This historical document was an internal policy review paper drafted in 2008-2009 by HUD’s Office of Policy Development and Research (PD&R) in collaboration with the Office of Fair Housing and Equal Opportunity (FHEO). The paper is a staff study in which Analysis of Impediments (AI) reports from Community Development Block Grant (CDBG) jurisdictions were randomly sampled and assessed according to a variety of criteria to help inform policy options relating to the overall AI process. The study is a descriptive analysis and not a legal compliance or program monitoring review. The paper has been cited by several studies, journals, and articles – including the Government Accountability Office’s 2010 report, “Housing and Community Grants: HUD Needs to Enhance Its Requirements and Oversight of Jurisdictions' Fair Housing Plans,” (GAO-10-905, September 2010) which referenced this study.