7 Tips for Reducing Fair Housing Liabilities

Hello everyone, and welcome to today's webinar. We'll give just a moment for everyone to join and then we'll get started. Hello, and welcome to today's webinar, seven tips to reduce fair housing liabilities. My name is Stephanie Anderson, and I'm the senior director of communications and social media at Grace Hill. I wanna personally thank you for joining us today. I also want to extend a special welcome to all Grace Hill, Ellis and Edge to Learn clients. And in celebration of Fair Housing Month, today's topic will explore the top liabilities associated with reasonable accommodations and modifications, fair housing questions, and trending Fair Housing Act topics with thoughtful consideration. Today's agenda is as follows. But before we get started, just a few housekeeping items. Today's webinar is being recorded and will be shared with all registered attendees later this week. As an attendee, you will be in listen only mode. This will help with any outside noise and disruption so that everyone can hear today's presentation without interruption. Of course, should you have any questions throughout today's presentation, please use the chat box located on your screen. I am so excited to formally introduce today's speaker. He is the owner of Alshire Consulting and the Vice President of Learning and Development at South Oxford Management. Wesley Alshire has worked within the property management industry for over twenty six years. During this time, he has grown from a part time leasing professional to a senior director and participated on state and local boards and education committees. Wesley's passion for learning and development has driven him to find new and creative ways to engage his audience by considering the granular details of the topic, creating a well thought out experience. His presentation style engages audiences with stories and analogies that connect realism and humor to relatable situations. Please welcome to our virtual stage, Wesley. Thank you. Thank you, Stephanie. And thank you, everyone. Welcome. And I appreciate you all joining today as we talk about one of my favorite topics, fair housing. I've actually, being in the industry for twenty six years, I have taught fair housing for somewhere over fifteen years, and I've lost track of how many years specifically it's been. But I want to go into that for just a moment with this session. And, I find myself whenever I do these sessions, whether it's live or whether it's a virtual session, asking people how they feel about whether or not they would do something deliberate to break a rule, to break the law, or to discriminate against someone. I'm going to ask you that same question. So I can't see you, I can't hear your answers, but I want you to ponder the question for a second. And this is a question I ask a lot of times when I'm doing a live session too. Would you deliberately, deliberately discriminate against someone who comes into your office? Think about that just for a second. Would you deliberately discriminate against somebody? The chances are, most of you, hopefully all of you would say absolutely not, because that would be against the law. But the point is, if we all attend fair housing, and we annually come to see something for fair housing, and we're not gonna deliberately discriminate against someone, you've got to ask yourself, why are we breaking the law? If we're not going to, and we know about it, and the majority of us are just all, we're decent people, we don't intend to do bad things. So we've got to ask ourselves why. Now, I believe it's because of innocent habits or even rigid habits, but with no actual intent to break the law, most of the time. That's why this session is focused on tips, tips to help reduce liability with fair housing. We talk all about the different policies and what guidelines come out and changing legislation, but I believe being is, if you actually just start with the fact that we aren't deliberately going to discriminate against someone, that it has to do with one of our, maybe one of our behaviors or our habits that has caused us to get ourselves in some trouble. So I'm going to point out seven tips today that talk about, that can basically help us deter or move away from some of those areas where we find ourselves in trouble with litigation. So let's start with the first one. Tip number one, think like a litigator or like a lawyer. And let me tell you what I think that means. So let's say for example, you're in your office and somebody comes in and they say, I've got an assisted animal. In our mind, we may be thinking policy, reasonable accommodations, and we may be trying to apply whatever rules or guidelines we have to those reasonable accommodations. But if we were to ever make a mistake or a slight variation to what rights we have, not just with fair housing, but with some other things that we're mandated by as well. Now, a lawyer comes back to look at this. They're not gonna just look at reasonable accommodations. Instead, the litigator is gonna look for the most broad coverage. Now, this isn't really about assistive animals in general, the idea of thinking like a litigator is it's about recognizing that fair housing guidelines have a lot of gray areas, and that's what we've gotta watch for. Would it be reasonable to take into account someone who has a lower credit score if their credit concerns are directly tied to them being a victim of domestic violence? Of course. So let's take that over in that direction for just a