Steering is an attempt to refer prospects to:

 other properties,

 certain buildings or areas within your property, or

 areas on the property such as playgrounds, busy roads, etc.

The following are examples of Steering (Wrong) and the same statements rephrased in a non-discriminatory way (Right):

WRONG

Walking from car to the property, you say, “Most of our families live near the playground.”

RIGHT

“We have a playground located near the mail room. Let me show it to you.”

WRONG

“The schools serving our properties are lousy.”

RIGHT

Offer factual information about locations of schools or school bus stops, but do not offer subjective information about a school’s quality or reputation. Encourage the prospect to visit the schools from sources other than you.

WRONG

“Most families don’t want to live… (near a busy street, next to the creek, on the third floor).”

RIGHT

“…is a heavily traveled street.”

Can children of the opposite sex share a bedroom?

Yes. This is a parent’s decision, not yours or the company’s. We can only establish occupancy limitation (i.e., number of persons in an apartment).

Can we still have “specials”?

Yes. All specials must be in writing, documented and offered to everyone. A verbal special is potentially very dangerous because there is no way to prove that such a special was offered to every prospect. Rather than use phrases such as “Ask me about our specials”, we need to be specific (e.g.; $200 off First months rent, expires April 30th).

For this reason it is important to update the rental schedule on a regular basis.

How do rules regarding bicycles apply?

The resident policies state that riding bicycles or motorcycles on sidewalks is prohibited. This applies to all residents – children and adults.

Can we limit families to the first floor?

No. This is discriminatory. Which floor to live on is a prospect’s decision.

Can a handicapped person have a parking space in front of his/her apartment?

Yes, if that person will pay for the signs and markings.

Why was the law changed to add families and the handicapped as protected classes?

The Fair Housing Amendments Act had three goals:

 Give HUD authority and power to enforce existing fair-housing laws.

 Make more housing available to families (and the homeless) as it is perceived that there is a shortage of such housing.

 Broaden protection of housing rights for the handicapped.

What are the penalties for discrimination?

A person who can prove discrimination can receive damages awarded by a federal court or an administrative law judge. A company will be fined $10,000 for the first offense, $25,000 for the second offense and $50,000 for the third offense.

*A Leasing Consultant or other employees can also be found personally liable for equal fines.*

Are older persons forced to live with families and young children?

The Fair Housing Amendment Act of 1988 creates two exceptions based on:

 A community where all persons are over the age of 62, or

 At least 1 person in each unit is over 55 and certain services exist and activities offered to cater to these people.

Can we offer senior citizen discounts?

Yes, if senior citizen discounts are part of your leasing policy and are applied equally to all seniors.

Does this apply to verification procedures?

Yes, in two important ways:

 First, you must make a note of the person’s name you spoke with to obtain prior residence or employment information. Make detailed notes, especially if an applicant’s history is poor.

 Second, all prospect leasing information must be retained for 2 ½ years. This is because the person who thinks he or she may have been discriminated against has up to 2 years to file a complaint with HUD. Holding the file for 30 months puts us safely past any processing delays within HUD after a complaint has been filed.

REMEMBER: Do not discriminate; do not steer prospects; do treat all persons equally; and know our statement of rental policy and other policies.