Housing Justice Center

PRIVATE ENFORCEMENT INITIATIVES

PRIVATE ENFORCEMENT INITIATIVES

PRIVATE ENFORCEMENT INITIATIVES

PURPOSE: PURPOSE: THE MISSION OF THE FAIR HOUSING JUSTICE CENTER (FHJC) IS TO ELIMINATE HOUSING DISCRIMINATION; PROMOTE POLICIES AND PROGRAMS THAT FOSTER OPEN, ACCESSIBLE, AND INCLUSIVE COMMUNITIES; AND STRENGTHEN ENFORCEMENT OF FAIR HOUSING LAWS. THE FHJC IS SEEKING AN FY2023 FHIP PEI MULTI YEAR GRANT TO PROVIDE HIGH-QUALITY COMPREHENSIVE FAIR HOUSING SERVICES, INCLUDING OUTREACH, EDUCATION, LEGAL ASSISTANCE, TESTING SERVICES AND ENFORCEMENT ACTIVITIES.; ACTIVITIES TO BE PERFORMED: ACTIVITIES TO BE PERFORMED: THROUGH THIS PROJECT, THE FHJC PROPOSES THESE CENTRAL TASKS: 1. CONDUCT COMPLAINANT INTAKE AT THE RATE OF 100 COMPLAINTS PER YEAR, 2. ASSIST COMPLAINANTS WITH DISABILITIES TO REQUEST THAT THEIR HOUSING PROVIDERS COMPLY WITH FAIR HOUSING LAWS IN RELATION TO REASONABLE ACCOMMODATIONS AND REASONABLE MODIFICATIONS, 3. SHARE RESOURCES REGARDING FAIR HOUSING RIGHTS, HOUSING ACCESSIBILITY, AND AVAILABLE HOUSING THAT IS DEEMED ACCESSIBLE WITH DISABILITY RIGHTS ADVOCATES, 4. CONDUCT 45 FAIR HOUSING TESTS AND FOUR COMPLIANCE MONITORING TESTS PER YEAR ALONGSIDE ALL THE NECESSARY RESEARCH AND ADMINISTRATIVE WORK THAT MAKES THIS POSSIBLE, INCLUDING MARKET AND LEGAL RESEARCH. INVESTIGATIONS WILL BE SYSTEMIC AND IN RESPONSE TO COMPLAINTS. THEY WILL FOCUS ON ALL LEGALLY PROTECTED CHARACTERISTICS. 5. CONDUCT MONITORING OF HOUSING PROVIDERS WHO HAVE PREVIOUSLY VIOLATED FAIR HOUSING LAWS; 6. WRITE AND DISTRIBUTE 8 E-NEWSLETTERS PER YEAR TO HELP RAISE AWARENESS OF ENFORCEMENT ACTIONS AND OTHER ACTIVITIES THAT WERE FUNDED BY THIS AND OTHER PEI PROJECTS. THE FHJC HAS APPROPRIATE STAFFING WITH THE EXPERIENCE AND SKILLS TO CONDUCT THE TASKS DESCRIBED IN THIS PROPOSAL. NINE STAFF PEOPLE WILL WORK ON THIS PROJECT, AS DESCRIBED IN THE STAFFING PLAN. THE FHJC CURRENTLY EMPLOYS 8 INVESTIGATIVE COORDINATORS, INCLUDING A DIRECTOR OF INVESTIGATIONS (8 YEARS OF EXPERIENCE) WHO ENGAGES IN STAFF SUPERVISION. THE FHJC EMPLOYS AN EVIDENCE MANAGER (4 YEARS OF EXPERIENCE) WHO PROVIDES SUPPORT TO THE INVESTIGATIVE COORDINATORS AND IS RESPONSIBLE FOR THE CONTROL, TRANSFER, MAINTENANCE, AND STORAGE OF ALL TESTING DATA AND EVIDENCE. IN ADDITION, THE FHJC ROUTINELY PROVIDES TRAINING AND TECHNICAL ASSISTANCE TO OTHER FAIR HOUSING TESTING ORGANIZATIONS AND CURRENTLY PARTICIPATES AS TRAINERS IN THE HUD SPONSORED INVESTIGATIVE SUPPORT FOR TESTING & ENFORCEMENT PROGRAMS (ISTEP) PROJECT WHICH PROVIDES COMPREHENSIVE TRAINING TO TEST COORDINATORS WORKING