HUD Clarifies Review Process for Sites’ Fair Housing Marketing Plans

On Sept. 22, HUD's Deputy Assistant Secretary for Multifamily Housing, Ben Metcalf, issued a memo that clarifies the review and approval of a multifamily property owner’s Affirmative Fair Housing Marketing Plan (AFHMP). This memo supersedes a May 2014 memo from the Office of Asset Management.

HUD’s Office of Fair Housing and Equal Opportunity (FHEO) is required to review initial AFHMPs for multifamily properties and any existing AFHMPs that have been updated based on the owner’s internal review and determination that the plan required modification.

Metcalf’s memorandum provides greater detail regarding the circumstances under which owners must submit updates to existing AFHMPs to FHEO for its review and approval. The new guidance also specifies that an AFHMP is required for projects new to multifamily assistance, including projects transitioning to the Project-Based Rental Assistance program through the Rental Assistance Demonstration Program.

The memorandum states that owners should review an existing AFHMP if:

• At least five years have passed since the last review;
• Significant demographic changes have occurred in the housing market area; and
• The local jurisdiction’s Consolidated Plan has been updated.

Owners must also submit an updated AFHMP when adopting a new residency preference in their admission policies.

If the owner’s analysis of an existing plan finds that the plan is satisfactory, no further documentation is required by HUD. If the owner’s analysis of an existing plan determines that the current AFHMP requires revisions, an updated AFHMP must be sent to HUD for approval.