We audited the U.S. Department of Housing and Urban Development’s (HUD) oversight of public housing agencies’ lobbying activities based on information we obtained while resolving recommendations from an audit of the Philadelphia Housing Authority which showed that the Authority engaged in lobbying activities that it failed to disclose.  Our audit objective was to determine whether HUD oversight was adequate to ensure that public housing agencies complied with Federal lobbying disclosure requirements and restrictions.

The audit showed that only 12 of about 3,300 agencies were reported to have engaged in lobbying activities during the audit period.  However, HUD policies generally did not ensure that the agencies that lobbied complied with Federal lobbying disclosure requirements and restrictions.  Of the 12 agencies reported to have engaged in lobbying activities, 9 spent $2.5 million on lobbying activities that they failed to disclose as required.  Four of the nine agencies were participants in HUD’s Moving to Work (MTW) program and spent $1.5 million on undisclosed lobbying activities.  Therefore, the risk of violations appeared to be greater at agencies participating in HUD’s MTW program.  Three of the MTW agencies incorrectly certified that they had not used Federal funds for lobbying.  Also, HUD could not provide all of the required lobbying certifications and disclosures for the 12 agencies on which lobbyists had reported during the review period.  Because HUD failed to implement adequate policies to monitor agencies’ compliance with lobbying requirements, (1) three agencies improperly spent about $129,000 in Federal funds on lobbying activities, (2) HUD lacked assurance that other agencies did not spend Federal funds on lobbying activities or violate other lobbying-related requirements, and (3) HUD risked creating an appearance of a lack of transparency.

We recommended that HUD require corrective action and pursue administrative sanctions as appropriate to address agencies’ violations of Federal lobbying disclosure requirements and restrictions and implement additional control policies or procedures to ensure that agencies comply with lobbying disclosure requirements and restrictions.