IN OTHER FHIP-FUNDED ORGANIZATIONS. THE FHJC ALSO HAS A FOUR-PERSON INTAKE & OUTREACH TEAM, LED BY A DIRECTOR, AS WELL AS A THREE-PERSON LEGAL TEAM AND A COMMUNICATIONS COORDINATOR.; EXPECTED OUTCOMES: EXPECTED OUTCOMES: THE FHJC WILL BRING ENFORCEMENT ACTIONS AGAINST HOUSING PROVIDERS AS WARRANTED, USING EVIDENCE GATHERED FROM THE PROPOSED INVESTIGATIONS. ENFORCEMENT ACTIONS WILL INCLUDE FILING LAWSUITS AND ADMINISTRATIVE COMPLAINTS WITH LOCAL, STATE, AND FEDERAL AGENCIES, INCLUDING HUD. THE FHJC WILL ALSO PROVIDE INTAKE COUNSELING, RESOURCES, AND TECHNICAL ASSISTANCE WITH SELF-ADVOCACY TO INDIVIDUALS WHO BELIEVE THEY HAVE BEEN DISCRIMINATED AGAINST. ANOTHER IMPORTANT, DISTINCT SET OF OUTCOMES EXPECTED ARE BENEFITS TO PEOPLE WITH DISABILITIES, AS FHJC STAFF WILL ASSIST THEM IN REQUESTING REASONABLE ACCOMMODATIONS AND MODIFICATIONS THAT THEY ARE ENTITLED TO UNDER FAIR HOUSING LAWS. THE FHJC WILL ALSO PROVIDE FINANCIAL RESOURCES THROUGH ITS EXISTING ADELE FRIEDMAN HOUSING ACCESSIBILITY FUND (NOT FINANCIALLY CONNECTED TO THIS PROPOSAL) IN CERTAIN SITUATIONS TO HELP RESIDENTS WITH DISABILITIES OBTAIN REASONABLE MODIFICATIONS. THE FHJC’S E-NEWSLETTERS WILL SUMMARIZE RESULTS OF ENFORCEMENT ACTIONS AND OTHER WORK CONDUCTED UNDER THIS PROJECT. THE FHJC WILL SUMMARIZE COMMUNICATIONS, ASSISTANCE OFFERED, AND RESULTS OBTAINED WHEN REPORTING TO HUD. HOUSING DISCRIMINATION CONTINUES TO IMPEDE ACCESS TO HOUSING OPPORTUNITIES IN FHJC’S SERVICE AREA FOR MANY SEGMENTS OF THE POPULATION, WHILE REINFORCING MANY DECADES OF RACIAL SEGREGATION. THE RESULTS OF FHJC SYSTEMIC TESTING INVESTIGATIONS, FUNDED BY FHIP PEI GRANTS AND OTHER SOURCES, OFFERS ADDITIONAL EVIDENCE THAT STRUCTURAL AND SYSTEMIC HOUSING DISCRIMINATION BY PRIVATE ENTITIES SUCH AS REAL ESTATE BROKERS, LANDLORDS, MANAGEMENT COMPANIES, AND OTHERS BASED ON RACE, NATIONAL ORIGIN, AND DISABILITY PERSISTS THROUGHOUT NEW YORK CITY AND THE SURROUNDING COUNTIES. AS A RESULT OF 18 YEARS OF FHJC TESTING INVESTIGATIONS, OVER 155 LAWSUITS HAVE BEEN FILED ALLEGING SYSTEMIC HOUSING DISCRIMINATION IN THE REGION. THESE CASES HAVE CHANGED THE WAY THAT MANY HOUSING PROVIDERS DO BUSINESS, OPENED MORE THAN 80,000 HOUSING UNITS TO PREVIOUSLY EXCLUDED POPULATIONS, AND RESULTED IN A TOTAL MONETARY RECOVERY OF OVER $54 MILLION IN DAMAGES AND PENALTIES. THIS MULTI-YEAR PEI GRANT WILL ALLOW THE FHJC TO CONTINUE PURSUING THESE PROVEN STRATEGIES, INCLUDING SYSTEMIC TESTING.; INTENDED BENEFICIARIES: INTENDED BENEFICIARIES: UNDER THIS PROJECT, THE FHJC WILL CONTINUE PROVIDING PERSONS FILING COMPLAINTS OF HOUSING