second. If someone has a credit that is lower than our minimum expectations, typically we would charge a higher deposit. But if that person is a victim of domestic violence, it is reasonable for us to consider that and make adjustments so that we're not overcharging in those circumstances. Or let's say if someone has a criminal record that conflicts with your rural criteria, would it ever be reasonable to review circumstantial information? The answer is yes. There are circumstances where we may need to consider alternative approaches or reviewing additional information when someone has some criminal records that aren't necessarily aligned with our protocol. So there will be times where it is reasonable to research broader coverage. And when things happen, look to HUD for clarification and guidance. So going back to the assistive animals, because this is a big topic for people. And I wanna point this document out for just one second. Of all the years I've been in the industry and all of the documents and research, I've got to say that this document, you can just Google it, it's FHEO twenty twenty-one. This is the most valuable HUD document I've ever seen. It is, if there's any of them that you actually just sit down and read it, I would highly recommend this one. It is the first time I've seen one that specifically walks through the entire process and helps you guide yourself for what questions to ask and how to ask them. And it even goes as far as to say, ask this, if they say A, do this, if they say B, do this. And it walks you through that full conversation. If you look at that document and get through the first, say four or five pages, you're gonna get to very specific questions that walk you through the process. And it's gonna simplify it significantly for you. And it takes a lot of the worry away on how we're dealing with it, because we have very specific clarification provided, very specific guidance given to us from HUD. So I highly recommend that, but that first tip was to think about the fact that litigation isn't gonna look at one policy, they're gonna look at the most broad coverage and find ways to see if we are in violation in any place. So we've gotta be aware of what other coverage might protect the same area. And I'll also mention another thing. We've got potentially some chats that might pop up. If you put something in the chat box and you don't get a response right away, don't worry, we will make sure to come back and we're gonna cover these topics, and we're gonna have a Q and A towards the end. So if I don't get to questions in the beginning, just let me find, just know that we're gonna come back and talk about it. I do see that I might have something here. Let me just check this real quick. All right. Right. Okay. Let's go to next one. Tip number two, be mindful of SOP limitations. This is one where we kind of get ourselves in a little bit of trouble. And the reason I say we get ourselves into trouble, and again, go back to realizing that we aren't deliberately discriminating, at least in most cases. Sometimes there are things in place that have us doing things a certain way where we might miss or might overstep something with a rigid policy that we should be making any kind of like adjustments to our policies. I'll you some specific example here. So for starters, this right here, what our policy says, this is one of those situations where we're just following the rules sometimes. And in other situations, it could be maybe an angry resident or overwhelmed at the moment or something that could cause us to be a little bit extra rigid with our policies. And it makes sense that we wanna stand by our policies because we want consistency. But at the same time, you've got to remember that with fair housing, we sometimes have to make accommodations, reasonable accommodations could be changes or adjustments to our policies and procedures. I'm going to show you a very specific clip that was pulled out of an SOP. So this statement is part of an SOP, and it's for, it's with a company I reviewed SOPs many years ago. So this is not, this is not very recent, but there are some of them that are still out there like this. But this specific statement was inside the policy for dealing with reasonable accommodations. It said, employees will require the individual to complete a reasonable accommodation request form. Now, is straight out of an SOP and it seems innocent, but it could create a liability on the property. And I wanted to bring this one specifically up because this is the kind of problem that I see the most, where we're on-site and we're just going along our day and we're following the rules, we're staying aligned with protocol and we're getting ourselves caught up in something. And there's a couple words in this that create an issue. It says, we'll require a request form. If someone makes a request to us, and they don't want to fill out the form, it is acceptable for us to fill out the form for them, or to take the verbal request as well. But if we're not actually considering it because they haven't filled out the form, we could be creating liability. So it's important to remember that it may be a policy, but you cannot stop the idea of helping someone or resist the idea of even considering it because someone hasn't filled out that form. It's really important. So this is one of them. Watch out for those rigid policies that could have us pushing someone in a direction that the courts will not necessarily agree with. Let's go to the next. This is avoid the Sherlock