Report 2019-111 Recommendation 20 Responses

Report 2019-111: Mobile Home Park Inspections: The Department of Housing and Community Development Must Improve Its Inspection Processes to Better Protect Park Residents (Release Date: July 2020)

Recommendation #20 To: Housing and Community Development, Department of

To ensure that it is aware of any potential conflicts of interest that its inspectors may have, HCD should by September 2020 develop procedures to review the annual and assuming-position Form 700s of all inspectors with reportable financial interests to identify potential conflicts of interest.

Annual Follow-Up Agency Response From July 2022

Form 700 manual fully implemented in February 2022 to review annual and assuming-position Form 700s of all inspectors with reportable financial interests to identify potential conflicts of interest.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented


1-Year Agency Response

On or about February 18, 2021, current and former HCD employees who previously failed to comply with Form 700 filing requirements were referred to the Fair Political Practice Commission (FPPC) per FPPC guidelines.

HCD also recently hired a new staff member to oversee the Form 700 filing process (referred to as HCD's Compliance Specialist). The Compliance Specialist will send emails/letters to all individuals who fail to timely file required statements. Individuals who do not properly respond to these notices will be referred to the FPPC pursuant to FPPC guidelines.

The Compliance Specialist will also ensure that HCD's inspectors file all required statements, and then will specifically review those statements to identify any conflicts of interest as required by this audit finding.

California State Auditor's Assessment of 1-Year Status: Pending

HCD's Form 700 process manual does not require review of filing materials in all instances when an inspector has identified reportable financial interests, as we recommended.


6-Month Agency Response

LAD working on flow chart depicting Form 700 process. Second Notice letters regarding form 700 filing non-compliance (relating to missing annual statements and/or leaving office statements) were mailed/emailed to non-compliant individuals on or about October 12, 2020. Non-compliant individuals who do not respond to the Second Notice letters within 45 days will be referred to the Fair Political Practice Commission (FPPC) per FPPC guidelines. Emails/letters relating to individuals who have failed to file assuming office statements/annual statements will be sent once new form 700 staff member is hired.

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

The HCD Legal Affairs Division (LAD) is working on flow chart depicting Form 700 process. First Notice letters regarding form 700 filing non-compliance (relating to missing annual statements and/or leaving office statements) were mailed/emailed to non-compliant individuals on or about August 13, 2020. Second notice letters will be mailed out in 60 days per Fair Political Practice Commission guidelines. Failure to respond to second notice will result in referral to the FPPC. Emails/letters relating to individuals who have failed to file assuming office statements/annual statements will be sent once new form 700 staff member is hired.

California State Auditor's Assessment of 60-Day Status: Pending


All Recommendations in 2019-111

Agency responses received are posted verbatim.