oversight

Fair Housing: Funding and Activities Under the Fair Housing Initiatives Program

Published by the Government Accountability Office on 1997-03-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              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
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   Resources, Community, and
                   Economic Development Division

                   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.


                   From the program’s inception through fiscal year 1997, the Congress has
Results in Brief   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




                   Page 1                       GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                        B-276176




                        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 testing1 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.


                        The Fair Housing Act, title VIII of the Civil Rights Act of 1968, prohibited
Background on the       discrimination in the sale, rental, and financing of housing based on race,
Fair Housing            color, religion, or national origin.2 The act allowed the Department of
Initiatives Program’s   Housing and Urban Development (HUD) to investigate and conciliate
                        complaints of housing discrimination and authorized the Department of
History, Funding, and   Justice to file suits in cases of a pattern or practice of discrimination or in
Activities              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


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



                        Page 2                                  GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
B-276176




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).


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.



Page 3                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                     B-276176




Figure 1: Fair Housing Initiatives
Program’s Appropriations, Fiscal     30   Dollars in millions
Years 1989 Through 1997

                                     25



                                     20



                                     15



                                     10



                                      5



                                      0

                                      1989          1990        1991     1992        1993        1994           1995   1996   1997

                                      Fiscal year



                                     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




                                     Page 4                               GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                          B-276176




                          and have experience in investigating complaints, testing for fair housing
                          violations, and enforcing legal claims or outcomes.


Activities Eligible for   The program provides considerable flexibility in the types of activities that
Program Funds             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      FHIP is an integral part of HUD’s fair housing enforcement and education
Component of HUD’s Fair   efforts that are concentrated within the Office of Fair Housing and Equal
Housing Enforcement       Opportunity. In addition to FHIP, this office is responsible for the oversight
                          of the Fair Housing Assistance Program, investigation and processing of
Activities                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).




                          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.



                          Page 5                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                        B-276176




Figure 2: Office of Fair Housing and
Equal Opportunity’s Budget for Fiscal                                                          Fair Housing Assistance Program's
Year 1996                                                                                      budget - $13 million




                                                                         60.7%                 Office of Fair Housing and Equal
                                                                                               Opportunity's operating
                                                                                               budget - $46.3 million




                                                                                               Fair Housing Initiatives Program's
                                                                                               budget - $17 million


                                        Source: GAO’s analysis of data from HUD.



                                        HUD uses discretion in deciding how FHIP funds are allocated among the
HUD Uses Discretion                     four program initiatives. Reflecting the program’s principal focus, HUD’s
in Allocating FHIP                      budget requests to the Congress set forth how it plans to divide the total
Funds, and                              amount of dollars requested for FHIP among the four initiatives. Notices of
                                        funding availability in the Federal Register indicate the dollar amounts HUD
Allocations Are                         makes available for competition under each program initiative.
Generally as Proposed
in Budgets to the
Congress
HUD’s Allocation of FHIP                According to the Acting FHIP Division Director, the Assistant Secretary for
Funds                                   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



                                        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.



                                        Page 6                                  GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                          B-276176




                          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.


Dollar Amounts Made       The Congress has appropriated amounts equal to or greater than the
Available for Each        amounts HUD requested each fiscal year until 1996.7 In accordance with its
Initiative                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.


                          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).



                          Page 7                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                          B-276176




                      •   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.


The Demand for FHIP       From fiscal year 1989 through fiscal year 1996, HUD received 2,090
Funds                     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


                          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.



                          Page 8                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                         B-276176




                         initiative grants, and about 36 percent was for education and outreach
                         initiative grants.


                         From the program’s inception through September 1996, a total of 220
FHIP Grant               different organizations received FHIP grants in 44 states and the District of
Recipients and           Columbia; 26 organizations received about half of all FHIP funds awarded.
Activities Are Diverse   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         Through fiscal year 1996, HUD awarded 483 grants totaling $86 million to
Concentrated Among a     support fair housing enforcement and education.9 Of the 220 different
Limited Number of        organizations that received grants, 26 received about half of the funds
                         awarded. These 26 organizations, located in 15 states and the District of
Grantees                 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.)




                         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.