syndrome. I don't know if you know what this means, but this is when someone appears to be trying to get one over on us. And it's frustrating because the truth is none of us really want to have a, one wants to get hustled, right? And we know that sometimes people are potentially trying to get away with something maybe to get out of a fee or something. And when that happens, if we decide to start looking extra close, then we're reviewing their request at a different level. And we suspect maybe that they're lying, or they're stretching the truth, or they're trying to do something to get out of paying your fees or whatever the case may be, we can't treat those people differently. Because if that person actually does have a viable, a reasonable accommodation request and a reasonable need, and we've decided to add any type of changed approach, then we are ultimately, we're treating people adversely because of their disability. So when we have someone bring in a request to us, it's important that we stay very specific in our protocol. We have to be consistent with people and treating one differently. Even if you think that they may be trying to, to hustle us, because that in itself could put us in violation of treating someone adversely because of their disability. I was reading an article and it said that, and this was an article when they released that most recent document on assistive animals. And it said that sixty percent of all of the HUD complaints that are coming in are because of disability related complaints. So it has to do with people requesting accommodations and modifications from us, and us not necessarily considering it or taking it as seriously. So the next one is the thirty second rule. When you get that request, thirty seconds, the truth is the thirty second rule does not exist. When someone comes into our office or asks us out on-site, they ask us a question about accommodation, you've got to remember that we are not required to answer within the next thirty seconds. We don't have to immediately. As a matter of fact, this specific tip, I really believe, I genuinely believe this. If all of us just got together and did this one thing, we could significantly reduce our liability. And that is when someone asks us a question that pertains to accommodations, modifications, or something fair housing related, instead of saying right off the bat, and giving some type of example, instead of that, just saying something like, I'm not quite sure, let me speak with my supervisor and I'll get back with you. If we were to do just that one thing and confirm on the spot, we could significantly reduce our liability just by not responding immediately. And it's important to know that we may not actually intend to discriminate against someone, but we could still say something that could put us in violation or at the very least, at the very least create litigation. And this session isn't just about violations of fair housing, it's about kind of preventing litigation. We can't prevent anyone from suing us because people can sue us at any time, but we can actually reduce our liabilities by reducing the amount of times that people attempt to sue us. And I'm gonna give you a very specific example of that here. There were over one hundred properties sued by a single person because of the words they used, not necessarily because of legal practices. Now, this is between twenty nineteen and twenty twenty. Somebody found a little bit of a loophole into their approach to how we answer phones, and what we say in response to something like criminal records, felonies. If you've been in the industry for the last couple of years, you know that a few years back, the way that we process applications changed significantly. I mean, it was a major shift. And this person was calling offices and trying to get people to slip up on how they responded when the person said, I have a felony, can I still live there? Well, story short, used to be these blanket policies where properties were not allowing someone to live at the property. If they had a felony for the last seven years or the last ten years ever in some cases, but this person called properties and victimized the office team, trying to get them to mix up their words. By doing so, they were recording them and they sued all of these properties. Now, it's possible that a lot of the cases could have gone into a judge and could have gone through litigation and the property could have been released from liability, it's possible, but the cost of litigation is very expensive. And in a lot of cases, companies would pay, they would pay out a settlement, a lesser amount, just to be done with it so that they didn't have to go through the litigation time and cost. And a lot of companies ended up doing that, and people were paying fifteen thousand or twenty thousand, or somewhere in that general range, just to be done with the case, because somebody said something on the phone immediately, and whether or not it was aligned with the policy or not, It was said in a way that was perceived that someone would not be welcomed just because they had a felony. And that was enough to create all these lawsuits. I'm pointing this out because we do not have to react immediately. And that's so important. There is no rule that says you've got thirty seconds to respond. So take your time, step back, and someone asks the question and say, I'm not sure, let me find out. And then just follow-up with it. That is the single best way to help us reduce liabilities when dealing with fair