DISCRIMINATION WITH FAIR HOUSING COUNSELING AND INTAKE, INVESTIGATIVE ASSISTANCE (TESTING), AND REFERRALS TO COOPERATING ATTORNEYS AND ADMINISTRATIVE AGENCIES. THE FHJC WILL PROVIDE THESE FAIR HOUSING SERVICES TO PERSONS WITH COMPLAINTS ALLEGING DISCRIMINATION BASED ON PROTECTED CHARACTERISTICS UNDER THE FEDERAL FAIR HOUSING ACT AND WITHOUT REGARD TO THE AMOUNT OF THE COMPLAINANT’S HOUSEHOLD INCOME. WORK WILL BE FOCUSED ON AFFIRMATIVELY FURTHERING FAIR HOUSING AND WILL REDUCE POVERTY CONCENTRATION AND RESIDENTIAL RACIAL SEGREGATION IN THE REGION, THIS PROJECT IS DESIGNED TO BENEFIT PEOPLE WHO IDENTIFY AS PEOPLE OF COLOR, WITH AN EMPHASIS PLACED ON BLACK AND BROWN PERSONS OR COMMUNITIES, IMMIGRANTS (ESPECIALLY INDIVIDUALS WITH LIMITED ENGLISH PROFICIENCY), INDIVIDUALS WITH DISABILITIES, AND FAMILIES WITH CHILDREN. IN ORDER TO AFFIRMATIVELY FURTHER FAIR HOUSING AND REDUCE POVERTY CONCENTRATION AND RESIDENTIAL RACIAL SEGREGATION IN THE REGION, THE FHJC WILL ALSO ASSIST INDIVIDUALS AND FAMILIES WITH FEDERAL HOUSING CHOICE VOUCHERS AND WITH OTHER RENTAL SUBSIDIES TO OVERCOME BARRIERS TO HOUSING CHOICE BASED ON SOURCE OF INCOME DISCRIMINATION, WHICH IS PROHIBITED BY NEW YORK CITY AND NEW YORK STATE FAIR HOUSING LAWS. THE FHJC SERVICE AREA HAS A POPULATION OF OVER 13 MILLION PEOPLE, ACCORDING TO THE MOST RECENT 2020 CENSUS. THIS REGION INCLUDES 65% OF THE POPULATION IN THE STATE OF NEW YORK AND ROUGHLY 3% OF THE UNITED STATES POPULATION. THE NEW YORK CITY REGION HAS ONE OF THE MOST DIVERSE POPULATIONS IN THE UNITED STATES, AND YET, HOUSING DISCRIMINATION AND RESIDENTIAL SEGREGATION ARE DEEPLY PERVASIVE. NEW YORK CITY IS THE THIRD MOST SEGREGATED CITY FOR BLACK PEOPLE AND THE SECOND MOST SEGREGATED CITY FOR LATINO AND ASIAN PEOPLE IN THE UNITED STATES. THE PROPOSED WORK WILL BENEFIT PEOPLE OF COLOR WHO LIVE IN SEGREGATED COMMUNITIES IN THE NEW YORK CITY REGION AND ALLOW THEM TO LIVE WITHOUT PENALTY IN NEIGHBORHOODS OF THEIR CHOICE. FURTHERMORE, THIS PROJECT WILL BENEFIT ALL RESIDENTS OF THE NEW YORK CITY REGION. HOUSING DISCRIMINATION DOES IMMENSE HARM NOT ONLY TO FAMILIES AND INDIVIDUALS, BUT TO ENTIRE COMMUNITIES. HOUSING DISCRIMINATION NOT ONLY RESTRICTS HOUSING CHOICE BUT ALSO PERPETUATES RESIDENTIAL SEGREGATION. SEGREGATION OFTEN LEADS TO FURTHER DISENFRANCHISEMENT, AS COMMUNITIES OF COLOR, BASED ON THE ZIP CODES TO WHICH THEY ARE CONFINED, FACE ADDITIONAL BARRIERS IN THEIR ACCESS TO HEALTHCARE, EDUCATION, TRANSPORTATION, AND EMPLOYMENT. THIS PROJECT WILL HELP ADDRESS THIS LEGACY OF HISTORICAL DISCRIMINATION.; SUBRECIPIENT ACTIVITIES: NONE

