This is the accessible text file for GAO report number GAO-11-737R 
entitled 'Financial Education and Counseling Pilot Program' which was 
released on July 27, 2011. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

GAO-11-737R: 

United States Government Accountability Office:
Washington, DC 20548: 

July 27, 2011: 

The Honorable Tim Johnson: 
Chairman: 
The Honorable Richard C. Shelby: 
Ranking Member: 
Committee on Banking, Housing, and Urban Affairs: 
United States Senate: 

The Honorable Spencer Bachus: 
Chairman: 
The Honorable Barney Frank: 
Ranking Member: 
Committee on Financial Services: 
House of Representatives: 

Subject: Financial Education and Counseling Pilot Program: 

The federal government has numerous programs designed to improve 
Americans' financial literacy, some of which are targeted at helping 
consumers determine whether and when to purchase a home, how to manage 
a mortgage, and how to deal with setbacks that could limit their 
ability to make timely mortgage payments. However, as we have 
reported, little is known about the effectiveness of specific 
strategies for improving financial literacy.[Footnote 1] In the 
Housing and Economic Recovery Act of 2008 (HERA), Congress created a 
pilot program to provide grants to providers of financial education 
and counseling services to prospective homebuyers.[Footnote 2] 
Pursuant to HERA, the goals of this education and counseling include 
increasing the knowledge and decision-making capabilities of 
prospective homebuyers, identifying successful methods resulting in 
positive behavioral change for financial empowerment, and educating 
prospective homebuyers about options for building savings. 

HERA also mandated that we submit a report to Congress evaluating this 
grant program, which was later named the Financial Education and 
Counseling (FEC) Pilot Program. Accordingly, the objectives of this 
report are to describe (1) the characteristics of the organizations 
providing services under the FEC program and how they were selected, 
and (2) what is known about the program's impact in improving the 
financial situation and behavior of homeowners and prospective 
homebuyers who participate in the program. To address these 
objectives, we reviewed FEC program applications, assistance 
agreements, and performance reports from organizations awarded grants 
through the program. In addition, we reviewed the Department of the 
Treasury's (Treasury) process and criteria for selecting grantees. We 
also interviewed all nine grantees of the program and staff at 
Treasury, which administers the program.[Footnote 3] Finally, we 
assessed the reliability of the data we reported and determined that 
the data were sufficiently reliable for the purposes of our report. 

We conducted this work from January to July 2011 in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings 
and conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. Enclosure I contains a more 
detailed description of our scope and methodology. 

Background: 

Section 1132 of HERA authorized the Secretary of the Treasury to make 
grants to eligible organizations to provide financial education and 
counseling to prospective homebuyers through what Treasury 
subsequently named the FEC Pilot Program. Treasury's Community 
Development Financial Institutions (CDFI) Fund administers the 
program, in collaboration with the department's Office of Financial 
Education and Financial Access (OFEFA). HERA authorizes not more than 
five pilot project grants, which the act states are intended to 
identify successful methods resulting in positive behavioral change 
and to establish program models for organizations to carry out 
effective counseling services.[Footnote 4] 

For fiscal year 2009, Congress appropriated $2 million to the CDFI 
Fund for the FEC program, and Treasury selected five organizations, 
each receiving $400,000, to provide services. For fiscal year 2010, 
Congress appropriated $4.15 million, of which Congress designated 
$3.15 million for an eligible organization in Hawaii. Treasury 
selected one eligible organization in Hawaii and three other 
organizations (two receiving $400,000 each and one receiving $200,000) 
to provide services. Under HERA, to be eligible for grant funding, an 
organization must be either a housing counseling agency certified by 
the Secretary of Housing and Urban Development (HUD); a state, local, 
or tribal government agency; a community development financial 
institution or a credit union; or any collaborative effort of any of 
these entities. Treasury's Notices of Funds Availability for the FEC 
program set certain minimum eligibility requirements related to 
applicants' ability and experience and stated that the program is 
targeted at low-income, low-wealth, and moderate-income individuals at 
least 18 years of age who do not currently own a home or pay a 
mortgage on a residence. Organizations receiving grant funds may use 
those funds to cover expenses such as personnel (salaries and 
benefits), consulting fees and contracts, and materials, supplies, and 
equipment, among other things. 

Financial education and counseling related to housing and 
homeownership (broadly referred to as housing counseling) can take 
several forms. Financial education generally provides individuals with 
information on topics such as the importance of saving and budgeting 
and may take place in a group setting. Counseling generally offers 
individuals personalized advice in a one-on-one setting and may 
include prepurchase counseling for potential homebuyers and 
postpurchase counseling on subjects such as home maintenance.[Footnote 
5] Housing counseling can be geared toward various populations--
homebuyers, homeowners, renters, senior citizens, and other 
populations with particular housing goals. It can take place in 
person, over the telephone, via a self-study computer module, or with 
a workbook and can vary in length from a single session to several 
sessions spread over a period of weeks or months. As we recently 
reported, research on the impact of financial education and counseling 
on consumer behavior has been limited. In a recent review of the 
literature, we identified only one evidence-based study that evaluated 
the effectiveness of a housing counseling program.[Footnote 6] 

