Marketing and Applications for Subsidized Housing – New Title VI Requirements

Do you know what Title VI is? Or how it affects the way a property is marketed or its application process? Leslie from Williams, Edelstein, and Tucker P.C. sits down with us to discuss the new notice and what it means for subsidized housing.

Estimated reading time: 4 minutes

Marketing and Applications for Subsidized Housing – New Title VI Requirements

What is Title VI?

Title VI of The Civil Rights Act prohibits discrimination based on three protected categories, race, color, and origin. From a housing standpoint, what that means is that someone cannot be denied housing in a federally-funded property because of these three categories. In addition, they cannot be provided a different level of service or benefits or be presented with a disadvantage or barrier to learning about housing based on these three categories.

HUD’s notice does not apply to conventional properties but focuses on properties that receive federal funds.

How can your marketing and application procedure negatively impact certain groups of people?

The reason why HUD issued this notice is that they were beginning to see a problematic trend of insufficient marketing. HUD found that housing providers were not making enough of an effort to reach out to their market to ensure that all racial groups had access to, and understanding of, their housing options.

This was especially the case in larger market areas. For example, larger cities or counties focused on the market in their direct neighborhoods. They focused on one demographic, which led to the exclusion of the other outlying demographics.

What are some effective vs. not effective marketing methods?

HUD has actually taken the guesswork out of marketing methods by laying out specific examples within the notice of what they feel qualifies as effective vs. not effective marketing methods. A brief example of how they have broken it down looks like this:

Not Effective

  • Word of mouth
  • Community organizations that are located in the local area or that serve a limited demographic
  • ‘For rent’ signs placed only on the property

Effective

  • Community organizations that are further away from the property and serve at least one or two different demographics
  • Placing ads on the radio, newspaper, or social media to reach a larger audience
  • Ads in public places
  • The property website is updated regularly to show availability, eligibility, and provide access to the application process.

What are some effective vs. not effective application procedures?

Again these suggestions came directly from HUD. In their opinion, only handing out paper copies created a barrier in larger market areas, especially if the leasing office operates under limited hours.

A better practice would be to have your application available on your website so that anyone can access it. Along with that, having a way for the prospect to be able to submit their application electronically. If that is not possible with your current setup, then having a drop box available removes any barriers for an applicant to submit the needed information.

What are some best practices that HUD recommends in order to give more people the opportunity to be housed?

The top two best practices to help ensure that more people have the opportunity to be housed at your property are as follows:

  1. Make sure all your property’s information, including availability and application process, is readily available in as many formats as possible.
  2. Periodically assess your waitlist and the demographics of who is currently living on your property. This will clearly indicate if your marketing efforts are reaching a widespread and diverse audience.

In conclusion, even though the notice regarding Title VI is directed at federally funded properties, every type of property, regardless of funding, should review its marketing and application procedures to ensure they are inclusive and fair housing friendly.

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[jonathan]: hello everyone welcome to episode fifty nine

of the fair housing insiders and another awesome topic for us to discuss today something

that is new when it comes to fair housing and that's hud's new title six

guidance on marketing and applications it sounds riveting i'm sure we're looking forward to leslie

thank you for being back in the show. How have you been leslie

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[leslie_tucker]: i have been great thanks jonathan have you

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[jonathan]: I'm good doing good yeah it's it's

amazing how much there's always new things to learn when it comes to fair housing

so we're glad to have you on here and give us an idea an overview

of how that's going to impact are

our guests re our audience for today so just a couple of housekeeping reminders remember

to keep in touch with us subscribe to us on youtube sign up for our

newsletter and if you're on instagram follow us at fair housing institute so let's

dive into our topic for today leslie this was a new one for me and

i was happy to see something um you know a new and fresh and it's

going to bring a lot of questions from our audience to like what do we

do with this so appreciate your expertise and being and we know you've been teaching

about this now for a little bit so let's kick it to you what is

it what is title six

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[leslie_tucker]: yeah well i'm glad that we are talking

about it jonathan because i know that a lot of my clients had not heard

about this notice was not familiar with it at all and was also not really familiar

with title six so i think it's important that um u s

house and providers are familiar generally with noticeof course you can go google it

and look it up for yourself but it is kind of dry so this is hopefully going

to give you some highlights so it's important just to kind of start out by

saying that because this notice is about title six it does not apply to conventional properties or

