Managers will accept and process applications in ...



OVERVIEW

Opening the Leasing Office

OVERVIEW

The guidelines/criteriaprocedures below are to be followed when on-site teams areis preparing/creating print (including mailers) and/or electronic advertising to be distributed completed at the start of every dafor the community.y, as the tasks will prepare the office staff to have all essential materials for the day.to “ABC”.

Print Advertising/MailersOffice Appearance

PROCEDURE

• ensureDoUse high resolution images and logos in all print advertising. If high resolution images of the property or logos are not available, please reach out to marketing department for assistance.Examine the leasing area, tables and restrooms to ensure they are clean and ready for the day.

• Wipe down leasing tables

Windex finger printed windows/doors

• Ensure restrooms are clean and have soap and towels

• Ensure that Fair Housing logo is included on any and all print advertising.Turn on coffee maker and ensure it is filled with water. Restock coffee pods, cups, sugar, and stirrers. Bake cookies and have snacks available.

o Follow Fair Housing guidelines when creating narratives and when using photos including people.

• Utilize tracking phone numbers and emails for print advertising as needed.

o Marketing department can provide you with this information.

• Have more than one person check for spelling and grammatical errors before distributing.Periodically throughout the day ensure that these items are restocked and available. Always ensure the coffee area, including the floor is clean.

•

• Utilize businesses with proper equipment for any necessary cutting services.Refill brochure/pamphlet holders.

• Do not use programs like Microsoft Word or PowerPoint to create print advertising. Free programs such as Canva are recommended to create a more professional look.Confirm leasing documents (applications, qualifying criteria, pet policy acceptance form, employmentemployment verification form, rental verification and welcome letters) are ready and available for new applicants.

• When direct mailers are being designed, please send final draft to marketing department and regional manager to review before distributing.

Electronic Advertising

• Use high resolution images and logos in all electronic advertising. If high resolution images of the property or logos are not available, please reach out to marketing department for assistance.

• Ensure that Fair Housing logo is included on any and all electronic advertising.

o Follow Fair Housing guidelines when creating narratives and when using photos including people.

• Utilize tracking phone numbers and emails for print advertising as needed. Marketing department can provide you with this information.

• Have more than one person check for spelling and grammatical errors before distributing.

• Do not use programs like Microsoft Word or PowerPoint to create print advertising. Free programs such as Canva are recommended to create a more professional look.

• Social Media Advertising

o All paid social media ads must be approved by Regional Manager and created by Marketing department unless otherwise advised.

o Facebook Marketplace ads are required to be posted from a personal account, not a business page. On-site team members should not use their own personal accounts to post for the community.

• Craigslist Advertising

o Delete old posts once they are 72 hours old to keep from having the account ghosted.

o Vary the narratives of the posts; do not post the same narrative or post title over and over. A good rule of thumb is to vary up 3-4 slightly different narratives.

o Be mindful of your cover photo (do not use clip art, feature a pool in December, etc.)

o Be mindful to not over-use all caps and multiple exclamation points.

• Google My Business Posts

o Google will delete posts after one week; schedule new posts on a regular basis.

• Call into Call Max to revert phones from night service to day service.

• Login into I Love Leasing to review scheduled visits, new prospect inquiries from the previous night, and a list of call backs from the previous day.

• Login into Yardi and create a current Unit Availability Report with Detail.

o Ensure that any new leases from the previous day have been entered into Yardi and that the unit is no longer listed as available.

o Review the Report with your Supervisor to identify special pricing on specific units.

• Call back all prospects from the previous day.

o Prospects want to be remembered, make them feel they were heard during their time with you while onsite/on the phone. Revisit items discussed during their visit/call, such as dogs name, time frame to move in, new pricing/availability etc.

o Be confident that your property is the best and use your best ABC techniques.

o Note in I Love Leasing / Yardi and on Guest Card, the date and time of the call back, be certain to document the discussion.

Owner/agents of HUD regulated multifamily properties are subject to several important federal civil rights laws affecting both admission and occupancy. These requirements seek to ensure that all applicants have equal access to affordable housing and that owners treat all tenants equitably.  In addition, states and local jurisdictions often establish their own civil rights laws that affect rental housing.

This is overview of the key federal civil rights and nondiscrimination requirements that pertain to admissions and occupancy in HUD regulated programs subject to the HUD Handbook 4350.3.

There are a number of technical terms used in the different Civil Rights Laws that have very specific definitions established by federal statute or regulations, or by HUD.  It is important to be familiar with the different laws and the definitions.