housing questions. Let's go to the next one. Tip number five, always report requests. Now, this is another area where there's a common situation that is, I believe, completely innocent, that's happening on our properties, that can create liability for us. And you may agree when you see what it is, here we go. All right. Someone asks about an accommodation request to our service team, and the response is something like, sorry, I can't help with that, you need to talk to the office. Now, this is an innocent habit, it can turn into a liability. If someone reports a reasonable combination, it needs to be responded to a timely. The reason, no, it's interesting because it's like, we're doing a good thing here, but we're also possibly creating a liability. It's good that the person would say, I'm not sure, for example, but if the person says you need to go talk to the office and does not react to it, then what if that person doesn't? What if that person files a claim insidating that they actually told someone that works with the company, which would be maybe this technician, and that person didn't report it. So if that happens, we could run into a problem. So for this tip here, I'm gonna say, make sure all of your team knows that if someone requests an accommodation or modification to any one of your team members, any of them, whether it be in writing or not, make sure that it's follow-up with. If individual person doesn't do so, it's okay, as long as they've passed on the message, they know who made the request, when they made the request and what the request was. So if this maintenance technician is walking by and someone says, Hey, my wife's in a wheelchair, I need a reserved spot. Instead of saying, we don't do that, or go talk to the office, say, Hey, let me get your apartment number and your name and write down the request and say, I'm going give this to the manager. You can go talk to the office, I recommend doing so, but I'll make sure they get the message and they can follow-up with you. Something as simple as that can help us prevent these reasonable accommodation requests from getting kind of lost in the shuffle. That's a really important one for us to do. So this is one of those things that happens frequently, it's something that's happening frequently, and it's an easy fix to just kind of reduce the risk of that liability, reduce the risk. That's what we're trying to do. Next tip. Encourage service providers to attend fair housing training. Now, this is a growing trend, and I've noticed this more and more as I travel around the country and I talk about fair housing with people, I've noticed that some companies are starting to ask their service providers to attend training for fair housing. And it's a good idea, because when you actually have a service provider working in your property, those service providers are considered an extension of your company, and therefore they're mandated by the same rules and guidelines. Now, is pretty important. If you realize that some companies have people visiting your properties and they may be working with your leasing team, they may be working with your residents or your applicants just in general, anyone, anyone that they come in contact with, if they're in contact with any of the people at your community, they're an extension of your community and therefore mandated by the same laws. And if they do something that's in violation of fair housing, the property can be held liable. And that's pretty important for us to know about. So if you have vendors out of your property, they're working at your property, they're doing all these different things. We wanna make sure that they've actually gone through some type of training. Now, this isn't necessarily a legal requirement, I'm not saying it's a legal requirement, but I have noticed that more and more areas are requesting that people get some type of training for the people that are actually gonna be visiting property or actually working on-site so that we don't have any issues that people aren't aware of. And it's interesting if you really think about how little something could be in order for it to be law breaking and someone who may not know about fair housing, realizing it. I'll give you an example of something. Let's say you've got someone outside doing, I don't know, repairing something in a breezeway, or painting or power washing, whatever the case may be. And someone walks up and they are maybe looking for an apartment and they're already on tour, but they're separated from the leasing person at the moment, or maybe walking through checking things out. What if someone walks up to a vendor and says, Hey, you know, there are a lot of kids over here? And innocently, the vendor saying, Oh yeah, there's a lot of kids, you can see them playing over here all the time. And it's an innocent statement, maybe, but that person could be breaking the law because then they're talking about the demographics of the community. In the most innocent form, it could put us in violation of Fair Housing, because we can't talk about the demographics of her property. Now, if you look at that situation and realize it's very civil, and it could seem as innocent as can be, but if the person doesn't know, it's something that could too easily happen. And that's where we get some liability. Well, not only that, also we have harassment that we have to worry about. If there is any type of harassment from a vendor with any of our current residents or any of our guests, that could be something that falls under fair