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We conducted a review of Home Forward (previously named the Housing Authority of Portland, OR) based on concerns noted during our ongoing internal audit of the U.S. Department of Housing and Urban Development’s (HUD) oversight of public housing authorities’ compliance with Federal lobbying disclosure requirements.  Our review objective was to determine whether Home Forward complied with Federal lobbying disclosure requirements and restrictions.

We found that Home Forward failed to disclose lobbying activities and improperly allocated $643 in lobbying-related expenses to Federal sources of funds.  Also, in at least one instance, it incorrectly certified that it had not used Federal funds for lobbying activities, and in another instance could not demonstrate that it had certified, as required, that it had not and would not use Federal funds for lobbying.  Home Forward took immediate corrective action during the audit and repaid the $643 from non-Federal funds.

We recommend that the Director of HUD’s Portland Office of Public Housing ensure that responsible Home Forward officials receive comprehensive training in lobbying disclosure requirements and restrictions and that all future HUD monitoring of Home Forward covers compliance with Federal lobbying disclosure requirements and restrictions.