properties that just have tax credits this applies only to properties that receive federal funds so home funds

it's going to be your section eight project based it's going to be our um this specific notice that HUD has put out really

only applies to hud funded properties your

your your p b r a properties two twos at eleven so those are the

people who should be focusing on this information tito six specifically is

part of the civil rights act again maybe not a lot of people

have heard about it but basically what it does is it prohibits discrimination um on the basis of only three protected categories race color and national origin so

from a housing standpoint what that means is that someone cannot be denied housing an

really funded property because of these three categories they can't be treated differently provided different services provided different benefits um

they can't have a disadvantage in learning about the housing which is really what we're going to be talking about today because

of these three categories so that's basically in a nutshell what title six does

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[jonathan]: perfect thank you and so for our

audience you know if you're in that genre thank you for being here and even

if you're not you may be we know there's always changes when it comes to

your portfole o or to where you where your job may be located so we

know this as broad implication so thank youfor that that over view and helping

us understand who this applies to so our next question for you is so how

can a property management companies marketing and application procedures negatively impact certain groups of

people

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[leslie_tucker]: the reason that HUD felt it necessary

to issue this notice is because they were seeing what they considered to be sort

of problematic or insufficient marketing efforts and what they were seeing is that housing

providers we're not making efforts to reach out far enough within their marketing area to

um to ensure that all groups all ethnicities and races within your market area

know about your property um they know you know how to apply to your property

what your policies are what your application procedures are um m so if you're know

not making efforts to um kind of widen your net as far as marketing efforts go that

can have a negative impact on different groups that have the opportunity to learn about

your housing this is particularly relevant in housing that maybein larger counties or cities that have

a larger marketing area and you know your particular property may be located in let's

say a predominantly white area you're not reaching out to other parts of that city or county where other

races or ethenicities are prevalent so that kind of makes it so your net is only cast within

say just this white area you're not going to be giving that opportunity to learn

about your housing to other ethnicities

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[jonathan]: very good yeah and i'm sure we

could do a deep dive and all the different marketing tools and and how those

would apply but well maybe leave that for another

show so that's that's excellent thank you for that explanation so uh let's touch on

marketing methods in general though again this is where i get geaked out any time

we talk about marketing so what have you been teaching what are

you telling your clients are efective and not effective marketing methods in order to

stay compliant with this new issue from HUD

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[leslie_tucker]: well this actually isn't coming from me

this is laid out directly in this notice hud gives some examples of some methods that

it considers to be effective and may be not so effective or making sure that

there's a wide range of people that have opportunities to get your housing some not

so effective methods. our first and foremost word of mouth

and i think probably any marketing person can tell you that that's just not the

best way to market a business a company or services um m using community organizations

is a really good idea to maybe put your applications out allowing them to

put you know flyers up in theirmeetings or in their now social events

just to get the word out about your property but only using one or two community organization to do

that a lot of times is not effective particularly if those community organizations only serve

maybe a limited demographic so that's not going to be effective

either putting for rent signs up at your property not effective because essentially the only people

that are going to be driving by your property are the ones that are you

know usually working or living in that immediate vicinity so hud does lay out you

know what they think are some better ideas too effectively market so using those community

organizations that i just mentioned they really love that idea but making sure that you

are scouting out different organizations that serve different populations different demographics within

your market area and reaching out to at least one or two of each of

them make sure again that you're casting that wide net placing adds with newspapers radio

i know it's a little bit of an antiquated method but hud does mention that

in its notices because again it does reach a large number of people that way using social

media is also a really good idea because you're reaching a lot of people

um putting ads in public places and making sure that you're website is updated with

you know a copy of your application making sure that your eligibility quite hearing your

availability information like that can be found on your website so another really good way

of marketing and allowing people to find out about your property

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[jonathan]: okay very good nice examples of effective

and not effective and glad hud spells that out for us for a bit there

so that's good so let's move on to application procedure does hud have any comments

or what are you teaching people we come to effective versus not effective application procedures

