Fundamentally, a conflict of interest is not a difficult concept to grasp. Conflicts of interest arise when anyone who works for, helps run,
or is an agent of an organization, stands to gain some benefit or financial interest from the organization’s activities. An obvious example of
a conflict of interest would be an agency making STRMU back rent payments on behalf of a tenant who lives in a unit that is owned
by a director on the organization’s board. However, conflicts of interest are not always so obvious.
For example, a person living with HIV on the Board of an AIDS Service Organization as a consumer representative finds herself
in need of emergency rental assistance. As a Board member whose duties include the creation of program policies
and the supervision of the chief executive of the organization, this potential HOPWA participant would be in a policy-setting and supervisory
role over the staff that deliver direct services. Or, a non-profit that also provides HOPWA rental assistance owns a
building with permanent housing rental units in it. A client who is receiving HOPWA TBRA assistance from the organization
would like to move into one of these units. Both of these scenarios represent conflicts of interest and neither is far-fetched.
Grantees and program sponsors should think through the types of conflicts of interest that might come up, given the services
they provide. Both should have detailed conflict of interest policies that are on company letterhead and provide a mailing address,
the name of the organizational official authorizing the policies, the date of the authorization, and a telephone number.
If a potential conflict of interest situation arises, HOPWA sponsors should consult with their grantee and grantees should consult
with their local HUD Field Office before proceeding.