                         Page 9                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                      B-276176




Table 1: Twenty-Six Organizations
Awarded the Highest Amounts of FHIP   Grantee                                Number of grants       Total amount of grants
Funds, Fiscal Years 1989 Through      National Fair Housing Alliance                         11                  $6,906,398
1996
                                      Lawyers’ Committee for Civil
                                      Rights Under Law of Boston
                                      Bar Association                                        12                   3,120,927
                                      Open Housing Center, Inc.                              11                   3,053,568
                                      Leadership Council for
                                      Metropolitan Open
                                      Communities                                            12                   2,598,474
                                      Metropolitan Milwaukee Fair
                                      Housing Council                                         9                   2,166,299
                                      Fair Housing Council of
                                      Greater Washington                                      9                   2,067,456
                                      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
                                      Southern California                                     5                   1,385,834
                                      Fair Housing Council of
                                      Northern New Jersey                                     6                   1,368,267
                                      Toledo Fair Housing Center                              5                   1,271,258
                                      Housing Opportunities Made
                                      Equal of Richmond                                       7                   1,268,215
                                      Massachusetts Commission
                                      Against Discrimination                                  9                   1,239,756
                                      Fair Housing Center of
                                      Metropolitan Detroit                                    6                   1,234,338
                                      Housing Discrimination
                                      Project                                                 8                   1,118,487
                                      Cuyahoga Plan of Ohio                                   7                   1,037,033
                                      Metro Fair Housing Services,
                                      Inc.                                                    4                   1,025,843
                                      Legal Aid Society of
                                      Albuquerque                                             2                   1,025,021
                                      John Marshall Law School                                4                   1,024,280
                                      Fair Housing Council -
                                      Kentucky                                                9                   1,022,120
                                      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
                                      Office                                                  4                     782,842
                                      Total                                                179                  $43,084,022


                                      Page 10                          GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                           B-276176




                           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.


Most FHIP Funds Are Used   FHIP grant awards reflect the program’s emphasis on private
for Enforcement            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).




                           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.



                           Page 11                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                       B-276176




Figure 3: Percentage of FHIP Dollars
Awarded for Each Initiative, Fiscal
Years 1989 Through 1996                                                                       202 Private enforcement initiative
                                                                                              grants - $40.5 million


                                                                8.5%                          37 Administrative enforcement
                                                                                              initiative grants - $7.3 million




                                                                                              56 Fair housing organizations
                                                                                              initiative grants - $15.8 million

                                                                                              188 Education and outreach
                                                                                              initiative grants - $22.4 million
                                       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                Seventy-nine different organizations received 202 private enforcement
Four Initiatives Are                   initiative grants ranging from $10,000 to $1 million and averaging about
Diverse                                $200,500.11 Of the 202 grants we reviewed, 181 were funded to carry out
                                       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.



                                       Page 12                                GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
B-276176




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



Page 13                      GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                              B-276176




                              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.


FHIP Funds May Not Be         To determine whether grantees used FHIP funds to sue the government, we
Used to Sue the Federal       asked HUD’s Office of General Counsel to identify FHIP grantees involved in
Government                    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       HUD has generally been satisfied with grantees’ use of funds. During the
Indicate General              grant performance period and before closing out a grant, HUD reviews
Satisfaction With Grantees’   quarterly reports and products provided by the grantee to ensure that the
                              organization’s performance is consistent with the grant agreement. At the
Use of Funds                  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

                              12
                                Two of the assessments did not indicate a rating.



                              Page 14                                GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                  B-276176




                  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.


                  We provided a draft of this report to HUD for review and comment. We
Agency Comments   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.


                  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



                  Page 15                      GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Contents



Letter                                                                                                1


Appendix I                                                                                           18

Examples of Eligible
Activities
Appendix II                                                                                          19

Data on Funding for
the Fair Housing
Initiatives Program
and the Demand for
Funds
Appendix III                                                                                         22

List of Grantees by
FHIP Initiative for
Fiscal Years 1989
Through 1996
Appendix IV                                                                                          36

Objectives, Scope,
and Methodology
Appendix V                                                                                           39

Major Contributors to
This Report
Tables                  Table 1: Twenty-six Organizations Awarded the Highest Amounts                10
                          of FHIP Funds, Fiscal Years 1989 Through 1996
                        Table II.1: HUD-Proposed Allocations, by Initiative and Fiscal               19
                          Year
                        Table II.2: FHIP Funds Made Available, by Initiative and Fiscal              20
                          Year




                        Page 16                    GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
          Contents




          Table II.3: Number of Applications for FHIP Grants, by Initiative             20
           and Fiscal Year
          Table II.4: Dollar Value of Applications for FHIP Grants, by                  21
           Initiative and Fiscal Year

