Affirmative Fair Housing Marketing Plan Policy
Revision Effective July 3rd

 

The Ohio Housing Finance Agency has updated its policy on the submission of Affirmative Fair Housing Market Plans (AFHMPs) to align with HUD's guidance and changes in the industry. The updated policy and associated forms are effective July 3, 2017.  The Affirmative Fair Housing Marketing Plan Guidance policy must be reviewed so that all changes and requirements are understood.

 

On April 14, 2014, HUD's Office of Fair Housing and Equal Opportunity (FHEO) published a memorandum,which clarifies when updated AFHMPs need to be submitted to FHEO for review and approval for HUD and USDA funded projects. HUD provided clarification that existing AFHMP must be reviewed by the owner when:

  • at least five years have elapsed since the last review,
  • the local jurisdictions' consolidated plan is updated, or
  • significant demographic changes have occurred in the housing market area.

If the owner's analysis finds that a property's plan is satisfactory, including demonstrating that the current marketing/outreach is targeting underserved individuals, the OHFA AFHMP Review Verification (PC-46)form should be completed and attached to the existing AFHMP. Owners do not need to send the Verification form to OHFA, but they must ensure that it is available, so that OHFA compliance analysts can review it during property reviews.

 

If the owner's analysis determines that the current AFHMP requires modifications or updates, the owner must submit the updated AFHMP for approval. OHFA continues to utilize the OHFA Affirmative Fair Housing Marketing Plan (PC-E45)form to fulfill the affirmatively furthering fair housing and market plan requirements for the multifamily properties that it funds. This includes, but is not limited to, housing tax credits, National Housing Trust Funds, Ohio Housing Trust Funds and HOME funds. HUD or USDA Rural Development funding may submit to OHFA the approved plan that was submitted to these agencies. When required, the updated AFHMP must be submitted to OHFA 60 days prior to expiration of the previous AFHMP.

 

In addition to the change in submission requirements, a full policy is now published, and changes were made to the PC-E45 form. The new policy includes information about affirmatively furthering fair housing, expectations in each area of the AFHMP, errors to avoid and many resources regarding fair housing. Changes to the PC-E45 form are as follows:

  • Edited the form to only three pages.
  • Changed the housing marketing area to being selected based on what is best suited to the project. The census tract, city/town, county or possibly the MSA can serve as the housing marketing area.
    • e.g. A rural property may select the county, whereas a property in densely populated area is likely to choose a city or census tract as the housing marketing area.
  • Added Ohio protected classes (ancestry and military status) to the "Least Likely to Apply" groups and spaces to list any local protected classes that may be considered underserved in the area of the property.
  • Added additional questions about the formatting of advertising, such as alternative formats or multiple languages.
  • Added questions in the "Training of Staff" section specific to tenant selection.

Industry partners, including OHFA's Program Compliance Advisory Committee, were consulted in the revision of this policy. Questions regarding this message may be directed to Betsy Krieger, Director of Program Compliance, bkrieger@ohiohome.org.

 

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