APPENDIX 13 AFFIRMATIVE MARKETING REQUIREMENTS In accordance with the California Fair Employment and Housing Act and the policy of First 5 LA and technical advisor the Community Development Commission of the County of Los Angeles, property owners or their designees must adhere to the following affirmative marketing guidelines in order to create awareness for the general public and certain community groups as to the availability of units designated for lower, low and moderate-income tenants. Applicability Property owners or their designees are required to provide an affirmative marketing plan and procedures for all developments with designated units. Procedures to be used must identify how persons in the housing market area who are not likely to apply for the housing without special outreach shall be informed and made aware of available affordable housing opportunities. First 5 LA recognizes two groups that are the least likely to apply without special outreach efforts, namely, African-American and Hispanic persons. The Affirmative Marketing Plan The Property Owner or designee s Affirmative Marketing Plan shall consist of a written marketing strategy designed to provide information and to attract eligible persons in the housing market area to the available units without regard to race, color, national origin, sex, religion, marital and familial status, handicap (disability), sexual orientation, ancestry or source of income. It shall describe initial advertising, outreach (community contacts) and other marketing activities, which will inform potential renters of the availability of the units. It shall also outline an outreach program which includes special measures designed to attract those groups identified as least likely to apply without special outreach efforts, (because of existing neighborhood racial or ethnic patterns, location of housing or other factors) and other efforts designed to attract persons from the total eligible population. The Property Owner must do the following: 1. Insert Equal Housing Opportunity logotype, statement or slogan on all written outreach tools (i.e. signs, advertisements, brochures, direct mail solicitations, press releases, etc.) 2. Display prominently the Fair Housing poster at the leasing office and project site from the beginning of construction through occupancy. (24 CFR 110.10). This poster must be at a minimum 11 inches by 14 inches (24 CFR 110.25). 3. Register the units on a County-supported housing data base or website (i.e., www.housing.lacounty.gov), per the request of First 5 LA or its designee. 4. In addition to the above, the Affirmative Fair Housing Marketing (AFHM) Plan shall outline: i. Commercial Media to be used (i.e., community newspapers and non-english language newspapers, radio, television, billboards, religious or local real estate publications, etc.).
ii. iii. iv. Marketing efforts to be used (i.e., brochures, letters, handouts, direct mail, signs, etc.) Community Contacts to supplement formal communications media for the purpose of soliciting group(s) least likely to apply for the available housing without special outreach efforts. They should be individuals or organizations (i.e., service agencies, community organizations, places of worship, etc) that have direct and frequent contact with those identified as least likely to apply. The contacts should also be chosen on the basis of their positions of influence within the general community and the particular target group. The Property Owner must agree to establish and maintain contact with the identified contacts. Specify means to assure that information regarding the availability of accessible/adaptable rental units reaches eligible individuals with disabilities will be disseminated to increase effectiveness of outreach and communications (e.g., Telecommunications Devices for the Deaf (TTY), materials on tape or in Braille, accessible locations for activities and meetings, etc.) v. State that access to all leasing offices for the project will be accessible to persons with disabilities as required by the American with Disabilities Act. vi. The written Affirmative Fair Housing Marketing Plan for each project shall be accompanied by a completed Affirmative Fair Housing Marketing Plan Summary (attached). Seniors Housing designed and operated for seniors is exempt from the Fair Housing Act regarding familial status if the following conditions are met: 1. A minimum of 80% occupancy by seniors 2. Demonstrate it is intended and operated for seniors 3. Age of occupants must be verified. Tenant Selection & Records 1. The Property Owner or designee shall maintain records of all prospective tenant applicants, including their race, ethnicity and gender, reasons for denial of application, placement on a waiting list, etc. 2. The Property Owner or designee shall also provide for the selection of applicants from a written waiting list in the chronological order of their application, insofar as is practicable, and provide prompt written notification to any rejected applicants of the grounds for any rejection. 3. The Property Owner or designee must certify that it has affirmatively furthered fair housing at the time of lease up and annually. Review of this affirmative marketing effort for rental projects will be conducted in conjunction with the Annual Owner s Tenant Certification process.