Figures   Figure 1: Fair Housing Initiatives Program’s Appropriations,                   4
            Fiscal Years 1989 Through 1997
          Figure 2: Office of Fair Housing and Equal Opportunity’s Budget                6
            for Fiscal Year 1996
          Figure 3: Percentage of FHIP Dollars Awarded for Each Initiative,             12
            Fiscal Years 1989 Through 1996




          Abbreviations

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


          Page 17                     GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix I

Examples of Eligible Activities



Type of initiative                        Eligible activities
Private enforcement initiative            • testing and other investigative activities to identify 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 initiative/    • staff training;
Continued development component           • education and outreach to promote awareness of services provided by new
                                          organizations;
                                          • technical assistance and mentoring services for new organizations; and
                                          • activities listed above under the private enforcement initiative.

Fair housing organizations initiative/    • projects that help establish, organize, and build the capacity of fair housing
New organizations component               enforcement organizations in targeted unserved and underserved areas of the country.
Education and outreach initiative         • media campaigns, including public service announcements, 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 initiative     • fair housing testing programs and other related 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.




                                         Page 18                           GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix II

Data on Funding for the Fair Housing
Initiatives Program and the Demand for
Funds
                                            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
Initiative            1989        1990          1991         1992       1993        1994         1995          1996      Dollars          Percent
Administrative
enforcement
initiative                0          0              0         $1.6      $2.1        $ 1.5        $ 3.0         $ 4.0      $ 12.2              12
Education and
outreach
initiative             $2.0       $2.0          $2.0              2.1    2.5          3.0          7.0           6.0            26.6          25
Fair housing
organizations
                           a           a             a              a        a
initiative                                                                            6.4          7.0         10.0             23.4          22
Private
enforcement
initiative              3.0         4.0           3.6             4.3    3.0          6.0          9.0         10.0             42.9          41
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.




                                            Page 19                              GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                            Appendix II
                                            Data on Funding for the Fair Housing
                                            Initiatives Program and the Demand for
                                            Funds




Table II.2: FHIP Funds Made Available, by Initiative and Fiscal Year
Dollars in millions
                                                                                                                                 Total
Initiative            1989        1990          1991         1992         1993         1994         1995         1996      Dollars         Percent
Administrative
enforcement
initiative                0          0              0         $2.5        $ 1.0        $ 1.5        $ 3.0            0        $ 8.0             8
Education and
outreach
initiative             $2.0       $1.9          $1.9              2.6       3.0          3.0          6.8        $ 2.0         23.2            24
Fair housing
organizations
                           a          a              a              a
initiative                                                                  2.6          7.0          7.3          3.0         19.9            20
Private
enforcement
initiative              3.0        3.9            3.8             3.0       4.0          9.0          9.0         12.0         47.7            48
                                                                               b            c
Total                  $5.0       $5.8          $5.7          $8.1       $10.6        $20.5        $26.1        $17.0         $98.8           100
                                            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
Initiative            1989        1990          1991         1992         1993         1994         1995         1996      Number          Percent
Administrative
enforcement
                           a          a              a                                                                 a
initiative                                                        16         24           17           18                        75             4
Education and
outreach
initiative             183         178           150          218          201          187          216            19        1,352            65
Fair housing
organizations
                           a          a              a              a
initiative                                                                   49           49           59           19          176             8
Private
enforcement
initiative              58          50             48             58         72           85           63           53          487            23
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.




                                            Page 20                                 GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                            Appendix II
                                            Data on Funding for the Fair Housing
                                            Initiatives Program and the Demand for
                                            Funds




Table II.4: Dollar Value of Applications
for FHIP Grants, by Initiative and Fiscal   Dollars in millions
Year                                                                                                                   Total
                                            Initiative                    1994            1995           1996      Dollar      Percentb
                                                                                                             a
                                            Administrative                $2.2            $3.6                       $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                       18.8            34.1            22.6       75.5            43
                                            enforcement
                                            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.