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[jonathan]: yeah okay so let's talk about application

procedures now does hud have any comments on what's effective what's not effective what are

you teaching in your classes now leslie application procedures is kind of the second

part of this notice and again this is

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[leslie_tucker]: not coming from me this is this

is straight from hood from this notice and what HUD is seeing as methods of of

distributing applications and information regarding application procedures um is that properties who or only

handing out let's say paper copies of applications that creates a barrier for people to obtain those applications particularly

again in those larger market areas where someone may not live very close to that property currently

they're not really going to be driving by that property you know unless they may be work around there

and this is especially it negatively impacts even more f say your leasing office maybe

has limited hours maybe you're only opened three days a week because you have a shortage of help

um and you know someone is only able to pick up a copy from your

office and drop off a copy of their completed application at your office if

you're only open a couple of days a week if you're only open you know

for a limited number of hours per day that makes it really hard for someone to apply to your property um

ideas that HUD lays out in the notice are the first one and they kind of

harp on this a lot is making your application available on website and

i think that is a really really easy solution to make sure anyone

that once it has access to your application making it so they can submit a

completed application online instead of just printing it out and then may be having to

mail it or bringing it in that may require some revisions to your website which

may or may not be something that you are interested in doing but again

it's probably a good idea and it makes sure that lots of people are able to apply

if they want to um ah expanding your business hours or if you're not able

to do that putting a drop box at your office so so maybe someone that has to submit a

paper copy or once to submit a paper copy can do that at any time

and not just during business hours may be they come after work or something like

that that also expands access you housing i think those are the primary examples of things that you can do

you give better access from application standpoint

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[jonathan]: yeah yeah very good i understand i

heard it loud and clear and i know our audience will share the same sentiments

that some nice nice overview on what would be effective and not effective in some

potential changes that our aunente may need to make to make sure they're in compliance

with this new directive very good thank you Leslie so what are some best practices

that hud recommends in order to give more people the opportunity to housed

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[leslie_tucker]: the two biggest best practices that i

see in the notice are almost kind of inundating people with information making sure thatany prospect that is out there

within your market area able to easily know about how to get an application how

to submit it what your criteria is what's your availability is what's your screening procedures

are so all this information really should be very readily available so either on your

website or if you are let's say distributing materials to community organizations

have that all with a copy of your application so people don't necessarily have to call you or maybe even

go on your website it's all right there some may think now this is too

much people can just call and inquire that's true they can

but this notice really really makes a big deal about providing over providing this type of information

to prospects the other best practice is to go back and periodically accept look

at your wait list look at your applicant pool look at who is living in your property currently

you want to go back and look and re assess see if you are getting: more applicants that are

maybe of a different race than you had in previous years are your efforts working are your

marketing and application changes effective in reaching a larger swath of people

i think you know that's really important because otherwise you have no idea if your

methods are having any effect on your you're demographics um m so those are the

two i think best practices that i would communicate from the notice

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[jonathan]: good yeah i appreciate that overview and

i know again our audience is really appreciate and taking some good good notes from

this episode

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[jonathan]: what is one effective change you can

make to your application process

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[leslie_tucker]: you can allow someone to submit their

application on line without having to visit your office

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[jonathan]: how can you make sure prospects are

aware of your application process

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[leslie_tucker]: you can list that process on your

website or you can include it in your marketing materials that

you submit that you distribute out to the community

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[jonathan]: should you ask for the race or

ethnicity of your applicants

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[leslie_tucker]: you don't have to hud doesn't require you to you can

ask for that information at least signing but it might be

a good idea in order to keep track of whether you're marking efforts are successful

or working

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[jonathan]: very good so close again so close

minute thirty six so

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[leslie_tucker]: i always miss

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[jonathan]: you broke your timefrom last the last episode so well

done and again i love a great summary so for our community please pay attention

to this you know it's it's something thats new from hud this is valuable

information if you have anybody the industry that you know can value well see the

value in this particular episode please share it with them so leslie thank you again

for being on the show and every please check out fair housing firm dot com

leslie is a national speaker she's an attorney and she also has a new section

on her site where she's selling custom excuse me templates for different forms and policy

so be sure to check that out and we will also include in the show

notes a link to her site and to that particular title six also if you'd

like to read it for yourself so thank you Leslie for being here thank you

everyone for being on the show remember if you have any questions about the show

please submit them on youtube because you could win a chance at having have it

ans a gift card we appreciate those questions that are very valuable to our whole

community and you could be featured on a future episode so give us our thumbs

up for today's episode thank you every one we'll see next time take care

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