Potential Fraud Risks and Schemes for HUD’s Capital Fund Program

Beginning in 2021, the U.S. Department of Housing and Urban Development (HUD), Office of Inspector General (OIG), conducted several audits to assess HUD’s anti-fraud efforts and to develop inventories of fraud risks in HUD programs. Our previous work found that HUD’s fraud risk management program was in its early stages of development, and we recommended that HUD perform program-specific fraud risk assessments and incorporate these assessments into an agency-wide plan to further advance its program.  To continue assisting HUD in improving its anti-fraud efforts, we conducted this work to identify potential fraud risks and schemes that that could negatively impact the Capital Fund formula grant program, HUD, and its public housing agencies (PHAs).  We identified four program-specific fraud risk factors that increase the chance of fraud occurring by increasing the incentive, opportunity, and likelihood that an individual will consider committing fraud.  We used these risk factors, along with the results of brainstorming sessions, interviews, and reviews of audit reports, investigations, and press releases from HUD OIG, and other agencies to develop an inventory of 73 fraud schemes.  The 73 fraud schemes include 58 that were listed in HUD’s fraud risk catalog and 15 schemes that we identified.  These fraud schemes can be used to defraud HUD and its PHAs and undermine the integrity of the Capital Fund program, which awarded $3.1 billion in formula grants in fiscal year 2024. We recommend that HUD use the fraud risks and schemes inventory in this report and involve relevant stakeholders to create a program-specific fraud risk inventory to support its anti-fraud efforts and enhance oversight of the Capital Fund program.  We also recommend that these fraud risks and schemes be communicated to all stakeholders, including public housing agencies.  Additionally, we recommend that HUD determine how data currently being collected can be leveraged to identify and mitigate fraud risks.