                                            Page 21                                GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix III

List of Grantees by FHIP Initiative for Fiscal
Years 1989 Through 1996


Recipient                                                         Location                    Initiative          Amount
1989 grants
Independent Housing Services                                      San Francisco, CA           EOI                  $45,020
National Association of Protection and Advocacy Systems           Washington, DC              EOI                   50,765
International Association of Official Human Rights Agencies       Washington, DC              EOI                   70,000
Metropolitan Washington Council of Governments                    Washington, DC              EOI                   26,954
National Fair Housing Alliance                                    Washington, DC              EOI                1,182,941
National Association of Protection and Advocacy Systems           Washington, DC              EOI                   30,000
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 Public Safety          Trenton, NJ                 EOI                   29,661
New Mexico State Housing                                          Santa Fe, NM                EOI                   51,594
Metropolitan Phoenix Fair Housing Centera                         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 Suburbs                 Winnetka, IL                PEI                   32,000
Leadership Council for Metropolitan Open Communities              Chicago, IL                 PEI                   88,000
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 the Boston Bar
Association                                                       Boston, MA                  PEI                  149,208
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
                                                                                                                (continued)


                                                Page 22               GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
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                 4,538,486
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 Center                            Denver, CO                   EOI                   75,000
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 Communities                         Chicago, IL                  EOI                   75,000
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 Board                            Kansas City, KS              EOI                   30,000
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
                                                                                                                            (continued)


                                              Page 23                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                                Appendix III
                                                List of Grantees by FHIP Initiative for Fiscal
                                                Years 1989 Through 1996




Recipient                                                                      Location                     Initiative          Amount
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, Inc.                             Miami, FL                    PEI                   66,470
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 Suburbs                              Winnetka, IL                 PEI                   51,800
Leadership Council for Metropolitan Open Communities                           Chicago, IL                  PEI                  218,681
South Suburban Housing Center                                                  Homewood, IL                 PEI                   34,591
Lawyers’ Committee for Civil Rights Under Law of the Boston Bar
Association                                                                    Boston, MA                   PEI                  234,861
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 Justice                        New York, NY                 PEI                  107,349
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                     Oklahoma City, OK            PEI                   98,337
Urban League of Pittsburgh, Inc.                                               Pittsburgh, PA               PEI                  118,161
Housing Opportunities Corporation                                              Memphis, TN                  PEI                  115,973
                                                                                                                              (continued)


                                                Page 24                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                               Appendix III
                                               List of Grantees by FHIP Initiative for Fiscal
                                               Years 1989 Through 1996




Recipient                                                                     Location                     Initiative          Amount
Housing Opportunities Made Equal of Richmond                                  Richmond, VA                 PEI                   74,142
Metropolitan Milwaukee Fair Housing Council                                   Milwaukee, WI                PEI                  101,861
Total                                                                                                      70                 6,047,445
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 Center                             Denver, CO                   EOI                   39,398
International Association of Official Human Rights Agencies                   Washington, DC               EOI                   40,000
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 Diversity                            Washington, DC               EOI                   88,995
National Fair Housing Alliance                                                Washington, DC               EOI                   75,000
Commission on Equal Opportunity                                               Atlanta, GA                  EOI                   75,000
Leadership Council for Metropolitan Open Communities                          Chicago, IL                  EOI                   60,000
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 Resource Board                       Hackensack, NJ               EOI                   58,200
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 Center                             Denver, CO                   PEI                   57,278
Mental Health Law Project                                                     Washington, DC               PEI                   90,000
Fair Housing Council of Greater Washington                                    Washington, DC               PEI                  186,795
                                                                                                                             (continued)


                                               Page 25                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
Housing Opportunities Project for Excellence, Inc.                           Miami, FL                    PEI                   77,376
South Suburban Housing Center                                                Homewood, IL                 PEI                   55,000
HOPE Fair Housing Center                                                     Wheaton, IL                  PEI                   68,000
Interfaith Housing Center of the Northern Suburbs                            Winnetka, IL                 PEI                   61,260
Chicago Lawyers’ Committee for Civil Rights Under Law, Inc.                  Chicago, IL                  PEI                   77,169
Access Living of Metropolitan Chicago                                        Chicago, IL                  PEI                  158,610
Leadership Council for Metropolitan Open Communities                         Chicago, IL                  PEI                   93,932
Lawyers’ Committee for Civil Rights Under Law of the Boston Bar
Association                                                                  Boston, MA                   PEI                  196,841
Housing Discrimination Project                                               Holyoke, MA                  PEI                  149,530
Lawyers’ Committee for Civil Rights Under Law of the Boston Bar
Association                                                                  Boston, MA                   PEI                  277,408
Lawyers’ Committee for Civil Rights Under Law of the Boston Bar
Association                                                                  Boston, MA                   PEI                  325,000
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                 5,698,291
1992 grants
Arizona Attorney General’s Office                                            Phoenix, AZ                  AEI                  231,920
Connecticut Commission on Human Rights and Opportunities                     Hartford, CT                 AEI                  439,312
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 Compliance                            Seattle, WA                  AEI                   55,340
                                                                                                                            (continued)



