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HomeMy WebLinkAbout065519 - General - Contract - US Department of Housing and Urban Development (HUD)Docusign Envelope ID: 8E3D8C4A-87F0-42ED-9EC8-D96lC993840D CSC No. 65519 Assistance Award/Amendment U.S. Department of Housing and Urban Development Office of Administration 1. Assistance Instrument 2. Type of Action N Cooperative Agreement ❑ Grant N Award ❑ Amendment 3. Instrument Number 4. Amendment Number 5. Effective Date of this Action 6. Control Number FF206K256002 1 03/09/2026 75-6000528 7. Name and Address of Recipient 8. HUD Administering Office CITY OF FORT WORTH Fair Housing Assistance Program 1000 THROCKMORTON US Department of Housing and FORT WORTH, TX 76102-0000 Urban Development UEI: F7RM BTZ8 D1D5 DUNS: 824614754 Washington, DC 20410 8a. Name of Administrator 8b. Telephone Number Erik Steinecker 206-220-5132 10. Recipient Project Manager 9. HUD Government Technical Representative Maya Heard Human Resources Manager, Civil Rights Office Bonita Howard 11. Assistance 12. Payment Method 13. HUD Payment Office Arrangement ❑ Treasury Check Reimbursement Fort Worth Field Accounting ❑ Cost Reimbursement ❑ Advance Check P. O. Box 2905 ❑ Cost Sharing N Automated Clearinghouse Fort Worth, TX 76113-2905 N Fixed Price 14. Assistance Amount 15. HUD Accounting and Appropriation Data Previous HUD Amount $0.00 15a. Appropriation Number 15b. Reservation number HUD Amount this action $30,600.00 ............................................................................................................................................................................................ 86 25/26 0144 FHEO-06-25-1 ........................ . Total HUD Amount.....................................$30,600.00................_..............................................Amount Previously Obligated....................$0.00..............................................._............ .....................Recipient Amount.........................................$0.00........................... .......Obligation by this action ..................................$30,600.:00.............................................. Total Instrument Amount $30,600.00 Total Obligation $30,600.00 16. Description This instrument authorizes the following funds to be ab bl te o dt theA enc . Fund Description Amount Code Obligated in this Action CPF Case $6,600.00 Processing Funds ACF Administrative $9,500.00 Cost Funds TRF Training $2,500.00 Funds S33 SEE Funds $12,000.00 Total $30,600.00 The Cooperative Agreement is comprised of the following documents: 1. Cover Page - HUD-1044 2. 2025 Contributions Agreement 3. Attachment A: FY2025 Criteria for Processing 4. Attachment B: FY2025 Standards for Timeliness 5. Attachment C: Payment Amounts for FHAP Case Processing 6. Attachment D: Using HUD Systems 7. Attachment E: FY2025 Partnership and Special Enforcement Effort Funds 8. Attachment F - Mandatory HUD Grant Agreement Provisions The performance period for this Agreement begins 1010112025 and ends 0913012026. The funds obligated by this instrument expire on 0913012030. The recipient must comply with all rules and regulations in accordance with the Fair Housing Assistance Program regulations (24 CFR § 115), the Memorandum of Understanding between the Recipient and HUD (including all subsequent addenda), and the FY2025 FHAP Guidance. 17. N Recipient is required to sign and return three (3) copies of this document to the HUD Administering Office 19. Recipient (By Name) Dianna M. Giordano/Assistant City Manager 18. ❑ Recipient is not required to sign this document. 20. HUD (By Name) Erik Steinecker Director, FHAP Division OFFICIAL RECORD CITY SECRETARY FT. WORTH, TX Signature & Title Date Signature & Title Date (mm/dd/yyyy) (mm/dd/yyyy) Vi-MA" 1�; 64 03/09/2026 '�Z/ 03/09/2026 ATTACHM ENT A FY2025 Criteria for Processing The Criteria for Processing (Criteria) are the standards by which HUD determines whether a complaint, cognizable under the federal Fair Housing Act and processed by a substantially equivalent state or local agency, meets the minimum requirements for quality and timeliness, and identify the documents that must be submitted to HUD in order to receive reimbursement. The Criteria are designed to assure the uniform, timely, and quality processing of housing discrimination complaints processed under substantially equivalent fair housing laws. The Criteria are enumerated under major subheadings, most of which describe the type of closure, (e.g., cause, no cause, conciliation). Subheadings I through III set out criteria that apply to most complaints. Subheadings IV through VII set forth additional criteria specific to particular types of complaint closure. For example, to meet the criteria for an administrative closure, criteria under subheadings I (Complaint Filing), II (Notification), III (Cause and No Cause Determinations), VII (Administrative Closures) may need to be met. An agency must meet the Criteria for each complaint processed and provide all complaint - related documentation identified in the Criteria to HUD within 30 days of completion of complaint processing. Such documentation must be submitted to HUD via the HUD Enforcement Management System (HEMS). An agency's failure to input all required information in HEMS in a timely manner will negatively impact an agency's performance rating. HUD will address a failure to meet the Criteria through performance deficiency procedures including, but not limited to, technical assistance, performance improvement plans, and suspension from FHAP participation. See 24 C.F.R. § 115.307(a)(3) and 24 C.F.R. § 115.210. HUD utilizes complaint closure review forms which combine the Criteria for Processing and the Standards for Timeliness into checklists for each type of complaint closure. These forms are available to FHAP agencies as an additional technical assistance tool to support high quality case processing. I. COMPLAINT FILING A. Quality Requirements: 1. All complaints must be timely filed in accordance with the substantially equivalent state or local fair housing law. 2. All complaints must be in writing, signed by the complainant, and contain the following information: a. The name and address of complainant; b. The name and address of each respondent; If a specific property is involved, the property's address and physical description, such as apartment, condominium, house or vacant lot; and d. A concise statement of the facts, including pertinent dates, constituting the alleged discriminatory housing practice. 3. Where the agency determines that there is insufficient information in the complaint to commence an investigation, the agency must notify the complainant in writing by no later than the fifth (5) day after receipt of the complaint and inform the complainant what information he or she must provide in order to commence an investigation and identify a reasonable timeframe for submitting such information. The agency must notify the complainant that unless he or she provides the required information within the specified timeframe, the agency may dismiss the complaint. 4. The FHAP agency must permit complaints to be filed with the assistance of an authorized representative or organization of the complainant. 5. The FHAP agency must permit complaints to be reasonably and fairly amended at any time. Such amendments may include, but are not limited to: a. amendments to cure technical defects or omissions; b. clarification, amplifications, or amendments of allegations in a complaint; or joinder of additional or substitute respondents. The FHAP agency should consider amended complaints as having been filed on the date the original complaint was filed. 6. If a FHAP agency requires complaints to be notarized, HUD will not reimburse the agency for a complaint not filed because the complainant did not get the complaint 2 notarized. To preserve the rights of aggrieved persons, a FHAP agency must refer such complaints to HUD for investigation under the federal Fair Housing Act as soon as practicable and, where necessary, consent to their reactivation. 7. Pursuant to 24 CFR § 115.210, and the March 7, 2001, memorandum entitled "Limitations on Accepting as Dual -Filings FHAP Cases That Implicate First Amendment," HUD will not reimburse FHAP agencies for complaints that implicate the First Amendment of the U.S. Constitution. The FHAP agency must alert HUD to complaints that it receives that may implicate the First Amendment so that HUD may analyze the complaint and determine if reimbursement is appropriate. These cases include those that are premised on additional protections afforded by state or local law to individuals based on sexual orientation or gender identity or expression that may implicate the first amendment rights of the respondent. 