Owners must be familiar with the regulations implementing these civil rights laws regarding fair housing and program accessibility, and with the applicable HUD Notices explaining those requirements.  HUD’s Office of Fair Housing and Equal Opportunity (FHEO) also provide technical assistance on these requirements.

Civil Rights Laws

Americans with Disabilities Act of 1990

Title II prohibits discrimination based on disability in programs, services, and activities provided or made available by public entities. HUD enforces Title II when it relates to state and local public housing, housing assistance and housing referrals.

Title III covers new construction and alterations of areas of public accommodation built after January 26, 1993.

This includes sales or rental office, stores, services or meeting rooms open to the public and model units.

Age Discrimination Act of 1975

This Act prohibits discrimination based upon age in federally assisted and funded programs or activities, except in limited circumstances. 

It is not a violation of the Act to use age screening criteria in a particular program if age distinctions are permitted by statute for that program or if age distinctions are a factor necessary for the normal operation of the program or the achievement of a statutory objective of the program or activity. 

Civil Rights Act of 1964 (Title VI)

Title VI prohibits discrimination on the basis of race, color, or national origin for programs and activities receiving Federal Financial assistance

Complaints must be filed within 180 days

Title VI applies to any program or activity receiving federal financial assistance, not just housing.  Each federal agency has its own Title VI regulations. 

In housing, Title VI and the Fair Housing Act apply to many of the same types of activities.  However, HUD has broader investigative authority in complaints related to violations of Title VI and the authority to impose different types of remedies than it does in cases involving violations of the Fair Housing Act. 

Title VI regulations require that recipients have an affirmative obligation to take reasonable steps to remove or overcome any discriminatory practice or usage that subjects individuals to discrimination based on race, color, or national origin.  The regulations also require that, even in the absence of prior discrimination, recipients should take affirmative steps to overcome the effects of conditions that result in limiting participation by persons of a particular race, color, or national origin.

Title VI regulations also require that owners maintain racial and ethnic data showing the extent to which members of minority groups are beneficiaries of federal financial assistance

Elderly Preferences (Title VI-D of the Community Development Act of 1992

Title VI, Subtitle D of the Housing and Community Development Act of 1992 (Title VI-D) authorizes owners of certain HUD multifamily assisted developments to elect to serve elderly families, limit the numbers of disabled families residing in the projects or to adopt preferences for elderly families, depending upon the type of project and whether certain requirements are met.  While owners must comply with all relevant sections pursuant to Title VI-D, owners should pay close attention to Sections 651 and 658 with respect to eligibility and tenant selection. 

While this statute is not a civil rights law, it is referenced because if it is applied incorrectly, an owner may be in violation of federal civil rights laws, as well as program requirements. 

Section 651 of Title VI, Subtitle D of the Housing and Community Development Act of 1992 permits owners of “covered Section 8 housing projects” designed primarily for occupancy by elderly families to adopt a selection preference for elderly families.  An owner may, but is not required to, implement this preference.   If the owner adopts the preference, it must be implemented in accordance with the rules described in paragraph 3-18 of the 4350.3. Owners of properties assisted through the following programs are eligible to implement this preference:

Section 8 New Construction;

Section 8 Substantial Rehabilitation;

State Housing Agency programs for Section 8 New Construction and Substantial Rehabilitation;

Rural Housing 515/8; and

Section 8 Property Disposition Set-Aside (applies only to properties that involve substantial rehabilitation).

Section 658 of Title VI of Subtitle D of the Housing and Community Development Act of 1992 (HCDA) permits owners of certain federally assisted projects to restrict occupancy in such projects (or portions of projects) to elderly families in accordance with the rules, standards, and agreements governing occupancy in effect at the time of the development of the project. Applicability:  only owners of properties that were originally designed for the elderly and assisted through the following programs are eligible to apply this restriction:

Section 236;

Section 221(d)(3) BMIR; and

Section 202 of the Housing Act of 1959, as Section 202 existed before the enactment of the Cranston-Gonzalez National Affordable Housing Act (i.e., Section 202 projects developed prior to 1991). See paragraph 3-20 B for 202/8 eligibility requirements.

NOTE:  In order to restrict occupancy to the elderly in accordance with Section 658, the project must have continuously operated solely as an elderly project.

