We audited the U.S. Department of Housing and Urban Development’s (HUD) Office of Multifamily Housing Programs’ monitoring of civil rights compliance.  Robust monitoring for civil rights compliance is critical to HUD’s goals to support underserved communities.  Our audit objective was to assess the extent to which HUD monitored civil rights compliance in its program activities.

HUD and performance-based contract administrators (PBCA) perform minimal monitoring of civil rights compliance when conducting management and occupancy reviews (MOR) for multifamily properties due to (1) a lack of training and emphasis regarding civil rights monitoring and (2) contract issues with the PBCAs.  From April 1, 2021, through December 31, 2023, HUD and the PBCAs monitored civil rights compliance for only 12 multifamily properties from a statistical sample of 132 properties.  By performing minimal monitoring of civil rights compliance, HUD is missing opportunities to identify discriminatory practices or civil rights violations, thereby missing opportunities to report these concerns to the Office of Fair Housing and Equal Opportunity for resolution.

We recommend that HUD’s Deputy Assistant Secretary for Multifamily Housing (1) implement training at the regional level to provide instruction on and stress the importance of monitoring civil rights compliance as part of the MORs conducted, (2) direct HUD staff to perform all required monitoring of civil rights compliance as part of the MORs conducted, (3) instruct the PBCAs to include the completion of the addendum B checklist as part of the MORs performed by the PBCAs, and (4) provide technical training to the multifamily property owners and management agents on monitoring for civil rights compliance as part of the MORs.