As a condition of receiving grant funds under the FEC program, 
grantees are to report on the results of five performance goals within 
6 months of disbursement and annually thereafter. Two of these are 
output goals: number of participants served and hours of class time, 
counseling, and instruction provided. The other three are impact goals 
that the grantees select. These impact goals seek to gauge the effect 
of counseling activities and include measures such as the average 
percentage increase in participants' household savings, average 
percentage decrease in household debt, and percentage of participants 
who improve their credit scores or use formal budgeting tools. 
Grantees for the fiscal year 2009 funding round of the FEC program 
received their grant funds in August 2010 and submitted the initial 
results of their output and impact goals to Treasury in January 2011. 
Grantees of the fiscal year 2010 round are not required to report 
their initial results to Treasury until July 30, 2011. 

The Nine FEC Grantees Are Generally Experienced and Were Selected from 
among Hundreds of Applicants: 

FEC Grantees Are HUD-Approved Housing Counseling Agencies That 
Primarily Target Low-Income Populations: 

The nine grantees that have received FEC funding are experienced and 
geographically diverse organizations. As seen in table 1, key 
characteristics of the organizations providing services under the FEC 
program include the following: 

* Type of organization. Eight of the organizations are nonprofit 
organizations that provide financial education and housing counseling 
services, and one is a public housing authority. 

* Geographic diversity. The nine grantees are geographically diverse, 
representing most major areas of the country and a mix of urban and 
rural regions. 

* Financial education or housing counseling experience. Most of the 
grantees have had at least 10 years of experience in financial 
education or housing counseling. For example, the Boulder County 
Housing Authority reported over 20 years of experience in housing 
counseling. The organization with the least amount of experience, 
Solita's House, Inc., has been providing counseling for roughly 5 
years. 

* Experience with federal grants. All of the grantees had recently 
received other federal grants, including Community Development Block 
Grants (CDBG) from HUD or grants from Treasury's CDFI Fund. These 
other grant programs typically require organizations receiving funds 
to periodically report on program performance and agree to audits of 
their financial statements. 

* Financial condition. Eight of the nine organizations reported no 
material findings from recent audits of their financial statements. 
One of the newer organizations had not yet conducted an annual 
financial audit. 

* HUD approval. All nine grantees are HUD-approved housing counseling 
agencies or part of a network of such agencies. As such, they met 
HUD's requirements for approval, including having provided housing 
counseling for at least a year and not having unresolved government 
audit findings.[Footnote 7] 

Table 1: Characteristics of Fiscal Year 2009 and Fiscal Year 2010 FEC 
Pilot Program Grantees: 

Name of grantee: Boulder County Housing Authority; 
Funding year and amount: FY 2009; $400,000; 
Type of organization: Public housing authority; 
Target population: Low-income and low-wealth population in Boulder 
County, Colorado, with a focus on Hispanic/Latino populations; 
Years of experience: More than 20 years of experience in housing 
counseling; 
Recent federal grant experience: HUD CDBG and housing counseling 
grants; Department of Agriculture grants; Department of Health and 
Human Services grants; 
Financial condition: No audit findings in 2006 and 2007; three audit 
findings in 2008, but none considered to be material weaknesses. 

Name of grantee: Georgia Financial Education Collaborative; 
Funding year and amount: FY 2009; $400,000; 
Type of organization: Collaboration of four nonprofit housing 
counseling agencies; 
Target population: Minority and low-income populations in Georgia and 
Alabama; 
Years of experience: The four agencies range from more than 20 years 
to more than 60 years of experience in housing counseling and 
financial education; 
Recent federal grant experience: All four agencies received funding 
for various homeownership counseling or foreclosure prevention 
programs, including HUD housing counseling grants; 
Financial condition: Lead applicant for the collaborative had an 
unqualified opinion on its 2008 financial statement audit. 

Name of grantee: Mission Economic Development Agency; 
Funding year and amount: FY 2009; $400,000; 
Type of organization: Nonprofit community-based, local economic 
development corporation; 
Target population: Low-and moderate-income Latino families in San 
Francisco, California; 
Years of experience: More than 10 years of experience in homeownership 
counseling and financial education; 
Recent federal grant experience: CDBG and housing counseling grants; 
Financial condition: Audit reports for the prior 3 years had 
unqualified opinions. 

Name of grantee: New Hampshire Housing Finance Authority; 
Funding year and amount: FY 2009; $400,000; 
Type of organization: Nonprofit public benefit corporation; 
Target population: Low-income, low-wealth population in New Hampshire; 
Years of experience: Roughly 16 years of experience in financial 
education and counseling services; 
Recent federal grant experience: Funding from HUD and U.S. Department 
of Agriculture; 
Financial condition: Annual audits with unqualified opinions from 2007 
to 2009. 

