The Departmental Enforcement Center's (DEC) Operations Division,
working with the DEC's five Satellite Offices, manages the day-to-day
recovery and enforcement strategies for selected high-risk properties.
The Division works with owners to achieve compliance. The Division
is responsible for policy development of enforcement strategies
for the DEC's Satellite Offices and the development and resolution
of its own enforcement cases.
The DEC's satellite offices focus on properties with physical and
financial deficiencies that are referred from HUD's Real Estate
Assessment Center (REAC) and Office of Multifamily Housing.
Referrals
The majority of the referrals that the Operations Division and
satellite offices receive are from REAC. We do, however, receive
elective and emergency referrals from the Office of Multifamily
Housing.
Physical
Referrals
REAC
assesses the physical condition of HUD's Multifamily Housing inventory. Properties
with a REAC inspection score of 30 points or less are automatically
referred to the DEC. Properties scoring between 31-59 may be referred
electively.
Financial
Referrals
In
addition to referrals of properties with physical deficiencies,
we also handle financial referrals, where the annual financial statements
(AFS) reflect compliance discrepancies. AFS statements are submitted
electronically to REAC through the Financial Assessment Subsystem
(FASS). Some of these submissions are handled routinely by multifamily
housing staff, while others are specially routed to the DEC for
evaluation and appropriate action.
Non-Filer
Referrals
Owners
who do not file timely annual financial statements with REAC are
referred to the DEC. The DEC's primary goal has been to obtain owner
compliance in filing the required statements. However, the DEC has
authority to impose civil money penalties (CMPs) against owners
of HUD-insured and assisted multifamily properties who do not comply.
Housing
Elective Referrals
In
some instances, irrespective of the REAC physical inspection scores
or the results of the AFS review, HUD's Multifamily Hub Directors
may refer projects to the DEC for further evaluation. These include
situations where an owner has violated the terms of a Use Agreement
or other agreements with the Department.