1. PUBLIC HOUSING
COMPLIANCE & CIVIL RIGHTS PROGRAMS
OCTOBER 24, 2012
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2. BASIC HUD CIVIL RIGHTS PROGRAM
REQUIREMENTS
1. Do not discriminate on the basis of race,
color, religion, sex, national origin,
disability, or familial status (children in
the household)
2. Provide equal opportunity to all eligible
applicants
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3. BASIC HUD CIVIL RIGHTS PROGRAM
REQUIREMENTS
3. Provide a reasonable accommodation
for the needs of persons with disabilities
4. Administer programs “in a manner to
affirmatively further fair housing”
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4. WHAT IS A COMPLIANCE REVIEW?
Comprehensive examination of Recipients’
operations under a variety of legal authorities, to
ensure that they are complying with the
requirements
of those laws
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5. THE LEGAL AUTHORITIES UNDER
WHICH WE REVIEW:
 Fair Housing Act
 Title VI of the Civil Rights Act of 1964
 Section 504 of the Rehabilitation Act of
1973
 Americans with Disabilities Act
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6. COMPLIANCE ASSESSMENT
 PIH: (1) number of complaints against the PHA in the
recent past; (2) PHA Plan reviews – specifically the AFFH
self-analysis required by 24 CFR 903.7(o); (4) analysis of
PICS data to determine if suspect racial concentrations
exist; (5) discussion with PIH staff
Key contacts:
 Executive Director, Section 504 Coordinator, Section 8
program chief, Public Housing program chief, head of the
maintenance department, tenant council presidents at
various properties (if applicable)
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7. BASIC STEPS FOR COMPLIANCE REVIEW
 Notification to PHA and request for data and
documents
 Off-site preliminary document and data review
 On-site review
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8. REVIEW RELEVANT DOCUMENTS
Reasonable Accommodation Policy
Grievance Policy/Procedures
Tenant policies/rules.
Waiting List
Employment and hiring policies
Documents associated with reasonable accommodation
requests from tenants and employees for last three years
Racial/ethnic data of employees and tenants.
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9. OUTCOMES
 LetterOf Findings – (Compliance/Non
Compliance)
 VCA (if appropriate)
 VCA monitoring
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10. SECTION 504 VIOLATIONS
 Inaccessible dwelling units and common
areas
 Lack of reasonable accommodation policy
and procedures
 Failure or delay in making reasonable
accommodation
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11. Fair Housing Act 42 U.S.C.
3608(d) and (e)(5): HUD & other
federal agencies must administer
programs and activities relating to
housing and urban development
“in a manner affirmatively to
further” fair housing policies.
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12. HUD CIVIL RIGHTS REGULATIONS
 A Public Housing Authority is required to provide a certification
of its AFFH compliance through its Civil Rights certification
with its Annual Plan (PHA) submission.
 Review AI to Fair Housing Choice Technical Assistance Memo
for Public Housing
Necessary Action by PHA
 Examine programs or proposed programs
 Identifies any impediments to fair housing within program
areas
 Address impediments in a reasonable time frame
 Maintain records reflecting these analysis and actions
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13. TAKE ACTION TO FIX THE PROBLEMS
PHA should
complete
a comprehensive
AI based upon its 5
year PHA plan cycle.
Update as needed in
your annual PHA
plan. 13

14. OVERCOME IMPEDIMENTS
 Address each identified impediment
 Set goals with measurable results
 Determine time period for completion
 Not everything can be accomplished in one
year – set a schedule & ID milestones
 Identify resources
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15. ON THE HUD WEB SITE:
 Promoting Fair Housing web page:
http://www.hud.gov/offices/fheo/promotingf
h.cfm
 Planning Guide:
http://www.hud.gov/utilities/intercept.cfm?h
ttp://www.hud.gov/offices/fheo/images/fhp
g.pdf
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16. CONTACT INFORMATION
 Barbara Delaney
 Philadelphia Center Director
 U.S. Department of Housing and Urban
Development
 Office of Fair Housing and Equal Opportunity
 100 Penn Square East
 Philadelphia, Pennsylvania
 Telephone: 215-861-7637
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