8. Pursuant to a Memorandum of Understanding between HUD and the Internal Revenue Service, the FHAP agency must identify in HEMS whether the property named in a complaint receives Low Income Housing Tax Credits. This is required for every complaint. 9. The FHAP agency must refer complaints to HUD when the agency receives allegations involving a practice that is not prohibited by the substantially equivalent State or local law, but which is prohibited by the federal Fair Housing Act. 10. FHAP agencies should only submit any cases for reimbursement that have a clear, primary basis in a prohibited characteristic that is covered by the plain language of the federal Fair Housing Act. For example, the Fair Housing Act prohibits discrimination based only on the following specifically protected characteristics: race, color, national origin, religion, sex, familial status, and disability. The Fair Housing Act does not include protections related to sexual orientation, gender identity, and gender expression; "source of income"; criminal records; height and weight; nor limited English proficiency. Any submitted complaints based on rights not expressly found in the federal Fair Housing Act and other relevant federal civil rights law will not be reimbursed. 11. If a housing discrimination complaint is filed against a recipient of federal financial assistance and therefore implicates civil rights laws that FHEO enforces other than the federal Fair Housing Act (multi jurisdictional), the FHAP agency shall notify FHEO so that FHEO may process that portion of the complaint. Other civil rights laws enforced by FHEO include: a. Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000(d) (prohibiting discrimination on the basis of race, color or national origin in programs or activities receiving federal financial assistance); b. Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794 3 (prohibiting discrimination based on disability in programs or activities receiving federal financial assistance); Section 109 of the Housing and Community Development Act of 1974, 42 U.S.C. § 5309 (prohibiting discrimination on the basis of race, color, national origin, religion or sex in any program or activity funded in whole or in part by the community development block grant programs); d. Title II of the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq. (prohibiting discrimination based on disability in programs, services and activities made available by public entities); e. Architectural Barriers Act, 42 U.S.C. § 4151 et seq. (providing that buildings, including publicly owned residences, designed constructed, leased or altered with certain federal funds must be accessible to persons with disabilities); and f. Age Discrimination Act of 1975, 42 U.S.C. § 6101 (prohibiting discrimination based on age in programs or activities receiving federal financial assistance). B. Required Documents: A signed, dated copy of the complaint, any requests for amendment(s) to the complaint, and evidence of compliance with the timeframes and requirements identified above. C. Complaint Filing with Multiple Complainants or Respondents: FHAP agencies will be reimbursed only for complaints that involve separate, distinct discriminatory actions that require a separate investigation. Where allegations may be made against two or more respondents, separate complaints should be filed against each respondent only when each respondent's conduct stands alone as a separate violation of the Act. Furthermore, if complainants are married and both are aggrieved persons, a single, joint complaint should be filed. If there are children under age 18 who reside in the household who may have been injured by the alleged discriminatory housing practice(s), they should be listed as "Other Aggrieved Persons" on that same complaint. FHAP agencies should not typically file separate complaints for spouses or children under 18 residing in the household. II. NOTIFICATION A. Quality Requirements: The FHAP agency must notify HUD within five (5) days of receiving complaints that are cognizable under the federal Fair Housing Act. In addition, the FHAP agency must serve notice of the complaint to each complainant and respondent in accordance with the timeframes identified in the substantially equivalent law and the following requirements. The notification letter to the complainant must consist of an acknowledgement of C! receipt of the complaint for filing, the designation of a complaint number, information related to the agency's processing procedures including the name and telephone number of a FHAP agency contact, and the complainant's rights and obligations under the substantially equivalent law, including time limits and choice of forums. 2. The notification letter to each of the respondents must consist of a description of the alleged housing discrimination practice upon which the complaint is based, include a copy of the complaint, and identify the name and telephone number of a FHAP agency contact. The notice to each respondent must advise the respondent of his or her procedural rights and obligations, including the right to file an answer within the timeframe identified in the substantially equivalent law. 3. A person who is not named as a respondent in a complaint, but who is identified as a respondent in the course of the investigation, may be joined as an additional or substitute respondent by service of a written notice. The notice must explain the basis for the agency's belief that the j oined person is properly j oined as a respondent and include information identified in paragraph 2 above. B. Required Documents: For complaints that are filed directly with the FHAP agency, the agency must enter information in HEMS regarding the complaint within five days of receiving the complaint, sufficiently notifying HUD of the complaint. In addition, the agency must provide HUD with a copy of the notification letters sent to the parties and must update HEMS to indicate when the agency sent the notification letters. III. CRITERIA FOR CAUSE AND NO CAUSE DETERMINATION Every cause or no cause determination must be based on an investigation that includes sufficient consideration of the complainant's and respondent's evidence, and a sufficient evaluation of any and all conflicting evidence. A cause or no cause determination must be based on a review of all relevant evidence the agency obtained during the investigation. The agency shall not act as an advocate for either the complainant or respondent and shall weigh the evidence objectively in light of the relevant substantially equivalent law. The basis for the cause or no cause determination must be well -documented. A. Quality Requirements: In addition to the criteria set forth in subheadings I and II above: Before the end of the 30'h day after the complaint is filed, the FHAP agency must initiate a comprehensive investigation of issues raised in the complaint. Respondent's defenses, relevant policies and practices, as well as all other relevant data, must be identified and analyzed and the complainant, respondent, and all relevant witnesses must be interviewed. Contradictions between complainant's allegations and respondent's response must be investigated and when applicable, comparative data must be obtained. Information must be independently 5 corroborated. Simply obtaining respondents' statements rebutting complainant's allegations is insufficient to resolve disputed issues of fact. 2. HUD recommends that FHAP agencies develop investigative plans for every complaint processed that is cognizable under the Fair Housing Act. For guidance on developing an investigative plan, FHAP agencies should refer to Chapter 7 of HUD Handbook 8024.01 REV-2 (Title VIII Complaint Intake, Investigation, and Conciliation Handbook). 3. In planning the investigation, the investigator and his or her supervisor must determine, on a complaint -by -complaint basis, whether on -site inspections and/or interviews are required. For most complaints, on -site inspections and/or interviews are the most thorough way to conduct an investigation. Some cases, e.g., where the complaint does not involve factual disputes or where evidence clearly demonstrates the allegations do not have merit, may not require an on -site visit. 