housing litigation as well. And it doesn't even have to be discrimination, it could even be as far as ****** harassment. ****** harassment is covered under *** as a protected class. And that could be a hostile environment, which could be very, it could be something that seems innocent, but makes someone feel uncomfortable. And if it's something that makes someone feel uncomfortable, it could create what's called a hostile environment. And that could be a liability for us as well. So it's really important that we take this kind of stuff in consideration. We really need to think about making sure that anyone interacting with any of our residents or any of our guests have all been through some type of training, or at least be aware of it. Now, I've even seen a company that had a handout of did you know, just did you know checklist? And they gave it to all of their vendors that would work out in the property, all the service providers, and just made sure they had it. And it was something as simple as a quick read, something really quick, just so they had something to help them know those little nuances that could get us into some trouble. So that's something that's really helpful, because it's kind of out of our control at that point. All right, and I'm gonna go to my seventh tip here, and then we'll take some time to talk about these. All right, number seven is quick links. So, know, HUD's website is vast, and there's a lot of legal documentation, there's a lot of information on there, and sometimes it's difficult to find stuff, but I don't necessarily know when it happened, but sometime within the last couple of years, HUD has really refreshed their website, And it's a lot easier to find stuff. And now that all of this refreshing and more efficient, intuitive approach to their websites in place, it's actually a pretty efficient site to use. So I'm going to give you a specific URL and like you to write down this URL, because this is just a little piece of gold that would be very valuable for us. Let's take a look at this URL here. All right. Okay, so when it comes to fair housing, we've gotta stay aligned with all the changes in legislation. This URL, hud dot gov siteindex quicklinks. This is such a wonderful page. And if you're looking for something local or you wanna see what's new in your state, there is just not a better place to get it. Before I pass this over, I wanna show you. I pulled this up for us, so let me grab it. And I wanna show you this page. Okay, so this is that URL I'm sharing on the screen. This is the page it's gonna take you to, and literally everything on their website is just categorized in alphabetical order. So let's say you live in, let me see, let me go down to Georgia, where I'm at. Under Gs, I can click on Georgia, check this out. It's a great site, great site. We've got new news that's local to us. Now, your company may be sending you through training here, or they may send you to annual fair housing training, and it's nice to do that, and a lot of companies will do it, but we are personally liable for any kind of litigation or any kind of a fair housing violation we do. We may be a part of, I'm sorry. So it's important for us to stay aware of what the changing legislation is. And unfortunately, how does it calling every single office for a little one on one, it's our personal responsibility to stay up to date. And this is how we can do it. So if you get this quick links and you go here, you can pull up your local area. Look, I've got featured location news. You can find out where you've got local resources, different things to learn about. Everything locally is going to be easily accessible from these pages. This is such a wonderful spot to go to, and you're going to just constantly be able to come here. I recommend you put something on your calendar once a month or every couple of weeks, have somebody just go in here, look at your local area and find out if there's anything that's changed, because if there are updates, you're going to find it right here. Great site to go to. All right, now I'm going to, let me see, we'll have chances here in a moment, if we want to talk about any of these different tips or anything specifically about fair housing, you want to cover while we're on the call, but I'm going to turn it back over real quick for Stephanie. Here we go. Thank you, Wesley, for leading us through this very, very important content. And we appreciate the way that you even went off script to show us such a great website. So love that. Before we dive into the live Q and A, because I know that's something that most of our attendees really wanna engage in, I do wanna draw your attention to the screen for just a moment. I wanna let our audience know that if your team is struggling with any of the topics discussed today, our team at Grace Hill is here to help you. We do truly understand the struggles of compliance along with the excitement of career advancement. So with our industry leading policy survey training and assessment solutions, you can proactively set the standard for your team all while giving them the professional development they crave, which is so, so important in today's landscape. Our experts are available for a personalized demo and consultation anytime after today's webinar to discuss your team's development and your personal goals. So go ahead, use that chat box for me, text the words fair housing in the chat box and a member of our team will connect with you shortly. So now back to the super exciting content with Wesley. At