(31 de marzo de 2026)- Luego que La Junta de Supervisión Fiscal (JSF) detuvo, la autorización solicitada por el Centro de Recaudación de Ingresos Municipales (CRIM) para utilizar hasta $6,863,411 de su fondo no asignado, destinados a un programa piloto para actualizar el catastro digital en Puerto Rico, el presidente de la Junta de Gobierno del (CRIM) y alcalde de Orocovis Jesús Colón Berllingeri y el director ejecutivo Javier García envío una carta con acuse de recibo con relación a la aprobación del uso del Saldo Certificado del Fondo del CRIM, por un monto de $6,863,411, para un proyecto piloto de dos años, adicional a las iniciativas del Plan Fiscal del CRIM, y diseñado para beneficiar a los municipios (el “proyecto”).
El proyecto tiene como objetivo identificar propiedades cuyos propietarios no figuran en las bases de datos del CRIM, no pueden verificarse a través del Registro de la Propiedad y, por lo tanto, permanecen inactivas en el catastro. El objetivo del CRIM es localizar a los propietarios de estas propiedades y determinar su estado de registro, para que puedan ser valoradas y, eventualmente, generar ingresos para los municipios.
31 de marzo de 2026
Mr. Robert F. Mujica Jr.
Executive Director
Financial Oversight and Management Board
The Center for Municipal Revenue Collection (“CRIM”) acknowledges receipt of the letter dated March 24, 2026, regarding the approval for the use of CRIM’s Certified Fund Balance, in the amount of $6,863,411, for a two-year pilot project, additional to the initiatives in CRIM’s Fiscal Plan, and designed to benefit municipalities (the “project”).
The project aims to identifr properties whose owners are not listed in CRIM’s databases, cannot be verified through the Property Registry, and therefore remain inactive in the cadaster. CRIM’s goal is to the owners of these properties and determine their registration status, so the properties can be valued and, eventually, generate revenue for the municipalities.
To implement the initiative, CRIM will temporarily hire 214 employees to conduct title research and appraisals. The project will operate under a hybrid model in which CRIM employs temporary staff assigned to municipalities, or municipalities can use their own employees and receive reimbursement through a Memorandum of Understanding (MOU). Reimbursements will be limited by CRIM-established caps and require adherence to monthly performance metrics. Municipalities must cover any employee salary costs that exceed CRIM’s reimbursement caps.
In this letter, the Financial Oversight and Management Board (“FOMB”), in connection with the approval of the funds, requests a series of documents from CRIM, even though the FOMB had not previously requested these documents, or CRIM promptly submitted them before the March 24 letter. Furthermore, without even reviewing the project documentation, the Board questioned the capacity of both CRIM and the municipalities to execute the MOUs described above.
With respect to the documentation requested:
• FY2025 Audited Financial Statements and FY2026 Budget-to-Actual Financial Statements: These documents had not been formally requested by the FOMB before the letter. CRIM sent both documents immediately on CRIM also notes that Budget-to-Actual figures are regularly reviewed by FOMB’s staff, offering ongoing visibility into CRIM’s financial position.
OR
REC-AUDAQÖN
MUNICAPALES
List ofInterested Municipalities, Including Those Interested in the Hybrid Modality. This information was provided to the FOMB on March 17, 2026, as previously requested.
DraftMOU with Claw BackProvisions for Noncompliance: A draft MOU was submitted to the FOMB on March 10, 2026, following its discussion at CRIM’s Governing Board meeting on February 26, 2026. The draft clearly outlines the responsibilities of all parties. Regarding the concern about varying municipal employee salaries, the MOU addresses this directly: CRIM will compensate participating employees according to the salary scale established in CRIM’s approved Remuneration Plan, and the participating municipality will cover any difference between the CRIM position salary and the employee’s actual salary. The MOU also includes performance metrics and a compliance validation framework.
Compliance Plan, Performance Measurement, and Economic Impact Breakdown by Municipality: These topics have been thoroughly discussed with FOMB’s staff during the last quarter of 2025 and into 2026. CRIM360, our operational platform, offers supervisors and administrators real-time tools to monitor and validate each employee’s work progress and its economic impact. Additionally, supervisory staff at CRIM’s Central Office are responsible for continuous compliance oversight and quality control.
As previously noted, FOMB’s letter questions about CRIM’s capacity based on issues unrelated to and not comparable with the project for which funding was requested. Each initiative has its own operational and regulatory complexities, and comparing unrelated programs is neither fair nor helpful for assessing this request. CRIM reaffirms that the work planned under this pilot project is separate from the initiatives included in CRIM’s Certified Fiscal Plan. Likewise, the references to the Essential Services Fund and the Ama de Llaves Program are misplaced, as CRIM plays no role— whether in design, administration, or implementation—in either program.
It would be highly beneficial for the FOMB to understand the objectives of this project and offer practical suggestions that aid its successful implementation, rather than creating additional obstacles, in the interest of effective collaboration.
CRIM reaffirms its commitment to collaborate and acknowledges the role assigned to the FOMB by law. At the same time, it is important to clarify that this role is purely one of fiscal oversight; it does not replace or override the powers expressly delegated by the Puerto Rico Municipal Code to CRIM’s Governing Board.
Some of the observations raised in the FOMB’s communication extend beyond fiscal oversight and, in practice, overstep upon administrative and public-policy functions that the law assigns exclusively to CRIM’s Governing Board. The Municipal Code clearly establishes the authority ofthe Governing Board to direct operations, define initiatives, and execute CRIM’s programs.
(ENRO DE RECAUDACIÖN
DC INGRLSOS MUNICIPALLS
CRIM is an entity created for the benefit of the municipalities and governed by mayors. It works with them daily and understands their specific needs, taking into account their resources and operational limitations. Because of this, CRIM is positioned to identify programs and initiatives that genuinely support municipalities and strengthen their local economies.
CRIM respects the Oversight Board’s role and values the collaborative efforts that have helped improve municipal revenues. CRIM remains receptive to the Board’s recommendations and proposals and will respectfully accept the FOMB’s intervention in those matters that have been explicitly delegated to it by law. However, it is concerning that, instead of helping resolve long-standing structural issues—such as updating the Digital Cadaster, the process has created obstacles, raised repeated objections, and added requirements that unnecessarily delay the implementation of a pilot program designed to address those issues.
There is an important distinction between oversight, which involves ensuring the proper use of fiscal assets, and imposing operational criteria that do not necessarily reflect the realities municipalities face. When these criteria, in practice, position the FOMB as the entity directing or conditioning CRIM’s day-to-day operations, collaboration risks becoming a mechanism that shifts the balance of powers established by law. Such a shift in the institutional balance ultimately impacts on the municipalities and, by extension, the residents they serve.
For these reasons, CRIM reaffirms its willingness to continue engaging in constructive dialogue and to provide relevant and reasonable information to support a responsible evaluation of the request submitted. Nevertheless, the success of this effort depends on a relationship built on institutional respect and clarity of each institution’s roles.
Cordially.