4. During the period beginning with the filing of a complaint and ending with the FHAP agency's determination or charge of discrimination, the agency, to the extent feasible, must attempt to conciliate the complaint (see more detail on criteria for conciliation in Section V of this document). 5. If the agency does not complete the investigative activities with respect to a complaint within 100 days from the date of receipt, it must notify the parties in writing of the reason(s) for the delay. Such notification letters must be sent within 110 days of the filing of the complaint. 6. At the end of each investigation, the agency shall prepare a Final Investigative Report (FIR). A FIR shall be dated and signed by at least one supervisor. The FIR shall contain: a. The names and dates of contacts with the parties and witnesses, except that the report will not disclose the names of witnesses who request anonymity; b. A summary of correspondence and other contacts with the complainant and the respondent; C. A summary description identifying other pertinent records examined; d. A summary of statements by witnesses, if applicable; and/or Interrogatories and answers provided, if applicable. 7. Each Determination shall be signed and dated by an authorized FHAP official. 8. The FHAP agency shall send the closure package to HUD within 30 days of closure. (See B below). 9. The FHAP agency will cooperate with HUD by providing information at regular intervals or upon request related to individual complaint investigations. Upon request, the FHAP agency shall provide status reports for each complaint that is over 100 days old. B. Required Documents: The case file shall include all evidence indicating that a comprehensive investigation was commenced and completed in accordance with the above requirements including, but not limited to: a copy of a signed, dated complaint; a copy of a FHAP agency determination, dated and signed by an authorized FHAP official; proof that a FHAP agency sent its determination letter to all parties; an FIR that meets the above listed requirements; an investigative plan (when such plan exists); a copy of the 100-day letters and evidence that they were sent, if applicable; and all other information pertinent to the investigation, including but not limited to interview notes, documentation of conciliation attempts and, when necessary, independent evidence corroborating respondent's defense(s). IV. CRITERIA FOR POST -CAUSE COMPLAINTS HEARD IN AN ADMINISTRATIVE HEARING, CIVIL ACTION, OR THROUGH JUDICIAL REVIEW In addition to the appropriate criteria set forth in subheadings I, II, and III above: A. Quality Requirements: After a cause determination and a charge of discrimination, or its equivalent, has been issued, and assuming the conciliation was attempted and failed, the complaint must be referred to appropriate counsel to prosecute the charge on behalf of the complainant, at government expense, before an administrative hearing body or civil court. B. Documents Required: HUD will accept such a complaint for reimbursement if the agency provides documentation of such a referral in, for example, correspondence, logs or pleadings. Additionally, the FHAP agency shall provide any final administrative hearing decision, consent decree, or settlement agreement entered to HUD within 30 days of such action. If the agency does not provide this information, HUD may request, and the agency will be required to return, up to 50% of the reimbursement previously paid to the agency for the complaint. ***NOTE: While the agency may obtain reimbursement on these complaints prior to final disposition by an administrative hearing body or a civil court, the agency must subsequently report to HUD the final status of such complaints. See 24 C.F.R. § 115.206(e)(8). FHAP agencies must input final status information directly in HEMS within 30 days of the administrative or judicial determination. C. Post -Cause Administrative Hearings or Judicial Filings: An agency may receive additional funds for engaging in certain post -cause enforcement actions. If, pursuant to the substantially equivalent law, an agency either conducts an administrative hearing or files a civil action upon election to enforce a finding of reasonable cause, HUD may provide additional payment. 7 Where the triggering event (i.e., conduct of administrative hearing or filing of civil action) for the supplemental payment does not occur, an agreement reached after a cause finding will not qualify as an enforcement action for purposes of this supplemental payment. Such cases will be reimbursed as any other cause case unless the disposition is a conciliation agreement (i.e., an agreement signed by the parties and the FHAP agency), in which case it will be reimbursed as any other case closed with a conciliation agreement. Where the triggering event has occurred, a FHAP agency will receive the supplemental payment even where the case is resolved by a subsequent agreement, e.g., through a consent decree. Agencies will receive this increased supplemental payment when the agency has engaged in post -cause enforcement actions and has documented its actions in HEMS. This documentation must occur in order for the GTR/GTM to authorize payment. V. CRITERIA FOR CONCILIATION During the period beginning with the filing of a complaint and ending with the agency's no cause determination or charge of discrimination, the agency, to the extent feasible, must attempt to conciliate the complaint. In conciliating a complaint, agencies must attempt to achieve a just resolution of the complaint and obtain assurances that the respondent will satisfactorily remedy any violations of the rights of the complainant and take actions to ensure the elimination of alleged discriminatory housing practices and the prevention of their occurrences in the future. These standards for conciliation remain in effect even if conciliation/settlement takes place after the agency's cause determination. A conciliation should provide both substantive individual relief for the complainant together with meaningful and effective public interest relief. Substantive individual relief includes both monetary relief and other affirmative relief required to make the complainant whole (e.g., approval or restoration of a housing opportunity, approval of a reasonable accommodation or reasonable modification request). The monetary relief afforded to the complainant should not be de minimis; it should compensate the complainant(s) for the harm alleged and be commensurate with relief obtained in other similar cases. Public interest relief can take a variety of forms depending on the circumstances of a given complaint. Generally, it means the conciliation agreement contains certain provisions such as implementation of nondiscriminatory policies; changes to existing policies and practices; attendance at fair housing training; and/or other action that provides remediation or relief for individuals other than a complainant(s). Public interest relief may also encompass prospective relief such as agreeing to ongoing testing to assure compliance; agreeing to make changes in policies at all a respondent's properties (not just the subject property); participation in education and outreach activities; and/or other affirmative relief that protects the public interest. FHAP agencies should be aware that a pattern of requiring only fair housing training is not meaningful public interest relief. HUD monitors will consider in every case whether other reasonable, appropriate forms of public interest should have been considered. Additionally, public interest relief cannot be meaningful or effective unless reporting and recordkeeping provisions are included to ensure that all required actions are completed. A conciliation should provide both substantive individual relief and meaningful / effective public interest relief and such relief should be recorded into the HEMS record. In addition to the appropriate criteria set forth in subheadings I, 1I, and III above: A. Quality Requirements/Required Documents: The FHAP agency must provide HUD with a signed and dated complaint, a chronology of actions taken up to the conciliation, copies of closure letters sent to the parties indicating that the complaint was closed due to a successful conciliation, together with a copy of the executed conciliation agreement. The