Applicant Percentages in the Fair Housing Marketing Plan

Affirmative Fair Housing Marketing Plans require race and ethnicity percentages.  Even though this information should not appear on the waiting list, it must be collected as part of your application process.

Section 4-14 of the 4350.3 Handbook addresses applications.  4-14(3) requires that applicant households complete Form 27061-H, the Race and Ethnicity Form, for each family member.  Providing race and ethnicity is optional, and there’s no penalty for not selecting a response.

In this case, the applicant should note on the form that they refuse, or choose not to share that information.  If the applicant refuses to give the information to you, you will need to only calculate the percentage from those that have been released.

It is very important to document race and ethnicity separate from your waitlist. The 4350.3, in Section 4-16(4), notes that, although race and ethnicity is collected on applications, “it is good practice to avoid including these types of data on the property waiting list.  This information is not directly relevant to tenant selection and might result in discrimination against some applicants.”

Following these procedures will allow us to calculate the percentages needed for the AFHMP, and at the same time guard ourselves against any allegations of discrimination.