Name of grantee: OnTrack Financial Education and Counseling; 
Funding year and amount: FY 2009; $400,000; 
Type of organization: Nonprofit United Way agency; 
Target population: Low-income/low-wealth residents of Asheville/ 
Buncombe County, a small urban area of Western North Carolina; 
Years of experience: More than 35 years of experience in financial 
education and counseling; 
Recent federal grant experience: HUD housing counseling grants, 
funding from the Department of Labor and Department of Health and 
Human Services; 
Financial condition: Audit reports for the prior 3 years had 
unqualified opinions. 

Name of grantee: Council for Native Hawaiian Advancement; 
Funding year and amount: FY 2010; $3.15 million; 
Type of organization: Certified Community Development Financial 
Institution; nonprofit community development corporation; 
Target population: Native Hawaiians and low-income populations 
throughout Hawaii; 
Years of experience: Roughly 7 years of experience in financial 
education and counseling; 
Recent federal grant experience: Various federal financial education 
and counseling grants, including grants from Treasury's CDFI Fund and 
the U.S. Small Business Administration; 
Financial condition: Annual audits with unqualified opinions since 
2001. 

Name of grantee: Greater Erie Community Action Committee; 
Funding year and amount: FY 2010; $400,000; 
Type of organization: Community action agency; 
Target population: Low-income/low-wealth prospective homebuyers in 
Erie County, Pennsylvania; 
Years of experience: More than 30 years experience in housing 
assistance; 
Recent federal grant experience: HUD housing counseling and Section 8 
grants; funding from Department of Health and Human Services; 
Financial condition: Audits in the prior 3 years had not indicated any 
findings. 

Name of grantee: Homewise, Inc; 
Funding year and amount: FY 2010; $400,000; 
Type of organization: Nonprofit housing organization; 
Target population: Prospective low-and moderate-income homeowners in 
Santa Fe, New Mexico; 
Years of experience: More than 17 years in assisting first-time 
homebuyers; 
Recent federal grant experience: CDBG, HUD housing counseling, and 
CDFI Fund grants; funding from NeighborWorks America; 
Financial condition: Audits in the prior 3 years had unqualified 
opinions. 

Name of grantee: Solita's House, Inc; 
Funding year and amount: FY 2010; $200,000; 
Type of organization: Nonprofit organization dedicated to homebuyer 
education and credit counseling services; 
Target population: Low- and moderate-income population in Hillsborough 
County, Florida, including the city of Tampa; 
Years of experience: Roughly 5 years' experience in housing and 
financial literacy counseling; 
Recent federal grant experience: HUD housing counseling grants, HUD 
national foreclosure mitigation grants; 
Financial condition: Has not yet conducted an annual audit.[A] 
Financial statements in prior 3 years had not shown negative change in 
net assets. 

Sources: FEC grantees, Treasury, and HUD. 

[A] According to its assistance agreement, Solita's House is required 
to provide the CDFI Fund with audited financial statements within 180 
days after the close of its fiscal year. 

[End of table] 

Treasury Followed a Standardized Process to Select the Nine FEC 
Grantee Organizations: 

Treasury's CDFI Fund and OFEFA had responsibility for selecting 
grantees. To select the nine grantees, Treasury first solicited 
applications, then followed a standardized review process for each 
application. In October 2009, Treasury issued a Notice of Funds 
Availability inviting applications for the fiscal year 2009 funding 
round of the FEC program. Applications were due roughly 1 month later 
and more than 200 organizations applied. According to Treasury, the 
CDFI Fund and OFEFA selected staff from their own offices to review 
the applications, as well as staff from other federal agencies, such 
as HUD and the Department of Health and Human Services. Treasury 
officials told us that in selecting the federal agency reviewers of 
FEC applications, they sought individuals with experience in financial 
literacy and education and examined their résumés. 

Reviewers assessed the applications using a scoring process developed 
by the CDFI Fund. Following a prescreening by OFEFA staff for basic 
eligibility, applications were scored in two phases. In phase one, 
each application was evaluated by one reviewer and given a rating 
score ranging from 0 to 5 points for each of four main sections of an 
application--Implementation Plan, Proposed Impact and Effective Use, 
Organizational Capacity, and Budget and Program Funding. Treasury 
provided reviewers with specific written guidance for each rating. 
[Footnote 8] For example, the guidance stated that if a reviewer was 
"highly confident" that an applicant had chosen the most appropriate 
impact measures for its proposed FEC activities, that applicant should 
be rated "excellent" (5 points) in the section on Proposed Impact and 
Effective Use. 

