Module 1
Introduction to AFHMP
Understanding the purpose, legal basis, and importance of Affirmative Fair Housing Marketing Plans
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Lesson 1
What is an AFHMP?
An Affirmative Fair Housing Marketing Plan (AFHMP) is a HUD-required document that outlines how multifamily housing owners and managers will market their properties to ensure equal housing opportunities for all persons.
Why AFHMPs Are Required
- Comply with Fair Housing Act requirements
- Prevent discrimination in housing
- Ensure diverse tenant populations
- Document affirmative marketing efforts
- Meet HUD program requirements
AFHMPs must be updated every 5 years and submitted to HUD for approval.
🔑 Key Points
- AFHMPs are required for all HUD-assisted multifamily properties
- Plans must be specific to each property
- Documentation is essential for compliance
- Regular updates ensure continued relevance
Lesson 2
Legal Framework
Fair Housing Act (1968)
The Fair Housing Act prohibits discrimination in housing based on seven protected classes:
- Race
- Color
- Religion
- National Origin
- Sex
- Familial Status (families with children under 18)
- Disability
Additional Requirements
Beyond the Fair Housing Act, AFHMPs must comply with:
- Section 504 of the Rehabilitation Act (1973)
- Americans with Disabilities Act (1990)
- HUD regulations 24 CFR 200.620 and 24 CFR 108
- State and local fair housing laws
Always check if your state or locality has additional protected classes beyond federal requirements.
🔑 Key Points
- Seven federally protected classes
- State/local laws may provide additional protections
- Compliance is mandatory, not optional
- Violations can result in penalties and loss of funding
Lesson 3
Who Needs an AFHMP?
AFHMPs are required for properties with HUD assistance, including:
- FHA-insured multifamily properties (5+ units)
- Properties with Section 8 Housing Assistance Payment contracts
- Properties with Section 236 rental assistance
- Section 202 elderly housing
- Section 811 housing for persons with disabilities
- Properties receiving HOME funds
- Low-Income Housing Tax Credit (LIHTC) properties in some jurisdictions
Even if not required, implementing an AFHMP is considered a best practice for all multifamily properties.
Timing Requirements
AFHMPs must be submitted:
- Before initial occupancy of new construction
- Before initial occupancy after substantial rehabilitation
- Every 5 years for existing properties
- When significant market changes occur
- When HUD requests an update
🔑 Key Points
- Most HUD-assisted properties need AFHMPs
- Plans required before occupancy begins
- Must be updated every 5 years minimum
- HUD approval required before implementation