The formula to determine the percentages of Elderly families and non-elderly families with disabilities:

The percentage of younger families with disabilities required, is the highest percentage of non-elderly disabled on two dates (10/28/92 & 1/1/92), unless that number exceeds 10% in which case the requirement is set at 10%

Fair Housing Act, Title VIII of the Civil Rights Act of l968

Prohibits discrimination in the sale, rental and financing of dwellings

1968 – race, color, religion, and national origin

1974 - sex

Technically, this is the only “fair housing” law

Fair Housing Amendments Act of 1988

Most comprehensive civil rights statute passed in 25 years & signed by President Reagan on 9/13/88

familial status

handicap/disabilities

Fair Housing Prohibits Discrimination

The Fair Housing Act prohibits discrimination in most housing and housing-related transactions with respect to the following basis:

Race;

Color;

Religion;

Sex;

Disability;

National origin; or

Familial status.

NOTE: Familial status refers to families living with children under the age of 18, regardless of age or number of children.  Familial status also includes pregnant women, families that are planning to adopt, and families that have or are planning to have foster children or to become guardians of children.

8. Fair Housing Prohibits Actions

Under the Fair Housing Act, owners or other housing providers must not take any of the actions listed below based on race, color, religion, sex, disability, familial status, or national origin:

Deny anyone the opportunity to apply to rent housing, or deny to any qualified applicant the opportunity to lease housing suitable to his or her needs;

Provide anyone housing that is different from that provided to others;

Subject anyone to segregation, even if by floor or wing;

Restrict anyone’s access to any benefit enjoyed by others in connection with the housing program;

Treat anyone differently in determining eligibility or other requirements for admission, in use of the housing amenities, facilities or programs, or in the terms and conditions of a lease.

Deny anyone access to the same level of services;

Deny anyone the opportunity to participate in a planning or advisory group that is an integral part of the housing program;

Publish or cause to be published an advertisement or notice indicating the availability of housing that prefers or excludes persons

Discriminate in the provision of brokerage services or in residential real estate transactions;

Discriminate against someone because of that person’s relation to or association with another individual; or

Retaliate against, threaten, or act in any manner to intimidate someone because he or she has exercised rights under the Fair Housing Act.

Additional Protections for Persons with Disabilities

Although the Fair Housing Act generally requires applicants to be given equal treatment and prohibits discrimination against anyone with respect to the prohibited bases, there are certain limited circumstances when the Act requires a housing provider to treat persons with disabilities differently to enable them to have equal access to, or enjoyment of, housing and other housing-related programs. 

Specifically, the Fair Housing Act requires housing providers to provide “reasonable accommodations” to persons with disabilities.  This means an owner may have to modify rules, policies, practices, procedures and/or services to afford a person with a disability an equal opportunity to use and enjoy the housing.  In addition, the Fair Housing Act contains specific accessibility requirements that apply to the design and construction of new multifamily housing built for first occupancy after March 13, 1991.

Section 504 of the Rehabilitation Act of 1973

Section 504 is specific to assisted housing and specific to “qualified persons with disabilities”.

Many of the more recent laws (both federal and state) have taken their wording directly from Section 504.

Section 504 prohibits discrimination based upon disability in all programs or activities operated by recipients of federal financial assistance. 

Although Section 504 often overlaps with the disability discrimination prohibitions of the Fair Housing Act, it differs in that it also imposes broader affirmative obligations on owners to make their programs as a whole, accessible to persons with disabilities. 

These obligations include the following:

Making and paying for reasonable structural modifications to units and/or common areas that are needed by applicants and tenants with disabilities, unless these modifications would change the fundamental nature of the project or result in undue financial and administrative burdens;

Operating housing that is not segregated based upon disability or type of disability, unless authorized by federal statute or executive order;

Providing auxiliary aids and services necessary for effective communication with persons with disabilities; i.e., large print, verbal recorded documents, etc;

Developing a transition plan to ensure that structural changes are properly implemented to meet program accessibility requirements; and

Performing a self-evaluation of the owner’s program and policies to ensure that they do not discriminate based on disability. 

Operating their programs in the most integrated setting appropriate to the needs of qualified individuals with disabilities.

Furthermore, the Section 504 regulations establish affirmative accessibility requirements for newly constructed or rehabilitated housing, including providing a minimum percentage of accessible units.  In order for a unit to be considered accessible, it must meet the requirements of the Uniform Federal Accessibility Standards (UFAS)

The Section 504 regulations also require that recipients not discriminate in employment based upon disability. 

Architectural Barriers Act of 1968

The Architectural Barriers Act requires that buildings and facilities designed, constructed, altered, or leased with certain federal funds after September 1969 must be accessible to and useable by handicapped persons.

