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Fair and Equitable Housing Office (FEHO)Affirmative Fair Housing Marketing Plan (AFHMP)

****Please complete all sections****

HCR’s Affirmative Fair Housing Marketing Plan Guide for Managing Agents, Owners, and Developers, located at http://www.nyshcr.org/AboutUs/Offices/FairHousing/, provides additional information concerning the submission of an Affirmative Fair Housing Marketing Plan.

SECTION 1 – PROJECT IDENTIFICATION

1a. Project Name: Click here to enter text.

1b. Address (include City, County, State & Zip Code): Click here to enter text.

1c. Project ID Number: Click here to enter text.

1d. Number of HCR-funded Units and Market Rate Units, if applicable: Click here to enter text.

1e. Project Type (check all that apply):

☐80/20☐Acquisition of existing occupied property☐Family☐Mitchell Lama☐New Construction☐Occupied Rehabilitation (tenants in place). List the number of unoccupied units affected Click here to enter text.☐Rehabilitation☐Senior: Choose an item.☐Site Improvement☐Special Needs

1f. Project Funding Sources:

☐HCR: Click here to enter text.☐NYS (non-HCR): ☐Federal: Click here to enter text.

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http://www.nyshcr.org/AboutUs/Offices/FairHousing/

☐Local government: Click here to enter text.☐Private (non-government): Click here to enter text.☐Other: Click here to enter text.

1g. Managing Agent Name, Address (including City, County, State & Zip Code), Telephone Number & E-mail Address: Click here to enter text.

1h. Owner Name, Address (including City, County, State & Zip Code), Telephone Number & Email Address:

Click here to enter text.

1i. Entity responsible for marketing (check all that apply):

(1) ☐ Owner☐ Agent☐ Other (specify): Click here to enter text.

(2) Name, Position, Address (including City, County, State & Zip Code), Telephone Number & Email AddressEnter Text

1j. To whom should approval and other correspondence concerning this AFHMP be sent? Indicate Name, Address (including City, State & Zip Code), Telephone Number, & Email Address:


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SECTION 2 – MARKETING PROGRAM & DIRECTION OF MARKETING ACTIVITY

2a. Affirmative Fair Housing Marketing Plan: (1) Plan Type: Choose an item.

NOTE: If Amended is selected in question 1, answer questions 2–4 below; if New, proceed to 2b

(2) Date of the first Approved AFHMP: Enter Date

(3) Reason(s) for current update:Click here to enter text.

(4) Date of Initial Occupancy: Enter Date

2b. Affirmative Fair Housing Marketing Start Date: Click here to enter a date.

NOTE : Affirmative Fair Housing Marketing must begin at least 120 days prior to initial or renewed occupancy for new construction and substantial rehabilitation projects.

Provide name and/or staff position responsible for Affirmative Fair Housing Marketing compliance.Click here to enter text.

2c. General Marketing Start Date: Click here to enter a date.

NOTE : General advertising must begin at least 90 days prior to initial or renewed occupancy for new construction and substantial rehabilitation projects.

(1) For existing projects, select below the reason general advertising will be used:Choose an item.

Choose an item.(2) Number of individuals currently on a waiting list: Enter Text

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SECTION 3 – DEMOGRAPHICS OF PROJECT AND HOUSING MARKET AREA

NOTE: The AFHMP must describe development and distribution of advertising materials which are to be produced in English, Spanish and other languages as reflected by the Least Likely to Apply (LLA) populations. Distribution should include circulation to the organizations and community-based groups serving these populations

3a. Housing Market Area:

(1) What is the Primary Housing Market Area? Click here to enter text.

(2) What is the Secondary Housing Market Area? Click here to enter text.

3b. Provide the demographic data of the primary housing market area.

White: Enter Percentage%American Indian or Alaska Native: Enter Percentage%Asian: Enter Percentage%Black or African American: Enter Percentage%Native Hawaiian or Other Pacific Islander: Enter Percentage%Hispanic or Latino: Enter Percentage%

3c. Based on demographic data of the primary housing market area, which populations have you identified as the LLA? Click here to enter text.

3d. Proposed Marketing Activities: Community Contacts:

☐ Complete and submit Worksheet 1 to describe your use of community contacts to market the project to those least likely to apply populations, and, if applicable, special needs populations and individuals with mobility and/or hearing/visual disabilities.

3e. Proposed Marketing Activities: Methods of Advertising:

☐ Complete and submit Worksheet 2 to describe your proposed methods of advertising that will be used to market to those least likely to apply. Attach copies of advertisements, radio and television scripts, Internet advertisements, websites, and brochures, etc.

