Narrative outline
FAIR HOUSING INITIATIVES PROGRAM PRIVATE ENFORCEMENT INITIATIVE. One section per scoring criterion, in the notice's order, so reviewers find each answer where they expect it. Fill in every [[NEEDS: …]] with your own facts.
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Narrative limit: 10 pages. Suggested pages follow each section's share of the points. 100 points in total. Plus up to 7 bonus points. Source: the official notice, Foa_Content_of_OFH-2600-DC-021C.pdf.
Capacity of Applicant and Relevant Organizational Experience · 20 points · about 2 pages
What reviewers look for (notice p. 35):
Address the extent to which your organization has the staff experience and organizational capacity necessary to successfully complete the proposed project. (See 24 CFR 125.105(c)) Diversified Funding Sources: Applicants are encouraged to secure the use of other resources to supplement the HUD award. (See 24 CFR 125.105(d)) Applicants that can demonstrate diversified funding resources will receive higher scores in this factor. PEI Applicants without the requisite experience may consider applying for a FHIP Fair Housing Organizations Initiative (FHOI) grant to improve capacity and gain experience. • You must include the following elements within your narrative response
- Description of Staff and Staff Expertise · 10 points: Experience of individual(s) who will work on the grant that will contribute to the success of the proposed project. o Describe each key staff member's fair housing enforcement related experience relevant to the proposed project, such as in complaint intake, complaint investigation, testing for fair housing violations, enforcement of meritorious claims, fair housing or other training, and/or disseminating information to the community; and explain how the staff member's experience will expressly contribute to the success of the project. o You must have more than two current key staff members with experience formulating or carrying out programs to prevent or eliminate discriminatory housing practices on board at the time the application is submitted (be specific when describing experience). o Identify key project staff by name and position and estimated percentage of time each will…
- Organizational Experience · 10 points: Experience of the organization applying for the grant that will contribute to the success of the proposed project. You must clearly demonstrate that your organization has: o a complete and effective staffing plan and sufficient and sufficiently qualified staff, including maintaining current staff and adding staff, proposed consultants and/or subrecipients as applicable during the period of performance, to successfully implement and complete the proposed project. Explain how you will evaluate the performance of and provide oversight for subrecipients, if any. o described past project(s) conducted similar in scope and complexity to the project proposed and/or engaged in activities that are readily transferable to the proposed project; and include the results of such past projects. o describe your organization's fair housing experience within the last three years if applying as a QFHO or…
[[NEEDS: your answer to this criterion, with facts and numbers from your organization]]
Need/Distress/Extent of the Problem · 50 points · about 5 pages
What reviewers look for (notice p. 35):
(breakdown shown below) You must include the following elements within your narrative response (See 24 CFR 125.105(a) and (b))
- Problem Statement and Proposed Solution (Program Objectives, Effectiveness of Plan and Alignment to Needs) · 10 points
- Required Narrative Element 1 · 10 points: Executive Order (EO) 14332, titled "Improving Oversight of Federal Grantmaking," is a directive issued by the White House on August 7, 2025 that requires federal discretionary grants to focus on performance-based investments that align explicitly with the Administration's policy priorities. It prohibits the use of funds to promote or subsidize immigration, illegal racial preferences or discrimination, or initiatives that promote gender ideology. It also encourages agencies to engage a broader range of recipients. HUD has made it clear that it is committed to the purpose of the Fourteenth Amendment to the U.S. Constitution which is to "do away with all governmentally imposed discrimination based on race. Eliminating racial discrimination means eliminating all of it." Students for Fair Admissions, Inc. v. President & Fellows of Harvard College, 600 U.S. 181, 206 (2023). To that end, the…
- Required Narrative Element 2 · 10 points: Under the current administration, federal fair housing enforcement is guided by three core principles: • Restore fair housing enforcement to its core statutory objectives; • Recognize that all Americans have civil rights and liberties that must be protected; and • Enforce the Fair Housing Act within constitutional limitations. Please describe how your application, if funded, would advance these principles.
