Compliance and affordable housing
FCRA and fair housing in tenant screening: what consistent has to mean
The exposure is not a wrong decision. It is two similar applicants getting different answers with no written rule to point at.
8 min read
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Compliance and affordable housing
FCRA, fair housing, and the LIHTC and HUD document sets.
Compliance and affordable housing
Income verification for LIHTC and HUD: the document set, and where it breaks
Affordable screening is a different document set, not a stricter version of conventional. A flow that only reads pay stubs cannot process the applicant at all.
8 min read
Compliance and affordable housing
A voucher holder's rent-to-income ratio should be run on their portion, not the contract rent
Applying a 3x standard to the full rent when the resident pays 30% of adjusted income declines qualified applicants, and in a growing number of jurisdictions it is unlawful.
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Compliance and affordable housing
Assets, not income, are where LIHTC certifications actually fail
A $9,000 savings account adds imputed income to a household certification. Missing it is a file finding, and the whole household has to be recertified.
8 min read
Compliance and affordable housing
A blanket criminal record exclusion is the screening policy most likely to produce a complaint
HUD guidance treats blanket criminal bans as a disparate impact risk. What survives review is a policy with a lookback, a severity test, and individualized assessment.
8 min read