this time, I would love to welcome attendees to ask questions using that chat box on your screen. And of course, as time allows, we will dig in to all of the questions that Wesley can answer. And while y'all are typing those in on the screen, I want to invite you to attend next month's webinar. So if you love today's content and want to again come back for another free webinar, on May seventeenth Rick Ellis will be here. He is going to talk about how to get more leases and keep those long term residents using his secret weapon FEP. And if you don't know what FEP is, you're gonna have to come back to the webinar to find out, but I promise you it's not to be missed. All right, Wesley, do we have anything in the queue for questions yet? Let's see here. I don't see any on my end. Let's see any at all. I think we're good. If there's any questions, let's type them in the chat box. Let me see chats. Let's see what we got. Oh, here we go. See if I can extend this section. All right, let me see, okay. Okay, I've got a couple here, I pulled it up now, let me see what I've got here, let me see. And Wesley, I'm seeing some questions too. Let me know if you want me to jump in and help. I know some of them were during your presentation. So I'm trying to figure out as well what they were referring to, but here's a great one. Can you go back to the beginning of your presentation? What was the publication that you recommended to read? Oh, it is actually, it's not a publication, it's a document. I'm gonna skip all the way back. You're talking about that one, the Google one? I believe so. Julie wanted to, yes, the FHEO. Yes, FHEO-twenty twenty-one. This is the most recent update with assistive animals. It has, of all the years I've worked in this industry, this is the most valuable piece of information. It goes through step by step for questions that you can get, that you can walk through that conversation with people when they have an assistive animal. And it's actually redefined it a little bit too. All of these years, we've looked at our assisted animals as a service animal and an ESA, emotional support. Although we're still kind of business as usual, this document has redefined it as service animals and other animals that provide support, which is kind of fascinating because there's always been this battle between what is a service animal, because a service animal is a dog or a midge or horse in accordance to ADA. And we've been complaining in the industry about that for years, because like people are trying to, they're trying to pull it over on us and get past fees by pretending like they have an assistive animal. Well, and because of that, there's been this back and forth debate. And I'll be honest, I'm a little bitter that it took other industries before HUD made this change, but HUD finally addressed some of the challenges we were facing with service animals. So according to this new documentation, a service animal is only a dog or a horse now, but other assistive animals are not just ESAs. So if there's another animal that provides a service, like a service animal, but it's not a dog or a major horse, then it would fall in the other category of other assistive animals, rather than being tied together with other suburb samples. So it's just a little bit of a reworking of it, but it's kind of business as usual as far as what we accept, but it tells you how to go through the conversation, what documentation is reasonable. And even in situations where you have unusual or odd pets that are not necessarily common household pets, it'll talk through what steps need to be taken or what additional information may be requested. It's great, great document. That's great. And of course, when you're talking about animals, that is a hot topic, not just during fair housing month, but year round, and it ties it right back to that SHERLOC syndrome you mentioned. Yeah, that's definitely one of the things, because if you've been in this industry for a while, we don't want people to pull an over on us. And this is one of the ones where people have, they've been pulling over us for years. And there's been all of these different instances where someone will bring in an animal and they'll not be an assistive animal and maybe have some fake documentation. And then people even getting attacked. I heard just last week of an instance where a large dog severely hurt two other animals, I'll just say that. It's unfortunate, but this document really helped with this, really helped with it. Okay, we have so many questions coming in and I know we're gonna run out of time. So I'm just trying to look through to see if there's some commonalities between them. Melissa has asked, what is the best answer when asked about having a felony? So that's a great question. Let me start with this. Your original criteria should have very specific guidelines on what is and what isn't acceptable for your criminal history. And I'm gonna go all the way back to the end again. Oh, let me get back to the end. I'm sorry, give me just one second. Being as they get very specific guidelines under real criteria, what you should say is if someone's Let me just go right to the point with the question. If someone says, I have a felony, is that gonna disqualify me? Just tell them that a felony does not disqualify you from living here. Give them the rental criterias and encourage them to apply for an apartment and treat them the same way. It's the easiest way of doing it. Just think of it as saying, someone saying, well, I'm not quite sure if my credit