U.S. Department of Housing and Urban Development New York State Of?ce Jacob K. avits Federal Building 26 Federal Plaza New York, New York 10273?0068 June 27, 2019 CERTIFIED MAIL RETURN RECEIPT REQUESTED Constance L. Frazier Commissioner Commission on Human Rights County of Reckland 50 Sanatorium Road Building A, 6?h Floor Pomona, NY 10970 Dear Commissioner Frazier: Subject: Fair Housing Assistance Program - Suspension In September 2016, the Of?ce of Fair Housing and Equal Opportunity or ?Of?ce?) of the U.S. Department of Housing and Urban Development or the ?Department?) conducted a Performance Assessment (?Assessment?) of the Rockland County Commission on Human Rights Or the ?Commission?), 24 CPR. The goal of the Assessment was to determine whether certi?cation as a participant in the Fair Housing Assistance Program should be renewed and extended for a period of five (5) years. The Assessment had found that the Commission failed to meet three of nine performance standards, and two budget and ?nance requirements. The Commission was informed on June 17, 2017, of such de?ciencies. To correct these, on May 4, 2018, was placed on a Performance Improvement Plan as a condition for continued participation in the FHAP Program. was informed that all PIP corrective actions needed to be completed within one year of the date of the Plan. The Commission was also informed that, after one year, this Of?ce would reassess its performance with respect to the standards and requirements identi?ed in the PIP, pursuant to 24 C.F.R. 115.206. If was not found to have made substantial improvement in its performance by the conclusion of the PIP, then the Commission would be placed on suspension from the FHAP program pursuant to 24 C.F.R. To facilitate full compliance with the PIP, this Office has been providing technical assistance as well as monitoring the Commission?s progress with respect to adherence to the above-cited performance standards and requirements through conference calls and on-site meetings. This is to inform you that, to date, despite this Of?ce?s provision of technical assistance during the past year, to date has shown limited progress in meeting PIP performance standards and requirements. More speci?cally: 1. Performance Standard #1 The agency must commence complaint proceedings, carry forward such proceedings, complete investigations, issue determinations, and make ?nal administrative dispositions in a timely manner. (24 C.F.R. Under the PIP, is expected to: a) Substantially improve upon the percentage of cases closed within a 100 dav timeframe. b) Substantiallyr improve upon its average case processing time. c) Meet all data entrv and support system requirements. As of this date, no significant improvement has been shown with respect to Performance Standard 2. Performance Standard #4 The agency must conduct compliance reviews for settlements, conciliation agreements, and orders resolving discriminatory housing practices. (24 C.F.R. Under the PIP, is eitpected to conduct compliance reviews of all conciliation agreements. As of this date, signi?cant improvement has been shown with respect to Performance Standard The agency has been working to conduct adequate compliance reviews of all conciliation agreements. 3. Performance Standard #7 The agency must demonstrate that it receives and processes a reasonable number of complaints cognizable under both the federal Fair Housing Act and the agency?s fair housing statute or ordinance. (24 C.F.R. Under the PIP, is expected to process, at a minimum, ten (10) cases during this corrective action period. 20 cases during a two year period) As of this date, no Signi?cant improvement has been shown with respect to Performance Standard Only 3 cases were ?led during this period. 4. Budget and Finance Requirements The agency must draw down its funds and provide quarterly reports in a timely manner as required at 24 CFR. Under the PIP, is expected to draw down its funds and provide quarterly reports during this period in a timely manner. As of this date, no signi?cant improvement has been shown with respect to these requirements even though FHEO provided technical assistance on three separate occasions during the PIP timeframe. In summary, continues to perform at an unacceptable level and is still failing to meet the requirements of the FHAP program. Pursuant to 24 CFR effective today through September 25, 2019, HUD is placing the Commission on suspension from the FHAP program for a period of 90 days. During the suspension period, HUD will not refer complaints to the Commission and will not provide FHAP funds (see 24 CFR However, HUD will continue to provide technical assistance during this period, as needed. Prior to the end of the suspension period, FHEO will conduct another performance assessment of the agency. If, following the performance assessment conducted at the end of suspension, has not corrected these de?ciencies, this Of?ce will recommend to the Assistant Secretary of Fair Housing and Equal Opportunity that she proceed to withdraw from the Fair Housing Assistance Program .pursuant to 24 CFR Pursuant to 24 CFR may respond to this letter within 30 days. If you have any questions regarding the Commission?s current compliance status under the FHAP Program, or any questions about the suspension process, please feel free to contact Ms. Salome Johannes at (212) 542-7517 or toll free at 1-800?496-4294. irector, Region II Of?ce of Fair Housing and Equal Opportunity cc: Ed Day, County Executive