conciliation agreement must be in writing, dated and signed by complainant, respondent, and the authorized FHAP agency representative, and include: HUD and FHAP complaint numbers; 2. Names of the parties; 3. Address and description of the subject property; 4. An effective date and the term in which the agreement remains in effect; 5. Relief that remedies the discrimination alleged in the complaint or is otherwise agreed upon by the parties and appropriate based on evidence obtained in the investigation of the matter; 6. As appropriate, relief that adequately vindicates the public interest, and prohibits future discriminatory housing practices by respondent; 7. A statement that the agreement constitutes closure of the complaint at HUD and the FHAP agency; 8. A statement that the agreement shall be made public unless the complainant and respondent otherwise agree, and an authorized representative of the agency determines that disclosure is not required to further the purposes of the substantially equivalent law. Circumstances that may result in partial or complete nondisclosure of a conciliation agreement may include, but are not limited to: Sexual harassment claims; A complainant's physical or mental condition, or medical diagnoses; or The fact that a complainant is a resident in a domestic violence shelter or other protected residence which complainant believes may, if disclosed, be a safety risk. E 9. Provisions that allow the FHAP agency to effectively monitor compliance with the agreement; and 10. A statement that violations of other civil rights laws have been alleged (if applicable). ***NOTE: A conciliation agreement does not prohibit HUD from taking action against respondent under other civil rights laws. When a complaint is subject to concurrent processing by HUD under other civil rights laws, the FHAP agency may not execute an agreement that resolves matters in regard to these laws without HUD's consent. VI. CRITERIA FOR CLOSURES BY SETTLEMENT WITHOUT FHAP AGENCY INVOLVEMENT (A.K.A., WITHDRAWALS WITH RESOLUTION) If complainant and respondent resolve the complaint without the FHAP agency's involvement, the complainant may withdraw the complaint by submitting a withdrawal request to the FHAP agency. In addition to the appropriate criteria set forth in subheadings I, II, and III above: A. Quality Requirements. The withdrawal request must be written; it must be signed and dated by complainant or complainant's authorized representative; identify the respondent(s) to whom the withdrawal applies; contain the HUD and FHAP agency complaint numbers; state the reason(s) complainant seeks to withdraw the complaint; contain a statement that the withdrawal was not obtained by coercion or threat of retaliation from any person, including but not limited to the respondent; and identify the terms of the resolution. B. Required Documents: The FHAP agency must provide FHEO with: a signed and dated complaint; a chronology of the FHAP agency actions prior to the withdrawal request; a copy of the signed and dated withdrawal request; documentation showing that the agency notified the complainant and respondent that the investigation would be terminated as a result of the withdrawal, and that the complainant could re -file the complaint if the terms of the resolution are not satisfied and the re -filing is received within the time limit for filing a complaint under the substantially equivalent law; and a copy of the closure letter. NOTE: The FHAP agency must not encourage or facilitate resolution without its involvement in lieu of proceeding with conciliation. If HUD discovers that such occurred, it will be addressed through performance deficiency procedures. VII. CRITERIA FOR ADMINISTRATIVE CLOSURES Performance Standard 2 in the FHAP regulations, at 24 C.F.R. § 115.206(e)(2), requires that administrative closures only be utilized in limited and appropriate circumstances. It is critical that FHAP agencies not close complaints administratively except under the specific 10 circumstances set forth below. A. Withdrawals without Resolution. If complainant decides to withdraw a complaint, even though the complaint has not been resolved, complainant must submit a withdrawal request. In addition to the appropriate criteria set forth in subheadings I, II, and III above: Quality Requirements: The withdrawal request must: be written; signed and dated by complainant or complainant's authorized representative; identify the respondent(s) to whom the withdrawal applies; contain the HUD and FHAP agency complaint numbers; state the reason(s) complainant seeks to withdraw the complaint; contain a statement that complainant is aware that the withdrawal terminates the FHAP agency's investigation; contain a statement that the withdrawal was not obtained by coercion or threat of retaliation from any person, including but not limited to the respondent. 2. Required Documents: The FHAP agency must provide FHEO: a signed and dated complaint; a chronology of FHAP agency actions prior to receipt of the withdrawal request; a copy of the signed and dated withdrawal request that meets the Quality Requirements set out above; and a copy of the closure letter provided to all parties indicating closure due to withdrawal by complainant without resolution. ***NOTE: If the withdrawal request indicates that there was coercion or threat of retaliation FHAP payment may be denied. B. Inability to Locate Complainant. The FHAP agency may administratively close a complaint when additional information is needed from complainant and he or she cannot be located. In addition to the appropriate criteria set forth in subheadings I, II, and III above: 1. Quality Requirements: If correspondence sent by the agency is returned with an indication that the complainant moved and left no forwarding address, the agency must take the following progressive steps to locate the complainant before administratively closing the complaint: a. Place at least four telephone calls to complainant's residence, cell phone number, and place of employment, two during normal business hours to work number and two during non -business hours to a residential/cell number. If an email address is available, the agency must attempt to email the complainant at least two times. b. Attempt to contact persons identified by complainant at intake to inquire as to complainant's whereabouts. Check other sources in an effort to obtain complainant's current contact information (e.g., telephone directory, Internet searches, postal 11 service, 411 information, utility company, or witnesses previously identified by complainant). d. Send a letter to the complainant's last known address by certified mail, advising complainant of the agency's intent to close the case unless complainant contacts the agency within ten days. If the tenth day elapses without a response, the case may be closed administratively by means of a written notice sent to all parties, including complainant at complainant's last known address. ***NOTE: If the FIR shows that the complaint was closed due to the inability to contact complainant without following the steps outlined above, the FHAP agency will not be reimbursed for processing the complaint. 2. Required Documents: The FHAP agency must provide the following documentation to FHEO: a signed and dated complaint; evidence that the above progressive steps were taken to locate complainant; evidence that the certified letter was returned unclaimed, and a copy of the closure letter sent to the parties indicating closure due to inability to locate complainant. C. Inability to Locate Respondent In addition to the appropriate criteria set forth in subheadings I, II, and III above: 1. Quality Requirements: A FHAP agency must make every effort to identify the correct name and address of each respondent in a complaint. However, there may be circumstances where a respondent cannot be identified or located. If the complaint identifies multiple respondents and only one cannot be adequately identified, the agency must not close the complaint administratively. Rather, the investigation must proceed and further efforts must be made during the investigation to identify the respondent whose correct name or address remains unknown. The complaint may be amended to remove those respondents who could not be located. If a sole respondent or all respondents cannot be identified or located, the complaint may be closed administratively if the agency first takes the following steps: a. The FHAP agency must attempt to obtain additional information from available sources that could result in identifying or locating the respondent, including Internet searches, cell phone numbers, cross reference directories, or property tax records that may identify the owner or prior residents of the property in question and provide enough information to identify or locate the respondent, serve the complainant, and begin the formal investigation. b. If a source appears to know the identity or location of a respondent that 12 the FHAP agency seeks, but that source refuses to provide the information voluntarily, the FHAP agency must subpoena the information. C. As appropriate, the FHAP agency should attempt an on -site visit, which may help locate and identify the respondent. d. If the above efforts to locate or identify the respondent are unsuccessful, a letter must be sent to the complainant giving him or her 10 days to provide information needed to locate or identify respondents. ***NOTE: In the absence of sufficient information, the case may be closed administratively, and written notice by regular and certified mail should be sent to the parties. 