The 45 applications with the highest scores in phase one advanced to 
phase two. In this second phase, Treasury further divided the 45 
applications into four groups based on the organizations' size and 
delivery method. Assigned to each group were two reviewers, as well as 
a Treasury staff member who served as team leader. The four teams in 
this second phase rescored the 45 applications following the same 
method used in the first phase. Reviewers read different applications 
in the second phase than they read in the first phase. On the basis of 
the second review, the 2 highest-scoring applications from each of the 
four groups, plus the next four highest scorers from the overall pool, 
became the 12 finalists. Treasury officials told us that a panel 
consisting of three CDFI Fund staff and two OFEFA staff then 
independently reviewed and ranked the applications of the 12 
finalists. Treasury had $2 million in funding for the fiscal year 2009 
round of the FEC program and chose to award five grants of $400,000 
each. In deciding which five organizations to fund, CDFI Fund and 
OFEFA staff selected five of the six highest-scoring applicants among 
the 12 finalists.[Footnote 9] 

For the fiscal year 2010 round of the program, Treasury officials told 
us that they did not have the same type of nationwide application 
process because of the large number of applications received in 2009. 
Instead, Treasury held a new application process for only Hawaii-based 
organizations because, as noted previously, Congress designated $3.15 
million of the $4.15 million appropriated for an eligible organization 
in Hawaii. Treasury received two applications from Hawaii-based 
organizations and, according to Treasury, followed the same process 
for reviewing these two applications that it used for the 2009 
applicants. For the non-Hawaii grants in the 2010 round of the 
program, Treasury awarded funds to three organizations that had been 
finalists in the 2009 round. 

Our review of documentation related to the selection process indicated 
that Treasury appeared to have developed reasonable selection criteria 
and appeared to have applied these criteria consistently, awarding 
grants to those applicants who received the highest ratings. Treasury 
officials also told us that they conducted due diligence before 
announcing the final FEC awards through reviews of the applicants' 
financial statements and consultations with HUD about the applicants' 
standing as HUD-approved housing counseling agencies.[Footnote 10] 
Treasury's standard operating procedures for the FEC program state 
that after grantees receive their awards, Treasury will continue 
oversight activities, such as reviewing the results of financial 
audits. 

Not Enough Time Has Passed to Assess the FEC Program's Impact, and 
Grantees May Need Guidance in Developing More Meaningful Impact 
Measures: 

Grantee organizations have been providing financial education and 
counseling services under the FEC program for less than a year, and 
therefore not enough time has passed to meaningfully assess the 
program's effectiveness and impact. The 2009 grantees have submitted 
only one performance report to date, and the 2010 grantees have not 
submitted any. Information for our review was therefore limited to the 
initial performance reports that the 2009 grantees submitted in 
January 2011. However, these data cover only a few months of program 
operations, while some desired outcomes of the FEC program, such as 
homeownership, can take years to realize. 

The five organizations that received grants under the fiscal year 2009 
round of the FEC program were notified of their awards in May 2010, 
and Treasury disbursed funds to these organizations in August 2010. 
Three of the five organizations began using their grant funds to serve 
prospective homebuyers in August 2010, and one began in October 2010. 
A fifth organization is using its grant funds for a financial 
education website, which was still under development as of June 2011. 
(See enclosure II for a description of the activities by the grantee 
organizations of the FEC program.) 

Grantees are to submit their first performance report within 6 months 
of disbursement, so only the January 2011 reports from the 2009 
grantees are available. Table 2 shows the performance goals of FEC 
program grantees, as approved by Treasury. Because grantees' 
activities and approaches are specific to each organization, the 
targets set forth in the goals differ. For example, Homewise has an 
output goal of serving 1,000 clients each year, while Solita's House 
has an output goal of serving 40 clients each year. According to staff 
at Homewise, the high goal is because the organization is using its 
grant in part to train staff at other organizations and it is 
including in the goal the clients expected to be served by these other 
organizations. By contrast, Solita's House's goal covers only direct 
services to clients and envisions a relatively high number of hours of 
service per client. Similarly, organizations' impact goals vary, and 
some organizations have established more challenging impact goals than 
others. For example, as seen in table 2, Georgia Financial Education 
Collaborative has a goal of increasing annual average household 
savings by 200 percent, while Boulder County Housing Authority's goal 
is to increase such savings by 25 percent. Such variation may be a 
function of differences in the starting point of the organizations' 
target audiences, as well as the extent of services they expect to 
provide to each client. In addition, some of the impact measures 
appear to measure interim steps (such as setting savings goals) rather 
than the ultimate desired outcome (such as meeting those goals). 

Table 2: Performance Goals of FEC Pilot Program Grantees: 

Grantee: Boulder County Housing Authority; 
Output goals: 
1. serve 150 clients each year; 
2. provide 11.5 hours of service per client; 
Impact goals: 
1. 25 percent increase in annual average household savings; 
2. 75 percent of clients use formal budgeting tools; 
3. 75 percent of clients increase their credit scores. 

Grantee: Georgia Financial Education Collaborative; 
Output goals: 
1. serve 140 clients each year; 
2. provide 10 hours of service per client; 
Impact goals: 
1. 200 percent increase in annual average household savings; 
2. 75 percent of clients use formal budgeting tools; 
3. 25 percent average decrease in household debt. 

Grantee: Mission Economic Development Agency; 
Output goals: 
1. serve 180 clients each year; 
2. provide 8 hours of service per client; 
Impact goals: 
1. 66 percent of clients create a long-term (12 months or longer) 
savings goal; 
2. 66 percent of clients increase their credit scores; 
3. 20 percent average decrease in household debt. 