Affirmative Fair Housing Marketing Plan Summary (RENTAL) 1a. Applicant or Owner s Name, Address (including city, state & zip code), telephone & email address 1b. Project s Name, Location (including city, and zip code) 1c. Number of Units 1d. Rental Range From $ To $ 1f. Approximate Starting Dates (mm/dd/yyyy) Advertising Date of Initial Occupancy Advertising to begin at least 90 days prior to initial 1h. Census Tract occupancy. Notification of intent to begin marketing shall be submitted to the Community Development Commission or Housing Authority of the County of Los Angeles no later than 90 days prior to initiation of marketing. 1e.Type of Housing Elderly Non-Elderly 1g. Housing/Expanded Housing Market Area 1i. Managing Agent s Name & Address (including city, state & zip code), telephone & email address 1j. Entity Responsible for Marketing (check all that apply) Owner Agent Other (specify) Name, Address (including city, state & zip code), telephone & email address 1k. Contact for Affirmative Fair Housing Marketing Plan (Name, Address (including city, state & zip code), telephone & email address) 2.Wait List (for existing projects) To add to waiting list (which currently has individuals) To reopen closed waiting list (which currently has individuals) 3a. Demographics of Project and Marketing Area (Complete Worksheet 1)
3b. Targeted Marketing Activity Based on your completed Worksheet 1, indicate which demographic group(s) in the housing market area is/are least likely to apply for the housing without special outreach efforts. White Hispanic or Latino American Indian or Alaskan Native Asian Black or African American Native Hawaiian or Other Pacific Islander Families with Children Persons with Disabilities Other ethnic group, religion, etc. (specify): 4a. Proposed Marketing Activities: Community Contacts Complete and submit Worksheet 2 to describe your use of community contacts to market the project to those least likely to apply. 4b. Proposed Marketing Activities: Methods of Advertising Complete and submit Worksheet 3 to describe your proposed methods of advertising that will be used to market to those lease likely to apply. Attach samples of advertisements, radio and television scripts, internet advertisements and websites, brochures, etc. 5a. Fair Housing Poster The Fair Housing Poster must be prominently displayed in all offices in which rental activity takes place (24 CFR 200.620(e)). Check below all locations where the Poster will be displayed. Rental Office Model Unit Other (specify): 5b. Affirmative Fair Housing Marketing Plan (AFHM Plan) The AFHM Plan must be available for public inspection at the rental office (24 CFR 200.625). Check below all locations where the AFHM Plan will be made available. Check all that apply: Rental Office Model Unit Other (specify): 5c. Project Site Sign All Project Site Signs should include the Equal Housing Opportunity logo, slogan, or statement (24 CFR 200.620(f)). Check below all locations where the Project Site Sign will be displayed. Check all that apply: Rental Office Model Unit Entrance to Project Other (specify): The size of the Project Site sign is/ will be: x The Equal Housing Opportunity logo or slogan or statement is/will be: x
6. Evaluation of Marketing Activities Explain the evaluation process you will use to determine whether your marketing activities have been successful in attracting the group(s) least likely to apply, how often you will make this determination, and how you will make decisions about future marketing based on the evaluation process. 7a. Marketing Staff What staff positions are/will be responsible for affirmative marketing?. 7b. Staff Training and Assessment: AFHM Plan (1) Has staff been trained on the AFHM Plan? Yes No (2) Is there ongoing training on AFHM Plan and Fair Housing Act issues in general? Yes No (3) Is yes, who provides it? (4) Do you periodically assess staff skills, including their understanding of the AFHM Plan and their responsibilities to use it? Yes No (5) If yes, how and how often? 7c. Tenant Selection Training/Staff (1) Has staff been trained on tenant selection in accordance with the project s occupancy policy? Yes No (2) What staff positions are/will be responsible for tenant selection?
7d. Staff Instruction/Training: Samples and Dates Please provide samples of AFHM/Fair Housing training, if any, provided/to be provided, to whom it was/will be provided, and dates of past and anticipated training. 8. Additional Considerations Is there anything else you would like to tell us about your AFHM Plan in order to ensure that your program is marketed to those lease likely to apply for the units and/or to be housed in them? Please attach additional sheets, as needed. 9. Review and Update By signing this form, the applicant/respondent agrees to review its AFHM Plan at least once every 5 years throughout the life of the loan and to update it as needed in order to ensure continued compliance with HUD s Affirmative Fair Housing Marketing Regulations (see 24 CFR Part 200, Subpart M). This shall be done more frequently if local conditions or project demographics significantly change. The Community Development Commission and the Housing Authority of the County of Los Angeles and/or HUD may monitor the implementation of this AFHM Plan at any time, and may also request modification in its format and/or content, when deemed necessary. I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate. Warning: HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802). Signature of person submitting this Plan & Date of Submission (mm/dd/yyyy) Name (type or print) Title & Name of Company