2. Required Documents: The FHAP agency must provide the following documentation to FHEO: a signed and dated complaint; evidence that the above progressive steps were taken to locate the respondent, including the signed letters identified in I (d) above giving notice to complainant or complainant's representative, evidence that certified letters were returned unclaimed, and closure letters to complainant or complainant's representative indicating inability to locate respondent(s). D. Failure of Complainant to Cooperate with the Investigation. A complaint may be administratively closed when complainant fails to respond to reasonable requests for information that is needed in order for the FHAP agency to make a determination. In addition to the appropriate criteria set forth in subheadings I, II, and III above: 1. Quality Requirements: a. The FHAP agency must inform the complainants and their representatives of their duty to cooperate with the investigation and the risk of the agency administratively closing the complaint if they fail to cooperate. b. The FHAP agency must make repeated attempts to contact complainants and their representatives by telephone and mail requesting the needed information. If these efforts are fruitless, the FHAP agency must send a letter to the complainant by certified mail return receipt giving complainant at least ten days from receipt of letter to provide the needed information to the agency. If the complainant's cooperation cannot be obtained using the above procedures, and the letter is not returned by the post office (i.e., marked addressee unknown, moved, left no forwarding address, etc.), the complaint should then be closed for failure to cooperate. 13 d. If the complaint is closed for failure of complainant to cooperate with the investigation, a closure letter must be sent to the complainant. 2. Required Documents: The following documents must be provided to FHEO: a signed and dated complaint; evidence that the above progressive steps were taken to obtain complainant's cooperation, including the signed letter identified in l (b) above giving notice to the complainant or the complainant's representative; and a copy of closure letter to the parties indicating closure because of failure of complainant to cooperate with the investigation. E. Lack of Jurisdiction In addition to the appropriate criteria set forth in subheadings I, II, and III above: Quality Requirements: In order to qualify for reimbursement, the lack of jurisdiction must not have been apparent on the face of the complaint at the time of filing, and must have become known only after further investigation. The following are examples of facts uncovered during an investigation that may justify reimbursement for an administrative closure for lack of jurisdiction: a) the complainant has not suffered the alleged harm needed to establish standing; b) the subject property qualifies for an exemption to coverage of both the Fair Housing Act and the substantially equivalent law. Note that if HUD, but not the agency, has jurisdiction over the complaint, the complaint must be referred to HUD for processing. 2. Required Documentation: The FHAP agency must provide the following documentation to FHEO: reason(s) for closing the complaint for lack of jurisdiction that demonstrates why HUD does not have jurisdiction, and that the lack of jurisdiction could not have been determined at intake; copies of closure letter sent to the parties that indicate reason for lack of jurisdiction closure, identify FHAP and HUD complaint numbers, and are signed by authorized FHAP agency official. F. Trial has Begun A complaint must not be closed merely because an aggrieved party has filed a civil action with respect to the same alleged discriminatory housing practice(s). In addition to the appropriate criteria set forth in subheadings I, II, and III above: Quality Requirements: No additional criteria. 2. Required Documents: To receive reimbursement for an administrative closure due to the commencement of a judicial trial the FHAP agency must produce: a document from the clerk of the court in the jurisdiction that hears the complaint or other sufficient documentation demonstrating that a trial has begun. 14 ATTACHMENT B FY2025 Standards for Timeliness Closures of Investigated Complaints 100 days or less: • Non -systemic complaints, not novel or complex, that are settled or conciliated. Includes withdrawals with resolution. • Non -systemic complaints, not novel or complex, where a cause or no cause decision has been made. 300 days or less: • Systemic complaints that are novel or complex, that are settled or conciliated. Includes withdrawals with resolution. 350 days or less • Systemic complaints that are novel or complex, where a cause or no cause decision has been made. Administrative Closures Inability to locate: 100 days or less Lack of jurisdiction: 30 days or less Failure to cooperate: 60 days or less Withdrawal without resolution: 75 days or less Closed because trial commenced: N/A Complaints that are reactivated: N/A Post -cause Enforcement and Final Disposition Actions Upload final status information: 30 days after final order or agreement ATTACHMENT C FY2025 Payment Amounts for FHAP Complaint Processing Conciliation: $3,400 Full Investigation (issue determination): $3,600 Post -cause enforcement action supplemental payments: • Administrative Hearing held: $5,000 • Civil Action filed: $8,000 Administrative Closures: $1,600 Withdrawals with Resolution: $1,600 A conciliation should provide both substantive individual relief for the complainant together with meaningful and effective public interest relief. Substantive individual relief includes both monetary relief and other affirmative relief required to make the complainant whole (e.g., approval or restoration of a housing opportunity, approval of a reasonable accommodation or reasonable modification request). The monetary relief afforded to the complainant should not be de minimis; it should compensate the complainant(s) for the harm alleged and be commensurate with relief obtained in other similar cases. Public interest relief can take a variety of forms depending on the circumstances of a given complaint. Generally, it means the conciliation agreement contains certain provisions such as implementation of nondiscriminatory policies; changes to existing policies and practices; attendance at fair housing training; and/or other action that provides remediation or relief for individuals other than a complainant(s). Public interest relief may also encompass prospective relief such as agreeing to ongoing testing to assure compliance; agreeing to make changes in policies at all a respondent's properties (not just the subject property); participation in education and outreach activities; and/or other affirmative relief that protects the public interest. FHAP agencies should be aware that a pattern of requiring only fair housingtraining ainin is s not meaningful public interest relief HUD monitors will consider in every case whether other reasonable, appropriate forms of public interest should have been considered. Additionally, public interest relief cannot be meaningful or effective unless reporting and recordkeeping provisions are included to ensure that all required actions are completed. A conciliation