Study of the

Fair Housing Initiatives Program
Study of the

Fair Housing Initiatives Program

Prepared for: 

U.S. Department of Housing and Urban Development
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Office of Policy Development and Research
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Prepared by: 

DB Consulting Group, Inc.
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Silver Spring, MD
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Authors: 

Kenneth Temkin
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Tracy McCracken
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Veralee Liban
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May 2011 
Study of the Fair Housing Initiatives Program
	

Acknowledgments --

This study could not have been completed without the assistance of a number of people, including staff from Fair Housing 

Initiatives Program (FHIP) grantee organizations, key informants, and U.S. Department of Housing and Urban Development 

(HUD) personnel. DB Consulting Group, Inc., gratefully acknowledges all of them for their significant contributions, support, 

and time, which contributed to the successful completion of this study. 

Richard Offner and Jeffrey May were instrumental in developing the overall research approach. May served as the project 

director until January 31, 2008, and managed the day-to-day intricacies of the project and helped to structure the data 

analyses presented in this report. Lesley Edmond, who served as a senior research analyst from 2006 to 2008, provided 

invaluable assistance to May on every aspect of the project, including the web-based survey, Notice of Funding Availability 

research, and development of the program history in section 2 of this study. 

This study includes information collected from key informant interviews and from site visits to 10 FHIP grantee organizations. To maintain their anonymity, this report does not list the names of key informants or grantees. We thank them for their 

time, however, and for their valuable insights regarding FHIP over the years. 

Todd Richardson and Judson James of HUD’s Office of Policy Development and Research provided insightful comments 

and assistance throughout this project; we are grateful for their help on many complicated research issues that had to 

be resolved during the course of the 2-year study. In addition, Jon Sperling of HUD provided invaluable assistance with 

assigning geographic identifiers to grant data and providing the research team with maps of the physical locations of 

grant-recipient organizations. 

The contents of this report are the views of the contractor, DB Consulting Group, Inc., and do not necessarily reflect the 

views or policies of the U.S. Department of Housing and Urban Development or the U.S. Government. 

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Study of the Fair Housing Initiatives Program
	

- Foreword -

This evaluation of the U.S. Department of Housing and Urban Development’s (HUD’s) Fair Housing Initiative Program (FHIP) 

is the first major study of the program in 15 years. The study confirms that FHIP funding is a critical component of the U.S. 

civil rights enforcement infrastructure. Fair housing organizations in communities across the country depend on FHIP funding to support their investigations and enforcement of laws that protect people from housing discrimination and that provide 

fair housing education and outreach activities. 

Among the study’s important findings is that, without FHIP enforcement funding, it is likely that most enforcement and 

investigatory work, particularly paired testing, would no longer occur. Although fair housing organizations are able to secure 

funding, in addition to their FHIP funding, from a variety of sources for education and outreach activities, few alternative 

funding sources are available to support testing and other investigative work that fair housing organizations conduct. 

This investigative work helps ensure equal access to housing for all individuals and families protected by federal, state, and 

local fair housing laws. The report shows, among other benefits, that when FHIP grantee organizations are the first point of 

contact for a complainant, the organization adds value in two ways: 

First, FHIP grantee organizations weed out cases that are not covered by civil rights statutes, as well as 

those cases in which the organization’s investigations show a complaint lacks merit. This vetting saves 

resources for HUD and state agencies that do not have to investigate these cases. 

Second, the investigative evidence provided to HUD and state agencies for a complaint on which a FHIP 

grantee organization has signed on as a complainant or representative adds merit to those cases. These 

are the cases that are much more likely to end in a conciliation or cause finding than are other cases in 

which the complainant comes directly to HUD and state agencies. Of particularly high value is testing 

evidence, which is limited almost exclusively to the cases that involve a FHIP grantee organization. 

Overall, the report supports maintaining funding for FHIP grantee organizations as an important policy priority for HUD. 

Raphael W. Bostic 

Assistant Secretary for Policy Development and Research 

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Contents 

Acknowledgments.......................................................................................................................................................... ii
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Foreword .........................................................................................................................................................................iii
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Executive Summary....................................................................................................................................................... ix
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Types of Awards Made Under FHIP.......................................................................................................................... ix
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FHIP Grantee Organization Activities......................................................................................................................... x
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Difference in Outcomes for FHIP-Referred and Non-FHIP-Referred Complaints ....................................................... xi
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Conclusions.............................................................................................................................................................xii
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Introduction.....................................................................................................................................................................1
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The Fair Housing Initiatives Program ...........................................................................................................................2
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1. Data and Methods......................................................................................................................................................4
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Key Informant Interviews...........................................................................................................................................4
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Notices of Funding Availability ...................................................................................................................................4
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HUD Administrative Data ..........................................................................................................................................4
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Title VIII Automated Paperless Office Tracking System ..............................................................................................4
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Web-Based Survey...................................................................................................................................................5
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Onsite Interviews With FHIP Grantee Representatives...............................................................................................9
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2. Program History .......................................................................................................................................................10
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Factors That Led to FHIP’s Implementation.............................................................................................................10
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Evolution of FHIP ....................................................................................................................................................11
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Education and Outreach Initiative............................................................................................................................11
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Private Enforcement Initiative ..................................................................................................................................14
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Fair Housing Organizations Initiative ........................................................................................................................16
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Administrative Enforcement Initiative .......................................................................................................................17
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Analysis of FHIP Grantees by Initiative.....................................................................................................................18
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Analysis of FHIP Funding by Organization Type .......................................................................................................21
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Analysis of FHIP Funding by HUD Region and Location ..........................................................................................24
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Award Summary .....................................................................................................................................................27
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3. Descriptive Analysis of FY 2003–FY 2005 FHIP Grantees.....................................................................................28
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Mission Statements of FHIP Recipient Organizations ..............................................................................................28
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Target Area for Respondents’ Fair Housing Activities...............................................................................................29
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FHIP Grant Recipient Organizations’ Age and Size..................................................................................................30
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Size of FHIP Grantees’ Fair Housing Component ....................................................................................................31
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Governance Structure of FHIP Grantees and Employee Characteristics ..................................................................32
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Sources of Budget for Enforcement Initiatives and Education and Outreach Activities .............................................33
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FHIP Funding of Enforcement Activities...................................................................................................................33
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Investigations..........................................................................................................................................................35
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Testing....................................................................................................................................................................35
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FHIP Support of Education and Outreach Activities.................................................................................................36
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Funding History.......................................................................................................................................................38
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Descriptive Analysis Summary ................................................................................................................................39
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4. Description of Procedures That FHIP Grantees Used To Handle Fair Housing Complaints.............................40
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Procedures Summary .............................................................................................................................................43
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5. FHIP Grantee Organizations’ Investigation and Testing Activities ......................................................................44
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Investigations..........................................................................................................................................................44
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Testing....................................................................................................................................................................46
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Organization-Initiated and FHAP-Initiated Investigations..........................................................................................50
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6. Description of FHIP Grantees’ Education and Outreach Activities .....................................................................51
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7. Comparing Outcomes for FHIP-Referred and Non-FHIP-Referred Complaints ................................................53
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Background on FHIP-Referred Complaints .............................................................................................................53
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Do FHIP Organizations Act As a Filter, Providing Cases More Likely To Be Jurisdictional and Have Merit?...............54
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Do FHIP Organizations Improve Outcomes for Complainants, Either as a Representative
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or Through Their Supporting Investigations? .......................................................................................................55
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Are FHIP Organizations Critical to Investigating Complicated Cases?......................................................................59
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Appendix A. Fair Housing Initiatives Program Web Survey in Telephone Instrument Guide Format .................A–1
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Appendix B. Interviewer Guide for Key Informants of the Program History.........................................................B–1
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Appendix C. Interviewer Guide for Case Studies for Data Collection.................................................................. C–1
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Appendix D. Mission Statements of Survey Respondents .................................................................................... D–1
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Appendix E. Sample FHIP Grantee Organization Intake Form...............................................................................E–1
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References ....................................................................................................................................................................61
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Additional Reading .......................................................................................................................................................62
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Glossary of Abbreviations and Acronyms..................................................................................................................63
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Study of the Fair Housing Initiatives Program 

List of Tables 

Table ES-1. Summary of FHIP Awards, FY 1989–FY 2006 ................................................................................................ x
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Table 1. Comparison of the Number of Grants and Dollar Amount of Grants Awarded to Web-Based Survey 

Respondents by Initiative, FY 2003–FY 2005 ..................................................................................................5
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Table 2. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents, 

FY 2003–FY 2005...........................................................................................................................................6
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Table 3. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents by Initiative, 

FY 2003–FY 2005...........................................................................................................................................6
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Table 4. Comparison of the Number of Grants and Dollar Amount of Grants Awarded to Web-Based Survey 

Respondents by Initiative, FY 2003–FY 2005 ..................................................................................................7
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Table 5. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents by Identified
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Organization Type, FY 2003–FY 2005 .............................................................................................................7
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Table 6. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents by Type 

of Recipient Organization, FY 2003–FY 2005 ..................................................................................................8
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Table 7. Comparison of the Number of Cases Closed for Survey Respondents and Nonrespondents, 

FY 2003–FY 2005...........................................................................................................................................8
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Table 8. Distribution of the Role of Fair Housing Initiatives in the Sampled Organizations’ Mission Statements..............9
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Table 9. Distribution of Sampled Organizations by Geographic Target Areas.................................................................9
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Table 10. Summary of Eligible Activities Under EOI Funding Categories, FY 1989–FY 1997..........................................12
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Table 11. Summary of Components Added to EOI Funding Category, FY 1999–FY 2006.............................................13
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Table 12. Summary of Eligible Activities Under EOI Funding Categories, FY 1998–FY 2006..........................................14
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Table 13. Summary of PEI Eligible Activities, FY 1989–FY 1997....................................................................................15
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Table 14. Summary of PEI Eligible Activities, FY 1998–FY 2006....................................................................................16
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Table 15. Summary of FHOI Eligible Activities, FY 1993–FY 2006.................................................................................17
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Table 16. Summary of AEI Eligible Activities, FY 1992–FY 1995....................................................................................18
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Table 17. Summary of FHIP Awards by Initiative, FY 1989–FY 2006 .............................................................................19
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Table 18. Summary of Non-SIP FHIP Awards by Initiative, FY 1989–FY 2006...............................................................19
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Table 19. Summary of the Share of Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006............................24
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Table 20. States and Territories Within 10 HUD Regions...............................................................................................25
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Table 21. The Role of Fair Housing in Survey Respondents’ Organizations...................................................................29
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Table 22. The Role of Fair Housing in Survey Respondents’ Missions by Organization Type .........................................29
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Table 23. Location and Population Size of Communities Targeted by Survey Respondents for Fair Housing Activities ..30
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Table 24. Summary of Survey Respondents’ Total Budgets, FY 2006...........................................................................30
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Table 25. Distribution of Survey Respondents’ Full-Time Employees, FY 2006 .............................................................31
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Table 26. Total Fair Housing Staff for Survey Respondents, FY 2007 ............................................................................31
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Table 27. Fair Housing Activity Shares of Total Budget for Survey Respondents, FY 2006 ............................................31
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Table 28. Survey Respondents’ Organizational Types...................................................................................................32
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Table 29. Characteristics of Survey Respondents’ Boards of Directors, FY 2007..........................................................32
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Table 30. Characteristics of Survey Respondents’ Employees, FY 2007.......................................................................32
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Study of the Fair Housing Initiatives Program 

Table 31. Sources of Funding for Enforcement Initiatives and Education and Outreach Activities for 

Survey Respondents, FY 2006......................................................................................................................33
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Table 32. PEI Grant Shares of Total Enforcement Budgets by Fair Housing Budget Size, FY 2006................................34
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Table 33. Comparison of Sources of Funding for Enforcement Activities for Large Groups and All 

Survey Respondents, FY 2006......................................................................................................................34
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Table 34. Distribution of Share of Individual-Initiated Investigations With PEI Grant Funding..........................................35
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Table 35. Distribution of Share of Grantee Organization-Initiated Inquiries Investigated With PEI Grant Funding............35
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Table 36. Distribution of the Share of Tests Conducted by Survey Respondents Funded by PEI Grants, FY 2006 ........36
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Table 37. EOI Grants’ Share of Total Enforcement Funding and Education and Outreach Budget by Fair Housing 

Budget Size, FY 2006 ...................................................................................................................................37
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Table 38. Comparison of Sources of Funding for Education and Outreach Activities for 

Survey Respondents, FY 2006......................................................................................................................37
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Table 39. Fair Housing Budget Changes for Survey Respondents, FY 2004–FY 2006 ..................................................38
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Table 40. Fair Housing Funding Changes for Survey Respondents, FY 2001–FY 2006.................................................38
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Table 41. Sources That Survey Respondents Used To Recruit Testers..........................................................................42
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Table 42. Number of Fair Housing Investigations That Survey Respondents Undertook by Type, FY 2006....................44
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Table 43. Investigations That FHIP Grantee Organizations Completed by Protected Class, FY 2006 ............................45
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Table 44. Outcomes for Fair Housing Investigations, FY 2006 ......................................................................................45
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Table 45. Investigations Completed by FHIP Grantee Organizations by Protected Class, FY 2006................................46
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Table 46. Outcomes for Fair Housing Inquiries and Investigations, FY 2006..................................................................46
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Table 47. Distribution of the Share of PEI-Grant-Funded Tests That Survey Respondents Conducted, FY 2006 ...........47
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Table 48. Proportion of Respondents Conducting Tests by Complaint Type, FY 2006 ..................................................48
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Table 49. Share of Respondents Completing a Test for Complaints Filed by Protected Class Type, FY 2006................48
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Table 50. Proportion of Individual Inquiries Resulting in an Enforcement Action.............................................................49
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Table 51. Sources That Survey Respondents Used To Recruit Testers..........................................................................49
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Table 52. Distribution of Share of Grantee Organization-Initiated Inquiries Investigated With PEI Grant Funding............50
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Table 53. Comparison of Proportion of Tests Conducted From Individual- and Grantee Organization-Initiated 

Complaints, FY 2006 ....................................................................................................................................50
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Table 54. Individuals and Organizations Receiving Fair Housing Education or Training From Respondents, FY 2006 ....51
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Table 55. Education and Outreach Activities That Respondents Completed and the Proportion of Activities Funded 

With EOI Grant Funding, FY 2006 .................................................................................................................52
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Table 56. Inquiries to HUD Field Offices That Were Converted to Complaints (Jurisdictional) ........................................54
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Table 57. Coding Method Used To Reclassify TEAPOTS Outcomes .............................................................................55
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Table 58. Comparison of Overall Representation for Non-FHIP-Referred and FHIP-Referred Complaints by Closure 

Type, FY 2003–FY 2005................................................................................................................................56
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Table 59. Comparison of Reasons for File Closure for Non-FHIP-Referred and FHIP-Referred Complaints, 

FY 2003–FY 2005.........................................................................................................................................56
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Table 60. Comparison of the Mean Number of Days Between HUD Receiving a Complaint and Closing a File for 

Non-FHIP-Referred and FHIP-Referred Complaints, FY 2003–FY 2005.........................................................57
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Study of the Fair Housing Initiatives Program 

Table 61. Comparison of the Mean Number of Days Between HUD Receiving a Complaint and Closing a File for 

Non-FHIP-Referred and FHIP-Referred Complaints by Closure Type, FY 2003–FY 2005..............................57 

Table 62. Testing as Part of a Complaint for Non-FHIP-Referred and FHIP-Referred Complaints, FY 2003–FY 2005 ....58 

Table 63. Case Outcomes for Cases With and Without Testing for Complaints, FY 2003–FY 2005...............................58 

Table 64. Regional Distribution of FHIP-Referred Cases and the Cause Finding and Conciliation Rate for Complaints 

by Region, FY 2003–FY 2005..................................................................................................................58 

Table 65. Proportion of Cases by FHIP Referral Type––Complaints Closed, FY 2003–FY 2005 ...................................59 

Table 66. Proportion of Design and Construction Cases by FHIP Referral Type––Complaints Closed, 

FY 2003–FY 2005 ..................................................................................................................................60 

Table 67. Proportion of Types of DOJ Investigations by FHIP Referral Type––Complaints Closed, 

FY 2003–FY 2005.........................................................................................................................................60 

List of Figures 

Figure 1. Comparison of Mean Non-SIP PEI and EOI Awards, FY 1989–FY 2006 ........................................................20
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Figure 2. Comparison of the Number of Non-SIP PEI and EOI Awards, FY 1989–FY 2006 ..........................................21
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Figure 3. Share of Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006 .....................................................22
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Figure 4. Share of Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006 .....................................................23
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Figure 5. Mean Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006..........................................................23
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Figure 6. Share of Non-SIP FHIP Awards by HUD Region, FY 1989–FY 2006..............................................................25
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Figure 7. Mean Non-SIP FHIP Awards by HUD Region, FY 1989–FY 2006..................................................................26
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Figure 8. Locations of Organizations Receiving FHIP Awards Scaled by Total Dollars Awarded, FY 1989–FY 2006......26
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Figure 9. Location of FHIP Grantees That Received Awards Scaled by Total Number of Awards, FY 1989–FY 2006....27
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Figure 10. Flowchart of Process That FHIP Grantees Used for Complaints ....................................................................41
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viii
 

 

 

Study of the Fair Housing Initiatives Program
	

Executive Summary --

This study examines the Fair Housing Initiatives Program (FHIP) from its inception in 1987 through 2006. The goals of this 

study are to create a history of FHIP, describe its grantees, analyze the types of grants awarded through the program, and 

analyze the outcomes of cases investigated by grant recipients, especially the comparison of the outcomes of cases referred 

by the grantees with those referred by others. It is useful to note the limitations of this study. It is primarily a process study of 

FHIP based on interviews with FHIP grantee organizations. Outcomes are reported based on cases that are referred to the 

U.S. Department of Housing and Urban Development (HUD). The study does not include reviews of cases not referred to 

HUD and does not assess the efficiency of FHIP or effects of the program. 

This study presents an analysis of the types of grants awarded by HUD under FHIP and the outcomes of cases investigated 

by grant recipients. The data used in this study are from four sources: (1) indepth interviews with present and past HUD staff 

who are knowledgeable about the program and representatives of 10 FHIP grantee organizations, (2) a HUD administrative 

database containing information about awards made under the program between fiscal year (FY) 1989 and FY 2006, (3) a 

web-based survey of organizations that received FHIP grants between FY 2003 and FY 2005, and (4) outcomes reported 

in HUD’s Title VIII Automated Paperless Office Tracking System (TEAPOTS) of complaints referred to HUD and closed 

between FY 2003 and FY 2005. 

Under FHIP, the HUD Secretary issues grants and enters into contracts and cooperative agreements with state and local 

government agencies, public and private nonprofit organizations, and other public and private entities that have programs 

designed to prevent and/or eliminate discriminatory housing practices . FHIP funding generally promotes public awareness 

of rights protected under the Fair Housing Act and enhances the ability of fair housing organizations (FHOs) to investigate fair 

housing complaints, especially through enforcement testing results that can be used as evidence of housing discrimination in 

legal proceedings.1 FHIP currently has three funding categories: (1) the Private Enforcement Initiative (PEI); (2) the Education 

and Outreach Initiative (EOI); and (3) the Fair Housing Organizations Initiative (FHOI).2 A fourth funding category, the Administrative 

Enforcement Initiative (AEI), was included in the initial program but has not been funded since FY 1995. Between FY 1999 

and FY 2004, HUD also granted Secretary Initiated Projects (SIP) awards to support national testing programs. 

PEI grants support private nonprofit organizations that enforce fair housing laws in conducting housing discrimination 

complaint processing, investigations, and other law enforcement activities to remedy violations of the Fair Housing Act. 

Usually, the investigations that PEI grantees conduct include testing to demonstrate disparate treatment. EOI grants enable 

recipients to develop and disseminate information to educate the public of rights under the Fair Housing Act and to conduct 

outreach activities to communities and stakeholders regarding fair housing issues. FHOI grants help increase the capacity of 

organizations that enforce Fair Housing Act provisions. 

Types of Awards Made Under FHIP 

HUD awarded a total of $283 million in FHIP grants between FY 1989 and FY 2006. The mean award during this period 

was $210,000. Most of these awards were either PEI or EOI grants. The mean PEI grant was $233,000, an amount almost 

twice the mean EOI amount awarded between FY 1989 and FY 2006 (Table ES-1). 

Nonprofit organizations received nearly three-fourths of the FHIP awards that HUD made between FY 1989 and FY 2006. 

Legal aid organizations received the second largest share of FHIP awards, followed by state and local governments. 

1 42 U.S.C. Section 3616a.
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2

 The FHOI funding category began in FY 1992 when FHIP was made a permanent program (Public Law 102–550 Section 905, approved 

Oct. 28, 1992).
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Study of the Fair Housing Initiatives Program
	

FHIP awards provide an important source of funding for grantees. According to the web-based survey data, FHIP awards 

in FY 2006 funded 58 percent of the combined enforcement initiatives and education and outreach efforts that grantee 

organizations conducted. Because relatively few alternative sources are available to support enforcement, FHIP awards 

support a larger share of grantee enforcement activity compared with the share of education and outreach efforts. In FY 

2006, grantees used 67 percent of their funds to support enforcement initiatives, compared with 34 percent of funds used 

for education and outreach efforts. 

Typically, fair housing funding to FHIP grantee organizations is not stable. About one-half of the survey respondents indicated their organization’s fair housing funding was sporadic between FY 2001 and FY 2006. HUD, recognizing the problem, 

began granting 3-year PEI awards in FY 2005. Although such awards reduce the year-to-year variability in the overall 

funding for FHIP grantee organizations, multiple-year awards reduce the number of 1-year awards (holding overall funding 

levels constant) available to organizations that do not have the capacity to be awarded a longer term PEI grant. These 

longer term awards are typically made to organizations with greater capacity, as measured by experience and infrastructure 

and usually meaning a longer track record, than recipients of 1-year awards. HUD generally needs to balance the tradeoff 

between making 1-year and multiple-year awards. Even with 3-year PEI awards, FHOs still face a challenge when making 

year-to-year budget and staffing projections. 

Initiative 

Total 

Awards (N) 

Percent of 

Awards 

Total Dollar 

Awards ($) 

Percent of 

Dollar Awards 

Mean Award 

($) 

Table ES-1. Summary of FHIP Awards, FY 1989–FY 2006 

AEI 34 3 7,462,109 3 219,474 

EOI 580 43 73,053,081 26 125,954 

FHOI 114 8 41,763,732 15 366,349 

PEI 610 45 141,860,388 50 232,558 

SIP 10 1 19,263,026 7 1,926,303 

Total 1,348 100 283,402,336 100 210,239 

AEI = Administrative Enforcement Initiative. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations Initiative. 

PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects.
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Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database
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FHIP Grantee Organization Activities 

Of the survey respondents, 40 conducted a total of 6,208 investigations in FY 2006, an average of 155 investigations 

per respondent (about 3 investigations per week).3 PEI funds financed 70 percent of the investigations that respondents 

completed in FY 2006. (Respondents did not report sources for the remaining 30 percent.) Most of the investigations (84 

percent) were related to rental housing complaints. Sales, lending, insurance, and other discrimination complaints accounted for the remaining 16 percent. Rental housing discrimination complaints are usually resolved faster than other types 

of housing complaints, which provides faster relief to the complainants. 

Using information from their investigations, FHIP grantee organizations determine which complaints need to be referred to 

HUD for further action. Most investigations that FHIP grantee organizations conduct do not result in the referral of the case 

to HUD; only 15 percent of inquiries and investigations completed in FY 2006 resulted in a filing of a fair housing complaint 

with either a Fair Housing Assistance Program (FHAP) agency or HUD. The most common outcome for investigations (43 

percent) was the finding that no discrimination occurred. The second most common outcome was that the FHIP organization was able to resolve the complaint without referring the matter to HUD or FHAP (27 percent). A mere 1 percent of 

investigations led to the filing of a housing discrimination lawsuit. Of the total number of complaints, 19 percent were still 

under investigation. 

Testing is one of the most important investigative methods that PEI grantee organizations use. Of the survey respondents, 

37 completed a total of 5,033 tests in FY 2006, an average of 136 tests per FHIP organization. As discussed previously, 

3

 Of the 180 organizations receiving FHIP grants between FY 2003 and FY 2005, 68 completed a sufficient number of questions in the survey to 

be included in the analysis. Responses were more detailed on some questions than on others. 

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Study of the Fair Housing Initiatives Program 

 

 

relatively few sources of funding are available for general enforcement activities; the same is true for testing. PEI funds 

supported about two-thirds of the tests that FHIP grantees conducted.4 

Difference in Outcomes for FHIP-Referred and Non-FHIP-Referred Complaints5 

Analysis of the cases that FHIP organizations refer to HUD, compared with all other FHIP complaints, found that FHIP 

grantee organizations play a vital role in screening out complaints that do not reflect fair housing violations and help resolve 

cases that exhibit evidence of discrimination without referring them to HUD or a FHAP agency. This finding is true for cases 

in which FHOs are included as a complainant and when they are representing a complainant. When compared with all 

inquiries referred to HUD, only 10 percent of FHIP-referred inquiries were found to be not under HUD jurisdiction, while 

62 percent of non-FHIP-referred inquiries were found to be not under HUD jurisdiction. This finding is consistent with the 

survey findings that show that FHIP organizations find that 43 percent of the cases they investigate do not have merit and 

thus are not referred to HUD or a FHAP agency. 

When cases were found to be under HUD jurisdiction, the FHIP organization referred the complaints to HUD, particularly 

those in which the FHIP organization was a complainant. These complaints were more likely to be closed as a cause finding 

or conciliation than were complaints that originated from other sources. According to data reported in the HUD TEAPOTS 

database, FHIP-referred complaints accounted for only 10 percent of the 26,090 cases that HUD closed between FY 2003 

and FY 2005, but 31 percent of the FHIP-referred cases closed because of a cause finding (19 percent) or conciliation (12 

percent). Of the complaints in which FHIP organizations were a complainant (4 percent), 71 percent closed as a conciliation 

or cause finding, compared with 43 percent of cases in which FHIP organizations acted as a representative to the complainant, and 37 percent of non-FHIP-referred complaints. 

In addition to a higher cause finding rate, the FHIP-referred cases ending in a cause finding took less time to complete (673 

days for FHIP as the complainant, 495 FHIP as the representative, and 708 days for non-FHIP-referred cases). 

In contrast, conciliations took somewhat longer on FHIP referrals (156 days for FHIP as the complainant, 149 days for FHIP 

as the representative, and 108 days for non-FHIP-referred cases). Again, this finding is consistent with FHIP organizations 

helping complainants and respondents resolve cases before filing with HUD. The longer time for FHIP-referred cases to 

reach conclusion implies that the easier cases to resolve are done by the FHIP organization directly without referring them 

to HUD, and the more complex cases are referred to HUD or a FHAP. This finding is consistent with survey findings showing that 27 percent of cases that FHIP organizations investigate are resolved without HUD or FHAP involvement. 

Better outcomes are found for FHIP-investigated cases, particularly those cases in which the FHIP organization is a listed 

complainant, and may be related to testing conducted by FHIP organizations. Of the 542 cases with testing reported as 

part of the case, 72 percent of the tests were done on cases in which a FHIP organization was the complainant (about 

42 percent of all cases in which a FHIP organization was a listed complainant had testing) and 13 percent when the FHIP 

organization was a representative (about 4.5 percent of all cases in which a FHIP organization was a representative). Only 

15 percent of all cases with testing did not appear to involve a FHIP organization (only 0.4 percent of all non-FHIP-referred 

cases had testing). Testing substantially improves the probability of a case being caused or conciliated, with 69 percent of 

cases with testing ending in a cause or conciliation, compared with 38 percent of cases without testing. 

FHIP organizations also appear to play a particularly critical role in a subset of case types. Specifically, FHIP organizations 

are disproportionately involved in design and construction cases (42 percent of such cases are FHIP referred), familial status 

cases (62 percent of such cases are FHIP referred), and pattern and practice cases referred to the U.S. Department of 

Justice (55 percent of such cases are FHIP referred). This statistic compares with FHIP organizations representing only 10 

percent of all cases that HUD or FHAP agencies investigate. 

4 Testing activities funded by non-FHIP sources went unreported to HUD, however. This unreported activity may be substantial; although the average share of tests funded with PEI grants was 64 percent, 30 percent of respondents funded fewer than one-half of their tests with PEI grants. 

5

 This section of the executive summary and section 7 were written by Todd Richardson of HUD. 

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Study of the Fair Housing Initiatives Program 

Conclusions 

This study presents four major findings: (1) FHIP grantee organizations act as a filter, and FHIP-referred complaints are 

much more likely to result in a cause finding or conciliation than are other sources; (2) complaints in which FHIP organizations are a complainant are more likely to be closed as a conciliation or cause finding compared with complaints in which 

FHIP organizations act as a representative to the complainant and non-FHIP-referred complaints; (3) FHIP organizations 

are the primary source for testing evidence associated with complaints and rely heavily on FHIP grants as a stable source 

of funding for enforcement and testing activities; and (4) FHIP organizations play a particularly important role related to 

design and construction, familial status, and pattern and practice cases, and these more complex complaints that are 

referred to HUD may be the reason why FHIP-referred cases may take longer to close than non-FHIP-referred complaints. 

xii
 

Study of the Fair Housing Initiatives Program
	

- Introduction -

This study examines the Fair Housing Initiatives Program (FHIP) from its inception through 2006. The goals of this study are 

to create a history of the program through 2006, describe its grantees, analyze the types of grants awarded through FHIP, 

and analyze the outcomes of cases that grant recipients investigate, especially the comparison of the outcomes of cases 

that the grantees refer to those that other organizations or individuals refer. It is useful to note the limitations of this study. It 

is primarily a process study of FHIP based on interviews with FHIP grantees. Outcomes are reported based on cases that 

are referred to the U.S. Department of Housing and Urban Development (HUD. The study does not review cases that have 

not been referred to HUD, nor does it assess the efficiency of FHIP or program impacts. 

HUD is responsible for enforcing Title VIII of the Civil Rights Act of 1968, commonly known as the Fair Housing Act.6

 As 

such, the HUD Office of Fair Housing and Equal Opportunity (FHEO) accepts and investigates complaints that allege housing discrimination based on race, color, national origin, and religion. The act was later amended to prohibit discrimination on 

the basis of sex, disability, or familial status in the sale, rental, or financing of most residential housing or other real estaterelated transactions. Although FHEO has primary enforcement responsibility, other entities including, but not limited to, state 

and local administrative agencies, the courts, and private organizations—especially nonprofit fair housing groups—have 

played critical roles as well (Wienk et al., 1994). 

Enforcement of the Fair Housing Act, to a large extent, begins with the filing of a fair housing complaint by persons who believe their fair housing rights have been violated. Thus, it is critically important that people, especially members of protected 

classes, who have historically faced discrimination in housing market transactions, are aware of their rights under the act 

(Abravanel, 2002). Without such knowledge, it is highly unlikely victims of discrimination would file fair housing complaints, 

and discriminatory practices would not be redressed. 

Fair Housing Organizations (FHOs) play a vital role in helping to promote fair housing throughout the United States. These 

organizations increase public awareness of discriminatory housing practices through education and outreach campaigns 

that advise consumers how and where to file complaints of housing discrimination and inform them of their rights under 

the act. Organizations that enforce fair housing laws conduct investigations to substantiate or dismiss claims of housing 

discrimination and equitably resolve violations of the Fair Housing Act. 

Organizations that engage in fair housing enforcement activities frequently use testing as an investigative tool to uncover 

covert forms of disparate treatment. Testing is a means for determining the existence of disparate treatment. Testers 

examine housing sites to uncover differences in treatment based on illegal discrimination of housing applicants who are 

eligible as members of a protected class. Testing can help determine if differences exist in the services provided or in the 

quality, content, or quantity of information given to home seekers based on their race, color, national origin, religion, sex, 

disability, or familial status. The U.S. Supreme Court has recognized and affirmed the importance of fair housing testing 

in combating housing discrimination.7

 Federal and state courts have also approved testing results in fair housing litigation 

and have ruled that testing provides important corroborative evidence that enables plaintiffs to meet their burden of proof 

(Wienk, et al., 1994).8 

6 Public Law 90-284, 82 Stat. 81.
�

7 Havens Realty Corp. v. Coleman, 455 U.S. 363, 373 (1982).
�

8

 Cases in which testing played a role in the final outcome of fair housing litigation include Richardson v. Howard, 712 F.2d 319 (7th Cir. 1983); 

Zuch v. Hussey, 394 F. Supp. 1028 (E.D. Mich. 1975); and United States v. Youritan Constr. Co. 370 F. Supp. 643 (N.D. Cal. 1973), modified 509 

F.2d.623 (9th Cir. 1975).
�

1
 
Study of the Fair Housing Initiatives Program
	

The Fair Housing Initiatives Program --

As the chief enforcer of the Fair Housing Act, HUD actively supports enforcement initiatives and education and outreach 

activities through the Fair Housing Initiatives Program, which was initially established in 1987 on an interim basis and revised 

and made permanent in 1992. FHIP was established to allow the HUD Secretary to issue grants and enter into contracts 

or cooperative agreements with state and local government agencies, public and private nonprofit organizations, or other 

public or private entities that have programs designed to prevent or eliminate discriminatory housing practices.9 Since 1989, 

HUD has awarded $282 million through 1,348 grants (Table 17). 