Owners must collect and maintain various types of information regarding prospective and current tenants to help establish compliance with program requirements such as the information used in the MOR Addendum B, etc.

Owners must keep civil rights related records in accordance with 24 CFR 1.6, 8.55(b), and 107.30.  The civil rights related records include race and ethnicity data, compliance with 504, and compliance with Executive Order 11063.

Owners are required to allow HUD staff and Contract Administrators access to the relevant records for their properties and other sources of information, as necessary, for determining compliance with civil rights and nondiscrimination requirements.

Fair Housing-Related Presidential Executive Orders:

Executive Order 11063:

Executive Order 11063 prohibits discrimination in the sale, leasing, rental, or other disposition of properties and facilities owned or operated by the federal government or provided with federal funds.

Executive Order 11246:

Executive Order 11246, as amended, bars discrimination in federal employment because of their race, color, religion, sex, or national origin.

Executive Order 12892:

Executive Order 12892, as amended, requires federal agencies to affirmatively further fair housing in their programs and activities, and provides that the Secretary of HUD will be responsible for coordinating the effort. The Order also establishes the President's Fair Housing Council, which will be chaired by the Secretary of HUD.

Executive Order 12898:

Executive Order 12898 requires that each federal agency conduct its program, policies, and activities that substantially affect human health or the environment in a manner that does not exclude persons based on race, color, or national origin.

Executive Order 13166:

Executive Order 13166 eliminates, to the extent possible, limited English proficiency as a barrier to full and meaningful participation by beneficiaries in all federally-assisted and federally conducted programs and activities.

Executive Order 13217:

Executive Order 13217 requires federal agencies to evaluate their policies and programs to determine if any can be revised or modified to improve the availability of community-based living arrangements for persons with disabilities.

504 Reference Chart

|PROPERTY STATUS | |APPLICABLE | |

|UNDER 504 |REFER |APARTMENT GOALS |COMMENTS |

| |ENCE | | |

|New construction |§ 8.22 |5% / 2% |All new construction must meet the goals. |

| | | | |

|Substantial alterations| | | |

| |§ 8.23 (a) |5% / 2% |Applicable to any site with: 15 or more apartments AND rehab/repair work costs|

| | | |greater than 75% of replacement value. |

|Other alterations | | | |

| | | |To the maximum extent feasible, properties must be made readily accessible & |

|Existing Housing |§ 8.23 (b) |5% / 2% |usable by individuals with disabilities. Maximum extent feasible defined as |

|Program | |(met over time) |not creating an undue financial and administrative burden for the property. |

|(properties not | | | |

|undergoing alterations)| | |Alterations of apartments and elements of apartments, when "considered |

| | | |together," trigger periodic compliance requirements at the property until the |

|Self-evaluation | | |percentage goals (5% / 2%) are reached. |

|completed | | | |

| | | |Alterations exclude normal maintenance or repairs, reroofing, interior |

|Common areas accessible| | |decoration, and changes to mechanical systems. |

| | | | |

| | | |Where multiple elements in an apartment are being replaced/repaired, the |

| | | |entire apartment must be made accessible up to the 5% / 2% goals. |

| | | | |

| | | |Property, when viewed in its entirety, must comply. |

| | | | |

| | | |Needs of existing persons with disabilities within a given household must be |

| | | |met through reasonable accommodation required by 504 and the Fair Housing |

| | | |Amendments, unless the accommodation is determined by the management to be an |

| |§ 8.24 | |undue financial and administrative burden or results in a fundamental |

| | | |alteration of the program. |

| | | | |

| | | |5% / 2% goals "activated" by substantial alterations or other alterations |

| | | |undertaken at the property. |

The Leasing Path

Knowing the areas that you will tour with a Prospect are ready is very important. The steps below are to be completed every morning.

Walk the path that will be used with Prospects throughout the day, making certain the path is free from debris. This will include:

Check all amenities ensuring they are clean and ready to help you “ABC”.

Verify that the golf carts are clean, including wiping down the seats.

Walk the model and hot units to ensure they are ready to shine.

Have in the model cleaning supplies, in the event of finger prints or dirty spots that require a quick touch up.

Turn on lights, if necessary.

Make certain you have keys available to all hot units

Unlock the pool, if needed. Verify the pool area is clean and tables are wiped down.

On weekends, some properties may not have scheduled Maintenance on staff, if this is the case you must verify trash compactors are clean and working properly.

................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download