- Required Narrative Element 3 · 10 points: You must clearly identify and describe the fair housing needs to be addressed, and the direct relationship between your proposed project and how, through your proposed project your organization plans to address housing discrimination in a way that meets those fair housing needs. Provide any available reference material that supports this rationale, including data, studies, reports, or other evidence. Describe how the proposed tasks and activities are aligned with the specific fair housing needs identified for the targeted area, and how the proposed activities foster and maintain compliance with civil rights and fair housing, including but not limited to addressing documented evidence of discrimination prohibited by the Fair Housing Act within the project area; and how you will use award funds to provide services in an area with unmet fair housing needs and/or expand fair housing…
- Required Narrative Element 4 · 10 points: Within the past 7 months, HUD opened various Secretary-initiated investigations (SII) to combat "new or sophisticated forms of housing discrimination." 42 U.S.C. 3613a(b)(2). A full list of ongoing Secretary-initiated investigations can be found here: https://www.hud.gov/hudclips/notices#fheo. Identify the investigation closest to your proposed project area and discuss whether the investigation aligns with your range of investigative and enforcement activities.
[[NEEDS: your answer to this criterion, with facts and numbers from your organization]]
Soundness of Approach · 20 points · about 2 pages
What reviewers look for (notice p. 35):
This factor is based on the: (1) Proposed Statement of Work (SOW) and Information Requirements; and (2) Budget and Cost Estimates. Your work plan must follow all NOFO requirements. You must include the following elements within your narrative response (See 24 CFR 125.105(b) and (d)): • Proposed SOW and Information Requirements: Activities proposed to be conducted with a schedule for completion. • Budget and Cost Estimates: The cost of each activity proposed. SOW Narrative • Identify quantifiable project goals and describe how these goals relate to each of the needs identified in response to Rating Factor 2. Goals are the results or outcomes the applicant intends to accomplish. • Identify and explain the proposed activities and specific deliverables, and anticipated outcomes consistent with the activities outlined in the SOW Chart. Include a description of your fair housing complaint…
- Statement of Work (SOW) and SOW Narrative · 10 points: Chart (use Appendix A as an example) Submit a separate complete SOW Chart for each separate consecutive 12-month period of performance of the 24-month project, and incorporate and describe all specific tasks and activities necessary for the proposed project. Add/edit Administrative and Program Tasks and add/edit tasks in Appendix A as necessary and appropriate for the proposed project. Your proposed activities and deliverables must be clear and measurable and directly related to the line items and overall expenditures in the proposed Budget. The SOW program tasks must include all proposed activities and major tasks related to complaint intake, complaint investigation, recruitment and training of testers, testing for fair housing violations, and enforcement of meritorious claims, and the budget must specifically set forth all expenditures necessary to implement enforcement related…
- Budget Form HUD-424-CBW and Budget Narrative · 10 points
[[NEEDS: your answer to this criterion, with facts and numbers from your organization]]
Achieving Results and Program Evaluation · 10 points · about 1 page
What reviewers look for (notice p. 35):
Considering your responses to Rating Factors 1 through 3, HUD will assess your plan to evaluate your achievement of proposed goals and the extent to which your organization evaluates and measures results and holds itself accountable to ensure effective program management. Your application must clearly outline the organization's strategy for measuring, evaluating and improving (if necessary) its program performance against proposed activity goals during the grant period of performance. All applications must include clear benchmarks for measuring success and progress towards relevant goals. Include the following elements within your narrative response (See 24 CFR 125.105(e)-(g))
- Measurement · 5 points: Describe and explain the strategies in place and that will be used to gather valid quantifiable data and measure outputs and outcomes for the program activities and goals outlined in the Statement of Work. Identify outcomes that reflect the anticipated effect your organization's proposed activities will have on its beneficiaries. Explain how the data gathered will be validated.
- Evaluation Plan · 5 points: Propose a plan to effectively evaluate progress toward stated objectives and goals. Explain how the organization will evaluate long-term outcomes of the proposed project work in your target service area.
[[NEEDS: your answer to this criterion, with facts and numbers from your organization]]
Bonus points (on top of the total)
Policy Initiative Preference Points · 7 points
What reviewers look for (notice p. 35):
Preference points are added to your overall application score. You do not need to address the policy initiatives in this section to receive an award. If you choose to address a policy initiative in your application, you must adhere to the information with any award. a. Historically Black Colleges and Universities (HBCUs) You may receive one (1) point, if you are an HBCU. To receive the point, you must include in your application documentation of your HBCU designation. OR You may receive one (1) point, if you are partnering with an HBCU. To receive the point, you must include in your application a letter of commitment and HBCU status documentation. The letter must confirm your partnership. The letter must also include the signature of a leadership official at the HBCU. b. Cooperation with real estate industry organizations You may receive one (1) point if you demonstrate within your…
[[NEEDS: your answer to this criterion, with facts and numbers from your organization]]
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Built from the official notice's scoring section. Section names, order and page limits come from the notice.