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Resident Individualized Assessments & Adverse Action Notifications

In view of the April 4, 2016 HUD Guidelines to Providers of Housing, POE believes it is necessary to utilize additional versions of the Adverse Action Notifications that property owners and property managers are required to send, when the owners/managers intend to decline an application placed by a prospective resident. The existing required prospective resident Adverse Action Notifications do not mention the reason for decline, do not mention anything about a criminal record, and they… [Read More]

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Employment Adverse Action Notifications – Change in Conditions of Employment

Adverse Action Notifications on prospective resident applications are required to be provided by the property manager/owner when it intends to decline an applicant, AND when the property manager/owner intends to approve an applicant, with an increased security deposit and/or a guarantor. One would think it is a much simpler choice when employers review prospective employee applications. Wouldn’t one? One would think Adverse Action Notifications on prospective employees are required to be provided by the employer… [Read More]

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Prospective Resident Individualized Assessment

Property Owners/Managers are in the business of leasing quality rental housing to quality prospective residents. All applications are processed with the goal of extending an offer to lease, to qualified applicants. Unfortunately, not all applications can be approved. HUD’s April 2016 Guidance to Housing Providers strongly states that no prospective resident may be automatically denied, due to the existence of a criminal record. HUD urges all Housing Providers to create and apply your written Resident… [Read More]

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HUD Guidance, Applicants with Criminal Records & Housing Providers

On April 4, 2016, the U.S. Department of Housing and Urban Development, Office of General Counsel, issued its Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing and Real Estate-Related Transactions. The Guidance, which strongly resembles the April 25, 2012 EEOC Enforcement Guidance to Employers on the Use of Criminal Records, advises that refusing to rent to people just because they have criminal convictions — and… [Read More]

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Compliance…Compliance…Compliance

Litigation against End Users of Consumer Reports and Investigative Consumer Reports continues to Snowball across the land. And record setting settlements are being paid by employers and other end-users of screening reports. Two-thirds of FCRA suits are being brought against End Users because of invalid Authorization and Disclosure documents or because of End User failure to provide proper Adverse Action Notifications with required enclosures. Authorizations and Disclosures must not include “release of liability” or other… [Read More]