will pass. Anything else that they might ask, say, we still encourage you to apply. It doesn't mean your applicant wouldn't be approved. And what's most important is that you don't want to make them feel as if you're discouraging them, such as, I guess what is more important that you stay away from things like saying, if someone says they have a felony, you wanna stay away from saying, well, some felonies, you might not be able to live here because it might get rejected, but if you wanna apply, you can apply anyway. You give the impression that it could be, then that's going to create an issue. I would stay away from that, encourage them to apply, share their rental criterias. And if they ask any deeper questions than what are answered by their criteria, it's a great question, let me find out, and I'll follow-up with you, and then follow-up with the person. That's the best way. Not using that thirty second, we have to give them a final definite answer, but don't make them feel as if the answer is no, if you need to seek out information for us. Great stuff. Okay, now this one came in from Casey and Casey has asked a very specific question. So Wesley, of course, if you're not able to get into the specifications, let us know. But the question reads, is it against ADA regulations if you cannot accommodate someone who uses a cane in the pool? Modifications were in fact offered but said no. Residents says they need a rail in, but the vendor said putting in a railing would hinder the infrastructure of the pool. Okay, so let me say two things. One, this is the one part of fair housing that makes the whole idea of it a little bit frustrating is there's so much circumstantial information behind it. Let me say this, if someone makes a request and it isn't reasonable, it creates either an undue financial or administrative burden, it wouldn't necessarily be reasonable. Now, I don't have enough information about the situation to know if that would create either of those. So if it would, then it would make sense to discuss with them alternative solutions. But it's hard to say because it's a case by case situation. However, and I'll leave this open to anyone, and I'm gonna push forward on a slide here too, that I'm happy to discuss any of these with you. Can't give you legal advice, but with more information about something, I may be able to help you understand it a bit more clearly. But the problem with all those requirements, I mean, requests, Just because they request it doesn't mean it has to be like that. And if it doesn't seem reasonable, it is considered acceptable to have a discussion with them and offer an alternative. If you believe that what they're requesting would create an undue financial or administrative burden. Now, if you're not sure, you might wanna get legal counsel on it, but there's nothing that says you can't talk with them and try to come up with something that would work for everyone. If you can't get to a point, can't get to a solution that way, you really need to speak with your legal counsel about that. It's just one of those things that when it happens and you're on the verge of rejecting something, it's so much less of a challenge if you speak with your legal counsel to make sure you're aligned before you reject the idea of something. Hope that helps out. But please also, if you wanna elaborate, I'd love to talk about the scenarios in detail. Do you have an example of a handout for vendors? I'm assuming they are referring to the did you know example you gave earlier? I have seen one. I have seen a handout for one. I don't have a current copy of one, but I do recall what it had, some of the things it had. It had simple things, it was just a tip sheet. You know what? I'll tell you what, let me see. Let me ask you this, Stephanie, is it possible if I send you a link to a Q and A document that you could send it out to attendees? Absolutely. We can absolutely do that. I know I have a document from HUD that explains some of the requirements from us, And it might be a quick solution just to end something like that. It's like a Q and A right from HUD. And when we get off the call, I'll pull it up and I'll send a copy to you. Excellent, thank you. A little bit off topic, but still on topic. Does HUD do secret shopping? Yes. Actually, but it's a different kind of secret shop. Well, let me explain this, because this is kind of a big deal. If anyone ever comes to your property and they feel as if they were treated adversely, or they were discriminated against, And that person files a complaint, they filed a complaint typically through HUD. And when HUD reviews it, it's possible that they would send out a shopper to your property, or maybe not sending them, it could be virtually, it could be an email, a phone call, a walk in, they could shop you by trying to create the same type of scenario with a shopper for you to help, and then see if that shopper fell as if they were discriminated against two. Because if they did that, if they sent the shopper, they tried to duplicate the same type of situation, same kind of person, same type of questions, same scenario. If they did that, and that shopper comes back and says, they did feel like you discriminated against them, then HUD will help support that litigation claim against your property. So yes, they absolutely do. As a matter of fact, they are the ones that do, but it's not for leasing techniques, it's for discrimination cases. Okay, we're nearing the end of our time. You think we can take one or two more, Wesley? Okay, let's