should provide both substantive individual relief and meaningful / effective public interest relief and such relief should be recorded into the HEMS record. ATTACHMENT D -USING HUD SYSTEMS LOCCS Security Procedures (FHAP) The Line of Credit Control System (LOCOS) is the primary grant disbursement system for HUD programs, including the Fair Housing Assistance Program (FHAP). Grant disbursements are facilitated via the internet through the eLOCCS system. As participants in the FHAP, substantially equivalent state or local agencies are permitted access to LOCCS and eLOCCS. The Department's Rules of Behavior and security guidelines require that the Approving Official for LOCCS transactions be the CEO, Board Officer, or Agency Director of an organization. An "Approving Official" is a LOCCS administrator who manages "users" in LOCCS. The Approving Official cannot be an individual serving in an interim or acting position and must have decision - making authority for the organization. The Approving Official is the only individual permitted to be the Secure Connection Coordinator, and those duties may not be delegated. To comply with IT Security guidelines, each individual with access to LOCCS must safeguard his/her User ID and Password. User IDs and Passwords must NOT be shared with others. Only authorized users should access LOCCS. Please note: there is a requirement for a separate LOCCS User ID and password from Secure Systems access for both users and approving officials. In the event the authorized user leaves the organization, the HUD Government Technical Representative (GTR) assigned to the current grant must be notified and a form IUD-27054 must be submitted to the GTR to terminate the employee who has left the organization and to authorize a new user, to be identified by the FHAP agency. HUD embraces a "Zero Tolerance Philosophy" for failure to secure important financial information. Failure to abide by conditions above or the general Rules of Behavior below applicable to all HUD computer systems will result in the following consequences: access for the individual will be terminated and will not be reinstated. The FHAP agency will be required to identify another individual to assume the role of the disqualified individual (i.e., as the approving official or authorized user). Rules of Behavior for HUD Systems The U.S. Department of Housing and Urban Development has granted access to the FHAP agency to utilize the Department's automated information resources (e.g., HEMS). As a condition of receiving this access the Agency is required to be aware of the Department's system security policies and to abide by these policies. Security policy emphasizes awareness practices for the purpose of safeguarding the Department's valuable information resources. The system user identification (USERID) and password issued to users are the FHAP agency's means to access these resources. They are to be used solely in connection with the performance of the responsibilities as set forth in the job description, contract or agreement(s) with the Department. Use by anyone other than authorized users are expressly prohibited. The authorized user agrees to be responsible for the confidentiality of the assigned information and accountable for all activity with their user identification (USERID). ATTACHMENT D —USING HUD SYSTEMS Further, users agree that you will not provide this confidential USERID/password to another user nor will the user sign on to HUD systems so that another person may access or operate the workstation in the user's absence or on their behalf. Actions of this type constitute a breach of system security and will result in immediate termination of your assigned USERID/password from the system. In addition, authorized users agree to: (a) Log -off the system when leaving the system/workstation area; (b) Refrain from leaving written passwords in the workstation area; (c) Avoid creating a personal password that can be easily associated with you; (d) Avoid posting printouts of sensitive output data on bulletin boards; (e) Avoid leaving system output reports unattended or unsecured; (f) Control input documents by returning them to files or forwarding them to the appropriate contact person in your office; (g) Avoid violation of the Privacy Act which requires confidentiality of personal data contained in government and contractor data files; (h) Immediately contact the HUD Inspector General's Office, as appropriate, regarding any suspected violation or breach of system security; (i) Cooperate in providing personal background information to be used in conducting security background checks to the extent required by Federal regulations; 0) Respond to any inquiries and requests for information you may receive from either the HUD Headquarters or management officials regarding system security practices. (k) Protect all electronic/optical media and hardcopy documentation containing sensitive information and properly dispose of it by shredding hardcopy documentation, or by contacting the HITS Help Desk to dispose of electronic/optical media. (1) Avoid saving sensitive HUD information on the local drive of a laptop, personally owned computer, or other mobile or portable technology ("flash drives", removable/external hard drives, etc.). (m) If sensitive data must be stored on any type of HUD -approved mobile/portable technology (laptops, removable hard drives, "flash drives", etc.), ensure that it is protected via encryption. (n) Individuals who telework or remotely access HUD information should do so only through approved remote access solutions (such as hudmobile.hud.gov), and should safeguard all sensitive information accessed in this manner. ATTACHMENT E FY2025 PARTNERSHIP AND SPECIAL ENFORCEMENT EFFORT FUNDS This attachment contains important details regarding eligibility and application procedures for FY2025 Fair Housing Assistance Program (FHAP) Partnership funds and Special Enforcement Effort (SEE) funds under the authority set forth at 24 C.F.R. § I I5.304(d) and § 115.305. I. GENERAL PURPOSE AND AGENCY ELIGIBILITY The purpose of Partnership funds is for an agency to utilize the services of individuals and/or public, private, for -profit, or not -for -profit organizations that have the expertise needed to effectively carry out the provisions of the agency's fair housing law. SEE funds are also available for agencies to enhance enforcement activities of the agency's fair housing law. All agencies currently participating in FHAP that are eligible to receive contributions funds are eligible to receive an award of 2025 Partnership funds, except for those agencies that are suspended. Agencies that are on a Performance Improvement Plan (PIP) may be eligible for Partnership funds, subject to discretion of the Government Technical Representative (GTR) and Regional Director. Agencies that qualify for a Partnership award are also eligible to receive 2024 SEE funds, subject to the requirements in 24 C.F.R. § 115.305. IL 2025 PARTNERSHIP FUNDS A. Specific Use of 2025 Partnership Funds Under the authority set forth at 24 C.F.R. § 115.304(d), HUD is making a total of up to $600,000 in 2025 Partnership funds available to eligible agencies. The use of Partnership funds awarded in 2025 is restricted to education and outreach activities. In cases where the respective GTR and Regional Director determines that the funds are sufficient and the agency has the capacity to effectively undertake both activities, an agency may receive authorization from the GTR to engage in both. i. Education and Outreach Activities Funds under this activity are provided for the purpose of conducting education and outreach to persons residing in the geographic area served by the agency, as well as education and outreach to persons and entities subject to the agency's fair housing law. Consistent with the purpose of Partnership funds, agencies should, to the maximum extent possible, partner with grassroots, faith -based or other community -based organizations in accomplishing the goals of this Partnership funding. Education efforts complement the mission of agencies by helping to ensure open and inclusive communities. Activities may include, but are not limited to, staging of public events and the production (including contracting for) of informational and promotional materials. Material and activities should stress the relationship between HUD and FHAP funded agencies, as well as the agency's responsibilities for enforcement of its own