June 14, 2016 in Fair Housing, Forms, HUD Guidance

Quick Tip for Creating an Affirmative Fair Housing Marketing Plan (AFHMP) Submission

Quick Tip for Creating an Affirmative Fair Housing Marketing Plan (AFHMP) Submission

As more Owners gear up for upcoming PBCA – conducted Management and Occupancy Reviews (MORs), many are discovering a common submission challenge as they attempt to update their property’s Affirmative Fair Housing Marketing Plan.  Specifically, when completing Worksheet 1 of the HUD AFHMP Form- 935.2A, the instructions require the owner to tabulate and document the race and ethnic breakout of the applicants on the property’s waiting list.  Depending on the number of pending applicants, this can be a laborious task if such information is not already being gathered as part of the application process.   The following is a summary of HUD’s regulatory guidance and PMCS’ best practice to consider to facilitate statistical gathering in an efficient manner at your property:

Regulatory Guidance

  1. The application for housing should include the race/ethnicity of the head of household (HUD Handbook 4350.3, Rev-1, Change 4, 4-14 B.1.a.)
  2. While additional information, such as race/ethnicity is collected on applications and retained in property files, it is a good practice to avoid including these types of data on the waiting list.  This information is not directly relevant to tenant selection and might result in discrimination against some applicants.  (HUD Handbook 4350.3, Rev-1, Change 4, 4-16 D.4.) .

PMCS Best Practice

To accomplish the statistical gathering needed to complete Worksheet 1 for your property, PMCS recommends owners include the Form HUD-27061-H, Race and Ethnic Data Reporting Form, as part of the application packet.  When applicants complete the application, ask them to return with that application, the HUD 27061-H.  Note:  Applicants still have the option to not identify their race/ethnic categories, but each adult member of the household must sign and date the form.  Upon receipt of these forms from applicant households, the owner can more easily tabulate this information to record on the appropriate column of Worksheet 1 of the AFHMP.