3f. Proposed Marketing Activities: Languages used in advertising (other than English):Click here to enter text.

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SECTION 4 – SPECIAL POPULATIONS

Preference in the selection of tenants in not less than Enter Text of the project’s regulated rental units shall be given to households, at least one member of which is a person with Special Needs.

Check all that apply:

☐ Families who are Homeless☐ Persons and Families who are in Long Term Recovery from Alcohol Abuse☐ Persons and Families who are in Long Term Recovery from Substance Abuse☐ Persons who are Frail Elderly☐ Persons who are Homeless☐ Persons with Intellectual/Developmental Disabilities☐ Persons who are Victims of Domestic Violence☐ Persons with AIDS/HIV Related Illness☐ Persons with Physical Disability/Traumatic Brain Injury☐ Persons with Psychiatric Disabilities☐ Veterans who are Homeless☐ Veterans in Long Term Recovery from Alcohol Abuse☐ Veterans in Long Term Recovery from Substance Abuse☐ Veterans with Intellectual/Developmental Disabilities☐ Veterans who are Victims of Domestic Violence☐ Veterans with AIDS/HIV Related Illness☐ Veterans with Physical Disabilities/Traumatic Brain Injury☐ Veterans with Psychiatric Disabilities☐ Veterans who are Frail Elderly

NOTE (1) : Priority will be given to such persons with special needs who have served in the armed forces of the United States for a period of at least six months (or any shorter period due to injury incurred in such service) and have been thereafter discharged or released from the armed forces under conditions other than dishonorable.

NOTE (2) : An experienced service provider shall refer prospective tenants with Special Needs to the project and provide supportive services pursuant to the written agreement approved by HCR attached to this Affirmative Marketing Plan.

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SECTION 5 – COMMUNITY PREFERENCE

5a. Is the owner requesting a Community Preference? Choose an item.

NOTE : If you answered NO, proceed to Section 6

(1) If you answered YES:

a. What is the geographic area for the Community Preference?Click here to enter text.

b. What is the reason for having a Community Preference?Click here to enter text.

c. How do you plan to periodically evaluate your Community Preference to ensure that it does not perpetuate a discriminatory impact on protected classes?


5b. What type of Community Preference is requested? Choose an item. If Other, please specify: Enter Text

5c. Is the Community Preference area the same as the AFHMP Primary Housing Market Area as identified in Block 3a? Choose an item.

5d. If Community Preference area is not the same as the AFHMP Primary Housing Market Area, please provide the demographic make-up of the individuals eligible for the preference.

White: Enter Percentage%American Indian or Alaska Native: Enter Percentage%Asian: Enter Percentage%Black or African American: Enter Percentage%Native Hawaiian or Other Pacific Islander: Enter Percentage%Hispanic or Latino: Enter Percentage%Persons with Disabilities: Enter Percentage%Families with Children: Enter Percentage%Other ethnic group, religion, etc. Enter Percentage%

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SECTION 6 – TENANT SELECTION PROCEDURES

6a. Tenant Selection Procedures:

(1) Describe how applications will be made available to prospective tenants (e.g., who to contact and where applications may be obtained). State when the initial application period will close.Click here to enter text.

(2) Describe the process by which applications will be received and logged and how a list of eligible applicants will be created.Click here to enter text.

(3) Detail efforts to be undertaken by the developer or agent to ensure confidentiality of applicants’ personal and private information. (Criminal records, child support payments, health status, social security number, etc.)Click here to enter text.

(4) Describe how tenant eligibility will be determined (e.g., income certification employment verification, creditworthiness).Click here to enter text.

(5) Describe the characteristics which cause an applicant to be rejected from consideration. Please include a brief explanation of the appeals process. (NOTE: appeals should be handled by a different person than the person who made the initial determination).Click here to enter text.

(6) Describe the steps to prepare and implement a public lottery, including the expected schedule to do so.Click here to enter text.

(7) Will a waitlist be maintained? Choose an item.

If so, please provide the term, and the method and frequency of updating.Click here to enter text.

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6b. Tenant Selection Training/Staff:

(1) Has staff been trained on tenant selection in accordance with the project’s occupancy policy?Choose an item.

Choose an item.(2) What staff positions are/will be responsible for tenant selection?


(3)(a) Has all staff who engage in the tenant selection process reviewed New York State Homes and Community Renewal’s Guide, Worksheet and Webinar Tutorial for Applying New York State’s Anti-Discrimination Policies When Assessing Applicants for State-Funded Housing Who Have Criminal Convictions? Choose an item.

If NO, please click on this link to view the relevant guidance material.