Grantee: New Hampshire Housing Finance Authority; 
Output goals: 
1. serve 200 clients each year; 
2. provide 8 hours of service per client; 
Impact goals: 
1. 50 percent of clients create a long-term (12 months or longer) 
savings goal; 
2. 100 percent of clients use formal budgeting tools; 
3. 33 percent of clients increase their credit scores. 

Grantee: OnTrack Financial Education and Counseling; 
Output goals: 
1. serve 100 clients each year; 
2. provide 5.5 hours of service per client; 
Impact goals: 
1. 25 percent average increase in household savings; 
2. 25 percent average decrease in household debt; 
3. 25 clients obtain or qualify for a home mortgage. 

Grantee: Council for Native Hawaiian Advancement; 
Output goals: 
1. serve 500 clients each year; 
2. provide 4 hours of service per client; 
Impact goals: 
1. 50 percent of clients create a long-term (12 months or longer) 
savings goal; 
2. 50 percent of clients increase their credit scores; 
3. 50 percent of clients obtain or qualify for a home mortgage. 

Grantee: Greater Erie Community Action Committee; 
Output goals: 
1. serve 50 clients each year; 
2. provide 12 hours of service per client; 
Impact goals: 
1. 250 percent increase in annual average household savings; 
2. 75 percent of clients use formal budgeting tools; 
3. 75 percent of clients increase their credit scores. 

Grantee: Homewise, Inc.; 
Output goals: 
1. serve 1,000 clients each year; 
2. provide 8 hours of service per client; 
Impact goals: 
1. 50 percent of clients increase their household savings; 
2. 50 percent of clients increase their credit scores; 
3. 400 clients obtain or qualify for a home mortgage. 

Grantee: Solita's House, Inc.; 
Output goals: 
1. serve 40 clients each year; 
2. provide 30 hours of service per client; 
Impact goals: 
1. 30 clients increase their annual savings; 
2. 18 clients create a long-term (12 months or longer) savings goal; 
3. 30 clients increase their credit scores. 

Source: grantees' assistance agreements. 

[End of table] 

As seen in table 3, the five fiscal year 2009 grantees have reported 
to Treasury output data--the number of clients served and hours of 
service provided to date. However, because no grantee had been 
providing services for more than a few months at the time of the 
January 2011 reports, not enough time has passed to compare these 
output data with the output goals noted above because the goals are 
based on activities to be performed over the course of a full year. 

Table 2: Output Data Reported by Fiscal Year 2009 Grantees of FEC 
Program for Services Provided August 2010 through December 2010: 

Grantee: Boulder County Housing Authority; 
Number of clients served: 21; 
Hours of class time, instruction, and counseling per client: 3.89. 

Grantee: Georgia Financial Education Collaborative; 
Number of clients served: 149; 
Hours of class time, instruction, and counseling per client: 8.6. 

Grantee: Mission Economic Development Agency; 
Number of clients served: 112; 
Hours of class time, instruction, and counseling per client: 6. 

Grantee: New Hampshire Housing Finance Authority; 
Number of clients served: 0; 
Hours of class time, instruction, and counseling per client: 0. 

Grantee: OnTrack Financial Education and Counseling; 
Number of clients served: 29; 
Hours of class time, instruction, and counseling per client: 2.5. 

Source: grantees' Performance Goal Reports. 

Note: Since the January 2011 reports, grantees have continued to build 
their counseling programs. As of June 2011, three grantees told us 
they had notable increases in the number of clients served since the 
January report, and four told us they had increased the average time 
served per client. 

[End of table] 

In the January 2011 Performance Goal Reports, two of the five fiscal 
year 2009 grantees did not provide any impact data to Treasury. One 
grantee--New Hampshire Housing Finance Authority--told us that its 
grant was being used to develop an interactive financial education 
website that had not been launched when the reports were due. Another 
grantee--OnTrack Financial Education and Counseling--said it had 
collected only baseline data at the time the performance report was 
due and said impact data would be collected as participants completed 
its financial education and counseling program in subsequent years. 
Three of the five grantees did provide some impact data in their 
January 2011 Performance Goal Report. The Mission Economic Development 
Agency provided information on the number of clients who created long-
term savings goals; the Boulder County Housing Authority reported on 
the number of participants who used budgeting tools; and the Georgia 
Financial Education Collaborative reported the average percentage 
change in prospective homebuyer savings, total number of clients using 
budgeting tools, and the average percentage change in outstanding 
household debt. Because these initial impact measures are based on 
services provided for no more than a few months--while the goals are 
based on at least a full year of service--and because of measurement 
issues discussed below, we are not providing the specific results of 
these initial measures. 

Grantees May Need Guidance in Establishing More Meaningful Impact 
Measures: 

We found that some grantees were calculating the results of the impact 
measures in an erroneous or misleading way or were not fully capturing 
meaningful information, which may limit the usefulness of these data 
for assessing program effectiveness. As we have reported, successful 
performance measures should be reliable--for example, they should 
produce the same result under similar conditions.[Footnote 11] 
Treasury officials told us that they discussed the specific impact 
measures with each grantee but had not yet provided guidance to the 
grantees on how to calculate the results of the impact measures. 
Without such guidance, Treasury and the grantees may be unable to 
accurately assess the extent to which homeowners and prospective 
homebuyers have improved their financial situation and behavior after 
receiving services under the FEC program. 