                                              Page 26                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
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 Suburbs                            Winnetka, IL                 EOI                   80,000
John Marshall Law School                                                     Chicago, IL                  EOI                  200,418
Leadership Council for Metropolitan Open Communities                         Chicago, IL                  EOI                   50,000
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 the Boston Bar
Association                                                                  Boston, MA                   EOI                  121,431
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 Research, Outreach and
Extension                                                                    Raleigh, NC                  EOI                  189,218
Gloucester County                                                            Glassboro, NJ                EOI                   62,845
State of New Jersey, Department of Public Advocacy                           Trenton, NJ                  EOI                  147,309
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 Center                            Denver, CO                   PEI                   95,000
National Fair Housing Alliance                                               Washington, DC               PEI                1,000,000
Fair Housing Council of Greater Washington                                   Washington, DC               PEI                  187,812
                                                                                                                            (continued)


                                              Page 27                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
Housing Opportunities Project for Excellence, Inc.                           Miami, FL                    PEI                   90,002
HOPE Fair Housing Center                                                     Wheaton, IL                  PEI                   66,640
Leadership Council for Metropolitan Open Communities                         Chicago, IL                  PEI                  110,777
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                 7,900,000
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 Compliance                            Seattle, WA                  AEI                  207,113
Southern Arizona Housing Center                                              Tucson, AZ                   EOI                   98,803
National Association of Protection and Advocacy Systems                      Washington, DC               EOI                  126,028
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 Council                     St. Louis, MO                EOI                   98,624
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
                                                                                                                            (continued)


                                              Page 28                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                               Appendix III
                                               List of Grantees by FHIP Initiative for Fiscal
                                               Years 1989 Through 1996




Recipient                                                                     Location                     Initiative          Amount
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 Under Law, Inc.                   Chicago, IL                  FHOI                  88,666
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 the Boston Bar
Association                                                                   Boston, MA                   FHOI                 209,386
Legal Aid of Western Missouri                                                 Kansas City, MO              FHOI                 155,398
Metropolitan St. Louis Equal Housing Opportunity Council                      St. Louis, MO                FHOI                 305,697
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 the Boston Bar
Association                                                                   Boston, MA                   PEI                  379,315
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
                                                                                                                             (continued)


                                               Page 29                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
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                14,219,736
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-Discrimination Division                  Salt Lake City, UT           AEI                  117,718
Catholic Community Services of Southern Arizona (dba the Direct
Independent Living Center)                                                   Tucson, AZ                   EOI                   77,448
Mental Health Advocacy Project                                               San Jose, CA                 EOI                   63,520
Independent Living Resource Center of San Francisco                          San Francisco, CA            EOI                   70,991
Conference of Mayors, Research and Education Foundation                      Washington, DC               EOI                  236,593
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 Communities                         Chicago, IL                  EOI                  875,787
Massachusetts Rehabilitation Commission                                      Boston, MA                   EOI                  103,000
Housing Discrimination Project                                               Holyoke, MA                  EOI                   87,825
Lawyers’ Committee for Civil Rights Under Law of the Boston Bar
Association                                                                  Boston, MA                   EOI                   94,163
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 Accessible Living                Raleigh, NC                  EOI                  191,640
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
                                                                                                                            (continued)


                                              Page 30                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                               Appendix III
                                               List of Grantees by FHIP Initiative for Fiscal
                                               Years 1989 Through 1996




Recipient                                                                     Location                     Initiative          Amount
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 Serving Persons With
Disabilities)                                                                 Denver, CO                   FHOI                 285,244
National Fair Housing Alliance                                                Washington, DC               FHOI               1,858,631
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 Justice                       New York, NY                 FHOI                 198,411
Lorain County Urban League, Inc.                                              Elyria, OH                   FHOI                 158,324
Protection and Advocacy for People With Disabilities                          Columbia, SC                 FHOI                 122,180
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 Center                             Denver, CO                   PEI                  216,000
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
                                                                                                                             (continued)