The activities funded by FHIP are generally designed to promote public awareness of the rights granted to people protected 

under the Fair Housing Act and improve the ability of existing organizations that investigate fair housing complaints by funding testing, the results of which can be used as evidence of housing discrimination in legal proceedings. Specifically, FHIP 

now has three funding categories: (1) the Private Enforcement Initiative (PEI); (2) the Education and Outreach Initiative (EOI); 

and (3) the Fair Housing Organizations Initiative (FHOI).10 A fourth funding category, the Administrative Enforcement Initiative 

(AEI), was included in the initial program, but has not been funded since FY 1995. Finally, HUD made awards to support 

national testing programs conducted between FY 1999 and FY 2004 under the Secretary Initiated Projects (SIP). 

PEI grants are generally provided to private nonprofit organizations that enforce fair housing laws to conduct housing 

discrimination complaint intake, investigations, and other law enforcement activities to remedy violations of the Fair Housing 

Act. The investigations that PEI grantees conduct usually include testing to uncover disparate treatment. The activities that 

EOI grants support enable recipients to develop and disseminate information that informs people about their rights under the 

Fair Housing Act and to conduct outreach activities to communities and stakeholders regarding fair housing issues. FHOIfunded activities generally include efforts to build the capacity of organizations that enforce Fair Housing Act provisions. 

Although FHIP was established a little more than 20 years ago, it has not been formally evaluated since a 1994 Urban 

Institute study, led by Ron Wienk, (who was assisted by Margery Turner, Aleda Freeman, and Martha Kuhlman) titled, An 

Evaluation of the FHIP Private Enforcement Initiative Testing Demonstration. That study evaluated the operation and effect 

of the testing component of the PEI component, including an assessment of the testing guidelines established for the 

demonstration phase of FHIP. The evaluation was based on information from first-year 1989 PEI grantees, interviews with 

individuals, and representatives of organizations that were affected directly or indirectly by the FHIP demonstration program. 

The study also analyzed data collected from a nationally representative sample of fair housing groups and a legal review of 

reported fair housing court cases in which testing was used (Wienk et al., 1994). 

The Urban Institute study reported that FHIP significantly increased the quality and quantity of fair housing complaint 

processing, including improvements in tester recruitment and training, the testing of a large number of cases, and provision 

for increased oversight and monitoring of testers’ performance. Tested cases are more likely to be referred to the federal 

government or private attorneys and to have a higher probability of receiving monetary relief than complaints not tested. 

FHIP-imposed testing standards, however, did not have a clear effect on improved case outcomes or results. 

In addition, the authors of the Urban Institute study concluded that FHIP grantees are seen as effective and professional 

facilitators of fair housing enforcement by other organizations operating within their local housing markets, including city 

officials, real estate agents, and other affected parties. Federal courts do not have a single, standard definition for acceptable 

9 42 U.S.C. Section 3616a. 

10 The FHOI funding category began in FY 1992 when FHIP was made into a permanent program (Public Law 102–550 Section 905, approved 

October 28, 1992).
�

2
 
Study of the Fair Housing Initiatives Program 

testing procedures but allow plaintiffs considerable latitude in providing probative evidence of discriminatory treatment. The 

testing procedures used are dictated by the facts and particular circumstances of the individual case, and not according to 

an established set of standards. 

The authors of the 1994 study also reported that FHIP demonstration testing guidelines provide a flexible and workable 

framework for testing. But the increased resources allocated to recruiting, screening, training, and reimbursing testers 

appear to be more effective in ensuring that testing is conducted objectively, systemically, and professionally rather than 

ensuring strict adherence to any particular testing guidelines. 

A number of changes have been made to the program that Wienk and his colleagues studied in the mid-1990s. The 

purpose of this study is to provide updated information about the types of organizations that receive FHIP awards, how 

they use these funds, the effect of these funds on the types of complaints referred to HUD, and the outcome of these 

complaints. This study, which follows the goals outlined in this project’s Statement of Work, is organized as follows. 

Section 1 provides a discussion about the data and methods used in the study and a program history that details how FHIP 

has changed since it began as a demonstration program in 1989. In particular, this history describes how the program has 

responded to support enforcement and education and outreach activities related to emerging fair housing issues since 

FHIP’s inception. 

Section 2 includes a descriptive analysis of the year-by-year awards based on information in HUD’s administrative database 

that tracks all of the awards granted between FY 1989 and FY 2006, including changes in the total amounts awarded, the 

types of organizations that received awards, the differences in the share of awards made for each program initiative, and 

the share of awards made to organizations located throughout the 10 HUD regions. 

Many types of organizations receive FHIP awards to conduct a range of enforcement initiatives and education and outreach 

activities to promote fair housing. Using information from a web-based survey of grantees, section 3 provides a descriptive 

analysis of the organizations that received FHIP awards between FY 2003 and FY 2005. This analysis presents information 

regarding FHIP grantees’ organizational structures and staff, the types of activities that these organizations undertake 

in their enforcement initiatives and education and outreach efforts, and the contribution that FHIP awards make toward 

grantees’ total funding. This analysis also presents information about the testing and education and outreach activities of 

survey respondents and representatives of 10 organizations, which were selected for onsite, indepth interviews to discuss 

how their group processes fair housing complaints. 

Section 4 details the procedures used to process fair housing complaints, using information collected through in-depth 

interviews and the web-based survey. Because these organizations often participate in litigation, the FHIP grantee representatives interviewed were not asked to describe any specific criteria that they used to determine whether a complaint should 

be investigated through testing or any other potential investigative technique. (The discussion guide used to conduct these 

interviews is presented in Appendix B. 

Section 5 presents descriptive analyses of the extent to which FHIP grants support enforcement activities for organizations 

that receive funds through the program. Because FHIP applicants receive more points if they demonstrate other sources 

of funding, it is expected that FHIP awards support a share of the overall activities related to fair housing initiatives among 

FHIP grantee organizations. The detailed data collected through the web-based survey document the contribution that 

FHIP awards make to participant organizations’ budgets. 

Section 5 also describes the testing activities that grantees used. The analyzed information comes from the web-based 

survey. This survey did not collect client-level information about complaints; rather, grantees were asked to provide aggregate information about the types of tests that they conducted. Grantees were not asked in the survey about specific 

outcomes for complaints investigated with tests compared with complaints investigated with other types of techniques. 

(The web-based survey instrument is included in Appendix A. 

Section 6 describes education and outreach activities that the program supports. Section 7 follows with an analysis of differences in outcomes for complaints referred to HUD by FHIP grantees compared with complaints referred by Fair Housing 

Assistance Program (FHAP) organizations or from people who contact HUD directly. 

3
 
 

 

4

1 Data and Methods

Study of the Fair Housing Initiatives Program 

This study analyzes a combination of qualitative information collected through key informant interviews, onsite interviews 

with representatives of FHIP grantees, FHIP Notices of Funding Availability (NOFAs), and the following three quantitative data 

sources: (1) a web-based survey administered to organizations that received a FHIP grant between FY 2003 and FY 2005; 

(2) the HUD administrative database of all grants awarded between FY 1989 and FY 2006; and (3) Title VIII Automated 

Paperless Office Tracking System (TEAPOTS) data of outcomes for all cases referred to HUD between FY 2003 and FY 2005. 

This section details how each data source was used to generate the findings presented in this report. 

Key Informant Interviews 

To identify the appropriate key informants to interview, the research team created a list of current and former HUD employees 

and fair housing professionals who are knowledgeable about FHIP’s history. This list of names was submitted to HUD for 

approval. The research team sent letters to each approved key informant requesting his or her cooperation for an interview. 

Research team members conducted key informant interviews, either through telephone calls or in person, with HUD-approved 

discussion guides (Appendix B). Team members recorded and transcribed the interviews. They used the views and opinions 

of key informants to analyze the reasons for some of the changes to the program that were identified in NOFAs and to provide 

general information about the effects of the program over time. 

Notices of Funding Availability 

The research team reviewed every FHIP-related NOFA that HUD issued between FY 1989 and FY 2006. When reviewing 

a given year’s NOFA, research team members identified HUD’s goals, eligible activities by initiative, funding availability by 

initiative, and total projected funding. This information was entered into an electronic database and used to develop a 

program history, which is presented in section 2. 

HUD Administrative Data 

The research team analyzed the types of initiatives funded and the types of organizations that received a FHIP grant between FY 1989 and FY 2006. HUD provided the research team with an administrative database that contained the names 

of every organization that received a FHIP grant and the amount of the award. Using information available in the Federal 

Register, research team members added the type of award that grant recipients received to the database. The types 

of awards included AEI, EOI, FHOI, PEI, and SIP. Team members added information from the Internet to the database, 

specifying, when possible, whether the recipient was a nonprofit, for-profit, or legal aid services organization; a state or local 

government; or from the Historically Black Colleges and Universities (HBCU) program. 

The research team also conducted Internet research to identify the organizational type for 1,194 of the 1,387 grants (86 

percent) made between FY 1989 and FY 2006. The total dollar amount ($265 million) of these 1,194 awards accounted for 

94 percent of the $283 million of all FHIP awards made between FY 1989 and FY 2006. 

Title VIII Automated Paperless Office Tracking System 

HUD tracks the outcomes for all complaints it receives in its Title VIII Automated Paperless Office Tracking System 

database. A critical aspect of this study is to determine any differences in outcomes for FHIP-referred complaints versus 

non-FHIP-referred complaints made to HUD. FHIP-referred complaints are not reliably flagged in the TEAPOTS database, 

however, so research team members used the following process to manually identify FHIP-referred complaints. 
Study of the Fair Housing Initiatives Program
	

Research team members examined the names of complainants, organizations, and representatives for each complaint in 

TEAPOTS that closed between FY 2003 and FY 2005. When matching these data, the research team looked for organization names that were the same or similar to organization names that received a FHIP grant between 1989 and 2005. 

After making this match, HUD further divided the FHIP-referred cases into two categories, those in which the FHIP organization 

was listed as a named complainant (with or without a co-complainant) and those in which the FHIP organization was listed as 

a representative or other organization. The analysis in Section 7 provides outcomes for cases in which a FHIP organization was 

a complainant, cases in which a FHIP organization was a representative or referring agency (these are all referred to as FHIPrepresented cases), and all other cases that HUD and FHAP agencies (referred to as non-FHIP cases) investigated. 

According to HUD staff, some issues exist with the data reported in the TEAPOTS database: because it is not compulsory, 

some FHAP agencies do not report complaint information into the system, and no standard procedures are available to 

report information about the amount or presence of monetary relief granted to a complainant. In response to these issues, 

HUD redesigned its relief data collection procedures under a new TEAPOTS contract. Nonetheless, the TEAPOTS database 

is the only available source that has comprehensive information about outcomes for cases referred to HUD, and so it is 

used in this study. 

Web-Based Survey 

The research team administered a web-based survey to representatives of all 180 organizations that received a FHIP grant 

between FY 2003 and FY 2005 (see the survey instrument in Appendix A). This survey included questions that FHEO added 

and the Office of Management and Budget approved. After securing approval for the survey instrument, HUD sent participation requests to potential respondents. To follow up, research team members made phone calls and sent e-mails to 

encourage organizations to participate. 

Of the 180 organizations, 68 answered enough questions to be included in this analysis, and the remaining 112 did not. 

Some representatives from nonrespondent organizations indicated the survey was too time consuming and chose not to 

use staff resources to complete it. At the time of the request, 4 of the organizations were no longer in operation. 

Although there were some differences in the types of organizations that responded to the survey, the differences did not appear 

to invalidate the survey data analyses. Survey respondents were more likely to have received PEI grants and to have been 

nonprofit organizations than were nonrespondents. However, the mean grant amount made to survey respondents was similar 

for nonrespondents, which reduces the likelihood that bias exists in the web-based survey results presented in this report. 

Between FY 2003 and FY 2005, PEI grants accounted for about one-half of the number of grants and 61 percent of the 

dollar amount of grants. Among survey respondents, however, PEI grants accounted for 68 percent of the number of grants 

and 85 percent of the dollar amount of these grants. Conversely, EOI grants accounted for only 31 percent of the number 

of grants made to survey respondents, which is 16 percentage points less than the 47 percent of all grants during FY 2003 

and FY 2005. For the same period, EOI grants made up only 14 percent of the dollar awards made to survey respondents, 

and EOI grants accounted for 26 percent of the total dollar amount awarded (Table 1). 

Type of Award 

Number of Grants Dollar Amount of Grants 

Share of All Grant 

Recipients (%) 

Share of Survey 

Respondents (%) 

Share of All Grant 

Recipients (%) 

Share of Survey 

Respondents (%) 

Table 1. Comparison of the Number of Grants and Dollar Amount of Grants Awarded to Web-Based Survey Respondents 

by Initiative, FY 2003–FY 2005 

PEI 51 68 61 85 

EOI 47 31 26 14 

FHOI 2 1 9 1 

SIP 1 0 5 0 

Total 100 100 100 100 

EOI = Education and Outreach Initiative. FHOI = Fair Housing Organizations Initiative. PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects.
�

Source: U.S. Department of Housing and Urban Development administrative database and web-based survey of Fair Housing Initiative Program grantees
�

5
 

Study of the Fair Housing Initiatives Program
	

Although PEI grants accounted for a relatively large share of grants that survey respondents received, the amount awarded 

to survey respondents was similar to all awards made between FY 2003 and FY 2005. Survey respondents received a total 

of 104 awards of the 339 awards made during this period. The mean award of $167,000 granted to survey respondents 

was only 5 percent less than the $176,000 award that nonrespondents received and was close to the overall $173,000 

mean award made between FY 2003 and FY 2005 (Table 2). 

The differences in the mean award amounts among survey respondents and nonrespondents were relatively small for each 

initiative. For example, the mean PEI award made between FY 2003 and FY 2005 was $208,000, which was $2,000 less 

than the mean PEI award made to survey respondents, and $1,000 greater than the mean PEI award made to nonrespondents. 

Greater differences were noted for EOI grantees: the mean EOI grant that survey respondents received between FY 2003 

and FY 2005 was $77,000, which is 25 percent less than the mean $100,000 EOI grant that nonrespondents received. 

The relatively small differences in the award amounts made to survey respondents when compared with nonrespondents 

suggest that the survey results were representative of all 180 organizations that received awards between FY 2003 and 

FY 2005 (Table 3). 

Total 

All Grant Recipients 

(N = 339) ($) 

Survey Respondents 

(N = 104) ($) 

Nonrespondents 

(N = 235) ($) 

Table 2. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents, FY 2003–FY 2005 

Dollars awarded 58,566,155 17,293,727 41,272,428 

Mean award 172,762 166,286 175,627 

Median award 159,240 204,206 100,000 

FHIP = Fair Housing Initiative Program. 

Source: U.S. Department of Housing and Urban Development administrative database and web-based survey of FHIP grantees
�

PEI 

All Grant Recipients 

(N = 172) ($) 

Survey Respondents 

(N = 71) ($) 

Nonrespondents 

(N = 101) ($) 

Table 3. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents by Initiative, 

FY 2003–FY 2005 

Dollars awarded 35,778,873 14,648,116 21,130,757 

Mean award 208,017 206,311 209,215 

Median award 218,938 205,830 188,538 

All Grant Recipients Survey Respondents Nonrespondents 

EOI (N = 7) (N = 32) ($) (N = 126) ($) 

Dollars awarded 15,114,896 2,445,611 12,669,285 

Mean award 95,664 76,425 100,550 

Median award 80,000 32,452 77,603 

All Grant Recipients Survey Respondents Nonrespondents 

FHOI (N = 7) ($) (N = 1) ($) (N = 6) ($) 

Dollars awarded 5,007,179 200,000 4,807,179 

Mean award 715,311 200,000 801,196 

Median award 720,000 NA 898,245 

All Grant Recipients Survey Respondents Nonrespondents 

SIP (N = 2) ($) (N = 0) ($) (N = 2) ($) 

Dollars awarded 2,665,207 0 2,665,207 

Mean award 1,332,604 0 1,332,604 

Median award 1,332,604 0 1,332,604 

EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations Initiative. NA = Not applicable. PEI = Private 

Enforcement Initiative. SIP = Secretary Initiated Projects. 

Source: U.S. Department of Housing and Urban Development administrative database and web-based survey of FHIP grantees 

6
 

 

Study of the Fair Housing Initiatives Program
	

As discussed previously, the research team identified an organization type for 86 percent of all of the awards made under 

the program. Between FY 2003 and FY 2005, nonprofit organizations accounted for 76 and 77 percent, respectively, of 

the number and dollar amounts awarded to survey respondents but accounted for 68 and 69 percent, respectively, of the 

number and dollar amounts awarded to all grant recipients. State and local governments accounted for 8 percent of the 

number of awards but only 1 percent of the awards that survey respondents received. For-profit organizations accounted 

for 5 percent of the dollar awards made between FY 2003 and FY 2005, but no for-profit organizations responded to this 

survey (Table 4). 

Although there were differences in the types of FHIP grant recipient organizations (between FY 2003 and FY 2005) that 

responded to the survey versus all FHIP grant recipients, the mean award that survey respondents received ($190,000) 

was close to the mean award that all the organizations that could be identified ($185,000) and nonrespondents ($183,000) 

received (Table 5). 

Relatively small differences were found in the mean awards made to survey respondents for each type of organization 

compared with nonrespondents. 

The mean award made to nonprofit survey respondents between FY 2003 and FY 2005 was $192,000, compared with 

$185,000 for nonrespondent nonprofit organizations. Similarly, the mean amount awarded to legal aid respondents was 

$169,000, which was similar to the $155,000 mean amount awarded to legal aid nonrespondents (Table 6). 

Of the FHIP grantee organizations that received an award between FY 2003 and FY 2005, 72 referred complaints to HUD 

that were closed in that same 2-year period (Table 7). Of these 72 organizations, about half responded to the web-based 

survey. The 35 organizations that responded referred a total of 543 complaints that closed between FY 2003 and FY 2005, 

for a mean of 16 complaints per organization. The 37 nonrespondents referred a total of 721 complaints that closed between 

FY 2003 and FY 2005, or a mean of 19 cases per organization (Table 7). This relatively small difference in the mean number 

of complaints referred to HUD that closed between FY 2003 and FY 2005 for survey respondents and nonrespondents 

suggests that the two groups’ profiles are similar, regarding the volume of complaints referred to HUD. 

Number of Grants Dollar Amount of Grants 

Organization Type 

Share of All Grant 

Recipients (%) 

Share of Survey 

Respondents (%) 

Share of All Grant 

Recipients(%) 

Share of Survey 

Respondents (%) 

Table 4. Comparison of the Number of Grants and Dollar Amount of Grants Awarded to Web-Based Survey Respondents 

by Initiative, FY 2003–FY 2005 

Nonprofit 68 76 69 77 

Legal aid 20 22 18 20 

For profit 1 0 5 0 

State or local government 8 1 3 3 

HBCU 3 0 5 0 

Total 100 100 100 100 

HBCU = Historically Black Colleges and Universities. 

Source: U.S. Department of Housing and Urban Development administrative database and web-based survey of Fair Housing Initiative Program grantees
�

Grants Awarded to Identified Organization Type 

All Grant Recipients 

(N = 286) ($) 

Survey Respondents 

(N = 85) ($) 

Nonrespondents 

(N = 201) ($) 

Table 5. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents by Identified 

Organization Type, FY 2003–FY 2005 

Dollars awarded 52,920,777 16,166,413 36,754,363 

Mean award 185,038 190,193 182,858 

Median award 202,650 206,223 159,240 

FHIP = Fair Housing Initiative Program. 

Source: U.S. Department of Housing and Urban Development administrative database and web-based survey of FHIP grantees
�

7
Study of the Fair Housing Initiatives Program
	

Nonprofit 

All Grant Recipients 

(N=194) ($) 

Survey Respondents 

(N=65) ($) 

Nonrespondents 

(N=129) ($) 

Table 6. Comparison of Mean and Median FHIP Grants Awarded to Web-Based Survey Respondents by Type of Recipient 

Organization, FY 2003–FY 2005 

Dollars awarded 36,342,259 12,474,759 23,867,500 

Mean award 187,331 191,919 185,019 

Median award 206,257 206,490 195,504 

All Grant Recipients Survey Respondents Nonrespondents 

Legal Aid (N=58) ($) (N=19) ($) (N=39) ($) 

Dollars awarded 9,262,210 3,216,335 6,045,875 

Mean award 159,693 169,281 155,022 

Median award 203,111 200,000 206,418 

All Grant Recipients Survey Respondents Nonrespondents 

For Profit (N=2) ($) (N=0) ($) (N=2) ($) 

Dollars awarded 2,665,207 0 2,665,207 

Mean award 1,332,604 0 1,332,604 

Median award 1,332,604 0 1,332,604 

State or Local All Grant Recipients Survey Respondents Nonrespondents 

Government (N=24) ($) (N=1) ($) (N=23) ($) 

Dollars awarded 1,814,731 475,319 1,339,412 

Mean award 75,614 475,319 58,235 

Median award 80,000 475,319 80,000 

All Grant Recipients Survey Respondents Nonrespondents 

HBCU (N=8) ($) (N=0) ($) (N=8) ($) 

Dollars awarded 2,836,369 0 2,836,369 

Mean award 354,546 0 354,546 

Median award 159,834 0 159,834 

FHIP = Fair Housing Initiative Program. HBCU = Historically Black Colleges and Universities.
�

Source: U.S. Department of Housing and Urban Development administrative database and web-based survey of FHIP grantees
�

All FHIP 

Grantee 

Organizations 

Organizations 

That Received a 

FHIP Grant 

Survey 

Respondents 

Survey 

Nonrespondents 

Table 7. Comparison of the Number of Cases Closed for Survey Respondents and Nonrespondents, FY 2003–FY 2005 

Total number of FHIP-referred cases closed 1,282 1,264 543 721 

Mean number of cases referred that closed 17 18 16 19 

N 76 72 35 37 

FHIP = Fair Housing Initiative Program.
�

Source: U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System data and web-based survey of FHIP grantees
�

Given that there were relatively small differences in the award amounts and the types of organizations that responded to the 

web-based survey compared with nonrespondents, the results of the web-based survey were likely to be representative of 

all the organizations that received FHIP awards between FY 2003 and FY 2005. The only caveat is that survey respondents 

disproportionately received PEI awards, so the survey results may be more representative of organizations that received 

such an award compared with EOI grant recipients. These results also do not account for the for-profit organizations, state 

and local government, and HBCU program grantees that represent 15 percent of all FHIP grantees. The web survey is most 

representative of the 85 percent of the grantee universe comprising nonprofit and legal aid agencies receiving PEI awards. 

8
 
Study of the Fair Housing Initiatives Program
	

Onsite Interviews With FHIP Grantee Representatives 

The research team conducted onsite interviews with representatives of 10 organizations that received FHIP grants between 

FY 2003 and FY 2005. During this 3-year period, 2 of the selected organizations received both a PEI and an EOI, 4 organizations received a PEI grant only, and the remaining 4 organizations received an EOI grant only. The sample of EOI 

grant recipients was selected from a frame that was stratified by the following organizational categories: legal aid services, 

nonprofit organizations, HBCUs, and local or state governments. The sample of PEI grantees was selected from a frame 

that was stratified into legal aid services and Fair Housing Organizations. 

After stratifying the organizations that received PEI and EOI grants, 10 organizations were selected to reflect the distribution 

of the role of fair housing initiatives in their overall missions among those 64 web-based survey respondents who provided 

information by January 22, 2008. Web-based survey respondents were asked whether fair housing work constituted an 

“exclusive, primary, significant role among several, secondary, or minor” role in their organizations’ missions. Of web-based 

survey respondents, 34 percent indicated that fair housing initiatives played an “exclusive” role, 25 percent indicated that 

fair housing initiatives played a “primary” role, and 38 percent indicated that fair housing initiatives played a “significant role 

among several” activities (Table 8). 

The distribution of the role of fair housing initiatives in the mission statements of the 10 organizations selected for onsite 

interviews was about the same as for all 64 web-based respondents who answered the question regarding the role of 

fair housing initiatives in their overall mission statements. This sample was selected to ensure that the distribution of the 

geographic coverage of the 10 organizations was the same as for all web-based survey respondents. Web-based survey 

respondents identified their organizations’ target area as multiple cities or counties, multiple states, single city, single county, 

single metropolitan area, statewide, or targeted neighborhoods. Based on responses to this question, the distribution of the 

sampled organizations’ target areas was about the same as for web-based survey respondents (Table 9). Research team 

members conducted onsite, semistructured interviews with the executive director and fair housing director of each of the 

10 selected organizations using an interview guide that HUD approved (Appendix B). The information that these interviewees provided was used to detail procedures that grantees used when processing complaints and the criteria they used to 

determine when to conduct fair housing tests. 

Role of Fair Housing Initiatives Exclusive Primary 

Significant Role 

Among Several Secondary Total 

Table 8. Distribution of the Role of Fair Housing Initiatives in the Sampled Organizations’ Mission Statements 

Number of web-based respondents as of Jan. 22, 2008 22 16 24 2 64 

Percent of web-based survey respondents 34% 25% 38% 3% 100% 

N 3 3 2 2 10 

Percent of sampled organizations 30% 30% 20% 20% 100% 

Source: Web-based survey of Fair Housing Initiative Program grantees 

Targeted Areas 

Multiple 

Cities or 

Counties 

Multiple 

States 

Single 

City 

Single 

County 

Single 

Metro 

Area 

Statewide 

Targeted 

Neighborhoods Total 

Table 9. Distribution of Sampled Organizations by Geographic Target Areas 

Number of web-based respondents 19 4 4 9 13 14 1 64 as of Jan. 22, 2008 

Percent of web-based survey 31% 6% 6% 13% 20% 22% 2% 100% respondents 

N 2 1 0 2 2 2 1 10 

Percent of sampled organizations 20% 10% 0% 20% 20% 20% 10% 100% 

Source: Web-based survey of Fair Housing Initiative Program grantees 

9
10

2 Program History

This section provides a history of the Fair Housing Initiatives Program. It begins with background about the factors that led 

HUD to institute the program, and how each program initiative evolved since inception in FY 1989. Following this discussion 

are analyses of the awards made under the program between FY 1989 and FY 2006. The awards, by year, were analyzed 

by the types of initiatives funded, types of organizations that received awards, and HUD regions where FHIP grantee organizations were located.

Factors That Led to FHIP’s Implementation

FHIP was authorized under Section 561 of the Housing and Community Development Act of 1987,11 as amended by the 

Housing and Community Development Act of 1992, to strengthen HUD’s ability to enforce Title VIII of the Civil Rights Act of 

1968,12 commonly known as the Fair Housing Act. FHIP grew out of a realization among participants that enforce fair housing laws that a need existed for a large, reliable source of funding for fair housing law enforcement activities—especially for 

use in testing conducted by private fair housing groups that supported HUD’s role of enforcing the Fair Housing Act.

The effectiveness of funding such groups was documented in a study of the Fair Housing Demonstration Program, which ran 

from 1980 to 1981, with the support of HUD and the National Committee Against Discrimination in Housing, Inc. The program 

provided nine local private fair housing groups with $20,000 per year for 2 years. The study found that each dollar of demonstration program grant funds generated between 2 and 3 dollars of additional activity by local groups (Wienk, et al., 1994).

In 1984, representatives of 25 FHOs adopted a resolution that urged the HUD Secretary to implement a mechanism that 

would directly fund private fair housing groups, and the U.S. Senate held hearings in 1986 on a proposal to establish the 

program. One key informant made the following statement:

So I went to the Secretary of HUD [who] was Samuel R. Pierce at the time. I said we are doing for the 

government what HUD cannot do for itself. We outlined our litigation that we had just gone through ... He 

listened. I said we must have direct funding from Washington to ... continue the work of antidiscrimination in housing in the New Jersey area and for all of the fair housing groups in the country. I think he went 

to the president. It was approved, but then it got back to us saying that something like this has got to go 

through the Congress. He just can’t do it. You can’t fund these groups because the president or the HUD 

Secretary feels that it is necessary; so we wasted another 2 years in the Congress, but it did pass.

The 1987 legislation that initially authorized FHIP, directed the HUD Secretary to provide funding to state and local governments or their agencies, public or private nonprofit organizations, or other public or private entities formulating or carrying 

out programs to prevent or eliminate discriminatory housing practices. Originally funded as a 2-year demonstration program that expired on September 30, 1990, FHIP was renewed as a demonstration program in November 1990 and made 

permanent in FY 1992 (Public Law 102–550, Section 905, approved Oct. 28, 1992). Another key informant explained why 

FHIP was not originally a permanent authorization:

In terms of the demonstration, the demonstration aspect of the FHIP program was a reluctance on the 

parts of organizations to agree to a permanent authorization—they [the private FHOs and the National Association of Realtors] were not completely convinced that the FHIP program, or the testing requirements 

that might be developed in FHIP, were something that they were ready to jump onto permanent authorization. 

Study of the Fair Housing Initiatives Program

11 The FHOI funding category began in FY 1992 when FHIP was made a permanent program (Public Law 102–550 Section 905, approved 

October 28, 1992).

12 42 U.S.C. 3616; Public Law 100-242, approved February 5, 1988.
Study of the Fair Housing Initiatives Program 

So, at that time there were a number of programs that were subject to what they call a sunset provision 

... that is why it was a 2-year demonstration. They wanted the ability to shut down the program if they 

found that they weren’t able or weren’t satisfied with the way the program was operating. 

The 1992 act that made the program permanent included provisions that reflect legislative changes in fair housing requirements subsequent to 1988. In particular, the 1992 act reflected provisions in the Fair Housing Amendments Act of 1988, 

the 1989 amendments to the Home Mortgage Disclosure Act, and the Equal Credit Opportunity Act Amendments of 1991. 

The changes require federal banking regulatory agencies to make referrals to the U.S. Department of Justice (DOJ) when a 

regulator has reason to believe that a pattern or practice of discrimination exists and referrals to HUD when a regulator has 

reason to believe that a lender violated the Fair Housing Act. The legislation making FHIP a permanent program also authorized FHIP funds to be used for implementing testing programs when there was a reasonable basis for doing so, establishing new FHOs or expanding the capacity of existing organizations, and conducting special projects or undertaking larger, 

long-term enforcement activities through multiyear funding agreements and funding litigation (GAO, 1997). 

Evolution of FHIP 

As detailed in the following section, FHIP has evolved from providing funding for a relatively flexible set of eligible activities 

among three funding categories to establishing separate components that fund activities targeted for specific fair lending 

issues or groups. These components mostly focus activities in areas consistent with HUD goals or fair housing issues that 

emerged after 1989. The following discussion presents an analysis of how each FHIP initiative, such as the EOI, PEI, FHOI, 

and AEI, has changed since FY 1989. 

Education and Outreach Initiative 

EOI funds are made available to Qualified Fair Housing Enforcement Organizations (QFHOs),13 FHOs,14 public and private 

nonprofit organizations or institutions, other private entities that are formulating or carrying out programs to prevent or 

eliminate discriminatory housing practices, state and local governments, and FHAP agencies. In addition, EOI grants for 

particular components, detailed below, typically require that an organization has demonstrated experience or expertise in 

issues related to the component. 

In general, the eligible activities within the EOI-funding category remained the same between FY 1989 and FY 1997. The 

eligible EOI activities in this period changed to reflect specific education and outreach needs for particular groups. For example, in FY 1991, the Notice of Funding Availability included designing education and outreach to people with disabilities, 

non-English-speaking people, and families with children under age 18, including those in homeless shelters. The FY 1992 

NOFA included funding for groups that developed education and outreach activities associated with community opposition 

to the location of residential facilities for people with disabilities. The FY 1994 NOFA included outreach activities to inform 

people with disabilities and their advocates about their rights to fair housing and to provide technical assistance to support 

compliance with housing adaptability and accessibility guidelines in the 1988 Fair Housing Amendments Act. 

In addition to requesting that EOI recipients target particular members of protected classes, NOFAs, starting in FY 1993, 

began to specify that education and outreach areas focus on particular topic areas. These areas reflected emerging fair 

lending issues at the time, and HUD wanted its EOI grant recipients to address them. The FY 1993 NOFA requested that 

EOI applicants provide housing, mortgage lending, appraisal, and insurance counseling. During this time, the Boston Federal Reserve Bank released its landmark study of mortgage lending discrimination, which, holding other factors constant, 

13 24 CFR Subtitle B, Ch. I, Section 125–103 defines a Qualified Fair Housing Enforcement Organization as any organization, whether or not it is 

solely engaged in fair housing enforcement activities, that (1) is organized as a private, tax-exempt, non-profit, charitable organization; (2) has at 

least 2 years of experience in complaint intake, complaint investigation, testing for fair housing violations, and enforcement of meritorious claims; 

and (3) is engaged in complaint intake, complaint investigation, testing for fair housing violations, and enforcement of meritorious claims at the time 

of application for FHIP assistance. 

14 24 CFR Subtitle B, Ch. I, Section 125–103 defines a Fair Housing Enforcement Organization as any organization, whether or not it is solely 

engaged in fair housing enforcement activities, that (1) is organized as a private, tax-exempt, non-profit, charitable organization; (2) is currently 

engaged in complaint intake, complaint investigation, testing for fair housing violations, and enforcement of meritorious claims; and, (3) upon the 

receipt of FHIP funds, will continue to be engaged in complaint intake, complaint investigation, testing for fair housing violations, and enforcement 

of meritorious claims. 

11
 
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showed that minority loan applicants were more likely to be denied. The FY 1996 NOFA requested that applicants show 

how their proposed education and outreach activities supported fair housing planning requirements of state and local governments subject to the Consolidated Plan, which included conducting an analysis of impediments to fair housing choice 

and undertaking actions to eliminate the identified impediments (Table 10). 