(3)(b) Have the tenant selection policies and procedures been updated to comply with the abovementioned New York State Homes and Community Renewal Guide and Worksheet?

Choose an item.

(4) Is all staff aware of the requirements of the final rule implementing the Violence Against Women Act of 2013 (VAWA), published by HUD on November 16, 2016, and prepared to implement all requirements (including documentation requirements) of the rule regardless of whether the project, assistance program or Owner, Developer and/or Marketing Agent meets the definition of “Covered housing program” or “Covered housing provider” under the rule, as the case may be?

Choose an item. If NO, please click on this link to review the rule.

(4)(a) Have the tenant selection policies and procedures been updated to comply with the abovementioned VAWA protections and requirements?

Choose an item.

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https://www.gpo.gov/fdsys/pkg/FR-2016-11-16/pdf/2016-25888.pdf

http://www.nyshcr.org/AboutUs/Offices/FairHousing/GPCC.htm

SECTION 7– ACCESSIBILITY POLICIES

7a. Describe the process and timeline for how requests for reasonable accommodations will be handled, including the appeal process, and who will be authorized to approve or deny any such requests.


7b. Does the project have a Telecommunication Device for the Deaf (TDD) or an equally effective communication system? Choose an item.

7c. Describe any procedures established to accommodate hearing and sight impaired applicants and tenants. (Examples of methods to be used might include readers, sign language, interpreters, and Braille materials.)


7d. Management agrees to give priority for fully accessible units to persons who are in need of the special design features of an accessible unit, and priority will be given first to those living in the complex and then to persons on the waiting list. ☐

☐ Complete and submit Worksheet 1 to describe your use of community contacts to market the project to those persons with mobility, hearing and/or vision impairment.

☐ Submit Sample Community Contact Letter for Persons with Mobility, Hearing, and/or Vision Impairment. The letter must identify the number and type of fully accessible, adapted and move in ready units the project will provide.

7e. The project will provide the following:

i. A minimum of units which will be fully accessible, adapted and move in ready, for persons who have a mobility impairment and will be marketed to households, at least one member of which, has a mobility impairment and shall provide a roll-in shower for the unit (even if a bathtub was initially provided) within 30 days of a request by any tenant; and

ii. A minimum of units which will be fully accessible, adapted and move in ready for persons who have a hearing or vision impairment and will be marketed to households, at least one member of which, has a hearing or vision impairment.

7f. Describe the efforts to market the units to persons with mobility, hearing and/or vision impairment and how those on-going efforts will be documented. Also indicate whether marketing efforts will continue after the rental of a unit to someone who does not need the special design feature. Click here to enter text.

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7g. State management’s policy for verifying a person’s disability and that it will be limited to only that which is needed to establish eligibility. Note: Verification may be required only after a tenant or applicant has asked that their disability be considered by management. Click here to enter text.

7h. Describe management’s written policy for service animals and assistance animals for people with disabilities. Click here to enter text.

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SECTION 8 – SMOKING POLICY

Describe the policy to be implemented:Click here to enter text.

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SECTION 9 – AFFIRMATIVE FAIR HOUSING MARKETING RECORD KEEPING

NOTE: The AFHMP and staffs’ Fair Housing training certificates must be available for public inspection at the sales or rental office.

Identify locations where the AFHMP will be made available:

☐ Rental office☐ Real estate office☐ Site office☐ Corporate office ☐ Other (specify): Click here to enter text.

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SECTION 10 – EVALUATION OF MARKETING ACTIVITIES

10a. How will you assess the success of your marketing efforts to reach those LLA populations identified?


10b. Who and/or which staff position will be responsible for conducting this assessment annually?


10c. How will you make decisions about future marketing based on the evaluation process?Click here to enter text.

10d. Detail what remedial efforts will be taken if LLA populations are insufficiently represented in the project:


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SECTION 11 – FAIR HOUSING TRAINING

11a. Has staff been trained on the rights and obligations under federal, state, and local fair housing laws? Choose an item.

11b. Describe AFHM and Fair Housing Act staff training that is provided. Identify who provided the training and how frequently it is provided, to whom it was/will be provided, and the dates of past and anticipated trainings:


11c. Include copies of any AFHM/Fair Housing staff training materials. ☐

11d. Do you periodically assess staff skills on the use of the AFHMP and compliance with the Fair Housing Act and all applicable nondiscrimination requirements? Choose an item.

11d(1) If YES, how and how often? Click here to enter text.

11d(2). If NO, please describe actions to be taken to afford staff with proper AFHMP and Fair Housing training:


11e. The Fair Housing Poster must be prominently displayed in all offices in which sale or rental activity takes place. Check below all locations where the Poster will be displayed:

☐ Rental Office☐ Real Estate Office☐ Entrance to Project☐ Other (specify): Click here to enter text.

