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9314 8000 3860 0209 9892 92 <br />00000007 3 <br />K <br />C. Performance Standard #3: During the period beginning `vith the filing of a complaint <br />and ending with filing a. charge or dismissal, the agency, to the extent feasible, attempts <br />to conciliate the complaint. After the charge has been issued, the agency, to tine extent <br />feasible, continues to attempt settlement until a hearing or a judicial proceeding has <br />begun. [24 CFR § 115.206(e)(3)]. <br />The corrective actions have been satisfied. A conciliation agreement template was provided <br />to the GTM on January 5, 2018. The final version of the conciliation agreement template <br />contained standard language that meets the FHAP Criteria for Processing. <br />D. Perforinance Standard #4: The agency conducts compliance reviews for settlements, <br />conciliation agree €vents, and orders resolving discriminatory, housing practices. 124 <br />CFR § 115.206(e)(4)] <br />The corrective actions have been satisfied. The agency submitted a conciliation agreement <br />template which contained a provision authorizing it to conduct compliance reviews. The <br />agency also identified the Civil Rights Investigator as the person responsible for conducting <br />the review. <br />F. Performance Standard #5: The agency must consistently and affinnatively seek and <br />obtain the type of relief designed to prevent recurrences of discriminatory practices. 124 <br />CFR § 115.206(e)(5)]. <br />The corrective actions have been satisfied. The GTNI provided sample conciliations <br />agreements to the agency prior to the start of the PIP which were used to develop its <br />template. The agency fin-ther indicated that ongoing conciliation attennpts are consistently <br />documented in HEMS. <br />F. Perforinance ,Standard #9: The agency must conform its performance to the provisions <br />of any written agreements executed by the agency and HUD related to substantial <br />equivalence certification, including but not linnited to the interim agreement or MOU. <br />[24 CFR § 115.206(e)(9)]. <br />The corrective actions have been satisfied. The agency confirmed that it world conform to <br />all written agreements executed related to its performance. During the PIP, the GTM and <br />Director met frequently to discuss the agency's progress and exchanged ideas for fiirtlner <br />improvements. <br />G. Budget and Finance Requirements- Agencies that enforce antidiscrimination laws in <br />addition to fair housing must provide annual certifications to HUD confirinirrg that it <br />spends at least 20% of its total operating budget (not including FHAP funds) on fair <br />housing activities. 124 CFR § 115.307(5)]. FHAP funds trust be segregated from the <br />agency's and the state or local government's other fiords and must be used for the <br />purpose that HUD provided the fiends. [24 CFR § 115.307(6)]. The agency draws down <br />its funds in a timely manner. [24 CFR § 115307(9)]. <br />The corrective actions have been satisfied. In collaboration with the FHAP Division <br />Program Analyst, the GTM reexamined fitnatncial documents reviewing FHAP fiends <br />expended by OCHRD from July t, 2014 to June 30, 2017. The Program Analyst and GTM <br />also reviewed the Single Act Audit report year ending Jane 30, 2016 for Orange County, NC <br />government. Although the Single Act Audit report did not reveal findings in the agency's <br />