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HOMEfires - Vol. 7 No. 1, January, 2006
Q: What are Participating Jurisdictions' (PJs) responsibilities for developing, disseminating, and implementing affirmative marketing procedures?
The affirmative marketing procedures must describe specific steps that must be taken to ensure tenants who are unlikely to apply for housing without special outreach have equal access to housing opportunities generated by the use of HOME Program funds. There are five elements that each PJ or state recipient's marketing procedures must include:
PJs must provide their affirmative marketing procedures to each owner developer of HOME projects with five or more HOME-assisted units. The requirement to affirmatively market must be included in the written agreement between the PJ and the owner. The PJ should ensure the owners have an understanding of the fair housing practices for advertising and soliciting applications (targeted populations should include those least likely to apply), know what records they must keep to document compliance, and how the PJ will assess the owner's marketing procedures and their success. The HUD field office may request that a PJ provide the marketing procedures during monitoring and may evaluate whether the PJ is ensuring that owners comply with its procedures. Consequently, PJs must evaluate project owners' records during on-site monitoring to ensure that compliance is taking place and being adequately documented. There is no submission requirement for affirmative marketing procedures in the HOME regulations. However, HUD is required to review these procedures whenever changes are made. PJs should periodically review their affirmative marketing procedures to determine if they are still appropriate to the market, since demographic and market conditions in jurisdictions are not static. If the demographics of the market have changed significantly, the PJ must update its affirmative marketing procedures and submit them to HUD for review, if requested. HUD recommends that this submission be part of the Consolidated Plan process so that the procedures are subject to public review and comment. With changing demographics in the United States, there are challenges when marketing to an eligible population that is limited English proficient (LEP). If there is an LEP population, HUD encourages the PJ to:
Additional information on Limited English Proficiency is located on the HUD website. For more information on affirmative marketing procedures, please refer to "Understanding the Basics" volume of Fair Housing for HOME Participants (HUD-2005-10-CPD). The guide is available from the Community Connections Clearinghouse (http://www.comcon.org) or by calling 1-800-998-9999.
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Content Archived: May 19, 2011 | |
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