In FY 1998, HUD indicated an interest in ensuring that immigrant communities were aware of their rights under the Fair 

Housing Act and acted to file complaints when they believed immigrants were victims if discrimination. The EOI eligible 

activities in FY 1998 reflected these priorities: all projects that EOI grants funded in that year had to focus on addressing fair 

housing needs of underserved and immigrant populations. Because HUD made the pledge to increase enforcement of discrimination laws, these education and outreach activities had to be designed so that they increased referrals of fair housing 

complaints and other information to HUD, and the complaints could be investigated. In addition, a separate NOFA issued in 

FY 1998 included a Nationwide Education Project that would, in cooperation with real estate industry groups, disseminate 

information regarding compliance with the housing adaptability and accessibility guidelines contained in the Fair Housing 

Amendments Act of 1988. 

Beginning in FY 1999, EOI NOFAs, rather than continuing to include specific groups to target or activities to complete, 

requested applicants for different EOI components. Although general education and outreach activities could be funded 

with applications to the EOI General Component, organizations could also apply for funding made available for outreach for 

specific activities (Table 11). 

NOFA Eligible Activities 

Table 10. Summary of Eligible Activities Under EOI Funding Categories, FY 1989–FY 1997 

FY 1989 Education: Developing materials on fair housing rights and responsibilities; developing fair housing and affirmative marketing instructional materials for education programs for state, regional, and local housing industry groups; providing education seminars and working 

sessions for civic associations, community-based groups, and other groups; and developing educational materials targeted at people 

in need of specific or additional information on their fair housing rights. Outreach: Developing state, regional, or local media campaigns 

regarding fair housing rights; bringing housing industry and civic or fair housing groups together to identify illegal real estate practices 

and determining how to correct them; designing specialized outreach projects to inform people of the availability of housing opportunities; developing and implementing a response to new or more sophisticated practices that result in discriminatory housing practices; 

and developing mechanisms to identify quick response to housing discrimination cases involving threats of physical harm. The change 

for the November 1989 competition was the inclusion of conducting national campaigns. 

FY 1990 No information was provided. 

FY 1991	� Same as 1989, except developing and implementing school curriculum for fair housing courses; Voluntary Affirmative Marketing Agreements; designing specialized outreach projects to inform people of the availability of housing opportunities (that is, people with disabilities, non-English-speaking people, and families with children under 18, including those in homeless shelters); including fair housing 

month activities; and establishing private FHOs in geographical areas where none exist. 

FY 1992	� Same as 1991, except developing informative materials about fair housing rights and responsibilities; developing educational materials 

targeted at people in need of specific or additional information on fair housing rights; and developing and implementing a response to 

community opposition to the location of residential facilities for people with disabilities, as defined by the FHA, where supportive health 

or human services are provided in connection with the housing. 

FY 1993 Same as 1992, except focusing on providing housing, mortgage lending, appraisal, and insurance counseling. 

FY 1994 Same as 1993, except focusing on informing people with disabilities and their support organizations and service providers, housing providers, and the general public on the rights of people with disabilities under FHA and on the location or availability of accessible housing 

or the modification of nonaccessible housing; providing guidance to housing providers on meeting the FHA obligation to make reasonable accommodations for people with disabilities; and developing materials and providing technical assistance to support compliance 

with housing adaptability and accessibility guidelines in the Fair Housing Amendments Act of 1988. 

FY 1995 Same as 1994. 

FY 1996	� Same as 1995, except activities that support fair housing planning requirement of state and local governments subject to the Consolidated Plan, including conducting an analysis of impediments to fair housing choice, and undertaking actions to eliminate the identified 

impediments. 

FY 1997	� Same as 1996, except providing educational materials, seminars and working sessions for schools, civic associations, neighborhood 

organizations, and other groups to support community-based EOI efforts; and providing technical assistance to support compliance 

with FHA’s accessible design and construction requirements and fair housing accessibility guidelines. 

EOI = Education and Outreach Initiative. FHA = Federal Housing Administration. FHO = Fair Housing Organization. 

Source: Fair Housing Initiative Program Notices of Funding Availability, FY 1989–FY 1997 

12
Study of the Fair Housing Initiatives Program
	

Year 

Component 

Added Component Component Activities 

Table 11. Summary of Components Added to EOI Funding Category, FY 1999–FY 2006 

FY 1999 Disability Provide information regarding fair housing rights to people with disabilities. 

Homeownership Improve access to homeownership for racial and ethnic minorities by addressing barriers to fair 

housing choice. 

Best Practices Collect prototypes of successful fair housing education and enforcement business practices. 

FY 2000 Fair Housing Partnership Create partnerships with FHAPs. 

Model Codes Partnerships Develop collaborative activities involving disability rights groups, housing industry organizations, 

and other agencies involved with building codes related to housing for people with disabilities. 

Community Tensions Intervention in areas where community tensions emerge and create volatile situations. 

FY 2001 No new components 

FY 2002 National Media Campaign Create a campaign for 2003 fair housing month activities. 

Fair Housing Awareness Create a national campaign to educate on abusive lending practices. 

FY 2003 Hispanic Fair Housing Provide bilingual materials and services to Hispanics to make them aware of and educated about 

Awareness their fair housing rights and responsibilities under the Fair Housing Act. 

Fair Housing and Minority Perform community outreach activities to educate people about fair housing and prepare them for 

Homeownership Component homeownership. 

FY 2004 No new components 

FY 2005 Asian and Pacific Islanders Develop and disseminate bilingual materials and services to Asian and Pacific Islanders. 

Awareness 

Minority-Serving Institutions Establish partnerships with HBCUs and tribal colleges and universities, Hispanic-serving 

institutions, and Asian and Pacific Islander-serving institutions. 

FY 2006 Hurricane Katrina Fair Provide fair housing education and outreach in Louisiana, Mississippi, Alabama, and Texas, and to 

Housing Awareness people displaced to other areas because of Hurricane Katrina. 

Subprime Lending Provide education regarding high-cost loans and abusive lending practices, and legal ways to 

combat such abusive practices. 

EOI = Education and Outreach Initiative. FHAP = Fair Housing Assistance Program. HBCU = Historically Black Colleges and Universities. 

Source: Fair Housing Initiative Program Notices of Funding Availability, FY 1999–FY 2006 

In most cases, the components that were added in a particular fiscal year directly reflected HUD’s goals. In FY 1997, for 

example, one of HUD’s goals was to expand housing choice, especially by increasing the development of scattered-site 

multifamily housing units. The Community Tensions Component was designed to address areas where local residents did 

not want such developments in their neighborhoods. The Disability Component, added in FY 1999, was consistent with 

HUD’s goal in FY 1998 to increase the real estate industry’s compliance with disability provisions of the Fair Housing Act. 

The FY 2000 NOFA included a Fair Housing Partnership Component that reflected HUD’s goal to increase partnerships 

between FHIP organizations and FHAP agencies. 

In FY 1998, components targeted specific immigrant groups, such as Hispanics, Asians, and Pacific Islanders, which 

reflected HUD’s goal to ensure that they were aware of their fair housing rights. In addition, the Fair Housing and Minority 

Homeownership Component addressed HUD’s goal of increasing homeownership among traditionally underserved groups. 

Components related to Hurricane Katrina victims and subprime lending issues addressed recent concerns and policy issues. The types of components included in FHIP NOFAs between FY 1998 and FY 2006 changed to balance the funding 

available with specific issues requiring education and outreach activities (Table 12). 

13
 
Study of the Fair Housing Initiatives Program
	

NOFA Eligible Activities 

Table 12. Summary of Eligible Activities Under EOI Funding Categories, FY 1998–FY 2006 

FY 1998	� All projects must focus on addressing the fair housing needs of underserved populations and immigrant populations; must be designed to increase referral of fair housing complaints and other information to HUD and to educate the public about their fair housing 

rights and procedures to file with HUD; same as 1997, except cannot use to develop new fair housing materials other than to supplement existing materials. 

Separate NOFA—Nationwide Education Project addressing one of the following: demonstrated cooperation with real estate industry 

organizations and dissemination of educational information and technical assistance to support compliance with the housing adaptability and accessibility guidelines contained in the Fair Housing Amendments Act of 1988. HUD anticipates that products will be available 

in at least three languages other than English. Deliverables: public service announcements for radio and television, posters, and other 

graphic materials. 

FY 1999	� Same as 1998, except Homeownership Component focused on improving access to homeownership for racial and ethnic minorities 

by addressing barriers to fair housing choice; and Best Practices Component collecting prototypes of successful fair housing education 

and enforcement business practices. 

FY 2000	� Same as 1999, except General Component focused on racial and ethnic minorities; Fair Housing Partnership Component focused on 

partnerships with FHAPs. Model Codes Partnership Component focused on collaborative activities involving disability rights groups, 

housing industry organizations, and other agencies involved with building codes; and Community Tensions Component focused on 

intervening when community tensions emerged and created volatile situations. 

FY 2001 Same as 2000, except Disability Component focused on disability rights; and General Component did not mention specific groups. 

Separate NOFA—Model Codes Partnership Component, same as 2000. 

FY 2002 Same as 2001, except Disability Component; National Media Campaign Component created campaign for 2003 fair housing month 

activities; and Fair Housing Awareness Component included national campaign to educate on abusive lending practices. 

FY 2003	� Same as 2002, except Hispanic Fair Housing Awareness Component must show 5 years as serving people of Hispanic origin; Fair 

Housing and Minority Homeownership Component included community outreach activities to educate on fair housing rights, and prepare for homeownership; and Model Codes Partnership Component is included. 

FY 2004 Same as 2003, except Hispanic Fair Housing Awareness Component must show 3 years as serving Hispanic people; and National 

Media Campaign Component was for 2005 fair housing month activities. 

FY 2005	� Same as 2004, except no Hispanic Fair Housing Awareness Component or National Media Campaign Component. Asian and Pacific 

Islanders Awareness Component must show bilingual materials and services to Asian and Pacific Islanders; and Minority-serving Institutions Component to establish partnerships with HBCUs and tribal colleges and universities; Hispanic-serving institutions, and Asian and 

Pacific Islander-serving institutions. 

FY 2006	� Same as 2005, except no Asian and Pacific Islanders Fair Housing Awareness Component or Minority-serving Institutions Component. 

Hurricane Katrina Fair Housing Awareness Component focused on Louisiana, Mississippi, Alabama, and Texas, or those displaced to 

other areas; and Subprime Lending Component focused on educating regarding high-cost loans and abusive lending practices, and 

legal ways to combat such abusive practices. 

EOI = Education and Outreach Initiative. HBCU = Historically Black Colleges and Universities. HUD = U.S. Department of Housing and Urban Development. NOFA = 

Notice of Funding Availability.
�

Source: Fair Housing Initiative Program NOFAs, FY 1998–FY 2006
�

Private Enforcement Initiative 

Private Enforcement Initiative grants generally make funds available to QFHOs and FHOs to conduct investigations and enforcement activities, including testing, in response to fair lending complaints filed by individuals who believe their rights have 

been violated under the Fair Housing Act. A key informant explained the reasoning behind using QFHOs and FHOs: 

That HUD has framed that slightly differently over the years, but it was always supposed to be for groups 

that were doing actual enforcement. There were sometimes when, ah well, that the definition of who was 

eligible for PEI has changed over the years. There was an amendment to the law that [was] initiated by the 

National Fair Housing Alliance to require qualified private fair housing groups, only to be able to get the 

PEI money and they had to have 2 years testing experience and enforcement experience. And the reason 

for that, there was some, I believe, some inappropriate spending of some of FHIP money to groups who 

were not enforcement entities. There was a very controversial grant in the FHIP program. 

14
 
Study of the Fair Housing Initiatives Program
	

In addition, a portion of a recipient’s PEI grant can be used for education and outreach activities. This allowable portion 

declined from 20 percent in 1989 to 5 percent in 2006. 

Few modifications to PEI eligible activities were made between FY 1989 and FY 1997, and there were separate components 

during this period. In each of those years, PEI grantees could use grant funds to conduct a core group of activities, such as 

investigations of systemic housing discrimination, conducting tests, or performing other types of investigative support for administrative and judicial enforcement. In some fiscal years, PEI funds could be used for a broader range of activities (Table 13). 

The greatest changes to the number of eligible activities between FY 1989 and FY 1997 occurred in FY 1993 when PEI 

grant funds could be used to discover and provide remedies for discrimination in public and private real estate markets and 

real estate-related transactions, such as making or purchasing loans, providing other financial assistance for sales and rental housing, engaging in insurance and appraisal practices, and advertising housing. These funds were available for testing 

and other investigative activities, building the capacity for housing investigative activities in underserved areas, and carrying 

out special projects, including the development of prototypes to respond to new or sophisticated forms of discrimination 

against people protected under Title VIII, such as in the areas of independent living and architectural barriers. In addition to 

changes in allowable activities conducted on complaints that a FHIP organization received, starting in FY 1991, PEI grant 

recipients could conduct testing of bona fide housing complaints referred by a FHAP agency (Table 12). 

The next big change to PEI funding came in FY 2005 with the introduction of the Performance-Based Funding Component. 

This component was designed to provide high-performing PEI grantees with 3 years of continuous funding to assist with 

strategic planning and systemic investigations. To qualify for this type of grant, a FHIP organization had to demonstrate excellent performance reviews for the most recent 2-year award period and a minimum score of 95 on their two most recent 

performance assessments from their government technical representatives. During FY 2005 and FY 2006, 25 PEI grantees 

received this type of award for their organizations. 

The first separate PEI component was included in the FY 1998 NOFA. The Joint Enforcement Component recognized that 

fair housing investigations often required organizations to work together and share information about particular complaints. 

NOFA Eligible Activities 

Table 13. Summary of PEI Eligible Activities, FY 1989–FY 1997 

FY 1989 Conducting investigations of systemic housing discrimination, professionally conducting testing or other investigative support for administrative and judicial enforcement, linking FHOs regionally in enforcement activities designed to combat broader market discriminatory 

practices, and establishing effective means of meeting legal expenses in support of litigating fair housing cases. 

FY 1990 Same as above. 

FY 1991 Same as above, except professionally conducting testing of bona fide housing complaints referred by FHAP agencies. 

FY 1992	� Only testing provisions, including conducting investigations of systemic housing discrimination, professionally conducting testing of 

bona fide allegations referred by FHAP agencies, and professionally conducting testing or other investigative support for administrative 

and judicial enforcement. 

FY 1993	� Same as 1991, except discovering and providing remedies for discrimination in the public and private real estate markets and real 

estate-related transactions, such as making or purchasing loans, the provision of other financial assistance for sales and rental housing, 

insurance redlining and appraisal practices, and housing advertising. Testing and other investigative activities, building the capacity for 

housing investigative activities in underserved or underserved areas, and carrying out special projects, including the development of 

prototypes to respond to new or sophisticated forms of discrimination against people protected under Title VIII, such as in the areas of 

independent living and architectural barriers. 

FY 1994 Same as 1993, except building the capacity to investigate, through testing and other investigative methods, housing discrimination 

complaints based on mental and physical disabilities. 

Separate NOFA to address property insurance and mortgage lending discrimination—activities included testing, obtaining evidence, and 

obtaining data. 

FY 1995 Same as 1994, except no separate NOFA. 

FY 1996 Same as 1995. 

FY 1997 Same as 1996, except conducting complaint intake of allegations of housing discrimination, evaluating testing results, and conducting 

mediations or other voluntary resolutions of allegations of fair housing discrimination. 

FHAP = Fair Housing Assistance Program. FHO = Fair Housing Organization. PEI = Private Enforcement Initiative. NOFA = Notice of Funding Availability. 

Source: Fair Housing Initiative Program NOFAs, FY 1989–1997 

15
 

Study of the Fair Housing Initiatives Program
	

As a result, the eligible activities under this component were for grantees to share data analyses for use in (1) developing 

investigations; (2) conducting joint preliminary investigative activities through testing, reviewing property records, developing 

strategies, conducting interviews, and so forth; (3) developing investigative materials for referral to HUD for action; (4) conducting regular meetings among organizations and with HUD to share information about potential violations for investigation 

based on complaints, data, or other sources; and (5) having regular contact with HUD to ensure project activities conformed 

with planned deliverables and that these deliverables met grant agreement requirements (Table 14). 

The FY 2000 NOFA promoted collaborative fair housing enforcement projects that proposed strategic planning among 

public fair housing enforcement agencies, which were state and local government agencies tasked with enforcing state fair 

housing laws, eligible under FHAP and FHIP. The key informants, as a group, agreed that NOFA changes were based on 

the priorities of the Assistant Secretary of HUD’s FHEO. In FY 2000, the funding for grants that covered 24 months was 

restricted to grantees that dedicated 60 percent of their activities and budgets on immigrant and other underserved groups. 

In response to Hurricane Katrina and concerns about predatory lending in the subprime market, the FY 2006 NOFA had 

separate components for enforcement activities related to both areas. 

NOFA Eligible Activities 

Table 14. Summary of PEI Eligible Activities, FY 1998–FY 2006 

FY 1998 Same as 1997, except for Joint Enforcement Component under which grantees share data analyses for use in developing investigations; conduct joint preliminary investigative activities through testing, review of property records, develop strategies, interviews, etc; 

develop investigative materials for referral to HUD for action; conduct regular meetings among organizations and with HUD to share 

information about potential violations for investigation based on complaints, data, or other sources; and have regular contact with HUD 

to ensure project activities conform with planned deliverables and that deliverables meet grant agreement requirements. 

FY 1999 Same as 1998. 

FY 2000	� Same as 1999, except for Fair Housing Partnership Component to promote collaborative fair housing enforcement projects that propose strategic planning between public fair housing enforcement agencies eligible under FHAP and FHIP organizations. The multiyear 

component restricted funds to efforts focused 60 percent of activities and budget to needs of immigrants and other underserved 

populations. 

FY 2001 Same as 2000, except no Fair Housing Partnership Component. 

FY 2002 Same as 2001. 

FY 2003 Same as 2002. 

FY 2004 Same as 2003. 

FY 2005 Same as 2004, except Performance Based Funding Component under which organizations with excellent ratings for 2002 and 2003 

can apply. 

FY 2006	� Same as 2005, except Hurricane Katrina Enforcement Component under which grantees focus their efforts on affected areas of 

Louisiana, Mississippi, Alabama, and Texas; and Subprime Lending Component under which grantees focus enforcement activities on 

subprime lending for discrimination. 

FHAP = Fair Housing Assistance Program. FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development. PEI = Private Enforcement Initiative. 

Source: FHIP Notices of Funding Availability, FY 1998–FY 2006 

Fair Housing Organizations Initiative 

In FY 1993, FHOI started to increase the capacity of existing organizations and to promote the development of new FHOs, 

especially in areas that had few such groups. Between FY 1993 and FY 1995, FHOI Continued Development and New 

Organizations grants were made available to QFHOs, other private nonprofit fair housing enforcement organizations, and 

nonprofit groups that were organized to build their capacity to provide fair housing enforcement (Table 15). A key informant 

discussed FHOI: 

Then we had the establishing of new fair housing groups ... and we opened up fair housing centers in 

Fresno, California; Montgomery, Alabama; and New Orleans. All three are still open and operating. ... 

Subsequently we got grants, the National Fair Housing Alliance, to open up groups in San Antonio; Boston; 

Houston, Texas; and Biloxi, Mississippi. 

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Study of the Fair Housing Initiatives Program
	

NOFA Eligible Activities 

Table 15. Summary of FHOI Eligible Activities, FY 1993–FY 2006 

FY 1993	� Continued Development of Existing Organizations. Eligible activities were the same as for PEI in the 1993 NOFA (Table 13). Establishing 

New Organizations: helping to establish, organize, and build the capacity of fair housing enforcement organizations in targeted areas 

that were not served or were underserved. First choice: Arkansas, Idaho, Mississippi, New Mexico, North Dakota, and Wyoming; second choice: Georgia, Iowa, Kansas, Louisiana, Missouri, Nebraska, Oklahoma, South Carolina, Texas, Utah, and Washington. 

FY 1994 Same as 1993, except targeted areas: First choice: New Hampshire, New Mexico, Puerto Rico, and Wyoming; second choice: 

Alabama, Louisiana, Mississippi, Nebraska, Oregon, and Utah. 

FY 1995 Same as 1994, except targeted areas: First choice: New Hampshire, Puerto Rico, and Wyoming; second choice: Alabama, Delaware, 

Oregon, and Utah; and nontargeted areas with proof that the area was underserved. 

FY 1996 Same as 1995, without Establishing New Organizations: includes technical assistance and mentoring services for new organizations; 

training for staff of new organizations; up to 20 percent for EOI; and other costs related to operations of new organizations. 

FY 1997 Same as 1996, with emphasis on disability groups and team partnerships with disability groups; only 5 percent available for EOI. 

Separate NOFA to create a new FHO in East Texas. 

FY 1998	� Establishing New Organizations Component: helping to establish, organize, and build the capacity of fair housing enforcement organizations in targeted areas that were not served or were underserved. Continued Development Component: emphasis on disability groups 

and partnerships between disability groups and FHOs. 

FY 1999 Same as 1998. 

FY 2000 Same as 1999, with no focus on disability groups. 

FY 2001 Same as 2000, except no Continued Development Component. 

FY 2002 Same as 2001. 

FY 2003 Same as 2002. 

FY 2004 Same as 2003, except that only sponsoring organizations were eligible for an Establishing New Organizations Component. 

FY 2005 Same as 2004. 

FY 2006 No funding provided. 

EOI = Education and Outreach Initiative. FHO = Fair Housing Organization. FHOI = Fair Housing Organization Initiative. NOFA = Notice of Funding Availability. 

PEI = Private Enforcement Initiative.
�

Source: Fair Housing Initiative Program NOFAs, FY 1993–FY 2006
�

In FY 1996, FHOI funds were made available only under the Continued Development of Existing Organizations component. 

According to key informants, fair housing enforcement participants believed that there was no need for HUD to support the 

development of new organizations; rather, there was a greater need for funding to expand the capacity of existing organizations, including those established with previous FHOI grants. 

This policy approach changed in FY 1998 when FHOI included two components: Establishing New Organizations and 

Continued Development. QFHOs could apply for funds available under the Establishing New Organizations Component; 

QFHOs, FHOs, and nonprofit groups that organized to build their capacity to provide fair housing enforcement could apply 

for grants under the Continued Development Component. The Continued Development Component was not included in 

any NOFAs after FY 2000. In FY 2004, only sponsoring organizations could apply for funds available under the Establishing 

New Organizations Component. No funds were made available for this component in the FY 2006 NOFA. 

Administrative Enforcement Initiative 

AEI made funds available to state and local fair housing agencies administering fair housing laws certified by the HUD 

Secretary as providing rights and remedies that were substantially equivalent to those provided in the Fair Housing Act. Although this funding category was included in the 1989 legislation, and in the subsequent 1992 legislation that made FHIP a 

permanent program, funding was made available only between FY 1992 and FY 1995. The reason for this change, according to a key informant, is that AEI was created to enable state and local agencies to design special enforcement projects 

that were not tied to regular complaint processing. A key informant made this statement about redirecting AEI funding: “The 

FHAP program basically doubled between 1995 and 1996, so there was enough money in FHAP to cover administrative 

enforcement needs of state and local agencies.” 

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Study of the Fair Housing Initiatives Program
	

Another key informant commented on AEI funding: 

So the Fair Housing Assistance Program was being funded so much by Congress, so that in the FHAP 

program that I was working on we didn’t know how to spend the money. There was so much money for 

the FHAP program we didn’t know how to spend it all. Now the FHAP program, which I won’t go into a lot 

of detail with, well, it has different categories of funding, and, ah, we created new categories of funding ... 

administrative overhead money, and in late ‘90 and late ‘95 and ‘96 we created and developed a whole new 

category of funding called special enforcement initiative. Where we didn’t spend all the money Congress 

was giving us for the FHAP program, well, we put what was left over in the special enforcement initiatives and gave it out to groups that were doing a particularly good job to do special enforcement projects. 

Well that was what administrative enforcement had been in the past; it was grants to FHAP agencies to 

do special projects related to enforcement. So, we recreated the administrative enforcement concept but 

directly out of the FHAP money. And the HUD regulations that were published in, I think, ‘95 had the special 

enforcement initiative in the regulations, and we started funding it immediately. 

Therefore, AEI was not renewed as an initiative in FHIP because it would be covered financially under FHAP. 

Grantees could use AEI funds for the following purposes: (1) providing technical assistance to state and local agencies 

administering housing and community development programs concerning applicable fair housing laws and regulations; 

(2) implementing fair housing testing programs; and (3) conducting investigations of systemic discrimination for further 

enforcement processing by state or local agencies, or for referral to HUD and DOJ. The FY 1993 NOFA specified particular 

types of fair lending issues as eligible activities (Table 16). 

The following section presents an analysis of FHIP’s funding history between FY 1989 and FY 2006. It begins with a discussion of FHIP funding patterns by type of initiative, followed by an analysis of the types of organizations that received FHIP 

awards and their location by HUD region. 

NOFA Eligible Activities 

Table 16. Summary of AEI Eligible Activities, FY 1992–FY 1995 

FY 1992	� Providing technical assistance to state and local agencies administering housing and community development programs concerning 

applicable fair housing laws and regulations; implementing fair housing testing programs; and conducting investigations of systemic 

discrimination for further enforcement processing by state or local agencies, or for referral to HUD and DOJ. 

FY 1993	� Focusing on areas of mortgage lending, insurance redlining, and appraisal practices; discovering and providing remedies for discrimination in the public and private real estate markets and real estate-related transactions, such as making or purchasing loans, the provision 

of other financial assistance for sales and rental housing, insurance redlining and appraisal practices, and housing advertising; implementing fair housing testing, and other related enforcement activity programs; conducting investigations of systemic discrimination for 

further enforcement processing by state or local agencies, or for referral to HUD and DOJ; and developing new procedures to increase 

the efficiency of operations. 

FY 1994 Same as 1993. 

FY 1995 Same as 1994. 

AEI = Administrative Enforcement Initiative. DOJ = U.S. Department of Justice. HUD = U.S. Department of Housing and Urban Development. 

Source: Fair Housing Initiative Program Notices of Funding Availability, FY 1992–FY 1995 

Analysis of FHIP Grantees by Initiative 

Among the funding categories were 580 EOI awards totaling $73 million and 610 PEI awards totaling $142 million. The 114 

FHOI awards granted from FY 1993 to FY 2006 totaled $42 million. Between FY 1992 and FY 1995, 34 AEI grants totaled 

$7.5 million. In addition to these four initiatives, 10 FHIP awards were granted under a Secretary-Initiated Projects (SIP) for 

a total of $19.2 million. These awards were applied largely toward a nationwide housing discrimination testing project that 

was conducted between FY 2000 and FY 2002 and for followup testing that was conducted between FY 2003 and FY 2005 

(Table 17). 

18
 
Study of the Fair Housing Initiatives Program
	

SIP represents a relatively unique set of awards that were made to support one-time testing activities. Therefore, in the 

remaining analyses such awards will be excluded. Removing SIP awards increased each initiative’s share of FHIP funding. 

PEI awards accounted for 46 percent of the total number of awards made between FY 1989 and FY 2006, followed by EOI 

awards at 43 percent. AEI and FHOI awards have made up a combined total of 12 percent of all FHIP awards made since 

the program started (Table 18). 

The mean FHIP award made between FY 1989 and FY 2006 was $197,000. FHOI awards, on average, were the largest, 

at $367,000, although such awards accounted for a small share of overall awards. The most common award, PEI grants, 

averaged $233,000, which was almost twice the amount of EOI awards. PEI awards, on average, have been larger than 

EOI awards in nearly every fiscal year since FY 1989 (Figure 1). 

PEI awards were slightly greater than EOI awards made between FY 1991 and FY 1994, with the mean award for both 

initiatives at approximately $200,000. This pattern changed in FY 1995, when the mean PEI award increased to nearly 

$600,000, but declined to $450,000 in FY 1996. The reason for this increase is that HUD made relatively few PEI awards 

between FY 1995 and FY 1996. During these 2 years, HUD awarded a total of 25 PEI grants—an average of 12.5 awards 

per year—compared with an average of 35 PEI awards in the other years. It is unclear what accounted for the relatively 

small volume of PEI awards made in FY 1995 and FY 1996. Some key informants indicated that it could have resulted from 

organizations requiring larger PEI grants to continue testing related to mortgage lending discrimination cases, which were 

being litigated during this period. Mean PEI grants have declined from their FY 1995 and FY 1996 levels to about $300,000 

per year between FY 1997 and FY 2000, and to about $200,000 since FY 2001. 

Initiative 

Total Number of 

Awards 

Percent of 

Awards 

Total Dollar 

Amount of Awards 

Percent of 

Dollar Awards 

Mean Award 

($) 

Table 17. Summary of FHIP Awards by Initiative, FY 1989–FY 2006 

AEI 34 3 7,462,109 3 219,474 

EOI 580 43 73,053,081 26 125,954 

FHOI 114 8 41,763,732 15 366,349 

PEI 610 45 141,860,388 50 232,558 

SIP 10 1 19,263,026 7 1,926,303 

Total 1,348 100 283,402,336 100 210,239 

AEI = Administrative Enforcement Initiative. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations Initiative. 

PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects.
�

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database
�

Initiative 

Total Number of 

Awards 

Percent of 

Awards 

Total Dollar 

Amount of Awards 

Percent of 

Dollar Awards Mean Award 

Table 18. Summary of Non-SIP FHIP Awards by Initiative, FY 1989–FY 2006 

AEI 34 3 7,462,109 3 219,474 

EOI 580 43 73,053,081 28 125,954 

FHOI 114 9 41,763,732 16 366,349 

PEI 610 46 141,860,388 54 232,558 

Total 1,338 100 264,139,310 100 197,414 

AEI = Administrative Enforcement Initiative. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations Initiative. 

PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects.
�

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database
�

19
 
Study of the Fair Housing Initiatives Program
	

Figure 1. Comparison of Mean Non-SIP PEI and EOI Awards, FY 1989–FY 2006 Mean Award

$700,000

$600,000

$500,000

$400,000

$300,000

$200,000

$100,000

$0

EOI  PEI

1989  1990  1991  1992  1993  1994  1995  1996  1997  1998  1999  2000  2001  2002  2003  2004  2005  2006

Fiscal Year

EOI = Education and Outreach Initiative. PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects. 

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database 

The mean EOI grant, with the exception of FY 1998 through FY 2000, has not changed as much as the mean PEI grant. 

The amount of the typical mean EOI grant has been around $100,000, with the exception of two periods: FY 1994 through 

FY 1995 and FY 1998 through FY 2000. Key informants did not indicate any reasons for the mean EOI award increases 

during these periods. Note that some education and outreach activities are funded from PEI grants. HUD required that 

5 percent of PEI grant funds be used to support education and outreach activities through 2003; the current requirement is 

that 10 percent of PEI funds be used to support education and outreach activities. 

HUD awarded between 20 and 30 PEI awards between FY 1989 and FY 1999; this volume increased starting in FY 2000 

and increased in every year to 60 awards in FY 2005, declining slightly in FY 2006 (Figure 2). The pattern is similar for the 

number of EOI awards. The number of such awards increased from about 20 per year between FY 1989 and FY 1998 to a 

high of nearly 70 EOI awards in FY 2003 and to the current level of about 45 EOI awards per year. 

20
 
Study of the Fair Housing Initiatives Program
	

Figure 2. Comparison of the Number of Non-SIP PEI and EOI Awards, FY 1989–FY 2006 

80

70

60

50

40

30

20

10

0

Fiscal Year

EOI  PEI

1989  1990  1991  1992  1993  1994  1995  1996  1997  1998  1999  2000  2001  2002  2003  2004  2005  2006

Number of Awards

EOI = Education and Outreach Initiative. PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects. 

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database 

Analysis of FHIP Funding by Organization Type 

As discussed previously, the research team identified the types of organizations that received 1,194 out of 1,348 FHIP grants 

(including SIP) made between FY 1989 and FY 2006. These awards totaled $265 million, or 94 percent of the $283 million 

of FHIP awards made since FY 1989. Excluding SIP awards (4 SIP awards went to nonprofit organizations and 6 went to 

for-profit organizations), organization type was identified for 1,184 (88 percent) of the 1,338 non-SIP awards; these awards 

accounted for 93 percent of the $264 million of non-SIP FHIP awards that HUD made between FY 1989 and FY 2006. 

Nonprofit organizations received the largest share of non-SIP FHIP awards made between FY 1989 and FY 2006. Such 

organizations received 70 percent of the awards made during this period and 75 percent of the dollars granted (Figure 3). 

Legal aid services had the next largest share of FHIP awards. These organizations received about 15 percent of the number 

and dollar amount of grants awarded between FY 1989 and FY 2006. 

A key informant explained how legal aid services started receiving FHIP awards: 

I think it was under [former HUD Secretary Andrew] Cuomo. The education money was primarily going to 

fair housing groups, and you could see significant change in those probably. Now, there were probably 

about 70 fair housing centers out there, but then Cuomo decided he wanted to spread the money out 

there, and he made a serious effort to bring in legal services, and for the enforcement side, and to open 

up the education money to anybody, to any organization. 

21
 
 

Study of the Fair Housing Initiatives Program
	

Figure 3. Share of Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006 Share of Awards

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

70%

15%

75%

14%

12% 7%

3% 3%

HBCU

State or local

government

Legal aid

Nonprofit

organization

Percent of Awards Percent of Dollar Awards

FHIP = Fair Housing Initiative Program. HBCU = Historically Black Colleges and Universities. SIP = Secretary Initiated Projects.
�

Note: This chart does not show two awards made to for-profit organizations for $979,000. Including these totals makes the figure more difficult to read.
�

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database
�

State and local governments received 12 percent of FHIP grants, but these awards were for smaller amounts than those 

that other types of organizations received, and they account for only 7 percent of FHIP funds awarded. Historically Black 

Colleges and Universities received 3 percent of FHIP grants and 3 percent of dollars awarded under the program. 