substantially equivalent fair housing law. B. Award Amount of 2025 Partnership Funds HUD has a total of up to $600,000 available for Partnership activities in 2025. The size of the awards will be dependent on the demonstrated need. Where a State has both State and local FHAP funded agencies, the State agency should avoid expending its efforts in the same geographic area as the local agency(ies). This year distribution of these funds will not be made on a formula basis. Decisions on requests for Partnership funds from FHAP agencies will be made in headquarters on a ease -by -case basis, with the actual fund commitment taking place in the field as with all other FHAP funds. C. Additional Guidance Regarding Partnership Funds Deliverables Where funds are used to produce education and outreach materials, such materials may include use of existing materials from previous education and outreach efforts (so long as they are in line with the Department's current priorities, including those in Attachment F, "Mandatory FHAP Grant Agreement Provisions"), but an agency should seek to expand the impact of those efforts by reaching additional audiences. New materials and strategies may also be developed, including the use of webinars, development and dissemination of PowerPoint presentations, publicizing the availability of materials developed, and the utilization of social media for education and public service announcements. Deliverables may also include written educational materials such as brochures, fliers, fair housing posters, and other educational and training material such as videos or power points for identified audiences suitable for providing fair housing education. Graphic materials may include, but are not limited to, separately produced and printed posters, bus advertisements, online advertisements, or other outreach materials to be distributed to targeted audiences physically or through social media that are designed to educate individuals, organizations, and housing providers about the provisions of the State or local fair housing law in connection with the specific topic areas identified above. III. 2025 SPECIAL ENFORCEMENT EFFORT FUNDS K This attachment contains important details regarding the operation of the 2025 SEE funds, which is being provided under the existing authority set forth at 24 C.F.R. § 115.305. This guidance covers the operation of the SEE Enforcement Fund only during the effective term of the 2025 FHAP Funding Guidance. SEE funds are on a formula basis for agencies that do Intake for their agency. The formula is as determined by the FHAP Division and will be provided with instructions in the coming months. A. Specific Use of the 2025 SEE Funds Under the authority set forth at 24 C.F.R. § 115.305, HUD is making available up to $600,000 in 2025 SEE funds to all eligible agencies. Use of 2025 SEE funds are meant to support agencies' enforcement activities and are prioritized for the following: • Cover costs related to conducting intake activities. • Supplement enforcement related costs associated with complex or protracted investigation; and • cover extraordinary enforcement and investigation related costs associated with fair housing enforcement activities. B. Award Amount of 2025 SEE Funds HUD has a total of up to $600,000 in SEE funds available in 2025. The size of the awards will be dependent on the demonstrated need and available resources and will be subject to the discretion of the FHAP Division. The distribution of these funds will be made on a formula basis. Decisions on requests for SEE funds from FHAP agencies will be made in headquarters on a case -by -case basis, with the actual fund commitment taking place in the field as with all other FHAP funds. C. SEE Fund Eligibility The eligibility requirements for SEE funds are codified by the FHAP implementing regulation at 24 C.F.R. § 115.305(a) and (b). Thus, an agency requesting a distribution of funds must meet at least three of the six baseline eligibility criteria set forth at § 115.305(a)(1) — (6). Regardless of whether an agency meets the criteria identified above in Section I and/or the baseline criteria for SEE funds under § 115.305(a), it will nonetheless be ineligible if 20 percent or more of an agency's fair housing complaints in the current case processing period have resulted in administrative closures. IV. FUNDING AND PERFORMANCE DEADLINES FOR BOTH PARTNERSHIP AND SEE FUNDS *NOTE: Depending upon expected utilization of funds (e.g., agency opt -outs), HUD reserves the right to provide additional funds to an agency(ies) to achieve maximum utilization of the funds available. Additionally, HUD has authorized discretion to decline distribution of funds to any agency that unsuccessfully meets the criteria identified above. The funds awarded through these 2025 Partnership and SEE awards must be obligated on or before November 15, 2025. Funds will be committed and obligated in accordance with the FHAP Funds Control Plan and the existing FHAP payment processes. All requisite performance indicated in the Statement of Work (SOW) must be completed within the performance period indicated on the HUD-1044. No requests for extensions to the period of performance will be permitted for this award, and to ensure sufficient time for review and approval of any remaining drawdowns, all performance in connection with both the Partnership and SEE funds must be completed no later than June 30, 2026. IV. DISTRIBUTION AND CONTROL OF 2025 PARTNERSHIP AND SEE FUNDS Eligible agencies will be required to prepare and submit a SOW to their GTR detailing the intended use of the funds. Agencies receiving both Partnership and SEE funds should draft separate SOWS for each fund type. Depending upon the amount of funding and the specifics of the SOW, a payment schedule may also be required at the discretion of the GTR. The SOW should clearly identify the proposed activities, price estimates, specific deliverables, intended audiences, and anticipated outcomes. An agency's proposed products or strategies may be modified by the GTR during the SOW approval process based on the GTR and agency's agreed positions regarding achieving the maximum benefits to the jurisdiction's geographic areas, proposed targeted populations, and/or other factors. All funds awarded under this Attachment will be distributed through the established FHAP payment process. Award funds will be assigned to the regions for disbursement as soon as practicable after approval by headquarters, and commitment and obligation of the award will be processed by the GTR, subject to this attachment. Control of these funds will comply with the requirements in this guidance, the FHAP governing regulations at 24 C.F.R. part 115, and the Uniform Administrative Requirements for Federal Awards at 2 C.F.R. part 200. 4 ATTACHMENT F MANDATORY PROVISIONS These provisions apply to all Grantees: The Grantee: (1) shall not use grant funds to promote "gender ideology," as defined in Executive Order (E.O.) 14168, Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government; (2) agrees that its compliance in all respects with all applicable Federal anti -discrimination laws is material to the U.S. Government's payment decisions for purposes of section 3729(b)(4) of title 31, United States Code; (3) certifies that it does not operate any programs that violate any applicable Federal anti -discrimination laws, including Title VI of the Civil Rights Act of 1964; (4) shall not use any grant funds to fund or promote elective abortions, as required by E.O. 14182, Enforcing the Hyde Amendment; and that (5) notwithstanding anything in the NOFO or Application, this Grant shall not be governed by Executive Orders revoked by E.O. 14154, including E.O. 14008, or NOFO requirements implementing Executive Orders that have been revoked. (6) Shall abide by Presidential Executive Actions affecting federal financial assistance programs: Executive Order (EO) 14219 (Ensuring Lawful Governance and Implementing the President's "Department of Government Efficiency" Deregulatory Initiative); 14218 (Ending Taxpayer Subsidization of Open Borders); guidance resulting from the White House Task Force established by 14202 (Eradicating Anti -Christian Bias) and the Senior Advisor to the White House Faith Office assigned by 14205 (Establishment of the White House Faith Office); 14182 (Enforcing the Hyde Amendment); 14173 (Ending Illegal Discrimination and Restoring Merit -Based Opportunity); 14151 (Ending