print advertisements, posters,
pamphlets and brochures;
� seminars, conferences, workshops and community
presentations;
� guidance to housing providers on meeting their Fair
Housing Act obligations;
� meetings with housing industry and civic or fair housing
groups to identify and correct illegal real estate
practices;
� activities to meet state and local government fair
housing planning requirements; and
� projects related to observance of National Fair Housing
Month.
Administrative enforcement � fair housing testing programs and other related
initiative enforcement activities;
� systemic discrimination investigations;
� remedies for discrimination in real estate markets;
� technical assistance to government agencies
administering housing and community development programs
concerning applicable fair housing laws and regulations;
and
� 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. ***