AFHM Plan Summary Form Instructions The Affirmative Fair Housing Marketing Plan requires that each applicant subject to these requirements carry out an affirmative program to attract prospective tenants of all minority and non-minority groups in the housing market area regardless of race, color, national origin, sex, religion, marital and familial status, handicap (disability), sexual orientation, ancestry or source of income. These groups include White, members of minority groups, i.e.., Black, American Indian/Alaskan Native, Hispanic or Latino, Asian, Native Hawaiian or Other Pacific Islander, person with disabilities, families with children, or persons with different religious affiliations in the housing market area who may be subject to housing discrimination on the basis of race, color, national origin, sex, religion, marital and familial status, handicap (disability), sexual orientation, ancestry or source of income. The applicant shall describe on this form the activities it proposes to carry out during advance marketing, where applicable, and the initial rent-up period. The affirmative marketing program also should ensure that any group(s) of persons normally not likely to apply for the housing without special outreach efforts know about the housing, feel welcome to apply and have the opportunity to rent. NOTES: Part 1 Applicant and Project Identification. A housing market area is the area from which a multifamily housing project owner/agent may reasonably expect to draw a substantial number of its tenants. If a housing market area is not demographically diverse in terms of race, color, national origin, sex, religion, marital and familial status, handicap (disability), sexual orientation, ancestry or source of income, an expanded housing market area may be used. This is a larger geographic area that may provide additional diversity. Indicate the housing or expanded housing market area in which the housing is/will be located, e.g., City of for housing market area, or City of and County of for expanded housing market area. For item 1f, specify approximate starting date of marketing activities to the groups targeted for special outreach and the anticipated date of initial occupancy. The applicant may obtain Census Tract location information, item 1h, from local planning agencies, public libraries and other sources of census data. Item 1i is to be completed only if a Managing Agent is implementing the plan. Part 2 Wait List In the case of existing project, specify how many individuals were or are on the waiting list at the time the advertising began or will begin. Part 3 Demographics and Marketing Area Least likely to apply means that there is an identifiable presence of a specific demographic group in the housing market area, but members of that group are not likely to apply for the housing without targeted outreach, including marketing materials in other languages for limited English proficient individuals, and alternative formats for persons with disabilities. Reasons for not applying can include, but are not limited to insufficient information about housing opportunities, language barriers, or transportation impediments.
Part 9 The applicant s authorized agent signs and dates the Plan. By signing the Plan, the applicant assumes full responsibility for its implementation. First 5 LA or its designee may at any time monitor the implementation of the Plan and request modification in its format or content, where First 5 :LA or its designee deem necessary. Notice of Intent to Begin Marketing. No later than 90 days prior to the initiation of rental marketing activities, the applicant with an approved Plan shall submit written notice of intent to begin marketing. The notification is required by the Affirmative Fair Housing Marketing Plan Compliance requirements.
Worksheet 1: Determining Demographic Groups Least Likely to Apply for Housing Opportunities (See AFHM Plan Summary, Block 3b) In the respective columns below indicate the percentage of each demographic group for the project (if occupied), waiting list (for existing projects), census tract, housing market area, and expanded housing market area (if the latter is needed to create a more diverse housing market area in terms of race, color, national origin, religion, sex, disability, or familial status). Wherever possible, statistics should be obtained from a local planning office, Community Development Block Grant Consolidated Plan, or another official source such as the U.S. Census Bureau (please see http://factfinder.census.gov. Under Decennial Census, click Get Data. Choose SF3, then detailed tables). If there is a significant under-representation of any demographic group in the project and/or on its waiting list relative to the surrounding housing market area, then those groups(s) that are under-represented will be considered least likely to apply without targeted outreach and marketing, and will be so identified in Block 3b of the AFHM Plan Summary. Maps showing both the Housing Market Area and Expanded Housing Market Area should also be attached. Demographic Characteristics White Project % Waiting List % Census Tract % Housing Market Area % Expanded Housing Market Area% (if used) American Indian or Alaskan Native Asian Black or African American Native Hawaiian or Other Pacific Islander Persons with Disabilities Families with Children Hispanic or Latino Other
Worksheet 2: Proposed Marketing Activities Community Contacts (See AFHM Plan Summary, Block 4a) For each targeted marketing population designated as least likely to apply in Block 3b, identify at least one community contact organization you will use to facilitate outreach to the group. This could be a social service agency, religious body, advocacy group, community center, etc. State the names of contact persons, their addresses and phone numbers, their previous experience working with the target population, the approximate date contact was/will be initiated, and the specific role they will play in assisting with the affirmative fair housing marketing program. Targeted Population(s) Community Contact: Name, address, telephone & email: Experience with target pop: 1. Date contact initiated: Specific marketing role: Name, address, telephone & email: Experience with target pop: 2. Date contact initiated: Specific marketing role: Name, address, telephone & email: Experience with target pop: 3. Date contact initiated: Specific marketing role:
Worksheet 3: Proposed Marketing Activities Methods of Advertising (See AFHM Plan Summary, Block 4b) Complete the following table by identifying your targeted marketing population(s), as indicated in Block 3b, 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. 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. Methods of Advertising Newspaper Targeted Population: Targeted Population: Targeted Population: Radio Stations TV Stations Electronic Media (e.g., internet advertisements, websites, etc.) Bulletin Boards Brochures, Notices, Flyers Other (specify)
Affirmative Fair Housing Marketing Certification Project Name: Address: I, the undersigned, on behalf of hereby certify under penalty of perjury that the marketing efforts for the above-named project is or have been conducted in complete adherence to the Affirmative Marketing Plan dated as previously accepted and approved by First 5 LA or its designee. Signature of Property Owner or Designee (Name) (Title) (Date)