Since FY 1989, nonprofit organizations have received the largest share of awards every year. The share that such organizations 

received ranged from a high of 90 percent in FY 1989 to a low of 52 percent in FY 1995, when state and local governments 

received 32 percent of FHIP awards (Figure 4). Legal aid services increased their share of awards from about 5 percent between FY 1990 and FY 1993 to 10 percent between FY 1994 and FY 1998 to the current share of about 20 percent. 

Nonprofit organizations received the largest mean FHIP award between FY 1989 and FY 2006, followed by HBCU, legal aid 

services, and state and local governments, respectively (Figure 5). Part of the explanation for the larger mean awards made to 

nonprofit organizations was that they received a larger share of PEI awards, which were, on average, greater than EOI awards. 

Nonprofit organizations received 70 percent of all FHIP awards between FY 1989 and FY 2006. These organizations 

received 82 percent of PEI grants, measured in terms of the number of awards made and total dollars awarded (Table 19). 

Conversely, EOI grants, which were, on average, about one-half of the mean PEI grant, were disproportionately awarded 

to state and local governments. Although such organizations received 12 percent of all awards made, representing only 

7 percent of the dollar awards, they received 23 percent of the total EOI awards made between FY 1989 and FY 2006 

and 16 percent of the EOI dollar awards made during the same period (Table 19). 

22
 
Study of the Fair Housing Initiatives Program
	

Figure 4. Share of Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006 Share of Awards (percent)

100

90

80

70

60

50

40

30

20

10

0

Nonprofit organization

Legal aid

State or local

government

HBCU

1989  1990  1991  1992  1993  1994  1995  1996  1997  1998  1999  2000  2001  2002  2003  2004  2005

Fiscal Year

FHIP = Fair Housing Initiative Program. HBCU = Historically Black Colleges and Universities. SIP = Secretary Initiated Projects.
�

Note: This chart does not show two awards made to for-profit organizations for $979,000. Including these totals makes the figure more difficult to read.
�

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database
�

Figure 5. Mean Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006 

$250,000 

$223,365 

$195,066 

$125,190 

$212,020 

Nonprofit organization  Legal aid        State or local government  HBCU 

Mean Award Bars

$200,000 

$150,000 

$100,000 

$50,000 

$0 

FHIP = Fair Housing Initiative Program. HBCU = Historically Black Colleges and Universities. SIP = Secretary Initiated Projects.
�

Note: This chart does not show two awards made to for-profit organizations for $979,000. Including these totals makes the figure more difficult to read.
�

Source: Authors’ calculations from U.S. Department of Housing and Urban Development administrative database
�

23
Study of the Fair Housing Initiatives Program
	

Type of Organization 

Share of Number of Awards 

Type of Award 

AEI (%) PEI (%) EOI (%) FHOI (%) Total (%) 

Table 19. Summary of the Share of Non-SIP FHIP Awards by Organization Type, FY 1989–FY 2006 

Nonprofit 0 82 58 75 70 

For profit 0 0 0 0 0 

Legal aid 0 16 13 23 15 

State or local government 100 1 23 1 12 

HBCU 0 1 5 2 3 

Total 100 100 100 100 100 

Type of Organization 

Share of Dollars Awarded 

Type of Award 

AEI (%) PEI (%) EOI (%) FHOI (%) Total (%) 

Nonprofit 0 82 63 82 75 

For profit 0 0 2 0 0 

Legal aid 0 16 11 16 14 

State or local government 100 1 16 0 7 

HBCU 0 1 8 1 3 

Total 100 100 100 100 100 

AEI = Administrative Enforcement Initiative. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHO = Fair Housing Organization. FHOI = 

Fair Housing Organizations Initiative. HBCU = Historically Black Colleges and Universities. PEI = Private Enforcement Initiative. SIP = Secretary Initiated Projects. 

Source: Authors’ calculations from the U.S. Department of Housing and Urban Development administrative database 

Analysis of FHIP Funding by HUD Region and Location 

The United States and its territories are divided into 10 HUD regions (Table 20). FHIP grants were not concentrated in any 

particular HUD region. No one region has received greater than 20 percent of the number of FHIP awards made since FY 

1989, or 23 percent of the dollar amount of FHIP awards made. Moreover, the share of grants made to HUD regions has 

changed over time, perhaps due to an increase in the number of fair housing groups in areas of the country that, before 

FHIP, did not have a large number of fair housing groups. 

Organizations in the Midwest Region, which includes Chicago—historically home to many fair housing groups—received 

the greatest number of FHIP awards. Since 1989, Midwest Region organizations received 20 percent of FHIP awards (Figure 6). This share has been relatively constant over the years. With the exception of FY 1989, Midwest-based organizations 

received 31 percent of FHIP awards and in FY 1996 received 30 percent of awards. Midwest-based organizations received 

between 18 and 22 percent of awards in a given fiscal year. 

Fair housing groups in the Southeast/Caribbean Region have received the second largest number of awards, with 15 percent 

of the awards since 1989 (Figure 6). This share, however, has grown since FY 1989, when fair housing groups in this region 

received only 5 percent of all awards. Between FY 1989 and FY 1993, Southeast/Caribbean-based organizations received 

8 percent of all FHIP awards. This share of FHIP awards grew to 13 percent in FY 1994 and to 18 percent between FY 2004 

and FY 2006. This increase could be the result of increased growth among fair housing groups located in this region. 

Compared with the Midwest Region and the Southeast/Caribbean Region, the number of awards made to organizations in 

the Mid-Atlantic Region has declined from 18 percent of all awards made between FY 1989 and FY 1991 to 12 percent between FY 2004 and FY 2006, reflecting that fewer awards went to organizations based in Washington, D.C. These organizations received 11 percent of all awards between FY 1989 and FY 1991 but only 3 percent between FY 2004 and FY 2006. 

There were relatively small differences in the overall sizes of FHIP awards made across the HUD regions. The mean FHIP 

grant, excluding SIP awards, made between FY 1989 and FY 2006 was $197,000; the mean grant by region for the period 

ranged from a low of $155,822 in the Great Plains Region to a high of $259,978 in the Mid-Atlantic Region (Figure 7). The 

reason for the relatively high mean award in the Mid-Atlantic Region is that the region includes Washington, D.C., where 

national organizations received relatively large grants. 

24
 
Study of the Fair Housing Initiatives Program
	

Region I 

New England 

Region II 

New York/New Jersey 

Region III 

Mid-Atlantic 

Region IV 

Southeast/Caribbean 

Region V 

Midwest 

Table 20. States and Territories Within 10 HUD Regions 

Connecticut 

Maine 

Massachusetts 

New Hampshire 

Rhode Island 

Vermont 

Region VI 

Southwest 

Arkansas 

Louisiana 

New Mexico 

Oklahoma 

Texas 

New York 

New Jersey 

Region VII 

Great Plains 

Iowa 

Kansas 

Missouri 

Nebraska 

Delaware 

District of Columbia 

Maryland 

Pennsylvania 

Virginia 

West Virginia 

Region VIII 

Rocky Mountain 

Colorado 

Montana 

North Dakota 

South Dakota 

Utah 

Wyoming 

Alabama 

Florida 

Georgia 

Kentucky 

Mississippi 

North Carolina 

Puerto Rico 

South Carolina 

Tennessee 

U.S. Virgin Islands 

Region IX
�

Pacific
�

Arizona 

California 

Federated 

States 

of Micronesia 

Hawaii 

Nevada 

Illinois 

Indiana 

Michigan 

Minnesota 

Ohio 

Wisconsin 

Region X 

Northwest 

Alaska 

Idaho 

Oregon 

Washington 

HUD = U.S. Department of Housing and Urban Development.
�

Notes: The Pacific Region includes Hawaii. The Northwest Region includes Alaska.
�

Source: HUD administrative data
�

Figure 6. Share of Non-SIP FHIP Awards by HUD Region, FY 1989–FY 2006 

Northwest 4% 

5% 

Pacific 12% 

13% 

Rocky 4% 

Mountains 4% Share of Dollars Awarded

Great Plains 4% 

4% 

Share of Awards

Southwest 7% 

8% 

Midwest 20% 

20% 

Southeast/ 15% 

Carribean 15% 

Mid­Atlantic 13% 

17% 

New York/ 10% 

New Jersey 11% 

New England 7% 

7% 

0%  5%  10%  15%  20%  25% 

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development. SIP = Secretary Initiated Projects.
�

Notes: The Northwest Region includes Alaska. The Pacific Region includes Hawaii.
�

Source: Authors’ calculations from the HUD administrative database
�

HUD awarded FHIP grants between FY 1989 and FY 2006 to organizations located in 215 cities in nearly every state (Figure 8). About 58 million people, who represent 20 percent of the total U.S. population as of 2000, lived in these 215 cities. 

As discussed later in this report, FHIP grantee organizations typically serve relatively large metropolitan areas (Table 23), and 

concentrations of FHIP awards were made to FHIP organizations located in the areas of New York City, Chicago, Los Angeles, 

and San Francisco. These four metropolitan areas have received relatively large total dollar awards since FY 1989 (Figure 9). 

25
 
Study of the Fair Housing Initiatives Program 

Region VII

Great Plains 

Figure 7. Mean Non-SIP FHIP Awards by HUD Region, FY 1989–FY 2006 

Northwest 

Pacific 

Rocky 

Mountains 

Great Plains 

Southwest 

Midwest 

Southeast/ 

Carribean 

Mid­Atlantic 

New York/ 

New Jersey 

New England 

$179,669 

$191,421 

$186,412 

$155,822 

$160,215 

$196,394 

$198,954 

$259,978 

$181,297 

$205,293 

$0  $50,000  $100,000  $150,000  $200,000  $250,000  $300,000 

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development. SIP = Secretary Initiated Projects.
�

Notes: The Northwest Region includes Alaska. The Pacific Region includes Hawaii.
�

Source: Authors’ calculations from the HUD administrative database
�

Figure 8. Locations of Organizations Receiving FHIP Awards Scaled by Total Dollars Awarded, FY 1989–FY 2006 

Region V 

Midwest Region II 

Region VIII New York/ 

Rocky Mountain New Jersey Region X 

Northwest Region I 

New England 

Region III Region IX Mid-Atlantic Pacific 

Region VI Region IV

Southwest Southeast/

Legend Caribbean 

Dollars Awarded by Place 

Less than $1M
�

$1M–$2.5M
�

$2.5M–$5.0M
�

$5M–$10M
�

More than $10M
�

HUD Regions
�

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development.
�

Note: This map does not include Secretary Initiated Projects awards or awards made in Alaska, Hawaii, or Puerto Rico.
�

Source: Authors’ analysis of the HUD administrative database
�

26
Study of the Fair Housing Initiatives Program 

Region VII

Great Plains 

Figure 9. Location of FHIP Grantees That Received Awards Scaled by Total Number of Awards, FY 1989–FY 2006 

Region V 

Midwest 

Region II 

Region VIII New York/
� Region X
� New Jersey Northwest Rocky Mountain Region I 

New England 

Region III Region IX Mid-Atlantic Pacific 

Region VI
�

Southwest
� Region IV 

Southeast/ 

Legend Caribbean

Grants Awarded by Place 

1–4
�

5–9
�

10–15
�

16–26
�

27–116
�

HUD Regions
�

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development.
�

Note: This map does not include Secretary Initiated Projects awards or awards made in Alaska, Hawaii, or Puerto Rico.
�

Source: Authors’ analysis of the HUD administrative database
�

Award Summary 

The mean FHIP award made between FY 1989 and FY 2006 was about $200,000. About an equal number of PEI and EOI 

awards were made during the same period. These awards accounted for 68 percent of non-SIP awards made and about 

75 percent of all non-SIP dollars awarded. PEI grants averaged $233,000 compared with $126,000 for EOI awards. Nonprofit organizations received the overwhelming share––about three-fourths of non-SIP FHIP grants and total dollars awarded between FY 1989 and FY 2006. FHIP grants were not disproportionately awarded in any particular region of the country, 

on the contrary, organizations that received a FHIP award were located in nearly every HUD region and in every state. 

27
 
28

This section presents a descriptive analysis of the types of organizations that received Fair Housing Initiatives Program 

grants between FY 2003 and FY 2005. The data used for this analysis were derived mainly from the web-based survey 

described in section 1. Unfortunately, not every respondent completed all of the questions, and the analysis of a given webbased survey question was restricted to organizations that provided responses to that question. As a result, the tables that 

report data from the web-based survey show the number of responses used in the calculations.

The descriptive analysis portion of this section begins with a discussion of the role that fair housing plays in the mission 

statements of FHIP grant recipients. As detailed later in this section, the mission of many FHIP grant recipients is to promote fair housing, typically as part of the larger objective to reduce discrimination in general, within the organization’s coverage area. This descriptive analysis continues with a discussion of the number of employees and budgets of the FHIP grant 

recipients, and the administrative structure (that is, the type of organization and, for nonprofits, the size and makeup of their 

boards of directors). This section is followed by a description of FHIP grant recipient employees, including their length of 

tenure, educational attainment, and level of experience. This analysis concludes with a description of the sources of funding 

that FHIP grantees used.

Mission Statements of FHIP Recipient Organizations

Survey respondent organizations typically promoted fair housing by reducing discrimination in their coverage areas. Some 

organizations focused their activities on a particular target group, such as people who are homeless, immigrants, or living 

with HIV/AIDS. These organizations’ missions often combined outreach with litigation support (see the full mission statements that respondents provided in Appendix D). Fair housing was a prominent part of the organizational missions for most 

survey respondents. Only 4 percent of these organizations indicated that fair housing played a secondary role in their activities. Conversely, fair housing had an exclusive role in the missions for 32 percent of respondents and a primary role for an 

additional 26 percent of respondents (Table 21).

Organizations that indicated that fair housing had either an exclusive or a primary role (as opposed to a lesser role) in their 

missions were typically regional or local fair housing centers. Of respondents, 38 percent indicated that fair housing had a 

significant role among several in their mission statements. The primary role was defined as the organization’s first goal: to 

work on fair housing. Organizations that considered fair housing as important but not a priority over other issues—a significant role among several—were usually legal aid services and state or local governments.

Each respondent’s organizational mission type, based on the mission statement provided in the survey, was classified as 

affordable housing, civil rights, disability rights, HBCU, or a homeless coalition. Civil rights organizations comprised 55 

percent of respondents, but they accounted for 86 percent of organizations that indicated fair housing had an exclusive role 

and 81 percent of organizations indicating fair housing had a primary role within their missions (Table 22).

Many civil rights groups indicated that their mission was to work toward eliminating housing discrimination. Conversely, 

legal aid services, which accounted for 14 percent of respondents, comprised 36 percent of respondents indicating that 

fair housing played a significant role among several in their activities (Table 22). The mission of many legal aid service 

providers is to provide low-income people with needed legal assistance, only some of which relates to housing discrimination complaints.

Descriptive Analysis of FY 2003–FY 2005 3 FHIP Grantees

Study of the Fair Housing Initiatives Program
Study of the Fair Housing Initiatives Program
	

Frequency of Role Type Percent (%) 

Table 21. The Role of Fair Housing in Survey Respondents’ Organizations 

Exclusive role 22 32.4 

Primary role 17 25.0 

Secondary role 3 4.4 

Significant role among several 26 38.2 

Total 68 100.0 

Source: Survey of Fair Housing Initiative Program grantees 

The Role of Fair Housing in Survey Respondent’s Missions 

Type of Organizational Mission 

Significant Role 

Among Several (N) 

Secondary 

Role (N) 

Primary 

Role (N) 

Exclusive 

Role (N) Total (N) 

Table 22. The Role of Fair Housing in Survey Respondents’ Missions by Organization Type 

Affordable housing 8 0 3 3 14 

Civil rights 3 1 13 19 36 

Legal aid 9 0 0 0 9 

Disability rights 4 0 0 0 4 

HBCU 0 1 0 0 1 

Homeless coalition 1 0 0 0 1 

Total 25 2 16 22 65 

Percent of Respondents 

Type of Organizational Mission 

Significant Role 

Among Several (%) 

Secondary 

Role (%) 

Primary 

Role (%) 

Exclusive 

Role (%) Total (%) 

Affordable housing 32 0 19 14 22 

Civil rights 12 50 81 86 55 

Legal aid 36 0 0 0 14 

Disability rights 16 0 0 0 6 

HBCU 0 50 0 0 2 

Homeless coalition 4 0 0 0 2 

Total 100 100 100 100 100 

HBCU = Historically Black Colleges and Universities. 

Source: Survey of Fair Housing Initiative Program grantees 

Target Area for Respondents’ Fair Housing Activities 

As fair housing issues relate to a particular housing market context, knowledge of local markets is important to any group 

working in a fair housing role. Consequently, FHIP grantees typically targeted their fair housing activities within a particular 

geographic area. Most frequently, FHIP grantee organizations’ target areas include multiple cities or counties, and some 

organizations target their activities statewide (Table 23). 

FHIP grantees targeted their activities to areas with relatively large populations. This approach may be due to larger population areas having a more supportive infrastructure, including local political groups and foundations, among other groups 

conducting fair housing activities. The mean population of the areas targeted by the 55 FHIP grantees that provided this 

information was just more than 2 million. The median population of these groups’ targeted areas was 1.2 million (Table 

23). The population in the relatively large target areas for survey respondents likely consisted of a diverse mix of racial and 

ethnic groups. A slight majority of FHIP grantees (52 percent) targeted their activities toward a specific group of protected 

class members. 

29
 
Study of the Fair Housing Initiatives Program
	

Number of Respondents Percent of Respondents 

Table 23. Location and Population Size of Communities Targeted by Survey Respondents for Fair Housing Activities 

Target Area Location 

A single city 4 6 

A single county 8 12 

A single metropolitan area 12 18 

Multiple cities and counties outside of a metropolitan area 33 49 

(includes statewide) 

Multiple states 3 4 

Other 7 10 

Targeted neighborhood(s) 1 1 

Total 68 100 

Target Area Population Size 

Mean 2,026,283 

Median 1,200,000 

N 55 

Source: Survey of Fair Housing Initiative Program grantees 

FHIP Grant Recipient Organizations’ Age and Size 

FHIP is 21 years old, yet the mean survey respondents’ organizations existed before the establishment of the program. 

Among the 68 survey respondents, the newest organization was 5 years old in 2007, and organizations were, on average, 

30 years old. The oldest organization among the survey respondents was formed in 1891. 

The total organizational budget for survey respondents ranged dramatically. Although the mean organizational budget 

in 2006 for 53 respondents was $2,680,721, 13 percent of survey respondents had a total organizational budget below $250,000. Another 20 survey respondents (38 percent of respondents) had a total organizational budget between 

$250,000 and $500,000. In contrast, 19 percent of respondents had a total organizational budget greater than $500,000, 

and 30 percent of respondents had a total organizational budget greater than $1.5 million (Table 24). 

A similar pattern existed for the number of full-time staff that respondents employed in FY 2006. The mean number of fulltime employees for 60 respondents was 28. Because that reported number of staff of one organization is so much larger 

than any other respondent, it is removed from the analysis. Of the respondents, however, 40 percent employed fewer than 

5 full-time staff members, and 77 percent had fewer than 30 full-time staff members (Table 25). 

Most respondents employed fewer than 25 full- and part-time staff members to conduct fair housing activities. The average 

number of employees conducting fair housing activities among the 57 respondents was 21. Only 5 percent of the respondents employed more than 50 people for fair housing activities; 21 percent employed fewer than 9 full- and part-time staff 

members for fair housing activities (Table 26). 

Total Budget Number of Respondents Percent of Respondents Mean Total Budget ($) 

Table 24. Summary of Survey Respondents’ Total Budgets, FY 2006 

< $250,000 7 13 148,164 

$250,000–$500,000 20 38 351,176 

$500,001–$1,500,000 10 19 850,338 

> $1,500,000 16 30 7,844,634 

Total 53 100 2,680,721 

Source: Survey of Fair Housing Initiative Program grantees 

30
 
Study of the Fair Housing Initiatives Program
	

Number of 

Full-Time Employees 

Number of 

Respondents 

Percent of 

Respondents 

Mean Number 

of Employees 

Table 25. Distribution of Survey Respondents’ Full-Time Employees, FY 2006 

< 5 24 40 4 

5–30 22 37 10 

31–100 12 20 70 

101–500 2 3 272 

Total 60 100 28 

Note: One respondent, a city agency, reported a total staff of 2,300. That observation was removed because it is such an outlier. 

Source: Survey of Fair Housing Initiative Program grantees 

Number of 

Fair Housing Staff 

Number of 

Respondents 

Percent of 

Respondents 

Mean Fair Housing 

Full-Time and Part-Time Staff 

< 9 12 21 6 

Table 26. Total Fair Housing Staff for Survey Respondents, FY 2007 

10–24 28 49 17 

25–50 14 25 31 

> 50 3 5 70 

Total 57 100 21 

Source: Survey of Fair Housing Initiative Program grantees 

Size of FHIP Grantees’ Fair Housing Component 

The mean fair housing budget in FY 2006 for 46 respondents was $306,000. For 43 percent of these respondents, fair 

housing activities comprised 100 percent of their total organizational budgets. The mean fair housing budget for these organizations was relatively large at $409,000. In contrast, fair housing funding was less than 25 percent of the total organizational budget for 39 percent of respondents (Table 27). The mean fair housing budget for these 18 organizations was only 

$218,000, about one-half of the fair housing budgets for organizations in which fair housing funds represented 100 percent 

of their budgets. 

Fair Housing’s Share 

Number of 

Respondents 

Percent of 

Respondents (%) 

Mean Fair Housing 

Budget ($) 

Table 27. Fair Housing Activity Shares of Total Budget for Survey Respondents, FY 2006 

< 25 18 39 217,446 

25–99 8 17 245,036 

100 20 43 409,445 

Total 46 100 305,722 

Source: Survey of Fair Housing Initiative Program grantees 

31
 
Study of the Fair Housing Initiatives Program
	

Governance Structure of FHIP Grantees and Employee Characteristics 

Of the respondents, 63 (93 percent) were representatives of nonprofit organizations; the remaining 5 respondents were 

representatives of either state or local governments (Table 28). 

The average size of the board of directors for these nonprofit agencies is 16 members. Members serve on boards of directors for a particular period of time. As of FY 2007, the length of time board members served was split evenly among less 

than 2 years, 2 to 5 years, 5 to 10 years, and greater than 10 years (Table 29). 

Survey respondents employed a diverse staff. This diversity may be a function of a HUD requirement that FHIP grantee organizations report the demographic makeup of their board members. On average, just more than one-half of respondents’ 

fair housing employees were non-Hispanic White in 2006, African Americans accounted for 25 percent of fair housing staff, 

and 18 percent were Hispanic. Asians and other racial groups comprised the remaining 5 percent of respondents’ fair 

housing employees. Women accounted for nearly three-fourths of respondents’ fair housing staff (Table 30). 

Although nearly all of the respondents were nonprofit or legal aid services, respondents’ employees have been with their 

organizations for a relatively long period of time. As of FY 2007, only 12 percent had been with the FHIP grantee for less 

than 1 year, and 70 percent of employees had been with 

the respondent for more than 3 years. This stability was 

also present for respondents’ organizational leadership. 

Since FY 2002, 62 percent of respondents have had only 

one executive director; 89 percent have had no more than 

two executive directors between FY 2002 and FY 2007. 

In addition to low staff turnover, FHIP grantee employees 

were well educated. On average, 74 percent of a FHIP 

grantee’s employees had at least a 4-year college degree. 

Of respondents’ employees, 27 percent had law degrees 

(Table 30), likely due to the importance of fair housing enforcement to FHIP grantees’ missions, which often involves 

some legal action or threat of legal action. 

Organizational 

Types 

Frequency of 

Role Type Percent 

Table 28. Survey Respondents’ Organizational Types 

State government 2 2.9 

Local government 3 4.4 

Nonprofit 63 92. 6 

Total 68 100.0 

Source: Survey of Fair Housing Initiative Program grantees 

Board Members’ Tenures Percent of Respondents 

Table 29. Characteristics of Survey Respondents’ Boards 

of Directors, FY 2007 

< 2 years 20 

2–5 years 32 

6–10 years 25 

> 10 years 23 

Total 100 

N 60 

Source: Survey of Fair Housing Initiative Program grantees 

Employee Characteristics 

Share of Reported 

Fair Housing Staff 

Table 30. Characteristics of Survey Respondents’ 

Employees, FY 2007 

Race: 

Non-Hispanic White 52% 

Black or African American 25% 

Hispanic 18% 

Other 5% 

Total 100% 

N 62 

Gender: 

Women 72% 

Men 28% 

Total 100% 

N 62 

Length of Employee Tenure: 

<1 year 12% 

1–2 years 19% 

3–5 years 24% 

6–10 years 23% 

> 10 years 22% 

Total 100% 

N 62 

Educational Attainment: 

Less than a high school degree 0% 

High school graduate 15% 

2-year college degree 9% 

4-year college degree 34% 

Master’s degree 13% 

Law degree 27% 

Doctor of Philosophy degree 0% 

Unknown 2% 

Total 100% 

N 62 

Source: Survey of Fair Housing Initiative Program grantees 

32
 
Study of the Fair Housing Initiatives Program
	

Sources of Budget for Enforcement Initiatives and Education and 

Outreach Activities 

One objective of this study is to document the contribution that FHIP awards make to grantee recipients’ budgets. Organizations that apply for FHIP awards receive points if they demonstrate that they have other sources of funding to support 

fair housing activities. Therefore, the expectation is that FHIP awards will not provide 100 percent of grantees’ total funding. 

Fewer funding sources appear to be available to support enforcement activities, however, so FHIP grants are likely to support a larger share of enforcement activities compared with education and outreach activities. In general, as detailed in the 

following section, the data are consistent with these expectations. 

Of the respondents, 51 provided detailed information about their sources of funding. FHIP grants provided a much larger 

share of the funding that respondents used for enforcement activities than for education and outreach activities. In 2006, 

the mean amount spent on fair housing activities by these organizations was $252,000, which was split between 70 

percent (a mean of $177,000) for enforcement activities and 30 percent (a mean of $75,000) for education and outreach 

activities (Table 31). 

Sources of Funding Enforcement Education and Outreach Total 

Table 31. Sources of Funding for Enforcement Initiatives and Education and Outreach Activities for Survey Respondents, 

FY 2006 

FHIP PEI grant 64% 4% 46.3% 

FHIP EOI grant 0% 30% 8.8% 

FHIP FHOI grant 3% 0% 2.5% 

CDBG from city, county, or 10% 32% 16.2% 

 state government 

Other funding from city, county, or 3% 12% 5.6% 

 state government 

HUD counseling funds 0% 6% 1.9% 

Proceeds from fair housing settlements 2.9% 0.4% 2.1% 

Realtors 0% 0% 0.1% 

Bankers/mortgage companies 1% 3% 1.3% 

Landlord associations 0% 1% 0.3% 

Foundations 6% 6% 5.8% 

Charitable donations 3% 3% 2.5% 

Other 8% 3% 6.5% 

Total 100% 100% 100% 

Mean $177,444 $74,492 $251,936 

N 51 51 51 

CDBG = Community Development Block Grant. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations 

Initiative. HUD = Department of Housing and Urban Development. PEI = Private Enforcement Initiative. 

Source: Survey of FHIP grantees 

FHIP Funding of Enforcement Activities 

FHIP Private Enforcement Initiative funds provided, on average, 64 percent of the overall enforcement funding among 

survey respondents, which was by far the largest source of funding for this activity. Community Development Block Grant 

(CDBG) funds from a FHIP grantee’s city, county, or state government provided 10 percent of total enforcement activity 

funds.15 When FHIP grantee organizations use CDBG funds made available by jurisdictions, they must comply with HUD’s 

requirement that these funds be used to affirmatively further fair housing objectives. The next largest source of funds for 

enforcement activities came from foundations, which provided an average of 6 percent of a FHIP grantee’s total enforcement funding in 2006. The remaining sources provided more than 3 percent of funds for survey respondents’ enforcement 

activities (Table 31). 

15 Note that CDBG funds are allocated by jurisdictions for a wide range of activities. The share of a grantee organizations’ fair housing activities 

funded by CDBG funds is not the same as the share of all CDBG funds that are allocated by a jurisdiction for fair housing-related activities. 

33
 
Study of the Fair Housing Initiatives Program
	

PEI grants constituted a larger share, on average, of organizations with relatively small budgets for combined enforcement 

initiatives and education and outreach activities. In 2006, PEI grants for respondents with combined enforcement funding 

and education and outreach budgets of less than $150,000 accounted for, on average, 93 percent of their total enforcement budgets. On the other hand, PEI grants for organizations with combined enforcement funding and education and outreach budgets greater than $400,000 comprised only 57 percent, on average, of their total enforcement budgets (Table 32). 

The organizations that had a total enforcement funding and education and outreach budgets of greater than $400,000 were 

able to raise a greater share of their funds from Fair Housing Organizations Initiative grants; 8 percent of the total enforcement budget for these groups came from FHOI grants, compared with 3 percent for all respondents. In addition to FHIP 

FHOI grants, organizations with relatively large enforcement budgets and education and outreach budgets raised a greater 

share of their enforcement funds from local city, county, or government sources (6 percent, compared with 3 percent for all 

survey respondents), perhaps due to their visibility within their coverage areas (Table 33). 

Total Enforcement 

and Education 

and Outreach Budget 

PEI Shares of 

Enforcement 

Budget 

(%) 

Number of 

Respondents 

Mean PEI 

Enforcement 

Funding 

($) 

Mean Total 

Enforcement 

Funding 

($) 

Table 32. PEI Grant Shares of Total Enforcement Budgets by Fair Housing Budget Size, FY 2006 

< $150,000 93 19 8,545 9,235 

$150,000–$250,000 73 8 112,343 154,226 

$250,001–$400,000 67 14 180,040 268,793 

> $400,000 57 10 222,449 387,729 

Total 64 51 113,846 177,444 

PEI = Private Enforcement Initiative. 

Source: Survey of Fair Housing Initiative Program grantees 

Sources of Funding for 

Enforcement Activities 

Total Enforcement and Education and 

Outreach Budget Greater Than $400,000 

All Survey 

Respondents 

Table 33. Comparison of Sources of Funding for Enforcement Activities for Large Groups and All Survey Respondents, 

FY 2006 

FHIP PEI 57% 64% 

FHIP EOI 0% 0% 

FHIP FHOI 8% 3% 

CDBG from city, county, 7% 10%

 or state government 

Other funding from city, 6% 3%

 county, or state government 

HUD counseling funds 0% 0% 

Proceeds from fair housing settlements 4% 3% 

Realtors 0% 0% 

Bankers and mortgage companies 0% 1% 

Landlord associations 0% 0% 

Foundations 4% 6% 

Charitable donations 2% 3% 

Total enforcement activities 100% 100% 

Mean $387,729 $177,444 

N 10 51 

CDBG = Community Development Block Grant. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations 

Initiative. HUD = U.S. Department of Housing and Urban Development. PEI = Private Enforcement Initiative. 

Source: Survey of Fair Housing Initiative Program grantees 

34
 
Study of the Fair Housing Initiatives Program
	

Investigations
�

PEI funding provides a substantial level of support for individual- and grantee organization-initiated investigation activities. 

Respondents reported that they used PEI funds for 70 percent of all individual investigations completed in FY 2006. Although 70 percent of all these investigations were funded with PEI grants, a great deal of variation existed among respondents. Of the survey respondents, 38 percent funded 100 percent of their individual investigations with PEI funds. Another 

13 percent funded between 75 percent and 99 percent of their individual investigations with PEI funds. Conversely, 28 

percent of respondents funded a relatively small share (less than 25 percent) of their investigations with PEI funds (Table 34). 

Survey respondents reported that FHIP PEI funds were used to finance 1,158 (65 percent) of the total 1,775 organizationinitiated investigations completed in FY 2006. When compared with individual investigations, a greater share of respondents 

funded all of their organization-initiated investigations with PEI grants. Most respondents (51 percent) funded 100 percent of 

their organization-initiated inquiries with PEI grants (Table 35), compared with 38 percent of respondents who funded 100 

percent of their inquiries from individuals with PEI grants. 

Percent of Investigations 

From Individual Complainants 

Funded With PEI Grants 

Number of 

Respondents 

Percent of Investigations 

From Individual Complainants 

Funded With PEI Grants 

Percent of 

Respondents 

Table 34. Distribution of Share of Individual-Initiated Investigations With PEI Grant Funding 

< 25 11 5 28 

25–49 6 39 15 

50–74 3 62 8 

75–99 5 95 13 

100 15 100 38 

Total 40 70 100 

PEI = Private Enforcement Initiative. 

Source: Survey of Fair Housing Initiative Program grantees 

Percent of Investigations 

Funded With PEI Grants 

Number of 

Respondents 

Percent of Organization-Initiated 

Complaints Resulting 

in Investigations 

Funded With PEI Grants 

Percent of 

Respondents 

Table 35. Distribution of Share of Grantee Organization-Initiated Inquiries Investigated With PEI Grant Funding 

Less than 25 8 6 23 

25–49 3 29 9 

50–74 2 62 6 

75–99 4 86 11 

100 18 100 51 

Total 35 65 100 

PEI = Private Enforcement Initiative.
�

Source: Survey of Fair Housing Initiative Program grantees
�

Testing 

PEI funds supported about two-thirds of the tests that FHIP grantees conducted. (Respondents were not asked to break 

out the share of tests from individuals versus organization-initiated inquiries that PEI grants funded.) The share of tests supported with PEI funds is nearly identical to the share of investigations of individual inquiries supported by PEI funds reported 

previously in Table 34. Note that the remaining testing activities were not funded by PEI grants and went unreported to 

HUD. This unreported testing activity may be substantial: although the average share of tests funded with PEI grants was 

64 percent, 30 percent of respondents funded fewer than one-half of their tests with PEI grants (Table 36). 