                                               Page 31                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
Housing Opportunities Project for Excellence, Inc.                           Miami, FL                    PEI                  324,121
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 Communities                         Chicago, IL                  PEI                  147,889
Lawyer’s Committee for Better Housing, Inc.                                  Chicago, IL                  PEI                  155,830
Leadership Council for Metropolitan Open Communities                         Chicago, IL                  PEI                  192,733
Interfaith Housing Center of the Northern Suburbs                            Winnetka, IL                 PEI                   78,998
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 the Boston Bar
Association                                                                  Boston, MA                   PEI                  373,415
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                     Cincinnati, OH               PEI                   92,264
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
                                                                                                                            (continued)


                                              Page 32                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
Metropolitan Milwaukee Fair Housing Council                                  Milwaukee, WI                PEI                  283,044
Metropolitan Milwaukee Fair Housing Council                                  Milwaukee, WI                PEI                  346,774
Total                                                                                                     108               26,483,790
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                1,131,301
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 Communities                         Chicago, IL                  EOI                   88,000
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 Universal Design                 Raleigh, NC                  EOI                  221,242
                                                                                                                            (continued)


                                              Page 33                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                              Appendix III
                                              List of Grantees by FHIP Initiative for Fiscal
                                              Years 1989 Through 1996




Recipient                                                                    Location                     Initiative          Amount
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.) Community
Housing Resources Board                                                      Eugene, OR                   EOI                  131,316
Golden Triangle Radio Information Center                                     Pittsburg, PA                EOI                   85,366
Tennessee Association of Legal Services, Legal Aid Projects                  Nashville, TN                EOI                   90,060
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 Under Law, Inc.                  Chicago, IL                  FHOI                 176,310
Fair Housing Council-Kentucky                                                Louisville, KY               FHOI                 164,838
Lawyers’ Committee for Civil Rights Under Law of the Boston Bar
Association                                                                  Boston, MA                   FHOI                 160,803
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 Center                            Denver, CO                   PEI                   93,953
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 the Boston Bar
Association                                                                  Boston, MA                   PEI                  599,096
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                     Cincinnati, OH               PEI                  214,657
Tenants’ Action Group of Philadelphia                                        Philadelphia, PA             PEI                  195,000
Metropolitan Milwaukee Fair Housing Council                                  Milwaukee, WI                PEI                  600,000
Total                                                                                                     69                16,317,485
                                                                                                                            (continued)




                                              Page 34                             GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
                                             Appendix III
                                             List of Grantees by FHIP Initiative for Fiscal
                                             Years 1989 Through 1996




Recipient                                                                      Location                         Initiative               Amount
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 Communities                           Chicago, IL                      PEI                      597,675
Open Housing Center, Inc.                                                      New York, NY                     PEI                      600,000
Austin Tenants’ Council                                                        Austin, TX                       PEI                      591,691
Total                                                                                                           9                      4,877,411
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.




                                             Page 35                                GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix IV

Objectives, Scope, and Methodology


              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,



              Page 36                      GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix IV
Objectives, Scope, and Methodology




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



Page 37                          GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix IV
Objectives, Scope, and Methodology




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.




Page 38                          GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Appendix V

Major Contributors to This Report


                       Patricia D. Moore
Resources,             Jeannie B. Davis
Community, and         Michael L. Mgebroff
Economic               Vondalee R. Hunt
                       Alice G. Feldesman
Development Division   John T. McGrail




(385648)               Page 39               GAO/RCED-97-67 HUD’s Fair Housing Initiatives Program
Ordering Information

The first copy of each GAO report and testimony is free.
Additional copies are $2 each. Orders should be sent to the
following address, accompanied by a check or money order
made out to the Superintendent of Documents, when
necessary. VISA and MasterCard credit cards are accepted, also.
Orders for 100 or more copies to be mailed to a single address
are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office
P.O. Box 6015
Gaithersburg, MD 20884-6015

or visit:

Room 1100
700 4th St. NW (corner of 4th and G Sts. NW)
U.S. General Accounting Office
Washington, DC

Orders may also be placed by calling (202) 512-6000
or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and
testimony. To receive facsimile copies of the daily list or any
list from the past 30 days, please call (202) 512-6000 using a
touchtone phone. A recorded menu will provide information on
how to obtain these lists.

For information on how to access GAO reports on the INTERNET,
send an e-mail message with "info" in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov




PRINTED ON    RECYCLED PAPER
United States                       Bulk Rate
General Accounting Office      Postage & Fees Paid
Washington, D.C. 20548-0001           GAO
                                 Permit No. G100
Official Business
Penalty for Private Use $300

Address Correction Requested