We identified an instance in which a grantee was not accurately 
calculating the impact measure of average percentage increase in 
prospective homebuyer savings. According to the grantee's calculation, 
a participant who began a financial education and counseling program 
with no savings but subsequently saved $500 was shown to have a 50,000 
percent increase in savings. In fact, a percentage increase cannot be 
meaningfully calculated from zero savings because any percentage 
increase on zero is infinite. As an alternative, a more accurate and 
useful way of calculating changes in savings might be to compute total 
savings at the beginning of the program across all participants, 
compute total savings at the end of a program across all participants 
and, based on these two figures, calculate an average percentage 
change in savings. This methodology would have the advantage of 
assigning more weight to larger values and less weight to smaller 
ones. In addition, it may be advantageous to focus on net savings--
that is, savings minus debt--to provide a more complete picture of an 
individual's financial situation. For example, under one scenario, an 
individual might increase his or her savings for a down payment on a 
home by reducing the amount allotted each month to pay down credit 
card debt. In this example, the individual would be saving more, but 
at the same time could be increasing his or her debt by paying off 
less of it each month. As a result, looking at changes in savings 
without taking into account changes in debt may lead to an inaccurate 
assessment of an individual's financial health. 

We also identified ways of potentially improving the usefulness of 
other impact measures that grantees chose to use: changes in household 
debt and changes in credit scores. As with savings, some grantees of 
the FEC program are calculating the percentage change in household 
debt for each participant separately, before computing the average 
change. As was the case with savings, it might be more accurate and 
useful to calculate the change by aggregating all debt at the 
beginning of a program across all participants, and again at the end, 
and then computing the average percentage change in debt. Another way 
to make this measure more meaningful might be to distinguish between 
types of debt, as lenders view some debt, such as mortgage or student 
loan debt, more positively than other debt, such as credit card debt. 
Looking at debt relative to income might also be useful, as lenders 
often look at a debt-to-income ratio when reviewing mortgage loans for 
prospective homebuyers. For example, both government-backed mortgage 
loans and conventional mortgage loans have specific debt-to-income 
ratio limits. With regard to credit scores, reporting participants' 
actual scores themselves, rather than just the number or percentage of 
participants who improve their scores, might provide a more complete 
picture of the participants' progress toward being ready for a 
mortgage. For example, borrowers must have a credit score of at least 
500 to qualify for a mortgage backed by the Federal Housing 
Administration; individuals with scores of 580 or higher are eligible 
for maximum financing, while those with scores of between 500 and 579 
are eligible for 90 percent loan-to-value financing. Comparing a 
participant's credit scores before and after receiving financial 
education and counseling with such benchmarks may help assess 
improvement toward qualifying for a mortgage. 

Conclusions: 

The organizations selected to serve prospective homebuyers under the 
FEC program are generally experienced in providing financial education 
and housing counseling, and Treasury's process for selecting these 
organizations appears to have been conducted using established 
criteria that were applied consistently. Because grantees have been 
providing services under the FEC program for less than a year, not 
enough time has passed to meaningfully assess the impact of the 
program or the effectiveness of individual grantees. However, the 
performance measures selected and the calculation of results for some 
impact measures may not provide fully reliable or meaningful 
information with which to assess the grantees and thus the FEC 
program's impact. In addition, in some cases the impact measures being 
used do not reflect the desired outcomes but instead represent interim 
steps, such as setting savings goals. By providing additional guidance 
and technical assistance to grantees on calculating the results of 
some impact measures and working with the grantees to improve the 
measures' design, Treasury can help avoid inaccurate calculations and 
ensure the most accurate assessment of the FEC program's impact. 

Recommendation for Executive Action: 

To help ensure that FEC program grantees' impact measures are useful 
and the results of these measures are accurately recorded, we 
recommend that the Secretary of the Treasury instruct the directors of 
the CDFI Fund and OFEFA to provide additional guidance or technical 
assistance to the grantees on how to accurately and meaningfully 
calculate the results of the impact measures. This guidance or 
technical assistance could take the form of recommendations on how 
best to measure and calculate changes in savings, debt, and credit 
scores. 

Agency Comments: 

We provided a draft of this report to the Department of the Treasury 
for review and comment. Treasury provided written comments, which are 
reprinted in enclosure III. In its comments, Treasury stated that it 
concurred with the observations in our report and plans to provide 
grantees with supplemental guidance in measuring the impact of the FEC 
program prior to the next reporting deadline. Treasury also provided 
technical comments, which we incorporated as appropriate. 

We are sending copies of this report to the Department of the Treasury 
and interested congressional committees. In addition, the report will 
be available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-8678 or cackleya@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs are on the 
last page of this report. Major contributors to the report were Jason 
Bromberg, Assistant Director; Tania Calhoun; Emily Chalmers; Pamela 
Davidson; Ronald Ito; Winnie Tsen; and Seyda Wentworth. 