35
 
 

Study of the Fair Housing Initiatives Program
	

Percent of Fair Housing Tests 

Conducted With PEI Grants 

Number of 

Respondents 

Percent of 

Respondents 

Mean Percent of 

Fair Housing Tests 

Conducted With PEI Grants 

Table 36. Distribution of the Share of Tests Conducted by Survey Respondents Funded by PEI Grants, FY 2006 

< 25 6 16 13 

25–49 5 14 39 

50–74 6 16 64 

75–99 9 24 84 

100 11 30 100 

Total 37 100% 64% 

PEI = Private Enforcement Initiative.
�

Source: Survey of Fair Housing Initiative Program grantees
�

FHIP Support of Education and Outreach Activities 

FHIP grants provided a smaller share of total funding used to support education and outreach activities compared with 

enforcement activities. On average, EOI grants provided 30 percent of the funding that survey respondents used in FY 2006 

to support education and outreach activities. CDBG funds that local, county, or state governments provided were an 

even larger source of support than FHOI grants. Funding from CDBG provided 32 percent of all funds used for education 

and outreach activities. HUD counseling funds and foundations each provided 6 percent of funds used for education and 

outreach activities; PEI awards provided a small (4 percent) share of funding for education and outreach activities (Table 

31). The share of education and outreach activities that PEI grants funded reflects a HUD requirement, as of 2003, that 10 

percent of PEI grant funds are to be used for education and outreach activities. Before 2003, HUD required that 5 percent 

of PEI grant funds were to be used for education and outreach activities. 

FHIP grants accounted for a larger share of survey respondents’ enforcement funding because of activities, such as filing 

complaints and judicial actions. Some potential funding sources may be named as defendants in such actions, perhaps 

leaving them less likely to fund enforcement activities compared with relatively uncontroversial education and outreach efforts. One interviewee stated— 

We were conducting a training [session] for the real estate industry, and I was introduced as the ‘enemy’ 

to the group. The moderator was doing it as a joke, but it makes it hard to get up before that audience to 

explain that we are here as a resource and not have them see you as an enemy. 

Given this attitude among some local housing market participants, Education and Outreach Initiative groups had more success receiving funding from other sources. 

One case study participant from an organization that was created in 1989 said the organization had chosen to focus 

exclusively on fair housing enforcement, which made it difficult to raise funds. This participant uses partnerships to fund 

education and outreach activities when it does not have a FHIP grant for that type of initiative. The organization partnered 

with groups, such as the American Institute of Architects, Consumer Credit Counseling Services, state real estate commissions, legal services, and other advocacy groups. These groups provided partnerships for actual funding, training facilities, 

and case referrals to the FHIP organization. This FHIP recipient increased its chances of obtaining a FHIP grant by leveraging these resources. The FHIP NOFA awards points in the grant selection process based on the percentage of outside FHIP 

funding leveraged by the organization. 

EOI grants accounted for a much larger share of the total education and outreach activities for organizations that had a 

relatively small overall budget for these combined activities, and they represented none of the funding for education and 

outreach activities for larger organizations. EOI grants provided 50 percent of the funds for education and outreach activities for respondents with a combined budget of less than $150,000 for enforcement initiatives and education and outreach 

activities. EOI grants’ share of education and outreach activities is even greater at 70 percent (Table 37). 

Organizations with relatively large combined enforcement funding and education and outreach budgets were able to fund 

a larger share of their education and outreach activities from grants that city, county, or state governments provided. On 

36
 
Study of the Fair Housing Initiatives Program
	

average, such funding sources provided 74 percent of respondents with a total enforcement funding and education and 

outreach budgets of more than $400,000, 30 percentage points less than the share of education and outreach activities 

funded from these sources for all respondents combined (Table 38). 

One case study participant in a major metropolitan area successfully operated without any EOI funding. Representatives 

of this organization said distributing newsletters and winning cases was the most effective use of outreach. Because the 

organization had been involved in influencing positive outcomes in a substantial number of fair housing cases, this outreach 

strategy was effective and, therefore, had no need for EOI grants. 

EOI grants can be a valuable source of support for outreach activities, especially for groups too small to receive PEI grants. 

For example, one case study participant in a rural area received EOI grants only. Representatives of this organization said 

that although they received PEI and EOI grants to do their work, they were too small for a substantial PEI grant. Although 

the FHIP NOFA does not make a distinction in terms of size for a grant award, this organization’s staff believes that their 

organization cannot support a sizable PEI grant for their performance area. 

Total Enforcement Funding 

and Education 

and Outreach Budget ($) 

EOI Share of Education 

and Outreach Budget (%) 

Number of 

Respondents 

Mean EOI 

Funding ($) 

Total Mean Education 

and Outreach 

Budget ($) 

Table 37. EOI Grants’ Share of Total Enforcement Funding and Education and Outreach Budget by Fair Housing Budget 

Size, FY 2006 

Less than 150,000 50 19 35,669 70,728 

150,000–250,000 70 8 49,999 71,790 

250,000–400,000 9 14 4,048 42,636 

Greater than 400,000 0 10 0 128,404 

Total 30 51 22,242 74,492 

EOI = Education and Outreach Initiative. 

Source: Survey of Fair Housing Initiative Program grantees 

Sources of 

Funding 

Total Enforcement Funding 

and Education and Outreach Budget 

Greater Than $400,000 

All Survey 

Respondents 

Table 38. Comparison of Sources of Funding for Education and Outreach Activities for Survey Respondents, FY 2006 

FHIP PEI 9% 4% 

FHIP EOI 0% 30% 

FHIP FHOI 0% 0% 

CDBG from city, county, or state government 42% 32% 

Other funding from city, county, or state government 32% 12% 

HUD counseling funds 0% 6% 

Proceeds from fair housing settlements 1% 0% 

Realtors 1% 0% 

Bankers/mortgage companies 0% 3% 

Landlord associations 1% 1% 

Foundations 7% 6% 

Charitable donations 1% 3% 

Other 4% 3% 

Total education and outreach activities 100% 100% 

Mean $128,404 $74,492 

N 10 51 

CDBG = Community Development Block Grant. EOI = Education and Outreach Initiative. FHIP = Fair Housing Initiative Program. FHOI = Fair Housing Organizations 

Initiative. HUD = U.S. Department of Housing and Urban Development. PEI = Private Enforcement Initiative. 

Source: Survey of FHIP grantees 

37
Study of the Fair Housing Initiatives Program
	

Funding History
�

A steady source of funding is critical for any fair housing group’s survival. One case study participant in a large metropolitan 

statistical area discussed the problem of inconsistent funding. The organization staff was reduced to two employees when it did 

not receive HUD funding during a round in which it applied. At a later date, the organization recruited additional employees, but 

the previous job cuts meant a loss to the organization of the fair housing expertise and institutional memory of its former employees. This organization, which received no HUD funding, sought other sources of financial support and added other services 

to ensure its continuation. It now receives foundation funding in addition to FHIP grants to help pay for fair housing activities. 

Unfortunately, fair housing budgets for most respondents fluctuated between years. Of the respondents, 45 provided information about their fair housing budgets between FY 2004 and FY 2006. The fair housing budgets for 36 percent of these 

respondents both increased and decreased during this period. Respondents said that a single year of an organization’s fair 

housing budget was not a good predictor for the next year. Of the respondents, 38 percent indicated that their fair housing 

budgets either increased or remained the same in every year between FY 2004 and FY 2006. Conversely, fair housing budgets decreased for 16 percent of respondents, and 4 percent of respondents saw a decrease in their fair housing budgets 

in at least 1 year without any increases in funding during this period (Table 39). 

Respondents were less likely to have their funding increased in every year when looking at a longer period of time. When 

asked about funding trends between FY 2001 and FY 2006, only 9 percent of 58 respondents indicated that funding for 

fair housing initiatives generally increased over time (Table 40). Twice as many respondents indicated that funding generally 

decreased over time. Most respondents, however, indicated that fair housing funding was up and down from year to year. 

Of respondents, 21 percent indicated that these changes were modest, but 33 percent indicated that fair housing funding 

changed dramatically from year to year (Table 40). 

When asked to identify the factors that most influenced year-to-year fair housing funding stability, many organization’s 

representatives indicated that HUD funding, especially PEI grants, were critical, reinforcing the findings reported in Table 

32, which showed the importance of FHIP PEI grants for funding enforcement activities. One organization’s representative 

wrote the following statement: 

Most important [for stability] is whether we get a HUD PEI grant from year to year. The CDBG funds in 

our states will not support enforcement, and foundations in our states are very limited and will not accept 

requests each year. As a result, we rely on FHIP funding for the majority of our casework. 

Reported Fair Housing 

Budgets 

Number of 

Respondents 

Percent of 

Respondents 

Table 39. Fair Housing Budget Changes for Survey Respondents, FY 2004–FY 2006 

Increased every year 12 27 

Decreased every year 7 16 

Increased in a year without a decrease 3 7 

Remained the same in every year 5 11 

Decreased in a year without an increase 2 4 

Increased and decreased over the period 16 36 

Total 45 100 

Source: Survey of Fair Housing Initiative Program grantees 

Fair Housing Funding Pattern Percent 

Table 40. Fair Housing Funding Changes for Survey Respondents, FY 2001–FY 2006 

Generally decreased over time 9 15.5 

Generally increased over time 5 8.6 

Relatively stable from year to year 13 22.4 

Up and down modestly from year to year 12 20.7 

Up and down significantly from year to year 19 32.8 

Total 58 100.0 

Source: Survey of Fair Housing Initiative Program grantees 

38
Study of the Fair Housing Initiatives Program 

Although FHIP grants, especially PEI grants, were critically important to most respondents’ abilities to sustain year-to-year 

activities, such grants were often made for 1 year only. As a result, respondents said, they faced difficulties making multiyear 

plans because they were uncertain about receiving FHIP grants in subsequent years. One respondent wrote the following: 

Our FHIP grant provides us with stability. It is the base for the work that we do and is 80–85 [percent] of 

our total budget. In the past we received only 1-year FHIP grants, which makes long-range planning and 

often staff retention difficult. One-year awards also limit applications for other FHIP funds, primarily the 

FHIP EOI funds. 

Another respondent indicated that the 1-year grant period restricted their ability to undertake multiyear fair housing 

investigations: 

It seems futile to plan a multiyear investigation since it is unclear if we will be able to fund it beyond 1 year. 

It also hurts our ability to recruit quality employees when we cannot guarantee them any job stability. In 

addition, our salaries are significantly below that of other nonprofits because the board is trying to conserve resources to ensure our continued existence. 

Recipients of multiyear awards indicated that they were able to use the grant funding to increase organizational stability and 

raise money, as one respondent wrote: 

The stability of a multiyear FHIP contract has greatly enhanced our ability to raise private funds. Individual, 

corporate, and foundation donors are confident that their donations will be used well because the HUD 

funds are secure. Also, we have additional time to spend on private fundraising when we only have to do 

the HUD application once every [3] years. 

These responses were typical of those received in the survey and underscored the importance of FHIP grants for FHOs. 

Given this importance, respondents indicated that the funding decisions that HUD made influenced their organization’s 

ability to retain staff, conduct fair housing enforcement initiatives and education and outreach activities, and raise funds 

from other sources. As a result, respondents highlighted the importance of ensuring that FHIP applications, submitted in 

response to Notices of Funding Availability, be evaluated in a systematic and objective manner that reflects an organization’s 

track record as an FHO. 

In addition to the statements from survey respondents, 7 of the 10 FHIP grantees interviewed stated that the funding for 

fair housing activities was up and down either moderately or significantly from year to year. Three stated that their funding 

for fair housing activities was stable from year to year. Seven grantees said that their organization started conducting fair 

housing activities after the creation of FHIP. The three FHIP interviewees with stable funding sources also happened to be 

from organizations that were in existence before the program’s implementation. In the past, groups had to raise the funds 

for enforcement initiatives and education and outreach activities from nonfederal sources before FHIP existed. It is possible 

to surmise that groups that had been created by or after FHIP grants adjusted to having FHIP funding on which to rely. 

Descriptive Analysis Summary 

Many FHIP organizations work in areas with large populations, and fair housing initiatives play a significant role in their missions. Respondents were overwhelmingly nonprofit organizations with long-term executive directors who employ ethnically 

diverse staffs—up to three-fourths of whom were women. Most employees in respondent organizations had at least a 

college degree, 13 percent had a master’s degree, and 27 percent had a law degree. More than 60 percent of their enforcement funding came from FHIP grants, but a little less than one-third of their education funding came from FHIP. The 

budgets for these organizations fluctuated over time in regard to funding for FHIP. The view of these organizations was that 

they need FHIP funding to continue their work but would prefer a guarantee that they will receive FHIP funding in the future. 

39
 
40

Description of Procedures That FHIP Grantees 4 Used To Handle Fair Housing Complaints

Study of the Fair Housing Initiatives Program

The complaint process discussed in this section is based on information collected from indepth interviews with representatives of 9 Fair Housing Initiatives Program grantee organizations out of the 10 selected for onsite interviews. These interviews were conducted onsite, using the discussion guides presented in the appendix. The representatives were asked to 

detail the procedures their organizations used to process fair housing complaints.

Out of concern that this information could be used in litigation, the discussion guides used in these interviews did not include 

questions about specific criteria that organizations used to determine if a complaint warranted an investigation or, if it conducted an investigation, the criteria that organizations used to conduct a test. Perhaps because the questions were restricted to general procedures, most respondents used a similar set of procedures to process fair housing complaints, outlined in 

the form of a flowchart with a schematic representation of the general process that FHIP grantees (Figure 10) used.

When they believe they have been subject to some sort of fair housing violation, most complainants contact the organization by telephone. When funding allows, respondents said, their organizations run public service announcements and produce and distribute brochures and newsletters that provide a telephone number for people to call to report discrimination.

During the first stage in the process, a complainant contacts a FHIP grantee organization and completes an intake interview with a fair housing specialist, who collects information about the nature of the complaint.16 The fair housing specialist 

collects contact information from the complainant, as well as the telephone number of an individual who is close to the 

complainant.

With the information collected during the intake interview, the fair housing specialist determines whether the complaint is 

jurisdictional; that is, whether the complaint represents a potential fair housing violation. For example, a complainant may 

contact a FHIP grantee organization and allege that a landlord is using a prohibited basis for a reason to evict her. During 

the intake interview, the housing specialist will determine if any other reason (that is, nonpayment of rent) exists as the basis 

of the eviction that is not a prohibited basis.

If the housing specialist, using information collected at intake, determines that a possible fair housing violation occurred, 

he or she refers the complainant to the either the organization’s enforcement coordinator or compliance officer. In general, 

complaints referred for indepth investigations typically have the following characteristics:

n The complainant is a member of a protected class.

n The Fair Housing Act covers the housing.

n The Fair Housing Act covers the respondent (person accused of violating the law).

n The complaint is still within the statute of limitations of the act.

Within 1 week of the initial intake, a fair housing staff member conducts a more indepth interview with the complainant. The 

information from this interview is recorded on an intake form (see an example of an intake form in Appendix E). During this 

interview, the fair housing staff member collects information regarding the property address, owner (if the complaint is about 

a rental property), household income information, members of the household, names of other organizations the complainant may have contacted, and information about the property involved, such as availability of property and price terms.

16 Note that FHIP grantee organizations refer to contacts as “complaints” compared with FHEO, which refers to contacts from individuals and 

FHIP grantee organizations of FHAP organizations as “inquiries.”
Study of the Fair Housing Initiatives Program
	

Figure 10. Flowchart of Process That FHIP Grantees Used for Complaints 

The complaintant contacts 

fair housing agency 

An initial intake interview 

is conducted by a fair 

housing specialist 

Is the injury/ 

complaint jurisdictional? 

No 

Yes 

Case closed—complaint may be 

referred to a legal services organization 

or real estate licensing agency 

depending on the issue 

An indepth intake 

interviews conducted by the fair 

housing staff 

No 

Does the 

evidence collected from the 

interview suggest illegal 

discrimination? 

Case closed—complaint may be 

referred to a legal services organization 

or real estate licensing agency 

The agency performs an 

indepth investigation that 

may include tests 

Yes 

Is there 

evidence of illegal 

discrimination? 

Yes 

No Case closed—complaint is informed 

of their right to pursue the complaint with 

HUD or another agency or the courts 

Agency helps 

complaintant file a 

complaint with HUD, 

DOJ, FHAP, or in court 

Agency helps 

complaintant resolve 

the case through formal 

or informal mediation 

Or 

DOJ = U.S. Department of Justice. FHAP = Fair Housing Assistance Program. FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and 

Urban Development. 

Source: DB Consulting Group, Inc.
�

41
 

Study of the Fair Housing Initiatives Program
	

It is important to note that FHIP grantee organizations do not classify discussions with a complainant (whom FHIP grantee 

organizations consider a client) the same as an interview with a third-party who may have information about the alleged 

fair housing violation. FHIP grantee organizations consider ‘interviews’ to be discussions with people other than the complainant who can provide details about the complaint. Therefore, FHIP grantee organizations can conduct an investigation 

without an interview defined by HUD, which is more expansive in its definition of interviews, and includes discussions with 

the complainant. 

Using the information that the complainant provided during the indepth interview, the FHIP enforcement coordinator determines whether the complaint is a fair housing-related violation. Complaints that the enforcement coordinator judges to be a 

potential fair housing complaint are subject to an indepth investigation. Case study participants reported using the following 

alternate techniques in their indepth investigations: 

n Testing. 

n Interviewing third-party witnesses. 

n Researching local building and zoning codes. 

n Researching area demographics. 

n Monitoring print advertising. 

n Conducting property searches. 

n Calling the respondent, when necessary, to gather information to determine if there has been a violation 

of the law. 

FHIP grantee representatives were not asked about the criteria that they use to determine the type of technique used for a 

particular investigation, although a FHIP grantee organization’s representative did indicate that testing is not conducted for 

complaints related to allegations of differences in the terms and conditions of housing. Although testing may not be the best 

method to collect evidence for every type of complaint, 9 out of the 10 FHIP grantee organizations that provided information 

about indepth interviews used it. One main reason why these organizations use testing, according to their representatives, 

is that they can conduct tests before making any potential contact with the housing provider. 

Survey respondents provided more details about the sources of testers used and the types of training their testers received 

before testers participate in an investigation. The survey respondents indicated that they used a variety of sources to recruit 

testers. The most common method, used by 97 percent of respondents, was to recruit testers referred to the organization 

by existing testers. According to 89 percent of respondents, the two most common sources of testers were referrals from 

staff and social services organizations (Table 41). 

According to the representatives of the 10 FHIP grantee organizations who were interviewed, all testers are screened; the 

process includes a background check for felony convictions, a disqualifier by HUD standards. Testers who pass the background check are required to receive training. Grantee organizations use presentations, role-playing exercises, and quizzes 

on fair housing laws to train potential testers. Training classes typically last from 3 to 6 hours in a 2-day period and are usually conducted in the evening and on weekends to accommodate testers’ schedules. 

FHIP grantee organizations must train testers; substantial turnover exists among testers, because many of them are 

volunteers (see discussion that follows). According to the survey respondents, they provided training to at least one-half of 

the people who conducted tests in FY 2006. Of the respondents, 41 percent indicated that all of their testers who comPercent of Respondents Using 

Source for Tester Recruitment 

Number of 

Respondents 

Table 41. Sources That Survey Respondents Used To Recruit Testers 

Referrals from current testers 97 38 

Informal referrals from staff acquaintances 89 37 

Social services organizations 89 36 

Graduate school 38 32 

Actors guilds or similar 3 29 

Advertising in a public paper or flyer 66 35 

Source: Survey of Fair Housing Initiative Program grantees 

42
Study of the Fair Housing Initiatives Program 

pleted tests received a training session in the same year; 20 percent provided training to at least three-fourths of testers; 

15 percent indicated that less than one-fourth of their testers received training; and the remaining 24 percent trained about 

one-half of their testers in FY 2006. 

Most respondents said they did not use paid staff to conduct tests; however, 8 percent of respondents indicated that they 

employed hourly or salaried staff for such a purpose. The remaining 92 percent of respondents indicated that they paid an 

honorarium or stipend to compensate people who conducted tests. No respondents used volunteers or other people to 

perform tests without compensation. Most respondents (80 percent) indicated that their testers conducted in-person visits 

most of the time, and 5 percent of respondents indicated that testers conducted in-person visits in a few of their tests. 

After the FHIP grantee organization completes the investigation, it reviews the evidence with the complainant, including 

any testing results (which include information that testers provided in a debrief session with FHIP grantee organization staff 

members) and interviews with third parties other than the complainant. Using information from this review, the organization 

determines if the evidence supports a finding that the party named in the complaint violated fair housing laws. 

If a FHIP grantee organization does not find a violation of the Fair Housing Act, the organization reviews this finding with the 

complainant, who usually does not pursue the case any further. If the evidence supports a finding of a fair housing law violation, however, the organization works with the complainant to identify the best course of action. 

One choice available to a complainant is to work with the FHIP grantee organization to conciliate a complaint with a respondent. For such cases the FHIP organization will act as the intermediary between the complainant and respondent and 

attempt to craft a resolution that is acceptable to both the complainant and respondent. 

As detailed in the next section, FHIP grantee organizations resolve 22 percent of all investigations without referring the complaint to HUD or filing in court. FHIP grantee representatives interviewed for this study indicated that HUD’s current reporting 

system does not capture this activity, although these resolutions provide relief to the complainant. As a result, HUD does 

not count these resolutions toward a FHIP grantee organization’s number of complaints that are included in its Statements 

of Work with HUD, so the current reporting method understates outcomes achieved by FHIP grantee organizations. HUD 

recognizes that FHIP organizations may settle a case without referring it to HUD. That is why HUD is beginning to collect these data to enable grantees the opportunity to count the number of settlements. The FHIP database, FICTICOS, is 

being populated with information from FHIP organizations on conciliations, settlements, monetary awards received, and 

total number of cases. Also, HUD is considering a revision of the eLogic Model for FHIP to allow these settled cases to be 

counted in grantees’ final counts of activities undertaken with FHIP funding. 

A complainant’s case is closed if a satisfactory resolution through mediation is found. If such a resolution cannot be found, 

the FHIP grantee organization will consult with the complainant regarding the next steps to take. The step available to the 

complainant is to file a complaint with a state or local fair housing organization, HUD, or the Department of Justice. Another option available is that the complainant can file suit in a federal or state court.17 FHIP grantee representatives did not 

provide information about the criteria that they use to determine where to pursue cases that, through an investigation, show 

evidence of a fair housing violation. 

Procedures Summary 

FHIP organizations tend to follow the same procedures for case processing regardless of the area of the country. A complainant will normally call an agency, which then conducts an intake interview to determine if the Fair Housing Act has been 

violated. After an indepth interview, FHIP investigates the complaint using testing, interviews, and other research. If the 

evidence indicates housing discrimination, the FHIP organization helps the complainant decide whether to file the case with 

HUD or in court. FHIP organizations will help conciliate a settlement between the complainant and violator but may not 

receive HUD credit for fair housing complaints that have reached conciliation for FHIP grant-reporting purposes. 

17 Representatives of organizations interviewed for this study were not asked about the ultimate resolution of cases filed in court. 

43
 
Study of the Fair Housing Initiatives Program 5 FHIP Grantee Organizations’ Investigation

and Testing Activities 

This section presents descriptive analyses of the Fair Housing Initiative Program grantee organizations’ activities related to 

investigations and testing. The section describes separate testing activities conducted in response to individual complaints 

versus those that are grantee organization-initiated. The results presented in this section are based on data provided in the 

web-based survey, which asked respondents about their volume of inquiries and investigations, testing, and education activities in FY 2006. The reason is that survey respondents were expected to have at hand complete data for that fiscal year 

to include in the survey. 

Investigations 

As discussed in the previous section, FHIP grantee organizations conduct investigations for all complaints that, through the 

initial intake interview with the complainant, represent potential fair housing violations. Investigations can be completed using techniques such as testing, interviews with third-party witnesses, and reviews of zoning and land use regulations.18 

A total of 40 respondents conducted 6,208 investigations for a mean of 155 per respondent (or, about three investigations 

per week) in FY 2006. The overwhelming share (84 percent) of investigations related to complaints regarding rental housing. 

The remaining four types of complaints (sales, lending, insurance, and other) accounted for 16 percent of the investigations 

that FHIP grantee organizations completed in 2006 (Table 42). By focusing on rental housing inquiries, it is likely that these 

investigations result in relatively fast relief to complainants.19 

Nearly all respondents indicated that they investigated a complaint that was based on a person’s race, national origin, or disability. A smaller share of respondents conducted an investigation related to a person’s religion or an alleged violation related 

to design and construction (Table 43). PEI funds are not used to support every type of investigation. Although nearly every 

survey respondent (98 percent) conducted an investigation based on a person’s race, only 85 percent of respondents used 

PEI funds to investigate such a complaint. This pattern is similar without regard to the basis of an investigation (Table 43). 

Of the respondents, 44 provided information about the outcomes of investigations completed in FY 2006. The most common outcome was that the investigation resulted in no finding of discrimination (34 percent). This finding is important: about 

one-third of investigations that FHIP grantee organizations conducted identify complaints in which no finding of discrimination exists, and so the case is not referred to HUD for processing. The second most common outcome (22 percent) was 

that respondents’ organizations were able to resolve the complaint without referring the matter to HUD or Fair Housing Assistance Program. For these complaints the FHIP grantee organization closes the complaint without having to involve HUD, 

thereby resulting in a relatively quick resolution of the complaint (Table 44). 

Rental Sales Lending Insurance Other Total 

Table 42. Number of Fair Housing Investigations That Survey Respondents Undertook by Type, FY 2006 

Total 5,185 487 328 75 72 6,147 

Mean 136 13 9 2 2 162 

Median 98 5 2 0 0 113 

N 38 38 38 38 38 38 

Percent of total 84% 8% 5% 1% 1% 100% 

Source: Survey of Fair Housing Initiative Program grantees 

18 Representatives of organizations interviewed for this study were not asked about the ultimate resolution of cases filed in court. FHIP grantee 

organizations did not provide information about the share of investigations that were completed with each type of investigation technique. 

19 Respondents did not provide breakdowns of investigations by type for individual versus agency-initiated inquiries. 

44
Study of the Fair Housing Initiatives Program
	

Protected Class 

Type 

Share of Respondents Who 

Investigated a Complaint for 

the Protected Class Type (%) 

Number of 

Respondents 

Share of Respondents Who 

Investigated a Complaint for 

the Protected Class Type 

With PEI funds (%) 

Number of 

Respondents 

Table 43. Investigations That FHIP Grantee Organizations Completed by Protected Class, FY 2006 

Race 98 44 85 41 

Color 59 37 57 30 

National origin 95 43 57 30 

Familial status 89 44 82 39 

Sex 80 41 75 36 

Religion 60 40 63 32 

Design and construction 77 39 69 32 

Disability 93 45 83 40 

FHIP = Fair Housing Initiative Program. PEI = Private Enforcement Initiative. 

Source: Survey of FHIP grantees 

Outcome 

Number of 

Investigations 

Percent of All 

Investigations 

Percent of All Investigations 

Closed in FY 2006 

Table 44. Outcomes for Fair Housing Investigations, FY 2006 

Led to fair housing complaint filed with FHAP or HUD 953 12 15 

Led to fair housing suit filed in a court 111 1 2 

Resolved by organization outside of HUD, a FHAP 1,692 22 27 

 agency, or court 

Investigated but no discrimination found 2,638 34 43 

Evidence referred to DOJ 20 0 0 

Referred to state licensing agency 5 0 0 

Referred to state attorney general 67 1 1 

Referred to a state non-FHAP agency 106 1 2 

Other 599 8 10 

Still under investigation as of the end of FY 2006 1,474 19 NA 

Total 7,665 100 100 

N 44 

DOJ = U.S. Department of Justice. FHAP = Fair Housing Assistance Program. HUD = U.S. Department of Housing and Urban Development. NA = Not available.
�

Note: Most respondents completed their survey between January and April 2008.
�

Source: Survey of Fair Housing Initiative Program grantees
�

It is important to note that FHIP grantee organizations only report information to HUD about investigations that are supported with PEI funds. On average, information is not reported for about one-third of investigations. For some FHIP grantee 

organizations, however, this proportion is much greater: PEI grant money funds less than 50 percent of investigations for 17 

out of 40 (43 percent) respondents (Table 45). 

Of all the investigations, 12 percent resulted in the filing of a fair housing complaint with either a FHAP agency or HUD, and 

1 percent of inquiries and investigations led to the filing of a fair housing lawsuit in a court. Of the complaints that were no 

longer under investigation as of FY 2006, 43 percent resulted in no finding of discrimination by the FHIP grantee organization, and 27 percent resulted in a resolution by the FHIP grantee, FHAP agency, or HUD (Table 46). 

Investigations that FHIP grantee organizations completed help to screen out complaints in which no discrimination exists 

and complaints that can be resolved relatively quickly, and so they reduce the number of cases referred to HUD. The large 

share of investigations for cases that are not referred to HUD reduces the investigative burden for the department and creates a cost-effective and efficient process to handle fair housing complaints. 

45
 
Study of the Fair Housing Initiatives Program
	

Protected Class 

Type 

Share of Respondents Who 

Investigated a Complaint for 

the Protected Class Type 

in FY 2006 (%) 

Number of 

Respondents 

Share of Respondents Who 

Investigated a Complaint for 

the Protected Class Type 

With PEI Funds (%) 

Number of 

Respondents 

Table 45. Investigations Completed by FHIP Grantee Organizations by Protected Class, FY 2006 

Race 98 44 85 41 

Color 59 37 57 30 

National origin 95 43 57 30 

Familial status 89 44 82 39 

Sex 80 41 75 36 

Religion 60 40 63 32 

Design and construction 77 39 69 32 

Disability 93 45 83 40 

FHIP = Fair Housing Initiative Program. PEI = Private Enforcement Initiative. 

Source: Survey of FHIP grantees 

Investigation Outcome 

Number of 

Investigations 

Percent of All 

Investigations 

Percent of 

All Investigations 

Closed in FY 2006 

Table 46. Outcomes for Fair Housing Inquiries and Investigations, FY 2006 

Led to fair housing complaint filed with FHAP or HUD 953 12 15 

Led to fair housing suit filed in a court 111 1 2 

Resolved by organization outside of HUD, a FHAP 1,692 22 27 

agency, or court 

Investigated but no discrimination found 2,638 34 43 

Evidence referred to DOJ 20 0 0 

Referred to state licensing agency 5 0 0 

Referred to state attorney general 67 1 1 

Referred to a state non-FHAP agency 106 1 2 

Other 599 8 10 

Still under investigation as of the end of FY 2006 1,474 19 NA 

Total 7,665 100 100 

N 44 

DOJ = U.S. Department of Justice. FHAP = Fair Housing Assistance Program. HUD = U.S. Department of Housing and Urban Development. NA = Not available.
�

Note: Most respondents completed their surveys between January and April 2008.
�

Source: Survey of Fair Housing Initiative Program grantees
�

Testing 

Some investigations that FHIP grantee organizations completed include testing. Testing is a controlled method of measuring and documenting variations in the quality, quantity, and content of information and services offered or given by real 

estate market participants . A test is designed to reveal differences in treatment and to isolate the causes of these differences (Fair Housing Center of Greater Boston, 2006). Fair Housing Organizations can conduct a number of different tests. 

One of the most common is a paired-test, under which two applicants with identical profiles contact a real estate market 

participant (such as the management agent of a rental property) and each request the same information. The only difference between the two people who contact the real estate market participant is their race or ethnicity, age, or gender. 

Sometimes testers contact the real estate market participant by phone or visit an office (if feasible) in person. Fair Housing 

Organizations can also conduct inspections of multifamily properties to determine if they comply with requirements that 

such units are disability-accessible. 

Testing is a vitally important component of many FHO activities. One respondent wrote that testing helps to fill an “evidence 

gap” by providing information about an alleged discriminatory event. This evidence, the respondent wrote, helps attorneys 

represent complainants in administrative or court actions. Another respondent wrote that “testing is the most crucial aspect” of all its fair housing activities: 

46
 
Study of the Fair Housing Initiatives Program
	

Testing evidence convinces the general public that discrimination still exists, convinces judges and hearing 

officers that a complainant has been harmed, and shows industry contractors where they need to change 

their practices to comply with the law. As an independent, mission-driven, nonprofit agency, we provide 

this tool in a way that is rigorous and, therefore, trustworthy. 

Another respondent wrote the following statement: 

Testing conducted under our programs provides the best evidence of housing violations and leads to 

positive results. 

The comparative analysis presented in section 7 is consistent with the sentiment that this respondent expressed, because 

FHIP-referred complaints sent to HUD more often result in a cause finding than non-FHIP-referred complaints. 

FHOs conduct tests in response either to complaints from individuals or from agencies. The difference between these two 

types of tests is that grantee organization-initiated tests are conducted to identify systematic discrimination, and they have 

the potential to help more people than tests conducted for individual complaints. This section discusses tests in response 

to individual inquiries and tests conducted in response to organization-initiated inquiries. 

Nearly all (82 percent) of survey respondents indicated that their organizations conducted fair housing tests. All of these 

organizations have a staff member to coordinate testing; 69 percent of respondents said that this staff member worked at 

least 75 percent of the time on test coordination activities. All six agencies interviewed stated that they will conduct testing 

on complaints in which the issues are testable. All stated that some of their testing was done for research purposes, or at the 

request of another agency to check for housing discrimination and to report on activities of the hiring agency’s employees. 

This type of testing is similar to secret shopping that other types of businesses occasionally conduct on their employees. 