11f. Project Site Sign:

NOTE : Project site signs, if any, must be displayed in a conspicuous place and must include the HUD-approved Equal Housing Opportunity and Accessibility logo, slogan/or statement, and the HCR logo.

Check below all locations where the Project Site Sign will be displayed. Please submit photos of Project signs.

☐ Rental Office☐ Real Estate Office☐ Entrance to Project☐ Other (specify): Click here to enter text.

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SECTION 12 – ADDITIONAL CONSIDERATIONS

Is there anything else you would like to tell us about your AFHMP to help ensure that your program is marketed to those least likely to apply for housing in your project? Please attach additional sheets as needed.


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SECTION 13 – ATTACHMENTS

Check all attachments included:

☐Census Demographic Data

☐Copies of advertising/marketing materials to be used (if available)

☐Smoking Policy (if separate)

☐Sample Community Contact Letter for LLA Populations and Sample Community Contact Letter for Persons with Mobility, Hearing and/or Vision Impairment.

☐Other Attachment (name): Click here to enter text. ☐Other Attachment (name): Click here to enter text. ☐Other Attachment (name): Click here to enter text.

☐Other Attachment (name): Click here to enter text.

☐Other Attachment (name): Click here to enter text.

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SECTION 14 – CONTINUED COMPLIANCE AND MODIFICATION OF THE AFHMP

I hereby certify that I have read and am familiar with the requirements and provisions of the New York State Homes and Community Renewal Affirmative Fair Housing Marketing Plan Guidelines, and all information stated herein and attached Exhibits, are true and accurate. The Owner, Developer and/or Marketing Agent understands that HCR’s approval of the project’s AFHMP is not intended to establish or to serve as legal advice.

The Owner, Developer and/or Marketing Agent agrees to implement its AFHMP and tenant selection procedures in accordance with all federal, New York State, and local fair housing laws and nondiscrimination requirements, including applicable HCR guidelines.

The Owner, Developer and/or Marketing Agent further agrees to review and update its AFHMP in accordance with all applicable guidelines in order to ensure continued compliance with HCR’s policies and procedures and the HCR Mortgage and/or Regulatory Agreement. The Owner, Developer and/or Marketing Agent acknowledges that its AFHMP must be updated every five (5) years to respond to the demographic changes in the primary housing market area.

The Owner, Developer and/or Marketing Agent understands that failure to comply with HCR’s policies and procedures and the HCR Mortgage and/or Regulatory Agreement shall subject the Owner, Developer and/or Marketing Agent to the fullest extent of the law including, but not limited to, HCR limiting or prohibiting the future participation of the undersigned, any subsidiaries or related entities in NYSHCR programs.

☐ I certify that the above information is correct to the best of my knowledge.

☐ I certify that the above information is correct to the best of my knowledge.

Name of person submitting this plan Name of person submitting this plan

Title & Name of Company Title & Name of Company

Date Date

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SECTION 15 - WORKSHEET EXHIBITS

Worksheet 1: Proposed Marketing Activities – Community Contacts (See AFHMP, Block 3c, 3d and 7d. (Attach additional sheets if needed.)

For each LLA population, at least three (3) community contacts should be provided, and at least one (1) independent living center or other organization that serves persons with mobility, hearing and/or vision impairment should be provided.

The appropriate number of Community Contact organizations will be determined on an individualized basis according to the local market area.

Target Population

Community Contact Name, Address and

Phone Number

Name of Contact Person

Method of Contact Approximate Date of Contact

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Worksheet 2: Proposed Marketing Activities – Methods of Advertising (See AFHMP, Block 3d) Complete the following table by identifying your targeted marketing population(s), as indicated in Block 3a, as well as the methods of advertising that will be used to market to that population. For each targeted population, state the means of advertising that you will use as applicable to that group and the reason for choosing this media. In each block, in addition to specifying the media that will be used (e.g., name of newspaper, television station, website, location of bulletin board, etc.) state any language(s) in which the material will be provided, identify any alternative format(s) to be used (e.g. Braille, large print, etc.), and specify the logo(s) (as well as size) that will appear on the various materials. Attach additional pages, if necessary, for further explanation. Please attach a copy of the advertising or marketing material.

Methods of Advertising Targeted Population

Newspaper(s)Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Radio Station(s)Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.TV Station(s)Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Web-based MediaClick here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Bulletin BoardsClick here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Brochures, Notices, FlyersClick here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Other (specify)Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.Click here to enter text. Click here to enter text.

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