Under the False Claims Act (31 U.S.C. §§ 3729–3733) and the Program Fraud Civil Remedies Act, whistleblower actions may be brought against entities receiving HUD funds (Section 8 housing, FHA mortgage insurance, CDBG grants, public housing authorities, etc.).
Key Qui Tam Provisions:
| HUD Program | Typical Fraud Pattern | Average Settlement Range | Case Volume (Annual New Filings) | |---|---|---|---| | FHA-Insured Mortgage Lending | Origination fraud, improper underwriting, false certifications | $5M–$250M | ~40–60 cases | | Section 8 Housing Choice Vouchers | Landlord overbilling, tenant fraud rings, PHA underreporting | $500K–$50M | ~15–25 cases | | Multifamily Housing (Project-Based Section 8) | Improper rent calculations, maintenance fund diversion | $1M–$100M | ~10–20 cases | | CDBG/Community Development Block Grants | Subgrantee invoice fraud, misappropriation, inadequate environmental reviews | $250K–$20M | ~5–10 cases | | Public Housing Authority Operations | Procurement kickbacks, Section 3 violations, phantom payroll | $500K–$10M | ~8–15 cases |
Source: DOJ Fraud Statistics (2021–2024), Taxpayers Against Fraud Education Fund case database.
| Firm | Focus | Market Position | |---|---|---| | Kohn, Kohn & Colapinto | Broader qui tam focus; not HUD-dedicated | National, DC | | Phillips & Cohen LLP | Healthcare/defense heavy; HUD occasional | Tier-1 boutique
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