do it. The SHERLAK syndrome. How do we address the online verifications from someone who paid an online therapist that has not treated the resident before this? You suspect that it was simply to get signed document for an ESA. How would you investigate this? Okay, so a couple of things. Listen here, Sherlock. So there's a couple of things. First off, that document that we spoke about earlier, that I recommended to Google, that one actually covers dealing with those types of documents and what is and isn't appropriate. But there's two things you need to realize with this. One, the document itself stating that there is an assistive animal is not enough because it doesn't address whether there's a disability and both things need to be present. If there is an assistive animal, it needs to be an assistive animal to help overcome the limitations of the disability for a disabled person. Both pieces need to be present. One of the challenges we run into with these forms is the form just says, I have an assistive animal, but it doesn't say that that assistive animal is assigned to me. And if that's the case, then they don't meet their criterias. It's gonna have both pieces. There is this animal, and there is a disability that is there for. So both pieces need to be present. But I can tell you that document specifically walks through the process of dealing with that. At the same time, just because someone has a virtual doctor does not necessarily mean that it would not be acceptable, especially after COVID. At this point, people sometimes come to us with, they may do tele doctors, tele medical visits or whatever, but that doesn't mean that it's not their current doctor. It doesn't mean it's not their family doctor. And it just could be based on the changing society right now, where people are doing a lot of things virtually. So just because it's virtual, doesn't mean it's not accurate, but both pieces need to be present. And look to that document, I guarantee it'll walk you right through the process and even tell you what specifically you can request from the medical provider with instructions you can give to the medical provider so that they feel more comfortable sharing information with you. All right, let's see. There are so many here. I don't see any of those on my end. Oh, I'm just so glad I'm here to help you, Wesley. Now I feel like I have some value today to this webinar because you have been providing so much. So I'm glad I could help. All right, let's take one more. Let's see, says, let's see who, this is from Kaylin. Physicians have been requiring her tenants to register their animal with websites. These sites charge a fee. What are your thoughts on that? Okay, so I know that there is a service and I think there's a couple of them where they have a screening process for animals and it's for all animals. And the fees are only charged, my understanding is fees are only charged if they are not an assistive animal. Anyone with an assistive animal would not have to pay any of those fees. So I've seen that, and I don't think that that's a bad thing. I do know that if someone has an assistive animal and they do not want to go through that process, you should not be forcing them to go through that process. But it is reasonable for you to have that process for pets, just assistive animals. If they don't want to fill it out, they don't want to complete it, they're making an assistive animal request, a reasonable accommodation request, then it is reasonable for us to take a different approach if they don't want to do that. Excellent, excellent feedback. Let's see, Tammy asked lots of questions. So let's take one of hers really quick. She says ESA or service animal in the office? Unless it's unreasonable. Personally, I can't think of a reason why it would be unreasonable for someone to have an assistive animal with them in the office. Unless you have a viable reason to say that it's unreasonable, couldn't see the reason why you wouldn't allow it. It would make sense to allow them. Now Tammy says that they are a pet free community. It does not matter. And that's a bit of a challenge going back to our policies. So we get SOPs, like we have our policy a certain way. It's a It's a bigger challenge for properties with pet free properties, because pet free or not, assistive animals are not to be treated as an animal, and it does not matter if you have a specific building for pets or no buildings for pets, assistive animals will not have to follow any of those rules. None of those rules will apply for assistive animals. Well, wonderful. Well, I just wanna thank all of our attendees today for coming and taking an hour of their time out of their day to learn not just seven tips to reduce fair housing liabilities, but you have given us well over that in terms of knowledge. And I really just wanna thank you, Wesley, for your time today. Being able to share this information is just so much of a value to everyone. And I couldn't think of a better month to have you here for Fair Housing Month, sharing all of your knowledge. Thank you, thank you very much. And please take down my information. If you have questions, you wanna chat, I'd love to talk about it. I'm happy to help. I can't give you legal advice, but I can maybe help guide you in the right direction when you have any questions. Thank you so much, Stephanie. You for having And thank you all very much for being here today. Absolutely, we appreciate you so much and I hope everyone has a fantastic day. Thanks again for joining. See you next time.