Of the respondents, 37 said they completed a total of 5,033 tests in FY 2006, an average of 136 tests per respondent.20 

PEI funds supported about two-thirds of the tests that FHIP grantees conducted. (Respondents were not asked to break 

out the share of tests from individuals versus organization-initiated inquiries funded by PEI grants.) The share of tests supported with PEI funds is nearly identical to the share of investigations of individual inquiries supported by PEI funds reported 

previously in Table 34. Note that the remaining testing activities were not funded by PEI grants and went unreported to 

HUD. This unreported testing activity may be substantial: although the average share of tests funded with PEI grants was 

64 percent, 30 percent of respondents funded fewer than one-half of their tests with PEI grants (Table 47). 

Although fair housing tests can be conducted for a range of real estate transactions, all of the respondents indicated that 

they completed a test for a complaint related to rental housing. Of the respondents, 84 percent indicated that they completed a test in FY 2006 for a complaint related to a purchase transaction, 40 percent conducted a test related to a lending 

complaint, and 25 percent completed a test related to an insurance complaint (Table 48). 

Respondents conducted tests in FY 2006 for complaints filed by an array of protected classes. Among respondents who 

conducted tests for complainants, 97 percent completed a test for a complaint filed by an African American, and 

Percent of Fair Housing Tests 

Conducted With PEI Grants 

Number of 

Respondents 

Percent of 

Respondents 

Mean Percent of 

Fair Housing Tests 

Conducted With PEI Grants 

Table 47. Distribution of the Share of PEI-Grant-Funded Tests That Survey Respondents Conducted, FY 2006 

< 25 6 16 13 

25–49 5 14 39 

50–74 6 16 64 

75–99 9 24 84 

100 11 30 100 

Total 37 100 64 

PEI = Private Enforcement Initiative.
�

Source: Survey of Fair Housing Initiative Program grantees
�

20 The web-based survey did not include questions about the factors that respondents used when deciding to conduct a test or the number 

of tests conducted per inquiry. In addition, the respondents were not asked about the number of tests they conducted in response to inquiries 

received in 2006 only. Therefore, the data do not allow for an analysis of the share of inquiries received in 2006 that resulted in a test. 

47
Study of the Fair Housing Initiatives Program
	

92 percent completed a test related to a complaint based on national origin or familial status. Respondents completed a 

test for a complaint filed by protected racial or ethnic classes as follows: 87 percent for a Hispanic, 34 percent for an Asian, 

29 percent for a Native American or Alaska Native, and 27 percent for a Hawaiian or other Pacific Islander. Respondents 

completed a test for a complaint filed by protected classes of people with disabilities as follows: about 8 in 10 respondents 

for a person with a physical disability, 50 percent for a complainant with a mental disability, and 34 percent for a complainant with a sensory disability (Table 49). 

Of the respondents, 37 reported information about the outcome of tests conducted in response to individual inquiries. Onehalf of the respondents indicated that fair housing law enforcement actions (which means that the complaint was referred to 

HUD) from testing resulted relatively infrequently. Conversely, 30 percent of respondents indicated that enforcement actions 

occurred from roughly one-half of the tests from individual inquiries that they received (Table 50). 

It is important to note that tests that do not generate an enforcement action can still result in relief to the complainant. As 

shown previously in Table 44, the FHIP grantee organization resolved 22 percent of investigations (regardless of whether 

they included testing) without referring the case to HUD, a FHAP, or a court. To the extent that tests result in a similar 

proportion of cases being resolved in the same manner, further tests could generate a larger number of resolutions beyond 

cases that have an enforcement action. 

To build consistency in the testing methodologies of the various agencies that undertake testing, FHIP grantees are mandated that HUD approve all testing methodologies before they are implemented. Given this requirement, it is not surprising 

Type of 

Complaint 

Number of Respondents 

Completing a Test 

Percent of 

Respondents 

Table 48. Proportion of Respondents Conducting Tests by Complaint Type, FY 2006 

Rental 38 100 

Sales 32 84 

Lending 14 40 

Insurance 9 25 

Source: Survey of Fair Housing Initiative Program grantees 

Protected Class 

Type 

Number of Respondents 

Completing a Test for Complaints 

Filed by Protected Class Type 

Percent of 

Respondents 

Table 49. Share of Respondents Completing a Test for Complaints Filed by Protected Class Type, FY 2006 

Black or African American 37 97 

Hispanic 34 87 

Asian 11 34 

Native American or Alaska Native 9 29 

Other race 3 10 

Native Hawaiian or other Pacific Islander 8 27 

Other color 4 13 

Religion 13 38 

Sex 22 61 

National origin 35 92 

Familial status 35 92 

Design and construction 23 64 

Physical disability 30 81 

Sensory disability 11 34 

Mental disability 17 50 

Other 0 0 

Source: Survey of Fair Housing Initiative Program grantees 

48
Study of the Fair Housing Initiatives Program
	

that nearly all survey respondents (97 percent) had a documented tester training manual. This manual was usually developed locally (28 percent of respondents), or based on a manual developed by the National Fair Housing Alliance (NFHA) (15 

percent of respondents). The manuals that the remaining 57 percent of respondents used were developed with a combination of local and NFHA information materials. 

Respondents used a variety of sources to recruit testers. The most common method, which 97 percent of respondents 

used, was to recruit testers that existing testers referred to the organization. The next two most common sources of testers, 

according to 89 percent of respondents, were referrals from staff and from social services organizations (Table 51). 

Case study grantees also used similar sources to recruit testers. Some FHIP organizations recruit testers from community 

events and from advertisements in newspapers and newsletters. Some staff members in larger cities may be called on to 

conduct tests for their organizations in the event of a tester shortage. All testers go through a screening process, which is 

determined by FHIP organizations. This process includes a background check because HUD requires that testers not have 

felony convictions on their records. This screening usually includes questions on a written application—just like an employment application. One case study grantee made the following statement: 

We recruit testers by word of mouth, community events, and personal references. The screening process 

includes completing an application. The testers are interviewed by the enforcement director (now ED). 

They have a 3-hour mandatory fair housing training, sent on practice sample test, and evaluated to determine if good tester. 

Testers who pass FHIP screening are required to be trained to conduct testing, which involves video presentations, roleplaying exercises, and quizzes on fair housing laws. The training classes can last from 3 to 6 hours in a 2-day period and 

are usually conducted in the evening and on weekends to accommodate testers’ schedules. Most survey respondents provided training to at least one-half of the people who conducted tests in FY 2006. Of the respondents, 41 percent indicated 

that all their testers who completed tests received a training session in the same year; 20 percent provided training to at 

least three-fourths of their testers; 15 percent indicated that less than one-fourth of their testers received training; and the 

remaining 24 percent trained about one-half of their testers in FY 2006. 

Most respondents said they did not use paid staff to conduct tests, however, 8 percent of respondents indicated that 

they employed hourly or salaried staff for such a purpose. 

The remaining 92 percent of respondents indicated that 

they paid an honorarium or stipend to compensate people 

who conducted tests. No respondent used volunteers A few 20 54 

Number of 

Respondents 

Percent of 

Respondents 

Table 50. Proportion of Individual Inquiries Resulting in 

an Enforcement Action 

or other people to perform tests without compensation. Most 3 8 

Most respondents (80 percent) indicated that their testers None 3 8 

conducted in-person visits most of the time, and 5 percent Roughly one-half 11 30 

Total 37 100 of respondents indicated that testers conducted in-person 

Source: Survey of Fair Housing Initiative Program grantees visits in a few of their tests. 

Percent of Respondents Using 

Source for Tester Recruitment 

Number of 

Respondents 

Referrals from current testers 97 38 

Table 51. Sources That Survey Respondents Used To Recruit Testers 

Informal referrals from staff acquaintances 89 37 

Social services organizations 89 36 

Graduate school 38 32 

Actors guilds or similar 3 29 

Advertising in a public paper or flyer 66 35 

Source: Survey of Fair Housing Initiative Program grantees 

49
Study of the Fair Housing Initiatives Program
	

Organization-Initiated and FHAP-Initiated Investigations
�

Some investigations do not result from inquiries that individuals made. Investigations can be ‘organization-initiated,’ which 

begin with systematic investigations of housing market patterns by FHIP grantee organizations (Table 52). Organizationinitiated investigations have the potential to help a large number of people if they uncover systematic discrimination against 

protected classes. Because this type of investigation is more complex, however, it typically requires more time to complete 

than an individual complainant investigation. 

It appears that a nearly equal number of respondents conducted most of their tests in response to either individual- or 

organization-initiated complaints (see the bolded numbers in Table 53). Of 41 respondents, 32 percent conducted most or all 

of their tests in response to an organization-initiated complaint and just about the same proportion (29 percent) conducted 

most or all of their tests in response to complaints brought by individuals. Of the respondents, 22 percent were equally likely 

to conduct tests from individual- or organization-initiated complaints (Table 53). 

According to the representatives of FHIP grantee organizations who were interviewed for this study, the number of tests 

conducted in response to individual-initiated complaints versus those that were organization-initiated was a function of the 

number of testable complaints a FHIP grantee organization received during a year. Some complaints, such as those related 

to the availability of either rental or sales housing, or the terms and conditions associated with either type of transaction, 

were more easily investigated with testing. Representatives of FHIP grantee organizations said it was difficult to know from 

one year to the next what share of individual complaints can be investigated using tests. 

In addition to conducting tests for individual- and organization-initiated complaints, some FHIP grantees conducted tests 

for local FHAP organizations. Most respondents (53 percent) indicated that they conducted tests in FY 2006 in response 

to a request from a HUD or FHAP agency; 38 percent of respondents conducted tests in response to a settlement or court 

order, and 36 percent of respondents conducted tests as part of a research program. 

Percent of Investigations 

Funded With PEI Grants 

Number of 

Respondents 

Percent of OrganizationInitiated Complaints Resulting 

in an Investigation Funded 

With PEI Grants 

Percent of 

Respondents 

Table 52. Distribution of Share of Grantee Organization-Initiated Inquiries Investigated With PEI Grant Funding 

< 25 8 6 23 

25–49 3 29 9 

50–74 2 62 6 

75–99 4 86 11 

100 18 100 51 

Total 35 65 100 

PEI = Private Enforcement Initiative. 

Source: Survey of Fair Housing Initiative Program grantees 

Share of Tests Conducted in Response 

to Organization-Initiated Complaints 

None or a Few 

(%) 

Roughly One-Half 

(%) 

Most or All 

(%) Total 

Table 53. Comparison of Proportion of Tests Conducted From Individual- and Grantee Organization-Initiated Complaints, 

FY 2006 

Share of tests conducted in 10 5 32 46 

response to individual-initiated 0 22 0 22 

complaints 29 2 0 32 

Total 39 29 3% 100 

Source: Survey of Fair Housing Initiative Program grantees 

50
Study of the Fair Housing Initiatives Program 6 Description of FHIP Grantees’ Education

and Outreach Activities 

Enforcement of fair housing laws, in many cases, depends on people who have suffered discrimination making complaints 

that can be investigated and remediated. Real estate participants, including realtors, lenders, and property managers, 

must be aware of actions that violate fair housing laws and avoid prohibited actions. Many Fair Housing Initiatives Program 

grantees conduct education and outreach activities that help to inform people who may be at risk for discrimination and 

real estate participants about the rights and responsibilities required by fair housing laws. Several survey respondents wrote 

about the importance of providing this service to the community: 

Without groups like ours, individuals do not know who to contact to help them or how to navigate the 

process and get the evidence they need to show they have been a victim of discrimination. We also 

distribute thousands of fair housing publications each year, which help educate housing providers, so they 

do not unknowingly discriminate. 

Another respondent wrote about education and outreach: 

They help the general public become aware of their rights under the Fair Housing Act and learn how to 

report a complaint. A broader education and outreach campaign is essential. If people don’t know their 

rights, they won’t know when they’re making violations or experiencing violations. If they don’t know 

there’s a problem, they can’t fix it. 

The grantees use education and outreach to increase enforcement activities, according to one case study participant, “We 

had a grant ... it was a moving ad, limited to 10 seconds—it doubled client load while it ran.”
�

Out of 68 respondents, 55 indicated that they provided fair housing education in FY 2006. Survey respondents provided fair 

housing training to 167,962 individuals, a mean of 3,054 people per respondent. Of the survey respondents, 52 provided 

fair housing training to 1,807 organizations, a mean of 35 organizations per respondent (Table 54).
�

Respondents referred to a variety of sources for materials they used for education and outreach activities in FY 2006. 

Of the respondents, 90 percent indicated they used materials they developed in house. In addition, 80 percent of these 

respondents used materials that HUD or the Federal Reserve Board developed. The two most common HUD sources that 

respondents used were Fair Housing: Equal Opportunity for All and Fair Housing Act Design Manual.
�

Number of People Receiving 

Fair Housing Education or 

Training From Respondent 

Number of Organizations With Staff 

Receiving Fair Housing Education or 

Training From Respondent 

Table 54. Individuals and Organizations Receiving Fair Housing Education or Training From Respondents, FY 2006 

Total 167,962 1,807 

Mean 3,054 35 

Median 610 19 

Min 100 2 

Max 33,000 210 

N 55 52 

Source: Survey of Fair Housing Initiative Program grantees 

51
Study of the Fair Housing Initiatives Program
	

The most common education and outreach activity, which 100 percent of respondents performed in FY 2006, was distributing educational materials. Other common activities included training landlords and apartment management agencies (96 

percent), training real estate agents (83 percent), and convening meetings for representatives of the housing industry and 

fair housing groups (85 percent) (Table 55). 

Education and outreach activities were not fully supported by Education and Outreach Initiative funds. Depending on the 

activity, such funds were used in FY 2006 to finance between 6 percent and 33 percent of individual education and outreach activities (Table 55). 

This finding was consistent with the analysis presented previously that showed that EOI funds provided about 30 percent of 

respondents’ 2006 budget for education and outreach activities. Presumably, the remaining funds used to finance education and outreach activities completed in FY 2006 came from local, county, and state governments, either through Community Development Block Grant funds or other sources—the two largest sources of the education and outreach budgets for 

survey respondents. 

Education and 

Outreach Activities 

Number of Respondents 

Undertaking Education and 

Outreach Activities 

Percent of 

Respondents 

Percent of Respondents 

Who Used EOI Grants 

To Finance Activities 

Table 55. Education and Outreach Activities That Respondents Completed and the Proportion of Activities Funded With 

EOI Grant Funding, FY 2006 

Develop educational materials 45 83 24 

Distribute educational materials 55 100 29 

Analyze local impediments to housing choice 32 59 6 

Provide housing counseling and classes 34 62 21 

Convene meetings to bring together the housing industry 47 85 26 

 and fair housing groups 

Develop technical materials on accessibility 11 22 27 

Launch media campaigns 24 45 33 

Training landlord and management agencies 53 96 25 

Training real estate agents 45 83 25 

Training lenders 17 33 24 

Training local government officials 39 74 18 

Other 12 63 25 

EOI = Education and Outreach Initiative. 

Source: Survey of Fair Housing Initiative Program grantees 

52
 
53

Comparing Outcomes for FHIP-Referred and 7 Non-FHIP-Referred Complaints

Study of the Fair Housing Initiatives Program

This section21 of the Fair Housing Initiatives Program study presents comparative analyses of outcomes for FHIP-referred 

and non-FHIP-referred complaints that were closed between FY 2003 and FY 2005. During this period, approximately 10 

percent of the 26,090 complaints that HUD and FHAP agencies closed were FHIP-referred cases. For this section, FHIP 

organizations are organizations that have ever received a FHIP grant.

The purpose of this section is to examine four hypotheses about the role FHIP organizations play in the process of enforcing fair housing laws. The hypotheses are as follows:

1.	FHIP organizations filter inquiries, reducing burden for HUD and FHAP investigators. The survey in 

section 5 shows that only 15 percent of cases that FHIP organizations investigated and closed were referred to 

HUD or FHAP agencies for investigation; 43 percent were determined not to have a case; and 27 percent were 

resolved by the FHIP organization itself without a referral to HUD or a FHAP agency. FHIP organizations appear 

to reduce the number of inquiries without basis for a complaint and some portion of the cases HUD or FHAP 

agencies likely would have conciliated. This survey result can be tested by comparing the proportion of inquiries 

brought by FHIP organizations to HUD compared with all inquiries brought to HUD. If most FHIP-referred 

inquiries are converted to a complaint then, this prescreening role might suggest that FHIP organizations are 

reducing the number of inquiries HUD and FHAP staff have to process.

2.	FHIP organizations act as a representative for complainants, resulting in better outcomes. Under this 

hypothesis, having a FHIP organization represent a complainant helps potential victims of housing discrimination 

in their contact with HUD or FHAP investigators and respondents. This approach would presumably lead to 

fewer administrative closures and more cause findings and conciliations as compared with other cases without a 

FHIP organization representative.

3.	FHIP organizations do testing and other investigations that increase the merit of a case and thus

lead to better outcomes for complainants. HUD and FHAP agencies rarely include testing as part of their 

investigation. Nearly all cases with testing evidence are those that involve a FHIP organization. The premise is 

that testing and other preinvestigation that a FHIP organization conducts increases the merits of a case and 

leads to better outcomes for the complainant.

4.	FHIP organizations are critical to the investigation of complicated cases. HUD and FHAP agencies react 

to complaints from individuals and thus are largely demand driven. Rarely do HUD and FHAP investigators identify a potential area of discrimination and initiate their own investigations. In contrast, as the survey results show, 

FHIP organizations initiate a significant number of their own investigations, particularly related to complicated 

cases such as fair lending, design and construction, pattern and practice, and zoning. If FHIP organizations are 

involved with most or all complaints related to fair lending, design and construction, pattern and practice, and 

zoning, this would support this hypothesis.

Background on FHIP-Referred Complaints

For this analysis, the FHIP-referred complaints are divided into two important subgroups:

1.	FHIP organization as the complainant. These are cases in which an FHO is listed as a complainant on a case.

2.	FHIP organization as the representative for the complainant. These cases do not have an FHO listed as a 

complainant but are instead listed as a representative to the complainant in the case.

21 Todd Richardson of HUD’s Office of Policy Development and Research wrote section 7 of this study.
Study of the Fair Housing Initiatives Program
	

The FHIP-referred complaints were identified using a methodology described in section 1. As discussed in that section, 

there may be some data reliability issues associated with the way HUD regional offices report data into the Title VIII Automated Paperless Office Tracking System. Nonetheless, the data are analyzed in this section, as they provide a rich source 

of information about outcomes for complaints referred to HUD and FHAP agencies by both FHIP grantees as compared 

with cases in which a FHIP organization is not involved. 

Before presenting this analysis, it is important to explain the process HUD and FHAP agencies use when they receive an 

inquiry about a suspected violation of the Fair Housing Act. For each inquiry22 it receives, HUD or FHAP agencies determine the jurisdictional elements associated with the allegation contained within the inquiry. If the inquiry is jurisdictional, it is 

classified as a complaint and entered and tracked in TEAPOTS. HUD or FHAP agencies investigate all complaints, and the 

investigator attempts to close the complaint through conciliation before the conclusion of the investigation.23 The statute 

calls for fair housing investigations conducted by FHEO and FHAP offices to be completed within 100 days of the filing of 

the complaint or inquiry. 

The purpose of the HUD or FHAP investigations is to determine if there is reasonable cause to believe the Fair Housing Act 

has been violated. A complaint will be closed through administrative closure if there are problems contacting the complainant or respondent (housing provider) or if it is determined later that the case was not filed in time. If a case is not conciliated 

successfully during the investigation, two possible conclusions exist. A determination of reasonable cause can be issued, 

which means there is evidence of illegal housing discrimination, and the case is then charged. After the case is charged, 

it may be filed in federal court or adjudicated at a HUD administrative hearing. The other possibility is that a determination 

of no reasonable cause is issued, which means that the investigator did not find reasonable evidence of illegal housing 

discrimination. 

Do FHIP Organizations Act As a Filter, Providing Cases More Likely To Be 

Jurisdictional and Have Merit? 

Table 56 shows the total number of inquiries that HUD received divided by those brought by a FHIP organization as a 

complainant or as a representative for a complainant and compares them with all inquiries that HUD received. As the table 

shows, 90 percent of FHIP-generated inquiries that are referred to HUD are converted to complaints, compared with 38 

percent of inquiries brought directly to HUD. This finding tends to support the survey results from section 6 that only 15 percent of FHIP cases are referred to HUD, suggesting that FHIP organizations play an important filtering role in the number of 

inquiries that HUD and FHAP agencies received. Expanding on the survey results that showed FHIP organizations brought 

only 15 percent of their inquiries forward as complaints to HUD or FHAP agencies, it is possible to estimate that FHIP organizations likely reduced the number of fair housing inquiries to HUD (mostly inquiries without merit) by 11,464 in the 3 years 

of FY 2003 through FY 2005. That is, FHIP organizations likely reduced HUD’s inquiry workload by nearly one-fourth. 

Non-FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as 

a Representative for a 

Complainant Total 

Table 56. Inquiries to HUD Field Offices That Were Converted to Complaints (Jurisdictional) 

Inquiry unfiled 62% 10% 10% 59%
�

Jurisdictional 38% 90% 90% 41%
�

Total 100% 100% 100% 100%

 N 36,489 754 1,269 38,512
�

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development. 

Note: Although Table 56 represents only cases for which HUD received an inquiry directly, all other tables in this section refer to filed complaints with either HUD or a 

FHAP agency and recorded in HUD’s Title VIII Automated Paperless Office Tracking System (TEAPOTS) database. 

Source: Authors’ analysis of the HUD TEAPOTS database 

22 HUD can receive inquiries from FHAP agencies and directly from individuals. This leads to some confusion regarding terminology. A FHIP 

grantee organization refers to a situation in which an individual contacts the organization alleging a fair housing violation as a complaint. HUD, in a 

similar circumstance, refers to this activity as an inquiry. 

23 42 U.S.C. Section 3610 (b) (1). 

54
 
 

Study of the Fair Housing Initiatives Program
	

Do FHIP Organizations Improve Outcomes for Complainants, Either as a 

Representative or Through Their Supporting Investigations? 

The second and third hypotheses presume that a FHIP organization involvement in a case should result in better outcomes 

for complainants. 

To test these basic hypotheses, data from TEAPOTS are analyzed. HUD uses the TEAPOTS data for all complaints filed either 

with HUD or a FHAP agency. Unlike the inquiries discussed previously, HUD or FHAP investigators determined that all the 

complaints used in this analysis were under the jurisdiction of either HUD or FHAP, as determined by the Fair Housing Act. 

A total of 23 potential outcomes are reported in the TEAPOTS database. To simplify this analysis, these 23 outcomes were 

recoded into four categories: (1) administrative closure, (2) conciliation and settlement, (3) a cause finding, and (4) a no 

cause finding, using the classification system detailed in Table 57. 

As Table 58 shows, 4 percent of the cases closed between 2003 and 2005 were cases in which a FHIP organization was 

listed as a complainant and 6 percent were cases in which a FHIP organization was listed as a representative to a complainant. Comparing their overall representation in number of cases to their share of cause cases show that FHIP organizations have a rate of cause twice their share of all cases (8 percent compared with 4 percent for a FHIP organization as a 

complainant and 11 percent compared with 6 percent for a FHIP organization as a representative for a complainant). 

In addition, Table 59 shows that 71 percent of the cases in which a FHIP organization is a complainant resulted in a conciliation (63 percent) or a cause (8 percent). These data compare with 37 percent for non-FHIP-referred cases. The 43 percent of 

cases that were conciliated or caused in which a FHIP organization was a representative for the complainant is still higher than 

the percentage of non-FHIP-referred complaints that resulted in a conciliation or cause outcome, but only by a small margin. 

Outcome Reported 

in TEAPOTS 

Outcome Used 

in the Analysis 

Table 57. Coding Method Used To Reclassify TEAPOTS Outcomes 

Untimely filed Administrative closure 

Dismissed for lack of jurisdiction Administrative closure 

Unable to locate complainant Administrative closure 

Complainant failed to cooperate Administrative closure 

Unable to identify respondent Administrative closure 

Complaint withdrawn by complainant without resolution Administrative closure 

Unable to locate respondent Administrative closure 

Closed because trial has begun Cause finding 

Conciliation and settlement successful Conciliation and settlement 

Complaint withdrawn by complainant after resolution Conciliation and settlement 

No cause determination No cause finding 

DOJ dismissal Cause finding 

DOJ settlement Cause finding 

FHAP judicial consent order Cause finding 

FHAP judicial dismissal Cause finding 

Litigation ended––discrimination found Cause finding 

Litigation ended––no discrimination found Cause finding 

Administrative hearing ended––discrimination found Cause finding 

Administrative hearing ended––no discrimination found Cause finding 

ALJ consent order entered after issuance of charge Cause finding 

ALJ dismissal Cause finding 

Election made to go to court Cause finding 

Appeals Court upholds ALJ finding of discrimination and no appeal Cause finding 

ALJ = administrative law judge. DOJ = U.S. Department of Justice. FHAP = Fair Housing Assistance Program. TEAPOTS = Title VIII Automated Paperless Office 

Tracking System. 

Source: Authors’ analysis of the HUD TEAPOTS database 

55
Study of the Fair Housing Initiatives Program
	

Outcome 

Category 

Non-FHIP-Referred 

Complaints 

(%) 

FHIP Organization 

as a 

Complainant 

(%) 

FHIP Organization 

as a Representative for a 

Complainant 

(%) 

Total 

(%) 

Total Number 

of Complaints 

Table 58. Comparison of Overall Representation for Non-FHIP-Referred and FHIP-Referred Complaints by Closure Type, 

FY 2003–FY 2005 

Administrative closure 91 4 6 100 3,213 

Conciliation and settlement 88 6 6 100 9,088 

No cause finding 94 1 5 100 12,845 

Cause finding 80 8 11 100 944 

Total 91 4 6 100 26,090 

FHIP = Fair Housing Initiative Program.
�

Source: Authors’ analysis of the U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System database
�

Outcome 

Category 

Non FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as 

a Representative for a 

Complainant Total 

Administrative closure 12% 13% 12% 12% 

Table 59. Comparison of Reasons for File Closure for Non-FHIP-Referred and FHIP-Referred Complaints, FY 2003–FY 2005 

Conciliation and settlement 34% 63% 36% 35% 

No cause finding 51% 15% 45% 49% 

Cause finding 3% 8% 7% 4% 

Total 100% 100% 100% 100% 

N 23,675 927 1,488 26,090 

FHIP = Fair Housing Initiative Program.
�

Source: Authors’ analysis of the U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System database
�

These findings are difficult to evaluate in terms of the hypothesis on whether or not FHIP organizations improve outcomes 

for complainants. FHIP involvement does seem to result in modestly improved outcomes for complainants that they refer 

to HUD or FHAP and represent, and much better outcomes for when they are a complainant or co-complainant. These 

findings could be due to FHIP organizations operating as a filter of complaints for HUD or FHAP rather than adding value 

through their role as a representative for the complainant. 

In addition, if FHIP organization involvement leads to a longer investigation time on the part of HUD or FHAP agencies, their 

role as a representative could slow down an investigation, and it might lead to less favorable outcomes. Table 60 shows 

that FHIP organizations as complainant or as representative result in slightly longer processing times by HUD, which may be 

because FHIP organizations refer more complicated cases to HUD and FHAP agencies. 

Table 61 shows a more nuanced picture of the average time to process, showing that cause finding cases with a FHIP 

organization involved were processed faster than non-FHIP cases, although conciliations and no cause finding cases with 

FHIP organization involvement took longer. 

The shorter amount of time it takes to investigate a cause finding case is consistent with the theory that FHIP organizations 

do a significant amount of the investigation work, including testing, to make a determination for a cause finding easier for 

HUD and FHAP investigators than a case that is brought independently by a complainant directly to HUD or a FHAP. This 

finding is particularly relevant for cases in which FHIP organizations act as the representative for a complainant. 

The longer amount of time it takes for a conciliation to occur once a case has been referred to HUD is consistent with the 

FHIP organizations acting as a filter by completing the easy-to-conciliate cases in house. As section 5 shows, FHIP organizations reported that 27 percent of the cases they investigated were resolved without filing with HUD or FHAP agencies, 

implying that FHIP organizations are conciliating the easy-to-conciliate cases without bringing them to HUD or a FHAP 

agency and suggesting that the cases being brought to HUD are likely to be the more complicated cases. 

56
 
Study of the Fair Housing Initiatives Program
	

The most compelling evidence supporting the hypothesis that FHIP organization investigation and testing improve outcomes for complainants is that FHIP organizations are the primary source of the testing evidence used to support a 

complaint. FHIP organizations are involved with only 10 percent of the total complaints that FHAP and HUD investigate, but 

they represent 85 percent of the cases with testing evidence. Table 62 shows that the bulk of the testing evidence comes 

from cases in which the FHIP organization is the complainant (72 percent), which likely explains the very high cause and 

conciliation rate for cases in which FHIP is a complainant, as discussed previously. In part, this result is probably because it 

is based largely on testing cases that a FHIP organization is likely to file as a complainant or co-complainant, because FHIP 

organizations likely choose to involve themselves in cases that have merit based on testing evidence. Of the 927 complaints 

in which a FHIP organization was a complainant, 42 percent have testing. This result compares with approximately 5 percent of the cases in which a FHIP organization acts as a representative (and only 0.4 percent for non-FHIP cases). 

Table 63 shows that a complaint that has testing involved is much more likely to result in a conciliation or a cause finding as 

compared with cases without testing. This finding is probably a large contributor to the much higher rate of complaints with 

a FHIP organization as a complainant ending in a cause finding or conciliation relative to other complaints. 

Table 64 shows the regional variation in outcome, which indicates the same pattern of higher “good outcomes” for FHIP 

organizations as the complainant across regions, with a smaller “better outcome” result for FHIP organizations acting as 

representatives for the complainant. Perhaps more interesting is that significant regional variation existed in the share of 

complaints processed, ranging from a low of only 3 percent in the Mid-Atlantic Region to a high of 23 percent in the Rocky 

Mountain Region. This variation in the proportion of cases that are referred by region raises more questions than it answers. 

Is it because of the allocation of FHIP grants or is it that FHIP organizations are more likely or willing to refer cases to HUD 

or a FHAP agency in some regions than in others? 

The evidence presented here generally supports the hypothesis that FHIP organization involvement in a case improves 

outcomes for complainants. Their role as an initial filter for cases and, in particular, their role of providing testing evidence 

to support a complaint seem to be their most powerful added values. The evidence that their role as a representative for a 

complainant improves complaint outcomes is not well supported from this analysis. 

Total Days From 

Filed Date 

Non-FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as a 

Representative for a 

Complainant 

Table 60. Comparison of the Mean Number of Days Between HUD Receiving a Complaint and Closing a File for NonFHIP-Referred and FHIP-Referred Complaints, FY 2003–FY 2005 

Median 149 169 190
�

Mean 227 291 265
�

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development.
�

Source: Authors’ analysis of the HUD Title VIII Automated Paperless Office Tracking System database
�

Outcome 

Category 

Non-FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as a 

Representative for a 

Complainant 

Table 61. Comparison of the Mean Number of Days Between HUD Receiving a Complaint and Closing a File for NonFHIP-Referred and FHIP-Referred Complaints by Closure Type, FY 2003–FY 2005 

Administrative closure 134 119 148 

Conciliation and settlement 108 156 149 

No cause finding 173 200 207 

Cause finding 708 673 495 

N 23,675 927 1,488 

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development.
�

Source: Authors’ analysis of the HUD Title VIII Automated Paperless Office Tracking System database
�

57
Study of the Fair Housing Initiatives Program

58

Non-FHIP-Referred 

Complaints

FHIP Organization as a 

Complainant

FHIP Organization as a 

Representative for Complainant Total

HUD Region

Total 

Cases (N)

Cause Finding or 

Conciliation (%)

Total 

Cases (N)

Cause Finding or 

Conciliation (%)

Total 

Cases (N)

Cause Finding or 

Conciliation (%)

Total 

Cases (N)

Cause Finding or 

Conciliation (%)

All FHIP 

Cases (%)

Headquarters 31 10 1 0 1 0 33 9 6

New England 1,363 38 16 88 72 40 1,451 39 6

New York/New Jersey 1,849 31 31 74 56 46 1,936 32 4

Mid-Atlantic 1,767 42 35 51 26 69 1,828 43 3

Southeast/Caribbean 3,966 28 80 63 260 44 4,306 30 8

Midwest 3,856 38 209 74 438 47 4,503 40 14

Southwest 3,089 38 115 63 264 38 3,468 39 11

Great Plains 2,575 45 111 89 87 32 2,773 46 7

Rocky Mountain 694 34 101 74 101 44 896 40 23

Pacific 3,667 39 119 73 103 39 3,889 40 6

Northwest 818 36 109 68 80 44 1,007 40 19

FHIP = Fair Housing Initiative Program. HUD = U.S. Department of Housing and Urban Development.

Notes: The Pacific Region includes Hawaii. The Northwest Region includes Alaska.

Source: Authors’ analysis of the HUD Title VIII Automated Paperless Office Tracking System database

Table 64. Regional Distribution of FHIP-Referred Cases and the Cause Finding and Conciliation Rate for Complaints by Region, FY 2003–FY 2005

Outcome Category Without Testing With Testing

Administrative closure 12% 8%

Conciliation and settlement 34% 63%

No cause finding 50% 23%

Cause finding 4% 6%

N 25,548 542

Source: Authors’ analysis of the U.S. Department of Housing and Urban 

Development Title VIII Automated Paperless Office Tracking System database

Table 63. Case Outcomes for Cases With and Without 

Testing for Complaints, FY 2003–FY 2005

Non-FHIP-Referred 

Complaints

FHIP Organization as a 

Complainant

FHIP Organization as a 

Representative for a 

Complainant Total

Testing 15% 72% 13% 100%

N 83 391 68 542

FHIP = Fair Housing Initiative Program.

