Module 5
Staff Training & Compliance
Ensuring all staff understand and implement fair housing requirements
Lesson 1
Required Staff Training
All staff involved in leasing, marketing, or management must receive comprehensive fair housing training.
Who Needs Training?
- Property managers
- Leasing consultants
- Maintenance staff
- Security personnel
- Marketing staff
- Administrative staff
- Regional managers
- Anyone with resident contact
Training Frequency
- Initial training for new hires before resident contact
- Annual refresher training for all staff
- Updates when policies or laws change
- Additional training if complaints occur
- Ongoing informal education and updates
HUD requires documentation of all training: dates, attendees, topics covered, trainer credentials.
🔑 Key Points
- All staff must receive fair housing training
- Training required annually at minimum
- Document all training thoroughly
- Update training when laws or policies change
Lesson 2
Training Content Requirements
Core Training Topics
- Fair Housing Act and protected classes
- Recognizing and avoiding discrimination
- Reasonable accommodations and modifications
- Familial status requirements
- Disability accessibility requirements
- Marketing and advertising compliance
- Application and screening procedures
- Handling discrimination complaints
- Cultural sensitivity and competency
- AFHMP goals and implementation
Scenario-Based Training
Effective training includes realistic scenarios:
Example:
Scenario Examples: 1. Applicant requests an emotional support animal in no-pets property - Must consider reasonable accommodation - Proper documentation to request - Cannot charge pet fees or deposits 2. Family with children applies for second-floor unit - Cannot steer to ground floor - Must show unit they requested - Cannot impose occupancy limits beyond code 3. Applicant needs interpreter for language assistance - Must provide language assistance - Cannot charge for interpreter - Consider multilingual materials
Role-playing and case studies help staff apply fair housing principles to real situations.
🔑 Key Points
- Cover all protected classes thoroughly
- Use real-world scenarios and examples
- Include property-specific policies
- Test understanding through exercises
Lesson 3
Compliance Documentation
Proper record-keeping is essential to demonstrate AFHMP compliance.
Required Records
- All completed applications (approved and denied)
- Waiting list with demographic data
- Reason for each denial (specific, objective)
- Marketing materials and advertisements
- Marketing budget and actual expenditures
- Outreach event attendance and materials distributed
- Partnership meeting notes and correspondence
- Staff training records and certificates
- Reasonable accommodation requests and responses
- Discrimination complaints and resolutions
- Annual AFHMP reviews
- Demographic data on applicants and tenants
Record Retention
- Retain records for minimum 5 years
- Some records may require longer retention
- Ensure records are accessible for HUD review
- Maintain confidentiality of personal information
- Store securely (physical and digital)
Lack of documentation is often interpreted as non-compliance. If you didn't document it, you didn't do it.
Annual Self-Assessment
Conduct annual review of:
- Applicant demographics vs. market area
- Tenant demographics vs. market area
- Marketing effectiveness by channel
- Outreach activities and reach
- Partnership productivity
- Reasonable accommodation requests
- Complaints or concerns
- Staff training compliance
- Areas for improvement
🔑 Key Points
- Document everything related to AFHMP
- Retain records for minimum 5 years
- Conduct annual compliance self-assessment
- Be prepared for HUD reviews at any time
Lesson 4
Avoiding Fair Housing Violations
Understanding common violations helps staff avoid discrimination.
Common Violations to Avoid
- Steering - directing applicants to specific units based on protected class
- Discriminatory advertising - ads that prefer or exclude protected classes
- Discriminatory statements - comments suggesting preference or limitation
- Different terms - offering different prices, terms, or conditions
- Refusing reasonable accommodations - denying legitimate requests
- Occupancy limits - restrictive policies that exclude families
- Selective enforcement - applying rules differently to different groups
- Retaliation - punishing residents who assert fair housing rights
- Sexual harassment - unwelcome sexual advances or comments
- Disability inquiries - asking about nature or severity of disability
NEVER ask about, comment on, or make assumptions based on protected class characteristics.
Red Flag Phrases
These phrases indicate discrimination:
- "Perfect for families" or "No children"
- "Close to church" or "Christian community"
- "Great for retirees" or "No seniors"
- "Able-bodied individuals only"
- "English-speaking preferred"
- "Professional singles" or "Young professionals"
- "Walk-up only" (suggesting no disabilities)
- Any reference to race, color, or national origin
Example:
Safe Approach: Instead of: "This unit is perfect for families with children." Say: "This is a 2-bedroom, 1-bath unit on the first floor." Instead of: "Are you able to climb stairs?" Say: "This unit is on the third floor with no elevator. Here are the features..." Instead of: "Most of our residents are professionals." Say: "We welcome all qualified applicants who meet our screening criteria."
🔑 Key Points
- Know common violations to avoid them
- Eliminate discriminatory phrases from vocabulary
- Treat all applicants identically
- Focus on property features, not resident characteristics