Signed by: 

Alicia Puente Cackley: 
Director, Financial Markets and Community Investment: 

Enclosures (3): 

[End of section] 

Enclosure I: Scope and Methodology: 

To describe the characteristics of the organizations providing 
services under the Financial Education and Counseling (FEC) Pilot 
Program, we reviewed the program applications of the five fiscal year 
2009 and four fiscal year 2010 grantees of the FEC program. In 
addition, we reviewed the Department of the Treasury's (Treasury) 
fiscal year 2009 and fiscal year 2010 Notices of Funds Availability 
and its standard operating procedures for the FEC program. We also 
reviewed the scoring sheets Treasury used in making its final award 
decisions and interviewed Treasury officials and grantee staff about 
the process followed to select grantees. 

To determine what is known about the FEC program's impact in improving 
the financial situation and behavior of homeowners and prospective 
homebuyers, we reviewed the program applications and assistance 
agreements of all nine grantees--five from the fiscal year 2009 round 
of the program and four from the fiscal year 2010 round of the 
program.[Footnote 12] We also interviewed staff of each of the 
grantees about activities planned and under way using FEC grant funds. 
In addition, we reviewed the output and impact data contained in the 
Performance Goal Reports that grantees submit to Treasury. In 
reviewing these reports, we assessed the accuracy and completeness of 
the data in them by discussing the data collection procedures with 
grantee staff. We determined that the output data (number of clients 
served and hours of service per client) were sufficiently reliable for 
the purposes of this report. Further, we noted similarities and 
differences in the performance measures that grantees have chosen to 
report and assessed the usefulness of some of the measures. We also 
assessed ways that some of the measures were being calculated, such as 
by examining one grantee's data for outliers and obvious errors and 
performing our own calculation of a case involving an outlier. 

We conducted this work from January to July 2011 in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings 
and conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Enclosure II: Activities of Grantee Organizations under the FEC Pilot 
Program: 

Grantee organizations are using a variety of approaches to serve 
prospective homebuyers under the FEC program. Below is a description 
of the activities of the nine grantees of the program. 

Fiscal Year 2009 Grantees: 

Boulder County Housing Authority (Boulder, CO): This organization 
offers an initial one-on-one appointment with a housing counselor 
followed by a series of five "tracks"--budget, credit, debt reduction, 
banking and savings, and homeownership training--each of which is 
followed with homework assignments and small workgroups that provide 
peer support. Participants receive gift cards and cash savings that 
total $500 after completing all of the tracks. 

Georgia Financial Education Collaborative (Atlanta, GA): An effort of 
four Department of Housing and Urban Development-approved housing 
counseling agencies, the collaborative is using a three-phase approach 
to serve prospective homebuyers: (1) a full-day workshop and an 
initial one-on-one session with a housing counselor, (2) 10 or more 
group financial education workshops, and (3) counseling for clients 
determined to be ready for a mortgage. 

Mission Economic Development Agency (San Francisco, CA): This agency 
offers a 6-hour workshop, offered in English and Spanish, with 2 hours 
focused on general financial education and 4 hours on the homebuying 
process. The agency also provides one-on-one financial coaching to 
help participants develop personalized financial action plans. 

New Hampshire Housing Finance Authority (Bedford, NH): This 
organization is developing an interactive online financial education 
and counseling website for use by existing clients of two housing 
programs. The website will include interactive features and focus on 
household budgeting and maintaining good credit. 

OnTrack Financial Education and Counseling (Asheville, NC): This 
organization provides one-on-one counseling and group education 
classes on-site at five apartment complexes. Its program also features 
a matched savings component to help with closing costs, down payment, 
or paying down debt that negatively affects credit scores. The 
financial coaches are residents of the targeted complexes. 

Fiscal Year 2010 Grantees: 

Council for Native Hawaiian Advancement (Honolulu, HI): The council is 
subcontracting services through partner organizations with specific 
expertise or geographic focus. The council's program includes group 
training, one-on-one counseling, matched savings, and deposit accounts. 

Greater Erie Community Action Committee (Erie, PA): The committee is 
using grant funds to provide a combination of one-on-one counseling, 
matched savings accounts, and group education. Participants begin with 
one-on-one counseling sessions with a debt and delinquency counselor. 
If deemed ready for home purchase within 3 years, participants are 
enrolled in a matched savings program and required to attend 10 group 
education classes. 

Homewise, Inc. (Santa Fe, NM): This organization is providing one-on- 
one financial counseling and group classes--offered in English and 
Spanish--in financial literacy and the homebuying process. It is also 
expanding its services to prospective homebuyers in Albuquerque, New 
Mexico, and training additional organizations that, in turn, are to 
serve prospective homebuyers in Portland, Oregon; Chicago, Illinois; 
and Charleston, South Carolina. 

Solita's House, Inc. (Tampa, FL): This organization is seeking to 
expand its current financial education and counseling program--which 
is offered in English and Spanish and includes homebuyer education, 
prepurchase counseling, financial literacy, and credit counseling--to 
incorporate new services, workshops, matched savings, and a pilot 
program focused on credit and household budgeting. 

