The housing market is an ever-changing landscape, and staying updated on the latest regulations is crucial for property managers to effectively navigate the industry. In recent times, the Department of Housing and Urban Development (HUD) has introduced new Title VI requirements that carry significant implications for fair housing. In this article, we will explore the key aspects of HUD’s new Title VI requirements, specifically what it means for screening and waitlist policies in subsidized housing.
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HUD’s Title VI requirements aim to foster equal access to housing opportunities while preventing discrimination. For property managers, understanding and adhering to these regulations is not only a matter of compliance but also an opportunity to create inclusive and welcoming communities. Let us explore four common questions that have arisen since the new updates.
Do the issues of applicant screening and waiting list management apply to all housing providers or only to federally subsidized housing?
In the case of screening policies and procedures, there is a need for all housing providers to be transparent and consistent with their process. However, this is not the case when it comes to waiting lists. For instance, private market properties are not required at all to keep a waiting list, whereas low-income tax credit housing usually does. In the case of federally funded housing, providers are required to keep lists and should also have supporting documentation if a claim were to arise.
How can applicant screening create barriers and exclude individuals based on their race, color, or national origin?
Consider this scenario; you have two applicants with poor credit from different backgrounds; one is approved while the other is not. The immediate question would be, why? Again your screening policies and procedures need to be clear and applied to every person in the same manner. This way, should a decision appear to be discriminatory or called into question, you will have the ability to show why the decision was made.
How can waitlist management disadvantage or exclude certain groups of persons from accessing housing opportunities?
Getting on a waitlist for housing presents unique challenges. Housing providers that severely limit access to do so can negatively impact or put certain groups of people at a disadvantage. For example, only accepting applications during “regular” business hours or that the person has to come in to fill out the application. Another common disadvantage is having the applications only available in English. Steps need to be taken to ensure that every person has equal access to completing and submitting applications so they can be added to the waitlist.
What are some best practices when establishing applicant screening and waitlist management procedures?
- Do you require a prospect to come into the management office in person on a certain date and time to be able to apply? As mentioned, this requirement may disadvantage minorities and persons with disabilities. Consider permitting applicants to apply using
a web and/or mobile site with clear information about availability, eligibility, selection criteria, and application processes. - Permit applications are to be picked up and dropped off during non-business hours.
- Make it clear that applicants who require assistance to complete the application can request it at any time during the process.
- In marketing and application materials include clear, and consistent information about unit sizes, amenities, approximate rents, subsidies or federal programs, the process for applying, eligibility requirements, and any admission preferences;
- Distribute copies of applications and relevant application materials in languages commonly spoken by eligible residents in the housing market area who are limited English proficient.
- Consider using a lottery as an alternative to first-come first-served policies where demand is high. While the use of a lottery has been acceptable, HUD appears now to have adopted it as a best practice, especially for large housing providers.
In conclusion, the new Title VI requirements introduced by HUD mark an important step forward in ensuring fair housing practices and equal access to housing opportunities for all individuals. By implementing policies and practices that prioritize fair housing, property managers can foster a positive environment that benefits residents, the community, and the industry as a whole. The first step is to keep up to date through articles like these and ensure that every staff member is thoroughly trained in fair housing laws and best practices.
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