Source: Authors’ analysis of the U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System database

Table 62. Testing as Part of a Complaint for Non-FHIP-Referred and FHIP-Referred Complaints, FY 2003–FY 2005
Study of the Fair Housing Initiatives Program
	

Are FHIP Organizations Critical to Investigating Complicated Cases? 

Differences between outcomes for FHIP-referred and non-FHIP-referred complaints could result from a variation in the share 

of protected class types among FHIP-referred complaints. Table 65 shows that FHIP organizations acting as a complainant 

have a much higher rate of being involved in familial status cases and a much lower rate of being involved in race and ethnicity cases, compared with cases in which the FHIP organization is a representative for the complainant, and for non-FHIPreferred complaints. 

Quite striking is that 41 percent of the total cases that FHIP organizations handled as a complainant are familial status complaints compared with 21 percent for FHIP organizations as a representative and 14 percent for cases in which FHIP organizations were not involved (Table 66). Equally striking is that only 25 percent of the cases that the FHIP organization acted as 

the complainant were race and ethnicity cases compared with the 51 percent of the non-FHIP-referred complaints. 

FHIP organizations also play an extremely important role in bringing design and construction complaints forward. They are 

involved in 42 percent of the design and construction complaints. 

In some instances, HUD is required to refer cases to DOJ for further investigation. For example, DOJ has exclusive authority for investigating zoning and land use cases. In addition, it has exclusively delegated authority to investigate pattern and 

practice cases and can pursue investigations beyond HUD’s 1-year statute of limitations. 

Table 67 shows that although FHIP organizations are involved in only 10 percent of all cases referred to HUD and FHAP 

agencies, FHIP organizations seem to play an important role in pattern and practice cases and a modestly important role in 

zoning/land use cases. 

FHIP organizations, particularly when they are the complainants, are key contributors to familial status, design and construction, and pattern and practice cases. For these types of cases, they participate in 40 to 60 percent of these complaint 

types, although they are involved in only 10 percent of all cases referred to HUD or FHAP agencies. 

The summary of findings from this section include (1) FHIP organizations act as a filter of nonjurisdictional complaints, and 

FHIP-referred complaints are much more likely to result in a finding of cause or conciliation than are complaints from other 

sources; (2) complaints in which FHIP organizations are a complainant are more likely to be closed as a conciliation or 

cause finding compared with complaints in which FHIP organizations act as a representative to the complainant and with 

non-FHIP-referred complaints; (3) FHIP organizations are the primary source for testing evidence associated with complaints and rely heavily on FHIP grants as a stable source of funding for enforcement and testing activities; and (4) FHIP 

organizations play an important role in complex complaints relating to design and construction cases and pattern and practice cases, and these more complex FHIP-referred complaints may be the reason why FHIP-referred cases may take longer 

to close than non-FHIP-referred complaints. 

Non-FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as a 

Representative for a 

Complainant Total 

Table 65. Proportion of Cases by FHIP Referral Type—Complaints Closed, FY 2003–FY 2005 

Race/ethnicity 51% 25% 46% 50% 

Disability 39% 39% 38% 39% 

Gender 10% 4% 11% 10% 

Familial status 14% 41% 21% 16% 

Other 4% 1% 3% 4% 

Total* 118% 108% 119% 118% 

N 23,587 915 1,487 25,989 

FHIP = Fair Housing Initiative Program.
�

*Sum of the subgroups adds to greater than 100 percent of the total due to multiple class cases.
�

Source: Authors’ analysis of the U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System database
�

59
Study of the Fair Housing Initiatives Program
	

Non-FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as a 

Representative for a 

Complainant Total 

Table 66. Proportion of Design and Construction Cases by FHIP Referral Type—Complaints Closed, FY 2003–FY 2005 

Design and construction 58% 37% 5% 100%
�

N 85 54 7 146
�

FHIP = Fair Housing Initiative Program.
�

Source: Authors’ analysis of the U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System database
�

DOJ 

Referrals 

Non-FHIP-Referred 

Complaints 

FHIP Organization as a 

Complainant 

FHIP Organization as a 

Representative for a 

Complainant Total 

Table 67. Proportion of Types of DOJ Investigations by FHIP Referral Type—Complaints Closed, FY 2003–FY 2005 

Criminal prosecutions 100% 0% 0% 100%
�

N 25 0 0 25
�

Other cases 79% 7% 14% 100%
�

N 11 1 2 14
�

Pattern and practice 44% 46% 9% 100%
�

N 43 45 9 97
�

Zoning/land use 78% 7% 15% 100%
�

N 102 9 20 131
�

DOJ = U.S. Department of Justice. FHIP = Fair Housing Initiative Program.
�

Source: Authors’ analysis of the U.S. Department of Housing and Urban Development Title VIII Automated Paperless Office Tracking System database
�

60
 
Study of the Fair Housing Initiatives Program
	

References --

Abravanel, Martin D. 2002. Public Awareness of Fair Housing Law: Does It Protect Against Housing Discrimination? Housing Policy Debate 13 (3): 469–504. 

Fair Housing Center of Greater Boston. 2006. The Gap Persists: A Report on Racial and Ethnic Discrimination in the Greater 

Boston Home Mortgage Lending Market. Fair Housing Center of Greater Boston, Boston, MA. Also available at http://www. 

bostonfairhousing.org/GapPersists.pdf. 

Wienk, Ron, John Simonson, Robin Ross Smith, Martha Kuhlman, and Jennifer Park. 1994. An Evaluation of the FHIP 

Enforcement Initiative Testing Demonstration. Washington, DC: The Urban Institute. 

61
 
Study of the Fair Housing Initiatives Program
	

Additional Reading --

5 U.S.C. Section 301 and Section 306. 1993. Government Performance and Results Act of 1993. Accessed June 2, 2008, 

from http://govinfo.library.unt.edu/npr/library/misc/s20.html. 

31 U.S.C. Section 1115(a) and Section 1116. 

Government Accountability Office. 1997. Fair Housing: Funding and Activities under the Fair Housing Initiatives Program. 

Washington, DC: Government Printing Office. 

Office of Management and Budget. 2004. “Rating the Performance of Federal Programs.” In: Budget of the United States 

Government: Fiscal Year 2004: 47–53. http://www.whitehouse.gov/omb/budget/fy2004/pdf/budget.pdf. (Accessed June 2, 

2008.) 

———. 2004. Detailed Information on the Fair Housing Initiatives Program Assessment. http://www.whitehouse.gov/omb/ 

expectmore/detail/10002186.2004.html. (Accessed March 21, 2008.) 

62
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Study of the Fair Housing Initiatives Program
	

Glossary of Abbreviations and Acronyms --

AEI Administrative Enforcement Initiative 

ALJ administrative law judge 

CDBG Community Development Block Grant 

DOJ U.S. Department of Justice 

EOI Education and Outreach Initiative 

FHA Federal Housing Administration 

FHAP Fair Housing Assistance Program 

FHEO Fair Housing and Equal Opportunity 

FHIP Fair Housing Initiatives Program 

FHO Fair Housing Organization 

FHOI Fair Housing Organizations Initiative 

GPRA Government Performance Results Act 

GTR government technical representative 

HBCU Historically Black Colleges, and Universities 

HUD U.S. Department of Housing and Urban Development 

NFHA National Fair Housing Alliance 

NOFA Notice of Funding Availability 

OMB Office of Management and Budget 

PART Program Assessment Rating Tool 

PEI Private Enforcement Initiative 

QFHO qualified fair housing enforcement organization 

SIP Secretary Initiated Projects 

TEAPOTS Title VIII Automated Paperless Office Tracking System 

63
 
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Fair Housing Initiatives Program Web Survey in A Telephone Instrument Guide Format

Study of the Fair Housing Initiatives Program

Please take a few minutes to complete this survey. DB Consulting is conducting a program evaluation of the Fair Housing 

Initiatives Program on behalf of the U.S. Department of Housing and Urban Development (HUD). This study is intended 

to provide HUD with an in-depth understanding of how fair housing agencies function and what role FHIP funds play in 

supporting their operation. This information may be used by HUD as part of future budget justifications for the program, 

design of new performance measures, and program changes. Your response to the survey is critical to the success and 

validity of this research.

Your participation in this survey is voluntary. The questions have been approved by the United States Office of Management and Budget, number xxxxxx. It is estimated that it will take you between 45 and 90 minutes to complete the survey. 

If you do not have time to complete the survey in one sitting, you can return to it at a later time.

Note that this is a survey of all FHIP agencies receiving grants between FY 2003 and FY 2005. Most of the questions are 

about your agency in 2006, whether or not you received a grant in FY 2005. This is intentional, as we are interested in how 

groups operate in years when they get funding as well as when they do not get funding. We think by asking about 2006, 

the information will be most fresh in your mind and we can analyze the data both by current grantees and former grantees.

To make responding to this survey easier for you, you may choose to use calendar year 2006 or your agency’s fiscal year 

2006, whichever you have better data on budget and program operations. Our objective is to have the best data possible 

for the most recently completed 12 month period.

Contact Information

In case we need to follow up with you to clarify any response, please provide the following contact information:

A) Name of Primary Person Completing Survey: .............................................._________

B) Title: ............................................................................................................_________

C) Phone Number: ..........................................................................................._________

D) Email: .........................................................................................................._________

Questions

Organizational Mission

As part of this evaluation, HUD is trying to understand the variety of models fair housing organizations use nationwide and in what context of the 

agency’s mission does their fair housing work fall. The following questions asked about your organization’s mission and structure:

1) What is the overall mission of your organization?

2) How does fair housing fit within your overall mission?

Exclusive role ..............................................................................................£

Primary role.................................................................................................£

Significant role among several.....................................................................£

Secondary role............................................................................................£

Minor role....................................................................................................£

Appendix
Study of the Fair Housing Initiatives Program 

Organization Structure 

3) Which of the following describes your organization? 

Non-profit ................................................................................................... £

State government ....................................................................................... £

Local government....................................................................................... £

4a) Does your organization have a Board of Directors? 

Yes ............................................................................................................ £

No .............................................................................................................. £

4b) If yes, what is the size of your organization’s Board of Directors (including vacancies)? _______ 

4c) How many of the Board of Director positions are currently vacant? _________ 

4d) Does your Board of Directors include representatives from: 

(a) Other civil rights organizations...........................................................................Yes £ No £

(b) Legal professionals ...........................................................................................Yes £ No £

(c) Residents of the target service area...................................................................Yes £ No £

(d) Landlords or landlord organizations...................................................................Yes £ No £

(e) Real estate agents/organizations.......................................................................Yes £ No £

(f) The lending industry (such as bankers)...............................................................Yes £ No £

(g) Government agencies .......................................................................................Yes £ No £

(h) Faith Based/Clergy............................................................................................Yes £ No £

(i) Other non-profits ................................................................................................Yes £ No £

(j) Unions/Labor Organizations ...............................................................................Yes £ No £

(k) Individuals representing themselves...................................................................Yes £ No £

4e) How many board members have been on the board for: 

(a) 10 years or longer? ...................................................................._________
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(b) 5 to 10 years?............................................................................_________
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(c) 2 to 5 years?.............................................................................._________
�

(d) Less than 2 years?....................................................................._________
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5a) Is your agency an operating member of the National Fair Housing Alliance? 

Yes (skip to 6) .............................................................................................£

No ..............................................................................................................£

5b) If No, is your agency a supporting member of the National Fair Housing Alliance? 

Yes .............................................................................................................£

No ..............................................................................................................£

6) Is it a member of any civil rights organizations? 

Yes .............................................................................................................£

 Specify ________________________________________ 

No ..............................................................................................................£

7) Is it affiliated with other organizations? 

Yes .............................................................................................................£

 Specify ________________________________________ 

No ..............................................................................................................£

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Organization History 

As part of this evaluation, HUD wants to know about organization history and where and whom it generally serves. This information will help 

understand more about FHIP organization stability and the overall geographic coverage by FHIP agencies nationwide. 

8) In what year was your organization founded (legally incorporated)? _________ 

9) In what year did it first become active in fair housing activities? _________ 

10a) Has your agency’s involvement in fair housing activities been continuous since that time or has it been discontinuous (that is, stopped 

doing fair housing activities at some point and then restarted)? 

Continuous (skip to 11) ...............................................................................£

Discontinuous.............................................................................................£

10b) If discontinuous, why did it stop providing fair housing services? 

10c) If discontinuous, in what year did it become active in fair housing activities for the most recent period of continuous activity? 

Service Area and Population 

11a) Please describe your organization’s fair housing primary service area? (That is, the area where you primarily market your program and 

where most of the clients you serve live).
�

Targeted neighborhood(s) ...........................................................................£

A single city ................................................................................................£

A single county ...........................................................................................£

A single metropolitan area...........................................................................£

Multiple cities and/or counties outside of a metropolitan area......................£

Statewide ...................................................................................................£

Multiple states (specify) _______________________.....................................£

Nationwide..................................................................................................£

Other (specify) _________________________...............................................£

11b) What is the approximate population of your fair housing primary service area? (That is, the number of people in the area where you 

primarily market your program and where most of the clients you serve live). ___________________ 

12a) In 2006, did your organization primarily market to a specific population or populations? 

Yes .............................................................................................................£

No (skip to 13) ...........................................................................................£

12b) If yes, what population(s) did your organization primarily market to in 2006 (you may select more than one)?
�

Persons with Disabilities..............................................................................£

Families ......................................................................................................£

Blacks or African Americans .......................................................................£

Hispanics or Latinos ...................................................................................£

Asians.........................................................................................................£

American Indians or Alaska Natives.............................................................£

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Native Hawaiians or Other Pacific Islanders................................................. £

Immigrants.................................................................................................. £

Low-Income ............................................................................................... £

Women....................................................................................................... £

Men ........................................................................................................... £

Other ......................................................................................................... £

 Specify _____________________________________ 

12c) In 2006, did your group limit its fair housing services to only families below a specified income threshold (such as low-income)? 

Yes ............................................................................................................£

No ..............................................................................................................£

13) Please indicate whether or not your organization provided the following fair housing services in 2006 (you may select more than one)?
�

Education and Outreach ........................................................................................Yes £ No £

Investigations Involving Testing...............................................................................Yes £ No £

Non-Testing Investigations (such as interviewing friendly witnesses) .......................Yes £ No £

Referrals to pro-bono or contingency attorneys .....................................................Yes £ No £

Research Involving Testing .....................................................................................Yes £ No £

Other ....................................................................................................................Yes £ No £

 Specify _____________________________________ 

14) If your organization provided other services beyond fair housing in 2006, what were the three largest types of programs provided? 

(a) Largest: ....................................................................................._________
�

(b) Second Largest: ........................................................................_________
�

(c) Third Largest:............................................................................._________
�

15a) How do you market your fair housing services? Check each activity you used in 2006.
�

Yellow pages...............................................................................................£

Radio advertisement ...................................................................................£

Newspaper advertisement ..........................................................................£

Bus advertisement......................................................................................£

Internet advertisement ................................................................................£

Brochures...................................................................................................£

Newsletters.................................................................................................£

Presentations to organizations/civic groups.................................................£

Other ..........................................................................................................£

 Specify _____________________________________

 Specify _____________________________________

 Specify _____________________________________
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15b) Does your organization have a Web page? 

Yes .............................................................................................................£

No ..............................................................................................................£

16a) Do you ask clients how they became aware of your fair housing services? 

Yes .............................................................................................................£

No (skip to 17) ............................................................................................£

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16b) Please indicate (by numbering 1,2,3), the three most common ways clients reported that they learned about your agency? 

Yellow pages..................................................................................... ________
�

Radio advertisement ......................................................................... ________
�

Newspaper advertisement ................................................................ ________
�

Bus advertisement............................................................................ ________
�

Internet advertisement ...................................................................... ________
�

Internet search (Google, Yahoo, etc) ................................................. ________
�

Friend, neighbor, or relative ............................................................... ________
�

Brochures ........................................................................................ ________
�

Newsletters....................................................................................... ________
�

Presentations to organizations/civic groups....................................... ________
�

Referral from another agency............................................................ ________
�

Other ................................................................................................ ________

 Specify _____________________________________ 

Technology 

17a) In 2006, approximately how many of your regular staff had a working computer available for their exclusive use? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

17b) In 2006, approximately how many of your regular staff had a working computer available for their exclusive use that also had access to the 

internet? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

17c) In 2006, did your organization have a working fax machine? 

Yes £ No £

17d) In 2006, did your organization use audio recorders in its fair housing testing? (select only one) 

Yes, all of the time £ Yes, some of the time £ No £ Not legal in our state £ We do not do testing £

17e) In 2006, did your organization use any of the following information services as part of its fair housing work? 

(a) Westlaw ........................................................Yes £ No £

(b) LexisNexis .....................................................Yes £ No £

(c) Census Data .................................................Yes £ No £

(d) Other ............................................................Yes £ No £

 Specify _____________________________________

 Specify _____________________________________

 Specify _____________________________________
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Employees 

At the core of any organization are its employees. HUD wants to know about the characteristics of fair housing employees, their education levels, 

fair housing training and experience, and length of tenure in employment. 

18) How many employees does your overall organization have? 

(a) Full time (35-hour workweek - include volunteers who fill regular staff positions, exclude temporary staff and professional services conducted 

by third-parties such as accounting, bookkeeping, and legal counsel)? 

(b) Part time (less than 35-hour work week - include volunteers who fill regular staff positions, exclude temporary staff and professional services 

conducted by third-parties such as accounting, bookkeeping, and legal counsel)? 

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18c) How many employees work on fair housing activities as a regular part of their job? 

(a) Full time?...................................................................................... ________
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(b) Part time? .................................................................................... ________
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19a) How many of your fair housing staff (both full-time and part-time) provided the following fair housing services in 2006. Please distinguish 

between primary (more than 50%) responsibility and occasional responsibility (less than 50%): 

Responsibility Primary Occasional Total 

(a) Intake? 

b) Education and Outreach? 

(c) Investigation? 

(e) Testing? 

(f) Statistical Analysis/Research? 

(g) Legal Referrals? 

(h) Policy Issues? 

(i) Advocacy? 

(j) Other? 

Speciy______________________________ 

19b) How many of your fair housing staff (both full-time and part-time) belong to each of these racial/ethnic groups? 

(a) Non-Hispanic White? ................................................................... ________
�

(b) Non-Hispanic Black or African-American?.................................... ________ 

(c) Non-Hispanic Asian?.................................................................... ________ 

(d) Non-Hispanic Native Hawaiian or Other Pacific Islander? ............. ________ 

(e) Non-Hispanic American Indian or Alaska Native? ......................... ________ 

(f) Non-Hispanic Other Race or Two or More Races? ........................ ________ 

(g) Hispanic or Latino AND White? .................................................... ________ 

(h) Hispanic or Latino AND Black or African-American?..................... ________ 

(i) Hispanic or Latino AND Asian?...................................................... ________ 

(j) Hispanic or Latino AND Native Hawaiian or Other Pacific Islander? ________ 

(k) Hispanic or Latino AND American Indian or Alaska Native? .......... ________ 

(l) Hispanic or Latino AND Other Race or Two or More Races?.......... ________
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19c) How many of your fair housing staff (both full-time and part-time) are women, and how many are men? 

(a) Women? ...................................................................................... ________ 

(b) Men? ........................................................................................... ________
�

19d) How many of your fair housing staff (both full-time and part-time) have the following as their highest level of education completed? 

(a) Less than high school graduate?.................................................. ________ 

(b) High school graduate only? ......................................................... ________
�

(c) 2-year college degree?................................................................. ________ 

(d) 4-year college degree?................................................................. ________ 

(e) Masters degree? .......................................................................... ________ 

(f) Law degree (J.D.)? ........................................................................ ________ 

(g) Doctorate (Ph.D.)? ....................................................................... ________ 

(h) Not Known?................................................................................. ________ 

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19e) How many of your fair housing staff (both full-time and part-time) have worked for your agency... 

(a) More than 10 years? ................................................................... ________ 

(b) 6 to 10 years?............................................................................. ________ 

(c) 3 to 5 years?............................................................................... ________ 

(d) 1 to 2 years?............................................................................... ________ 

(e) Less than 1 year?........................................................................ ________ 

19f) How many of your fair housing staff (both full-time and part-time) have worked on fair housing issues, whether or not with your agency ... 

(a) More than 10 years? ................................................................... ________ 

(b) 6 to 10 years?............................................................................. ________ 

(c) 3 to 5 years?............................................................................... ________ 

(d) 1 to 2 years?............................................................................... ________ 

(e) Less than 1 year?........................................................................ ________ 

19gi) How many staff in 2006 had responsibility for coordinating tests? _________ 

19gii) If you had a test coordinator(s) in 2006, please describe the testing-related training the test coordinator(s) had received and when they received 

that training. 

19hi) How many staff in 2006 had responsibility for doing complaint intake? _________ 

19hii) If you had intake staff in 2006, please describe the intake-related training that they have received and when they received that training. 

20a) Over the past five years how many different Executive Directors have you had for your organization? 

20b) If different than the Executive Director, over the past five years how many different Fair Housing Program Directors have you had for your 

organization? _________ 

21) How much did your organization spend in FY 2006 on fair housing related staff training and continuing education? 

$_________ 

Budget 

One of the core goals of this evaluation is to understand the financial stability of fair housing organizations from year-to-year. The following questions 

ask about total budget, sources of funding for fair housing activities, and general budget stability from year-to-year. 

22) What was your organization’s TOTAL operating budget for its fiscal year 2006? 

$_________ 

23) What was your organization’s FAIR HOUSING operating budget for its fiscal years: 

(a) 2004? ........................................................................................$________ 

(b) 2005? ........................................................................................$________
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(c) 2006? ........................................................................................$________
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24) For the organization’s fiscal year 2006, please indicate the amount of dollars from each source that supported your FAIR HOUSING operations, 

please distinguish between enforcement activities and education and outreach activities (if unable to differentiate between activities, please provide 

the “Total” amount and indicate “DK” under “Enforcement” and “Education and Outreach”): 

Enforcement Education & Outreach Total 

(a) FHIP PEI $_________ $_________ $_________ 

(b) FHIP EOI $_________ $_________ $_________ 

(c) FHIP FHOI $_________ $_________ $_________ 

(d) CDBG from City, County, or State $_________ $_________ $_________ 

(e) Other funding from City, County, or State $_________ $_________ $_________ 

(f) HUD Housing Counseling Funds $_________ $_________ $_________ 

(g) Proceeds from fair housing settlement(s) $_________ $_________ $_________ 

(h) Realtors $_________ $_________ $_________

 (i) Bankers/Mortgage Companies $_________ $_________ $_________

 (j) Landlords or Associations $_________ $_________ $_________

 (k) Foundations $_________ $_________ $_________

 (l) Charitable Donations $_________ $_________ $_________

 (k) Specify

 ___________________________________ $_________ $_________ $_________

 ___________________________________ $_________ $_________ $_________ 

25a) Over the past five years, would you describe your funding FROM ALL SOURCES for fair housing activities to be: 

Generally increasing over time.....................................................................£

Relatively stable from year-to-year...............................................................£

Up and down modestly from year-to-year ...................................................£

Up and down significantly from year-to-year................................................£

Generally decreasing over time ...................................................................£

25b) Please explain what most affects the stability of your fair housing funding from year-to-year: 

26a) In the past five years (since 2001), has your organization received funds from settlements as a result of lawsuits or administrative complaints? 

Yes .............................................................................................................£

No ..............................................................................................................£

26b) If yes, what is the total amount your organization has received from settlements in the past 5 years as a result of as a result of lawsuits or administrative complaints? $_________ 

Enforcement Activities 

Please answer the following questions if your organization conducted any enforcement activities in 2006, whether or not you received a PEI grant. 

Enforcement activities involve receiving, initiating, and/or investigating fair housing complaints. 

27) Did your organization receive and/or investigate fair housing complaints in 2006? 

Yes .............................................................................................................£

No (skip to 60) ............................................................................................£

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Inquiries 

28) How do you track and log fair housing inquiries (An inquiry is the initial request for assistance on an allegation of what appears to be unlawful housing discrimination)? (check all that apply) 

(a) Each inquiry is recorded in a database ................................................... £

(b) Each inquiry is recorded in a paper file .................................................. £

(c) Inquiry is noted in some other format...................................................... £

(d) Inquiries are not tracked......................................................................... £

29) Are any of the following items collected at time of initial contact? 

(a) Name..................................................................................................... Yes £ No £

(b) Address ................................................................................................ Yes £ No £

(c) Phone ................................................................................................... Yes £ No £

(d) Nature of Inquiry .................................................................................... Yes £ No £

(e) Intake specialist response ..................................................................... Yes £ No £

30a) From how many individuals or organizations (excluding your agency) did the agency receive a fair housing inquiry in 2006? 

30b) How many FAIR HOUSING investigations were “agency initiated” (for example, initiation of a systemic investigation based on renting patterns in a 

community)? 

31) How many of the FAIR HOUSING inquiries and other investigations in 2006: 

(a) Led to fair housing complaints filed with HUD or FHAP?........................._________or none £

(b) Led to fair housing suits filed in court? ..................................................._________or none £

(c) Were resolved by your organization outside of HUD/FHAP or court? ....._________or none £

(d) Were investigated but no discrimination was confirmed? ......................._________or none £

(e) Still under investigation? ........................................................................_________or none £

(f) Led to evidence being referred to the Department of Justice? ................_________or none £

(g) Were referred to a state licensing agency? ............................................_________or none £

(h) Were referred to the State Attorney General? ........................................_________or none £

(i) Were referred to a state non-FHAP agency? ..........................................._________or none £

(f) Resulted in some other outcome? 

Other Outcome 1: ______________________________ ......................._________

 Other Outcome 2: ______________________________ ......................._________

 Other Outcome 3: ______________________________ ......................._________
�

32) What are the total number of FAIR HOUSING inquiries where the agency conducted some sort of an investigation in 2006 (an investigation is any 

proactive work by the fair housing agency to obtain evidence to validate the potential complaint)? _________ 

33a) How many of the FAIR HOUSING inquiries from individuals were investigated using FHIP PEI funds?_________or none £

33b) How many of the “agency initiated” FAIR HOUSING investigation were conducted using FHIP PEI funds?_________or none £

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34) In 2006, of investigations undertaken, how many were: 

Number 

What proportion of inquiries investigated were investigated 

with PEI funds? 

All Some None 

(a) Rental _________ £ £ £

(b) Sales _________ £ £ £

(c) Lending _________ £ £ £

(d) Insurance _________ £ £ £

(e) Other _________ £ £ £

35) In 2006, did your FHIP investigate any inquiries involving the following protected classes? If yes, were any investigated using PEI funds? 

(a) Race ..................................................................................Yes £

(b) Color .................................................................................Yes £

(c) National Origin ...................................................................Yes £

(e) Familial Status ...................................................................Yes £

(f) Sex ....................................................................................Yes £

(g) Religion .............................................................................Yes £

(l) Design and Construction ....................................................Yes £

(m) Disability (excluding design and construction) ...................Yes £

(h) Other _________________ .................................................Yes £

 No £ ; 

No £ ; 

No £ ; 

No £ ; 

No £ ; 

No £ ; 

No £ ; 

No £ ; 

No £ ; 

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

With PEI? Yes £

 No £

No £

No £

No £

No £

No £

No £

No £

No £

36) Did you do any investigations in 2006 that used consultants or specialists? 

Yes ................................................................................................ £

No (skip to 38) ............................................................................... £

37) For investigations that used consultants or specialists, what types of service did they provide? 

(a) Engineering/Architecture ....................................................Yes £

(b) Statistical Analysis..............................................................Yes £

(c) Other .................................................................................Yes £

 No £

No £

No £

Fair Housing Testing 

38) Does your organization conduct fair housing tests? 

Yes ................................................................................................ £

No (skip to 60) ............................................................................... £

For organizations conducting fair housing tests: 

39) Is there a staff person charged with coordinating tests? 

Yes ................................................................................................ £

No (skip to 41) ............................................................................... £

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40) If yes, approximately how much of that person’s time in a year is dedicated to coordinating tests?
�

“All”............................................................................................................ £

“Three-quarters” ........................................................................................ £

“Roughly Half”............................................................................................ £

“One-quarter or less” ................................................................................. £

41) Do you have documented tester training manual? 

Yes ............................................................................................................ £

No (skip to 43) ........................................................................................... £

42) If yes, please describe how you developed the tester training manual (you may indicate more than one)?
�

Primarily locally developed ......................................................................... £

Primarily NFHA developed manual ............................................................. £

Primary Housing Discrimination Study (HDS) manual ................................. £

Other ___________________________________ ......................................... £

43) Indicate if any testers were recruited in 2006 from the following methods: 

Referrals from current testers.............................................................. Yes £ No £

Informal referrals from staff acquaintances .......................................... Yes £ No £

Social service agencies....................................................................... Yes £ No £

Graduate school ................................................................................. Yes £ No £

Actors guilds or similar........................................................................ Yes £ No £

Advertising in a public paper or posting flyers...................................... Yes £ No £

No testers recruited in 2006 ....................................................................... £

44) Of the testers conducting tests in 2006, about what proportion were NEW testers in 2006?
�

“All”.............................................................................................................£

“Three-quarters” .........................................................................................£

“Roughly Half”.............................................................................................£

“One-quarter or less” ..................................................................................£

45) Of the testers conducting tests in 2006, about what proportion had attended a tester training session in 2006?
�

“All”.............................................................................................................£

“Three-quarters” .........................................................................................£

“Roughly Half”.............................................................................................£

“One-quarter or less” ..................................................................................£

46) How did you compensate the majority of your testers in 2006? 

Volunteers (no compensation) .....................................................................£

Paid an honorarium or stipend ....................................................................£

Paid staff (hourly or salary) .........................................................................£

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47) Approximately what proportion of your testing in 2006 was based on a complaint of discrimination from an individual complainant (excluding your 

own “agency initiated” tests or tests initiative at the request of HUD or a FHAP agency)? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

48) Approximately what proportion of your testing in 2006 was “agency initiated” (for example, initiation of a systemic investigation based on renting 

patterns in a community)? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

49) Were any tests conducted in 2006 in response to a request from HUD or FHAP agency? 

Yes .............................................................................................................£

No ..............................................................................................................£

50) Did your agency conduct any tests in 2006 for the housing industry as part of a “self-testing” program? 

Yes .............................................................................................................£

No .............................................................................................................£

51) Did your agency conduct any tests in 2006 as part of a research project (such as to measure the level of discrimination in your community)? 

Yes .............................................................................................................£

No .............................................................................................................£

52) Did your agency conduct any tests in 2006 for compliance testing in response to a settlement or court order? 

Yes .............................................................................................................£

No .............................................................................................................£

53) How many TOTAL fair housing tests were conducted by the agency in 2006? _________ 

54) How many TOTAL fair housing tests were conducted by the agency in 2006 that were funded with FHIP PEI funds? _________ 

55) Please indicate if in 2006 you conducted one or more of the following type of fair housing test: 

(a) Rental ............................................................................................Yes £ No £

(b) Sales..............................................................................................Yes £ No £

(c) Lending..........................................................................................Yes £ No £

(d) Insurance.......................................................................................Yes £ No £

56) Please indicate if in 2006 you conducted one or more of the fair housing test for these protected classes: 

(a) Black or African American ..............................................................Yes £ No £

(b) Hispanic or Latino ..........................................................................Yes £ No £

(c) Asian..............................................................................................Yes £ No £

(d) American Indian or Alaska Native ...................................................Yes £ No £

(e) Native Hawaiian or Other Pacific Islander........................................Yes £ No £

(f) Other Race......................................................................................Yes £ No £

(g) Other Color ....................................................................................Yes £ No £

(h) Religion..........................................................................................Yes £ No £

(i) Sex..................................................................................................Yes £ No £

(j) National Origin.................................................................................Yes £ No £

(k) Familial Status ................................................................................Yes £ No £

(l) Design and Construction .................................................................Yes £ No £

(m) Physical Disability (excluding design and construction) .................Yes £ No £

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______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

(n) Sensory Disability (excluding design and construction) ......................................Yes £ No £

(o) Mental Disability (excluding design and construction) .......................................Yes £ No £

(p) Other ................................................................................................................Yes £ No £

57) Approximately what proportion of your testing is done through in-person visits? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

58) Approximately what proportion of your testing based on individual (non “agency-initiated”) complaints in 2006 resulted in some type of enforcement action? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

59) Approximately what proportion of your agency initiated testing in 2006 resulted in some type of enforcement action? 

“All” £ “Most” £ “Roughly Half” £ “A few” £ “None” £

Education and Outreach Activities 

Please answer the following questions if your organization conducted any education and outreach activities in 2006, whether or not you received 

an EOI grant. Education and outreach activities are activities that include developing education materials, analyzing local impediments to housing 

choice, providing housing counseling and classes, convening meetings that bring together the housing industry with fair housing groups, developing technical materials on accessibility, and mounting public information campaigns. 

60) Did your organization undertake any FAIR HOUSING education and outreach activities in 2006? 

Yes .............................................................................................................£

No (skip to 70) ............................................................................................£

61) Please indicate which of the listed fair housing education materials your organization uses in its education and outreach activities (please only 

indicate a brochure is used if 10 or more individuals received or used the material in 2006). 

Fair Housing: Equal Opportunity for All (English/Spanish) - HUD .............................................................................................. 

Fair Housing Act Design Manual - HUD.................................................................................................................................... 

Fair Housing for HOME Participants - HUD .............................................................................................................................. 

Fair Housing Planning Guide - HUD ......................................................................................................................................... 

Putting Your Home on the Loan Line is Risky Business (English/Spanish) - Federal Reserve .................................................... 