Radical and Wasteful Government DEI Programs and Preferencing); and 14148 (Initial Rescissions of Harmful Executive Orders and Actions) (7) Shall not issue findings utilizing disparate impact liability as defined by Executive Order 14281 (Restoring Equality of Opportunity and Meritocracy) (8) Must administer its grant in accordance with all applicable immigration restrictions and requirements, including the eligibility and verification requirements that apply under title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, as amended (8 U.S.C. 1601-1646) (PRWORA) and any applicable requirements that HUI), the Attorney General, or the U.S. Citizenship and Immigration Services may establish from time to time to comply with PRWORA, Executive Order 14218, or other Executive Orders or immigration laws. If applicable, no state or unit of general local government that receives funding under this grant may use that funding in a manner that by design or effect facilitates the subsidization or promotion of illegal immigration or abets policies that seek to shield illegal aliens from deportation. CITY OF FORT WORTH: Name: Dianna Giordano Title: Assistant City Manager Date: 07/13/2026 AL RECOMMENDED: /�2c2f4,yL �i Q.p4�oann ame: Kristen Smith a4F FORT ��a itle: Human Resources Director a°moo °op♦� duo o=� d p TTEST: aa�naEzaSaaa ame: Jannette Goodall itle: City Secretary CONTRACT COMPLIANCE MANAGER: By signing, I acknowledge that I am the person responsible for the monitoring and administration of this contract, including ensuring all performance and reporting requirements. ame: Maya Heard itle: Human Relations Manager APPROVED AS TO FORM AND LEGALITY: By: Q!L�-4d L' 42 z Name: Jordan P. AlvarezP. Alvarez Title: Assistant City Attorney II CONTRACT AUTHORIZATION: M&C: 26-0487: 06/09/2026 Form 1295: N/A OFFICIAL RECORD CITY SECRETARY FT. WORTH, TX M&C Review Page 1 of 2 Official site of the City of Fort Worth, Texas A CITY COUNCIL AGEND FR WORTH Create New From This M&C DATE: 6/9/2026 REFERENCE **M&C 26- LOG NAME: 14FY2025 FAIR HOUSING NO.: 0487 PROGRAM (FHAP) CODE: C TYPE: CONSENT PUBLIC NO HEARING: SUBJECT: (ALL) Ratify Execution of a Fair Housing Assistance Program Cooperative Agreement with the United States Department of Housing and Urban Development to Process Housing Cases for Fiscal Year 2025, Approve Acceptance of Funds in an Amount Up to $30,600.00, Waive Indirect Costs, and Adopt Appropriation Ordinance RECOMMENDATION: It is recommended that the City Council: 1. Ratify the execution of a Fair Housing Assistance Program Cooperative Agreement through the Human Resources Department, on behalf of the Fort Worth Human Relations Commission with the United States Department of Housing and Urban Development for Fiscal Year 2025 and accept funds in the amount up to $30,600.00; 2. Waive the transfer of indirect cost revenue due to the General Fund in the estimated amount of $1,850.00 and 3. Adopt the attached appropriation ordinance increasing estimated receipts and appropriations in the Grants Operating Federal Fund, subject to receipt of the grant, in the amount up to $30,600.00, for the purpose of funding a Fair Housing Assistance Program Cooperative Agreement DISCUSSION: On March 17, 2026, the Human Resources Department received a Fair Housing Assistance Program (FHAP) Cooperative Agreement with the United States Department of Housing and Urban Development (HUD). Pursuant to this Cooperative Agreement, HUD will provide funding to the Human Resources Department, a designated FHAP agency, based on the number of fair housing complaints resolved from July 1, 2024, to June 30, 2025. The contractual reimbursement of funds is based on activities conducted within the preceding twelve months (Performance Period). Human Resources Department staff, on behalf of the Fort Worth Human Relations Commission, resolved four (4) complaints during this period. Additional funds are awarded to qualifying FHAP agencies for administrative costs and training. The Cooperative Agreement provides payment for the following: Resolution of four (4) housing discrimination complaints in the amount of $6,600.00; Administrative costs in the amount of $9,500.00; Training funds in the amount of $2,500.00 for mandatory HUD training; and SEE Funds in the amount of $12,000.00 for Special Enforcement Effort activities. A waiver of the collection of Indirect Cost Revenue otherwise due to the General Fund from the FHAP contract is being requested. The Human Resources Department has determined that remitting indirect cost reimbursement to the General Fund would result in fewer available programming dollars, which, when compounded by yearly fluctuations in funding, unanticipated delays in the receipt of funding, the threat of federal cuts to HUD programming, and increasing salary and benefits costs, could jeopardize the Department's ability to successfully fulfill the provisions of the program. The cost to the General Fund of this waiver is estimated at $1,850.00. The grant is a pay -for -performance grant, where the amount awarded is for services previously http://apps.cfwnet.org/council_packet/mc_review.asp?ID=34530&councildate=6/9/2O26 6/17/2026 M&C Review Page 2 of 2 rendered. Currently, two employees' salaries and benefits are paid with funds received as part of this FHAP contract and prior FHAP contracts: one (1) Human Relations Manager totaling $156,483.00, 100\% grant -funded, and one (1) Human Relations Investigator totaling $93,844.00, also 100\% grant -funded. If funding ends —for example, if HUD decides to terminate the contract in the future —the affected employees will not yet have performed services for the next contract year. Several options may be available to retain high -performing talent should that occur, including funding the positions through General Funds, or the employees may seek employment elsewhere, either within or outside the City. FISCAL INFORMATION/CERTIFICATION: The Director of Finance certifies that, upon approval of the above recommendations and adoption of the attached appropriation ordinance, funds will be available in the current operating budget, as appropriated, in the Grants Operating Federal Fund. The Human Resources Department (and Financial Management Services) will be responsible for the collection and deposit of funds due to the City. Prior to expenditures being incurred, the Human Resources Department has the responsibility to validate the availability of funds. This is a fee -for -service grant. Fund Department Account Project Program Activity Budget I Reference # Amount ID I I ID I I I Year I (Chartfield 2) Fund Department Account Project Program Activity Budget Reference # Amount ID ID Year (ChartfieId 2) Submitted for City Manager's Office by: Dianna Giordano (7783) Originating Department Head: Kristen Smith (2697) Additional Information Contact: Heather Wiggins (7230) Maya Heard (7566) ATTACHMENTS Executed City of Fort Worth FY25 HUD-1044.pdf (CFW Internal) ORD.APP_14FY2025 FAIR HOUSING PROGRAM (FHAP) AO(R2).docx (Public) http://apps.cfwnet.org/council_packet/mc_review.asp?ID=34530&councildate=6/9/2O26 6/17/2026 FORT WORTH. City Secretary's Office Contract Routing & Transmittal Slip Contractor's Name: Fair Housing Assistance Program (FHAP) Subject of the Agreement: Acceptance of funds for FHAP co-op agreement N/A N/A N/A M&C Approved by the Council? * Yes 0 No ❑ If so, the M&C must be attached to the contract. Is this an Amendment to an Existing contract? Yes ❑ No 0 If so, provide the original contract number and the amendment number. Is the Contract "Permanent"? *Yes ❑ No 0 If unsure, see backpage for permanent contract listing. Is this entire contract Confidential? *Yes ❑ No 0 If only specific information is Confidential, please list what information is Confidential and the page it is located. N/A N/A Effective Date: March 09, 2026 If different from the approval date. Expiration Date: March 08, 2029 If applicable. Is a 1295 Form required? * Yes ❑ No 21 *If so, please ensure it is attached to the approving M&C or attached to the contract. Project Number: If applicable. TBD *Did you include a Text field on the contract to add the City Secretary Contract (CSC) number? Yes 0 No ❑ Contracts need to be routed for CSO processing in the followingorder: rder: 1. Katherine Cenicola (Approver) 2. Jannette S. Goodall (Signer) 3. Allison Tidwell (Form Filler) *Indicates the information is required and if the information is not provided, the contract will be returned to the department.