[End of section] 

Enclosure III: Comments from the Department of the Treasury: 

Department Of The Treasury: 
Community Development Financial Institutions Fund: 
601 Thirteenth Street, NW, Suite 200 South: 
Washington, DC 20005: 

July 20, 2011: 

Ms. Alicia Puente Cackley: 
Director, Financial Markets and Community Investment: 
U.S. Government Accountability Office: 
441 G Street N.W. 
Washington, D.C. 20548: 

Dear Ms. Cackley: 

Thank you for the opportunity to comment on the Government 
Accountability Office (GAO) draft report titled Financial Education 
and Counseling (FEC) Pilot Program. The Community Development 
Financial Institutions Fund (CDFI Fund) concurs with the observations 
noted in the report. We are pleased that you acknowledged our efforts 
to conduct a fair and reasonable review process and that you noted the 
challenges faced in determining the impact of the program so soon 
after the awards were made. 

While we are confident that the FEC Pilot-Program awardees selected 
will design and implement successful financial education programs, we 
agree that additional assistance to awardees in measuring the impact 
of the program would be beneficial. Working with the Treasury's Office 
of Financial Education and Financial Access, the CDFI Fund plans to
provide awardees with supplemental guidance prior to the next 
reporting deadline. 

Thank you again for the opportunity to comment on the draft report. We 
appreciate your efforts and the collaborative relationship that you 
fostered during the course of your review. 

Sincerely, 

Signed by: 

Donna J. Gambrell: 
Director: 

[End of section] 

Footnotes: 

[1] GAO, Financial Literacy: A Federal Certification Process for 
Providers Would Pose Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-11-614] (Washington, D.C.: June 28, 
2011). 

[2] Pub. L. No. 110-289, Title I, Subtitle B, § 1132, 122 Stat. 2654, 
2727 (2008). 

[3] For the purposes of this report, we use the term "grantee" to 
refer to organizations that were awarded grants under the FEC program. 

[4] HERA provides that, "the Secretary of the Treasury shall authorize 
not more than 5 pilot project grants," which Treasury has interpreted 
to mean not more than five pilot project grants per fiscal year. 

[5] According to Treasury's Notices of Funds Availability for the FEC 
program, examples of financial education and counseling services 
include assisting prospective homebuyers in developing monthly 
budgets, building personal savings, improving credit scores, and 
financing or planning for major purchases. 

[6] [hyperlink, http://www.gao.gov/products/GAO-11-614]. The study 
that evaluated a housing counseling program was Abdighani Hirad and 
Peter M. Zorn, A Little Knowledge Is a Good Thing: Empirical Evidence 
of the Effectiveness of Pre-purchase Homeownership Counseling 
(Cambridge, Mass: Joint Center for Housing Studies, Harvard 
University, 2001). The study found that borrowers who received 
prepurchase counseling were, on average, 13 percent less likely to 
become 60-day delinquent during the study period. In addition, those 
who received individual counseling were half as likely to become 
delinquent as those that received their counseling in a classroom. 

[7] Once a housing counseling agency is HUD-approved, it must meet 
certain requirements, including (1) providing counseling to at least 
30 clients in a 12-month period; (2) employing staff trained in 
housing counseling, with at least half of the counselors having 6 
months or more of experience; and (3) undergoing financial audits, 
with those expending $500,000 or more in federal funds in a year 
undergoing a single or program-specific financial audit for that year 
and those expending less than $500,000 in a year in federal funds 
undergoing an independent audit every 2 years. See 24 C.F.R. Part 214; 
OMB Circular A-133. 

[8] According to Treasury guidance, the Implementation Plan refers to 
traits such as the applicant's understanding of the demand for FEC 
services and its marketing, outreach, and delivery strategy. Proposed 
Impact and Effective Use refers to the three impact measures an 
applicant has selected and its method of evaluating and documenting 
behavioral change in program participants. Organizational Capacity 
refers to the applicant's capacity, skills, and expertise. Budget and 
Program Funding refers to the extent to which an applicant has 
adequate funding to successfully implement the FEC program. 

[9] According to Treasury, one of the five highest-scoring 
organizations was not chosen in fiscal year 2009 because HUD indicated 
some concerns regarding its continued status as a housing counseling 
agency at the time of the fiscal year 2009 award process. Treasury 
provided this organization an award in the fiscal year 2010 round 
after consultations with HUD determined that the organization was 
again meeting its requirements. 

[10] In one case where the applicant was a collaborative entity, 
Treasury officials told us that they reviewed the financial statements 
of the organization designated as the lead applicant but not of the 
other members of the collaborative. 

[11] For example, see GAO, Tax Administration: IRS Needs to Further 
Refine Its Tax Filing Season Performance Measures, [hyperlink, 
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22, 
2002), 45-53. 

[12] An assistance agreement is a formal agreement between Treasury 
and grantees that includes the terms and conditions of the FEC grant. 
These agreements contain information on the output and impact goals 
that grantees will seek to achieve with their grant funds. 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: