Module 7
AFHMP Implementation & Monitoring
Putting your plan into action and tracking effectiveness
Lesson 1
Implementation Steps
Before Accepting Applications
- Submit AFHMP to HUD for approval
- Wait for HUD written approval
- Train all staff on AFHMP requirements
- Develop marketing materials with EHO logo
- Establish partnerships with community organizations
- Set up record-keeping systems
- Begin marketing campaign (60+ days before lease-up)
Do NOT begin accepting applications until HUD approves your AFHMP.
During Initial Lease-Up
- Implement multi-channel marketing campaign
- Track all inquiries and applications
- Monitor demographics of applicants
- Conduct ongoing community outreach
- Partner organizations actively referring
- Documentation of all activities
- Adjust marketing if demographics don't match goals
Ongoing Operations
- Maintain continuous marketing presence
- Keep partnerships active
- Quarterly demographic analysis
- Annual comprehensive AFHMP review
- Update marketing strategies as needed
- Staff training refreshers
- Submit updates to HUD every 5 years
🔑 Key Points
- HUD approval required before accepting applications
- Implementation begins before lease-up
- Continuous monitoring and adjustment required
- 5-year updates mandatory
Lesson 2
Tracking and Measuring Success
Effective AFHMPs include metrics to measure progress toward fair housing goals.
Key Metrics to Track
- Applicant demographics by protected class
- Tenant demographics vs. market area
- Source of applicants (how they heard about property)
- Marketing reach by channel and demographic
- Outreach event attendance and demographics
- Partnership referral numbers
- Website traffic and engagement
- Inquiries vs. applications vs. lease signings
- Reasonable accommodation requests
- Discrimination complaints
Data Collection Methods
- Voluntary demographic questionnaires
- "How did you hear about us?" on applications
- Marketing tracking codes/links
- Event sign-in sheets
- Partnership referral forms
- Website analytics
- Inquiry and tour logs
Demographic data collection must be voluntary and separate from the application. Never use for selection decisions.
Example:
Sample Quarterly Report: Quarter: Q1 2024 Applicants: 45 - Hispanic/Latino: 35% (market area 42% - target exceeded) - White: 40% (market area 35%) - Black: 20% (market area 18%) - Asian: 5% (market area 4%) Sources: - Online: 60% - Community referral: 25% - Drive-by: 10% - Other: 5% Outreach: - 3 community events attended - 200 brochures distributed - 2 new partnerships established Actions: - Continue Hispanic outreach (on target) - Increase online presence - Develop partnership with Asian community center
🔑 Key Points
- Track demographics of applicants and tenants
- Measure marketing effectiveness
- Document all outreach activities
- Use data to adjust strategies
Lesson 3
Annual Review and Updates
AFHMPs require annual internal review and updates every 5 years or when significant changes occur.
Annual Review Checklist
- Compare tenant demographics to market area
- Assess effectiveness of marketing channels
- Review partnership productivity
- Evaluate outreach event success
- Analyze reasonable accommodation requests
- Review any discrimination complaints
- Check staff training compliance
- Verify record-keeping completeness
- Assess budget utilization
- Identify areas for improvement
When to Submit Updates to HUD
- Every 5 years (mandatory)
- Significant change in market area demographics
- Change in property ownership or management
- Change in property use or target population
- Substantial property rehabilitation
- When HUD requests an update
- If current plan not achieving goals
Mark your calendar for the 5-year update deadline. Late submission can jeopardize HUD financing.
Update Submission Process
- Review and update market area analysis
- Update demographic data with latest census
- Revise marketing strategies based on effectiveness
- Update community partnerships
- Document changes and improvements made
- Submit to HUD Regional Office for approval
- Wait for written approval before implementation
Example:
Annual Review Summary: Date: December 15, 2024 Property: [Your Property Name] Achievements: ✓ Tenant demographics closely match market area ✓ All staff completed training ✓ 12 outreach events attended ✓ 5 active community partnerships ✓ All marketing materials compliant Challenges: ⚠ Asian population still underrepresented (2% tenants vs 4% market) ⚠ Limited response from online advertising Action Items for 2025: → Establish partnership with Asian community center → Advertise in multilingual publications → Improve website SEO and accessibility → Increase social media presence
🔑 Key Points
- Conduct thorough annual internal review
- Submit updates to HUD every 5 years
- Use data to improve effectiveness
- Document all review activities