62) If you used other educational materials in 2006 created by an outside group, please provide the names and source of each (for example, a 

brochure developed by the National Fair Housing Alliance (NFHA), your state’s civil rights office, or another fair housing group):

 i. Name: __________________________________ Source: ______________________________ 

ii. Name: __________________________________ Source: ______________________________ 

iii. Name: __________________________________ Source: ______________________________ 

63) Has your organization developed its own education materials (only indicate “yes” if the materials are currently used in your education and 

outreach activities)? 

Yes .............................................................................................................£

No (skip to 65) ............................................................................................£

64) For educational material developed locally, please provide a title, purpose, target audience, language, and if its development was paid for 

with the FHIP EOI grant (if more than three developed, list three used most often in 2006).

 i. Title of locally developed material 

Purpose (i.e., How to spot a predatory loan) 

A–13
 
Study of the Fair Housing Initiatives Program 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

______________________________________________________________________________________________________________________ 

 

 

 

 

 

 

 

 

 

 

 

 

Target Audience (i.e., Hispanic homebuyers) 

Language (i.e., English) 

Funded with current or past EOI grant: ................................. Yes £ No £

ii. Title: 

Purpose: 

Target Audience 

Language : 

Funded with current or past EOI grant: ................................. Yes £ No £

iii. Title: 

Purpose: 

Target Audience 

Language : 

Funded with current or past EOI grant: ................................. Yes £ No £

65) Please describe any fair housing education material that you think HUD should be developing and producing. 

66) What types of Education and Outreach activities did your organization undertake in 2006? For each, indicate if it was undertaken at all followed by whether or not it was funded all or partially with FHIP EOI funds. 

(a) Develop education materials?.................................................................... Yes £ No £ ; With EOI? Yes £ No £

(b) Distribute education materials? ................................................................. Yes £ No £ ; With EOI? Yes £ No £

(c) Analyze local impediments to housing choice?.......................................... Yes £ No £ ; With EOI? Yes £ No £

(d) Provide housing counseling and classes? ................................................. Yes £ No £ ; With EOI? Yes £ No £

(e) Convene meetings that bring together the housing industry with 

 fair housing groups?.................................................................................. Yes £ No £ ; With EOI? Yes £ No £

(f) Develop technical materials on accessibility?.............................................. Yes £ No £ ; With EOI? Yes £ No £

(g) Mount media campaign(s)? ....................................................................... Yes £ No £ ; With EOI? Yes £ No £

(h) Training to landlords/management agencies?............................................ Yes £ No £ ; With EOI? Yes £ No £

(i) Training to real estate agents? .................................................................... Yes £ No £ ; With EOI? Yes £ No £

(j) Training to lenders? ................................................................................... Yes £ No £ ; With EOI? Yes £ No £

(k) Training to local government officials?........................................................ Yes £ No £ ; With EOI? Yes £ No £

(l) Other (specify) ........................................................................................... Yes £ No £ ; With EOI? Yes £ No £

67) How many total people received direct fair housing education or training from your organization in 2006? 

68) How many separate organization’s did you provide fair housing training to their staff in 2006? 

69) Do you undertake customer service survey of individuals after they receive training? 

Yes .............................................................................................................£

No ..............................................................................................................£

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Study of the Fair Housing Initiatives Program 

 

 

 

FHIP Program Overall 

This final section of the survey is seeking information on challenges with current FHIP program implementation and your opinions on possible 

program changes. 

70) To what extent have there been implementation problems, notable hardships, or significant costs associated with the administration of your 

FHIP grant? 

(a) Implementation Problems .................................................................................Yes £ No £

(b) Notable hardships ............................................................................................Yes £ No £

(c) Significant costs ...............................................................................................Yes £ No £

(d) If yes to any, please specify __________________________________________________________ 

71) What are the most significant challenges for organizations fair housing program? 

Very 

significant 

Somewhat 

significant 

Not at all 

significant 

Consistent funding for enforcement operations £ £ £

Consistent funding for education and outreach activities £ £ £

Staff retention £ £ £

Staff expertise/training £ £ £

Other_____________ £ £ £

72) Please rate your agreement with the following statements about HUD’s role in supporting private fair housing organizations with appropriation 

levels held constant? 

Agree a lot 

Agree a 

little 

Disagree a 

little 

Disagree a 

lot 

HUD should set standards for FHIP agency investigations £ £ £ £

Standards for testing should be developed so FHIP agencies could have “certified 

testing programs” £ £ £ £

Make all PEI grants 3-year awards, but have fewer PEI and EOI grants each year £ £ £ £

Discontinue PEI 3-year awards and fund more EOI grants £ £ £ £

Discontinue PEI 3-year awards and fund more PEI grants £ £ £ £

Reinstate the FHOI Program and have fewer overall PEI grants £ £ £ £

73) In your own words, in what ways do the services your group provides add value to promoting and enforcing fair housing laws? 

74) Please tell us what things you see as being problems with the FHIP program and what you think might be done to fix those problems. 

75) Please use the following space to provide any further comments on either the challenges facing FHIP agencies, HUD’s role in supporting 

FHIP agencies, or concerns that were not captured in the survey. 

Thank you very much for your participation in this survey. If you have any questions regarding the survey please contact the survey director, xxx 

of DB Consulting group, toll-free at 1-888-xxx-xxxx or email at xxx@DBConsulting.com. 

A–15
 
B–1

Interviewer Guide for Key Informants of the B Program History

Study of the Fair Housing Initiatives Program

Appendix

Introduction

HUD & DB’s role

The basic purposes of these telephone interviews are to obtain information. To understand better the history of the Fair 

Housing Initiatives Program (FHIP), HUD has asked DB Consulting Group, Inc. to conduct interviews with key informants 

from the history of the FHIP program. These interviews are necessary to gather a full history of FHIP and to understand how 

the recipients have changed over the years. Through these telephone interviews, we will gather anecdotal information that 

may only be available through interviews rather than a document review.

Use of the information

The data collected will be used to create a full history of the FHIP program from 1988 until 2006. The principal user of the 

data is the United States Department of Housing and Urban Development (HUD).

Description

This telephone interview should take about 30-45 minutes of time for you to complete. You will tape record the conversation and will complete a summery of the interview afterwards. Interviews will have been previously scheduled via telephone 

and advance letters will have been sent to the key informants reminding them of their scheduled interview time and the 

purpose of such interview.

Confidentiality

This interview is confidential. You must avoid mentioning or disclosing any materials that would link a specific interviewee with 

the interview outside of DB. When discussing your job you should never reveal any information, you obtain during an interview 

with an unauthorized person. Unauthorized disclosure of individual information collected is subject to federal privacy protections. Unauthorized disclosure of information and the falsification of information are immediate grounds for dismissal.

You must assure respondents that the information provided will be used solely for the purpose of the study and only by HUD.

Conducting the Telephone Interview 

	 n Introducing the interview 

All of these steps must be followed in all cases:

 a. Introduce yourself. Give the following introduction (or a similar one):

“I am ___ from DB Consulting Group, Inc., on behalf of the United States Department of Housing and Urban 

Development. We are conducting telephone interviews of key informants of the history of the Fair Housing 

Initiatives Program throughout the country.”

 b. Introduce the Advance Letter:

“You may remember receiving a letter a few days/weeks ago. This letter explains the interview. I would 

like to take the time to read this important information to you now.” Read the key points in the letter to the 

respondent.

 c. Then ask:

“Do you have any questions regarding what I have read/you have read about the interview?
Study of the Fair Housing Initiatives Program 

 

 

d. After answering this question ask:
�

“Are you able to conduct the interview at our scheduled time?”
�

If so, begin explaining the interview to the respondent.
�

If the response is no: 

If a respondent is not available, (this should not be the case since the interviews have been prescheduled) 

begin to explain again the purpose of the interviews and the time sensitive 

Explaining the telephone interview/survey 

n General explanation 

Building rapport with respondents begins when you first call them and they answer the phone. Maintaining this 

rapport throughout the interview is critical to ensuring that you collect full and valid information. Providing a 

sincere and friendly atmosphere with the respondent will foster honesty and full answers. 

A few respondents will want additional information about the interview. Try to identify his/her specific objections 

and tailor your answer accordingly. A thorough understanding of the interview is key to a good explanation. 

You may provide the following general explanation: 

“Your participation is critical to providing a full history of the FHIP program. Please be as candid and detailed 

in your answers. Please be assured that your answers will not be used outside of the study and history that is 

being created for HUD.” 

Duration 

“The interview will take 30-45 minutes to complete.” 

Beginning the Interview 

How to ask questions 

Ask questions exactly as worded and ask every question. Since the interview involves gathering information for to create a 

history, respondents may offer information that is not asked. Please follow up on such responses by asking, “Why is that?” 

The point of the interview is to gain as much knowledge of the history of FHIP as possible. If a respondent misunderstands 

or misinterprets a question you can repeat the question and give the respondent another chance to answer the question. 

Getting Respondents to answer 

When a respondent’s answers do not meet the objective of the question, you can probe to clarify an answer. Brief assenting comments show the respondent that you are giving your attention to an answer and stimulate them to talk further. You 

should expect pauses during the interview, so please give the respondent time to answer a question. Repeating a question 

is useful when a respondent does not understand or misinterprets a question, is indecisive about and answer or strays from 

the subject. Repeating the respondents answer is also useful in helping to clarify responses and prompting the respondent 

to enlarge his/her statement. Please refrain from interjecting your ideas, which may influence interviewee responses. 

Clarifying answers 

Neutral questions and probes in a neutral tone of voice will elicit clear answers. These types of questions will show interest; 

however, you must quickly recognize when respondents answers fail to meet the question’s objective and when it is necessary to get correct information. Maintaining rapport is key to eliciting answers while attempting to clarify answers. Your manner of answering questions must not be demanding or sharp. When a respondent provides an unclear answer, there are 

techniques to obtain a clearer answer. One such technique that you may wish to use sparingly is to indicate in your probe 

that is you who does not understand the question. This may arouse the respondents desire to help. Stimulating discussion 

does not mean unnecessarily prolonging the interview or influencing respondent answers. 

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Study of the Fair Housing Initiatives Program 

 

 

Interviewer demeanor 

Your role as an interviewer is to remain objective. In order to do this you must adopt a professional and friendly businesslike-attitude. Your tone and attitude is key to developing a rapport that will elicit answers. You must not indicate personal 

opinion about replies to questions including your tone of voice. 

Respondents 

HUD and DB have already identified the key informants and will provide their information to you. Persons to be interviewed 

will include HUD headquarters officials, executive directors of fair housing organizations, and authors of different fair housing 

articles and books. 

Script 

You will be provided specific questions for the interview that are attached and will use a computer where to input the respondents’ answers to each question. 

Instrument Features 

n The interviewer will collect the information in a computer database. 

Components: 

n Verification of interviewee contact information 

n Questionnaire 

B–3
 
C–1

Interviewer Guide for Case Studies Cfor Data Collection

Study of the Fair Housing Initiatives Program

Appendix

Attachment

Customized Interview Questions for the Site

Introduction

HUD & DB’s role

The basic purpose of these site visit interviews is to obtain information. To understand better the process by which a Fair 

Housing Initiatives Program (FHIP) grantee processes complaints and conducts education and outreach, HUD has asked 

DB Consulting Group, Inc. to conduct interviews with FHIP grantees that were selected through a web survey, grantee 

applications and final reports. These interviews are necessary to conduct a process evaluation of the grantees. Through 

these site visit interviews, we will gather anecdotal information that may only be available through interviews rather than a 

document review.

Use of the information 

The data collected will be used to conduct a process evaluation of FHIPs. The principal user of the data is the United States 

Department of Housing and Urban Development (HUD).

Description

This site visit should take no more than two days to complete. You will tape record any interviews conducted and transcribe 

them. You will also complete a summary of the interview afterwards. You will gather documents that are not confidential for 

analysis. The site visits will have been previously scheduled via telephone and confirmed with letters reminding the agencies 

of their scheduled site visit time and the purpose of the visit.

Confidentiality

This site visit interview is confidential. You must avoid mentioning or disclosing any materials that would link a specific 

interviewee with the interview outside of DB. When discussing your job you should never reveal any information, you obtain 

during an interview with an unauthorized person. Unauthorized disclosure of individual information collected is subject 

to federal privacy protections. Unauthorized disclosure of information and the falsification of information are grounds for 

immediate dismissal. You must assure respondents that the information provided will be used solely for the purpose of the 

study and only by HUD. 

How the Site Visit Should Be Conducted

This guide contains allocation of how to divide the site visit. All of the information provided is subject to change to accommodate the staff of the site. The following information should be used as a guide.

n First Day 

You should conduct as many interviews as you can on the first day. The interview of the Executive Director or 

Program Manager will take approximately two hours. The interviews of other fair housing staff will take approximately one hour each.

After the interviews are complete, the DB staff member should begin collection and review of documents with 

the time remaining on the first day.
Study of the Fair Housing Initiatives Program 

 

 

 

 

 

 

 

n	 Second Day 

The DB staff member should resume collection and review of documents on the second day. If there are other 

questions based upon the information collected onsite, those questions should be asked onsite. Any follow-up 

interviews should take no more than approximately half an hour each. 

Conducting the Site Visit Interview 

Introducing the Interview 

All of these steps must be followed in all cases: 

n	 Introduce yourself. Give the following introduction (or a similar one): 

“I am ___ from DB Consulting Group, Inc., on behalf of the United States Department of Housing and Urban 

Development. I am here to conduct an interview of your staff for a process evaluation of the Fair Housing 

Initiatives Program grantees throughout the country.” 

n	 Introduce the Confirmation Letter: 

“You may remember receiving an e-mail a few days/weeks ago. This letter explains the interview. I would like to 

take the time to read this important information to you now.” Read the key points in the letter to the respondent 

n	 Then ask:
�

“Do you have any questions regarding what I have read/you have read about the interview?
�

n	 After answering this question ask:
�

“Are you able to begin he interview at our scheduled time?” 

If so, begin explaining the interview to the respondent.
�

If the response is no – then set another time for the interview during the visit. Also, remind the interviewee that 

time is of the essence since the interviews were designed to be conducted while onsite. 

Explaining the site visit interview 

n	 General explanation 

Building rapport with respondents begins when you first meet them and introduce yourself. Maintaining this rapport throughout the interview is critical to ensuring that you collect full and valid information. Providing a sincere 

and friendly atmosphere with the respondent will foster honesty and full answers. 

A few respondents will want additional information about the interview. Try to identify his/her specific objections 

and tailor your answer accordingly. A thorough understanding of the interview is key to a good explanation. 

You may provide the following general explanation: 

“Your participation is critical to providing a full evaluation of the FHIP grantees. Please be as candid and detailed 

in your answers. Please be assured that your answers will not be used outside of the study and evaluation that 

is being created for HUD. HUD has agreed to take the answers in aggregate fashion and will not know who 

gave what answer to what question.” 

n	 Duration 

“The interviews will take approximately 30-45 minutes to complete.” Explain that for the program director or 

executive director – it will probably be 1 hour to 2 hours. 

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Study of the Fair Housing Initiatives Program 

 

 

 

 

n Beginning the Interview 

Ask questions exactly as worded and ask every question. Since the interview involves gathering information for 

a process evaluation, respondents may offer information that is not asked. Please follow up on such responses 

by asking, “Why is that?” The point of the interview is to gain as much knowledge of the FHIP grantee as possible. If a respondent misunderstands or misinterprets a question you can repeat the question and give the 

respondent another chance to answer the question. 

n Getting Respondents to answer 

When a respondent’s answers do not meet the objective of the question, you can probe to clarify an answer. 

Brief assenting comments show the respondent that you are giving your attention to an answer and stimulate 

them to talk further. You should expect pauses during the interview, so please give the respondent time to 

answer a question. Repeating a question is useful when a respondent does not understand or misinterprets a 

question, is indecisive about and answer or strays from the subject. Repeating the respondents answer is also 

useful in helping to clarify responses and prompting the respondent to enlarge his/her statement. Please refrain 

from interjecting your ideas, which may influence interviewee responses. 

n Clarifying answers 

Neutral questions and probes in a neutral tone of voice will elicit clear answers. These types of questions will 

show interest; however, you must quickly recognize when respondents answers fail to meet the question’s objective and when it is necessary to get correct information. Maintaining rapport is key to eliciting answers while 

attempting to clarify answers. Your manner of answering questions must not be demanding or sharp. When a 

respondent provides an unclear answer, there are techniques to obtain a clearer answer. One such technique 

that you may wish to use sparingly is to indicate in your probe that is you who does not understand the question. This may arouse the respondents desire to help. Stimulating discussion does not mean unnecessarily 

prolonging the interview or influencing respondent answers. 

n Interviewer demeanor 

Your role as an interviewer is to remain objective. In order to do this you must adopt a professional and friendly 

businesslike-attitude. Your tone and attitude is key to developing a rapport that will elicit answers. You must not 

indicate personal opinion about replies to questions including your tone of voice. 

Respondents 

HUD and DB have already identified the agencies for these visits and will provide their information to you. Persons to be 

interviewed will include executive directors of fair housing organizations, enforcement directors and staff, and education 

directors and staff. 

Script 

You will be provided a laptop and a spreadsheet to capture the respondents’ answers to each question. After each 

interview, you will write a summary and dictate notes into your digital recorder to allow you to complete your interview report 

later. You are to follow-up with your own questions for any issues or interesting items that you see on site. The information 

will be inputted into the interview report at the end of the day’s interviews. 

Equipment 

You will be provided a digital recorder and laptop for the site visits. These pieces of equipment will be your responsibility 

while on-site for these interviews. 

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Study of the Fair Housing Initiatives Program 

 

 

 

 

 

 

 

 

Document Gathering 

You will gather documents during these site visits from the agency. These documents will give more information regarding 

the agencies activities. The list of documents should include but not be limited to the following: 

n Educational materials for the public 

n Marketing materials for different types of media 

n Historical documentation on the agency 

n Any enforcement activity information that is not confidential, including any tester training materials 

n Any past proposals 

n Any HUD reports 

n Any reports to other agencies that are not confidential 

n Any other documents that the agency volunteers. 

These documents can be photocopied and can only be used for the purpose of the research study. Any other use of the 

documentation such as for personal business shall be grounds for immediate dismissal. 

Ending the Visit 

Please thank the agency for hosting you and direct any other inquiries they may have to Tracy McCracken at 877-589-4020 

or Judson James, who is the Government Technical Representative for the study, at 202-402-5707. 

C–4
 
Study of the Fair Housing Initiatives Program D Appendix

Mission Statements of Survey Respondents 

Role of Fair Housing 

Mission in Mission 

Enforcing civil rights laws through compliance, mediation, advocacy, and education.	� Significant role 

among several 

To increase affordable housing opportunities for all. The organization contributes to this mission by helping individuals and Significant role 

families remove barriers to housing choice based upon who they are, not what they can afford. among several 

The mission of the organization is to promote and protect civil rights, particularly the civil rights of poor, minority, and disad- Significant role 

vantaged people, in order to facilitate their participation in the social, economic, and political systems of our nation. among several 

To create affordable housing and community development opportunities for very low- to moderate-income families and Significant role 

individuals. among several 

We are part of a legal aid program that provides free civil legal services to low-income and disadvantaged people. Significant role 

among several 

Housing is a basic human right, which is integral to the well-being of both the individual and the community. The organiza- Significant role 

tion is an innovative, regional non-profit corporation, whose purpose is to improve the quality of life by improving housing among several 

conditions for all residents of area, particularly low-income households, those with special needs, and those who face 

discrimination. The organization seeks to eliminate physical, economic, and social barriers, thereby, ensuring a broad and 

diverse choice of decent, safe, and affordable housing that meets each individual’s needs and provides secure and stable 

tenure. We work to accomplish this by providing a comprehensive array of services to assist people in securing adequate 

housing at an affordable price; promoting the creation and preservation of affordable housing; and forging partnerships 

with public officials, community groups, and private institutions to build broad-based support and public awareness. 

To plan, develop, and implement programs that foster self-sufficiency through educational, social, physical, and economic Significant role 

development. among several 

The organization is a private non-profit corporation which provides legal representation to farm worker, minority, and low Significant role 

income communities throughout rural areas of the state. Its mission is to provide legal advocacy for the rural poor through among several
�

litigation and community education in priority areas of housing, civil rights, employment, health and environmental justice, 

and education.
�

The organization works to maintain or improve the health of people with HIV/AIDS by resolving their legal issues. Significant role 

among several 

The organization seeks to increase affordable home ownership opportunities for low- and moderate-income immigrants in Significant role 

our city and its suburbs through the provision of technical assistance and counseling, and affordable, accessible second among several 

mortgage loans. Through its work, we help immigrant homebuyers and homeowners to surmount barriers to discrimination, cultural, and linguistic isolation and unfamiliarity with the housing, mortgage, and banking systems in this country. 

The organization fosters the dignity, pride, and self-esteem of people with disabilities and enhances the options available to Significant role 

them, so they may choose and maintain individualized and satisfying lifestyles. We offer peer-oriented independent living; among several 

services; public education, awareness and development; individual and systemic advocacy; and enforcement of civil rights 

on behalf of people with disabilities. We recognize the innate rights, abilities, needs, and diversity of people with disabilities, and work toward their integration into community life, and serve as an agent of social change. 

The primary mission of our organization is to provide equal access to justice for persons not able to pay for legal and Significant role 

other essential services. It is a vehicle for keeping many low-income people from falling permanently into the category of among several 

chronically poor. It is also a vehicle by which many low-income people successfully get back on their feet and become 

self-sustaining. 

Protect, promote, and expand the legal and civil rights of persons with disabilities. Significant role 

among several 

Our commitment is to provide quality civil legal services to individuals and non-profit groups whose circumstances limit Significant role 

their access to legal assistance. As part of our commitment to clients we try to prevent and solve legal problems, so they among several 

will have an opportunity for a more self-reliant life. 

To provide management and oversight over all the U.S. Department of Housing and Urban Development (HUD) and other Significant role 

federal funding received in the city that is designed to assist low- to moderate-income citizens. among several 

D–1
 
Study of the Fair Housing Initiatives Program
	

Role of Fair Housing 

Mission in Mission 

The mission of the organization is to work collaboratively toward the prevention of homelessness and the creation of last- Significant role 

ing solutions for homeless and at-risk families, children, and individuals throughout our state. The organization advocates among several 

for and provides a continuum of housing and a variety of services to improve the health, well-being, and stability of those it 

serves. 

Promoting equal, affordable, and accessible housing opportunities for all. Significant role 

among several 

The organization is committed to providing high-quality civil legal advice, representation, and education to the disadvan- Significant role 

taged of our coverage area, so as to protect their personal safety, enhance their opportunities and living conditions, and among several 

promote self-sufficiency. Our work helps our clients deal with many of life’s most basic needs: a safe home, enough food 

to eat, a quality education, and protection against exploitation and discrimination. 

The organization’s mission is to facilitate the production and preservation of housing, community, and economic development opportunities in partnership with for-profit and non-profit organizations by leveraging local and federal funds with 

other financing sources to: 

• create and maintain stable neighborhoods, 

• retain and expand the city’s tax base, and 

• promote economic opportunities through community empowerment, and retain and create jobs and business opportunities for the benefit of our city’s residents. 

To use legal skills to reduce the causes and effects of poverty. Significant role 

among several 

The mission of the organization is to positively affect the lives of coverage-area citizens with developmental and other Significant role 

disabilities and their families across the life span, and to work toward increasing their independence, productivity, and among several 

integration into their communities. 

To provide human services and advocacy that will enable African Americans, and other minority groups residing in our Significant role 

metropolitan area, to cultivate and develop their individual and group potential on a par with all other residents of the area. among several 

Our mission is to promote social and economic empowerment as a means of overcoming poverty and dependency, thus, Significant role 

stimulating the sustainable development of communities and its residents, especially those of our coverage area. among several 

The organization offers free legal services for low-income persons and those over 60 who have serious civil legal problems Significant role 

and need legal help to solve them. Our mission is to provide or coordinate the delivery of high quality legal services to low- among several 

income individuals, families, and groups. 

To provide high-quality free legal assistance to low-income residents of our coverage area with civil legal needs. Significant role 

among several 

Provide civil legal services to low-income and elderly residents in housing and benefits cases. Significant role 

among several 

The organization’s mission is to work together with neighbors to provide services and create opportunities, which em- Secondary role 

power individuals, and build strong interdependent communities. 

The mission of the organization, a historically African American university, includes teaching, research, and public service. Secondary role 

To expand its community and public-service role, the organization was established in 1988. The mission of the organization is to address the pressing developmental needs of affordable housing, neighborhood revitalization, and economic opportunity for persons in our city, county, and surrounding rural communities. Funded in part by HUD, the program primarily 

concentrates on housing-related services, including housing rehabilitation, home buyer education and counseling, and fair 

housing education. 

To end discrimination. Secondary role 

To eliminate illegal discrimination in housing, especially racial discrimination, and to promote balanced living patterns. Primary role 

To improve disadvantaged neighborhoods and fund public services and programs through grants management, consoli- Primary role 

dated and neighborhood planning. Also includes funding for affordable housing and economic development activities for 

low- and moderate-income persons. 

To provide all coverage-area citizens, within constitutional limitations, fair housing services that will result in the protection Primary role 

of equal housing opportunity from discrimination based upon race, color, national origin, sex, religion, familial status, or 

disability. 

Our mission is to work to eliminate housing discrimination and assure choice in our coverage area by providing those at Primary role 

risk with effective information, intervention, and advocacy. 

Working to sustain and expand the availability of quality affordable housing for low- and moderate-income residents of Primary role 

our coverage area. We provide outreach, counseling, and education to homeowners, landlords, tenants, and the public 

regarding local housing issues. 

D–2
 
Study of the Fair Housing Initiatives Program
	

Role of Fair Housing 

Mission in Mission 

Serve as a catalyst for coordinating resources and partnerships that promote economic self-sufficiency, family strengthen- Primary role 

ing, and enhance the quality of life for children, families, and seniors. 

To fight housing discrimination in our cover age area and to ensure equal housing opportunities throughout our state. Primary role
�

To end discrimination in housing and public accommodations and to ensure that all people are fairly and decently housed. Primary role
�

To ensure equal access to credit and capital for the under-served populations and communities throughout the state Primary role 

through education, outreach, advocacy, and legislation. 

To ensure that all who seek housing have an equal opportunity to rent, purchase, finance, or insure the property they Primary role 

choose. The organization is a private, non-profit organization, which has effectively served the metropolitan area since 

1975. 

To eradicate housing discrimination in the northern portion of our state through teaching fair housing education and investi- Primary role 

gating complaints of housing discrimination. 

Our mission is the elimination of unlawful housing discrimination and promotion of decent and affordable housing through Primary role 

advocacy and education. 

The organization seeks to eliminate all forms of illegal discrimination that can impede equal access to housing and housing Primary role 

services for all. 

Dedicated to promoting and developing fairness and equal housing opportunity for all people. Primary role 

To promote fair housing, fair public accommodations, and economic opportunities through advocacy, education, and Primary role 

public and/or private partnerships. 

To eliminate housing discrimination in our state. Primary role 

The promotion of a unitary housing market that eliminates discrimination based upon race and all other protected classes, Primary role 

and the fostering of stable, long-term diverse communities. 

The organization is committed to a process of eliminating all forms of housing discrimination in our coverage area through Exclusive role 

fair housing education, enforcement, and advocacy. 

The mission of the organization is to ensure that all people have equal access to housing opportunities in our state. Exclusive role 

Because our state’s low-income residents are particularly affected by discriminatory housing practices, the organization 

devotes its scarce resources principally to assisting the state’s low-income residents. 

Our mission is to promote fair housing and work to eliminate discrimination in housing. Exclusive role 

The organization was established in the early 1960s specifically to combat housing discrimination. The mission is to Exclusive role 

assure the people of seven counties an equal opportunity to live in the housing and communities of their choice through 

education, advocacy, enforcement of fair housing laws, and creation of housing opportunities. 

Our mission is to eliminate housing discrimination and ensure equal opportunity in housing for all people. Specifically, we Exclusive role 

are seeking to eliminate housing discrimination against all persons because of race, color, religion, national origin, sex, 

disability, familial status, and sexual orientation. In furthering this goal, we engage in activities designed to encourage fair 

housing practices through educational efforts; assist people who believe they have been victims of housing discrimination; 

identify barriers to fair housing in order to counteract and eliminate discriminatory housing practices; work with elected and 

government representatives to protect and improve fair housing laws; and take all appropriate action to ensure that the fair 

housing laws are properly and fairly enforced. 

The organization’s mission is to eliminate practices of housing discrimination and to promote diverse, open communities Exclusive role 

through education and advocacy. 

To promote fair housing throughout our coverage area by working to guarantee all people equal access to housing oppor- Exclusive role 

tunities and by working to create and maintain integrated housing patterns. 

To eliminate or reduce unlawful housing discrimination, to inform and educate protected classes of fair housing rights, and Exclusive role 

to inform housing providers of their fair housing responsibilities and obligations. 

To secure fair and equal housing opportunities in our coverage area in accordance with local, state, and federal fair hous- Exclusive role 

ing laws. 

Our mission is to eliminate housing discrimination in our state through education, counseling, and advocacy. Exclusive role 

The mission of the organization is to ensure equal access to housing opportunities for all persons. To achieve its mis- Exclusive role 

sion, the organization educates the public on fair housing laws, provides assistance to individuals who have experienced 

housing discrimination, monitors the community for compliance with applicable housing laws, and offers information and 

counseling on housing-related issues. 

The organization works to eliminate housing discrimination and to ensure equal housing opportunities for all. Exclusive role 

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Study of the Fair Housing Initiatives Program
	

Role of Fair Housing 

Mission in Mission 

A non-profit corporation for the production and protection of affordable housing. The purpose of the corporation is exclu- Exclusive role 

sively for educational and charitable purposes: 

• to produce and to advocate for the production of affordable housing; 

• to prevent from loss of, or displacement from, existing housing; 

• to eliminate discrimination in housing; and 

• to bring together diverse groups and individuals to aggressively work toward solutions. 

We work to eliminate housing discrimination and promote open communities in our metropolitan region. Exclusive role 

The organization is dedicated to eliminating housing discrimination and furthering equal housing opportunities through Exclusive role 

education, outreach, advocacy, and enforcement of fair housing laws. 

The mission is to assure equal access to housing and other related services to the residents of our coverage area. The Exclusive role 

organization will achieve this purpose through education, investigation, and enforcement of applicable laws. 

To educate and advocate for equal access to quality, affordable housing for everyone in our coverage area. Exclusive role 

To ensure equal housing opportunity for all residents of the state. Exclusive role 

To ensure equal housing opportunity and educate the community on the value of diversity. Exclusive role 

To provide equal access to housing through education and enforcement of the fair housing laws. Exclusive role 

To eliminate housing discrimination and ensure equal housing opportunity for all people in our region. Exclusive role 

The organization is dedicated to the creation of racially and economically integrated communities and the elimination of Exclusive role 

housing discrimination. 

Note: References to a survey respondent’s name or coverage area were removed to retain anonymity. 

Source: Survey of Fair Housing Initiative Program grantees 

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E Sample FHIP Grantee Organization Intake Form

Study of the Fair Housing Initiatives Program

Appendix

Fair Housing Council

Intake Sheet

Date:________________________

Case No.:____________________

Interviewer.___________________

Complainant Name(s)_______________________________________________________________________________________

Mailing Address:___________________________________________________________________________________________

_________________________________________________________________________________________________________

Physical Address (if different):________________________________________________________________________________

_________________________________________________________________________________________________________

Phone No.: ( )________________________________ Other No.s.: ( )_________________________________________

Contact Person____________________________________________________________________________________________

Address__________________________________________________________________________________________________

Phone ( )_____________________________________ Message Phone ( )_____________________________________

M F FHH Age_____Marital Status S M W D Other__________________________

Race____________________ National Origin___________________ Disability Y N

U.S. Citizen Y N Other_______________________________________________

Household Income____________________Mo/Yr 

Source of Income/Employer___________________________________________________________

Claimants Source of Income___________________________________________________________

Household Members Source of Income________________________________________________

Reason/Basis for Contacting FHC:______________________________________________________

Other People/Organizations You Have Contacted______________________________________ 

Household Members:

Name Age Race Gender Relationship

Case No.:_______________

A:/Intake.Wpd
Study of the Fair Housing Initiatives Program 

 

 

 

 

 

 

 

__________________________________________________________________________________________________________ 

 

Property Information: 

Name:____________________________________________________________________________________________________ 

Address:__________________________________________________________________________________________________ 

Phone: ( )__________________________________
�

Unit No.:______ Bedrooms:______ Baths:______ Rent Amount $____________ Deposit Amount $___________
�

Application/Credit Check Fee $_________
�

Current Tenant Y N
�

Respondent Information: 

Owner On-Site Manager Maintenance Broker/Management Company Realtor Insurance Company Municipality 

Housing Authority Advertiser Lender Homeowner Association Developer Other______________________________ 

Name:____________________________________________________________________________________________________ 

Address:__________________________________________________________________________________________________ 

Phone: ( )_________________________________________ 

Owner Information: 

Owner On-Site Manager Broker/Management Company Realtor Insurance Company Municipality Housing 

Authority Advertiser Lender Homeowner Association Developer Other________________________________________ 

Name:____________________________________________________________________________________________________ 

Address:__________________________________________________________________________________________________ 

Phone: ( )_________________________________ 

Referral Information: 

Initial Referrals:_____________________________________________________________________________________________ 

Case No.:_______________ 

A:/Intake.Wpd 

E–2
 
Study of the Fair Housing Initiatives Program 

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Complete Chronological Narrative of Client Complaint: 

Page_____ Of _______ 

E–3