PRIVATE ENFORCEMENT INITIATIVES

PRIVATE ENFORCEMENT INITIATIVES

FAIR HOUSING ORGANIZATION INITIATIVES

PRIVATE ENFORCEMENT

ORGANIZATIONS INITIV

PRIVATE ENFORCEMENT INITIATIVES

PRIVATE ENFORCEMENT

ORGANIZATIONS INITIV

PURPOSE: PURPOSE: THE MISSION OF THE FAIR HOUSING JUSTICE CENTER (FHJC) IS TO ELIMINATE HOUSING DISCRIMINATION; PROMOTE POLICIES AND PROGRAMS THAT FOSTER OPEN, ACCESSIBLE, AND INCLUSIVE COMMUNITIES; AND STRENGTHEN ENFORCEMENT OF FAIR HOUSING LAWS. THE FHJC IS SEEKING AN FY2024 FHIP FHOI CONTINUING DEVELOPMENT COMPONENT GRANT TO PROVIDE HIGH-QUALITY COMPREHENSIVE FAIR HOUSING TESTING SERVICES AND ENFORCEMENT ACTIVITIES, SPECIFICALLY IN PRE-APPLICATION MORTGAGE LENDING PRACTICES OF HOUSING SALES LENDERS.; ACTIVITIES TO BE PERFORMED: ACTIVITIES TO BE PERFORMED: THE FHJC WILL CONDUCT 35 FAIR HOUSING TESTS ACROSS ITS SERVICE AREA. INVESTIGATIONS WILL BE SYSTEMIC AND FOCUSED ON PRE-APPLICATION MORTGAGE LENDING PRACTICES AND HOUSING SALES TO DETERMINE WHETHER HOME BUYERS ARE BEING AFFORDED THE SAME SERVICE, TREATMENT, AND INFORMATION ABOUT AND ACCESS TO MORTGAGE FINANCING SERVICES AND PRODUCTS WITHOUT DISCRIMINATING BASED ON PROTECTED CHARACTERISTICS UNDER THE FEDERAL FAIR HOUSING ACT AND APPLICABLE LOCAL AND STATE LAWS. TESTING WILL FOCUS ON LENDERS LOCATED IN TOWNS, CITIES AND NEIGHBORHOODS THAT HAVE HISTORICALLY EXPERIENCED AND ARE EXPERIENCING PATTERNS OF RACIAL SEGREGATION. AS THE FHJC IS THE ONLY FULL SERVICE FAIR HOUSING ORGANIZATION OPERATING WITHIN THE FIVE NEW YORK CITY BOROUGHS, AND THERE IS A LACK OF LENDING TESTING HAPPENING IN THE REST OF THE NEW YORK CITY REGION, THERE WILL BE NO SHORTAGE OF AREAS AND ENTITIES ON WHICH TO FOCUS TESTING. LENDER TESTING INVESTIGATIONS ARE EXTREMELY TIME-CONSUMING, INVOLVE COMPLEX TRANSACTIONS, REQUIRE CAREFUL DESIGN AND SUPERVISION BY A SKILLED INVESTIGATIVE COORDINATOR, AND MUST BE EXECUTED BY TESTERS WHO ARE WELL-TRAINED AND WHO HAVE EXCEPTIONAL ACTING ABILITIES. THE FHJC HIRES AND TRAINS PROFESSIONAL ACTORS TO CONDUCT LENDING TESTS, AND THE FHJC’S NATIONAL PROJECTS AND INVESTIGATIONS COORDINATOR (PROPOSED PROJECT MANAGER) AND NATIONAL FIELD CONSULTANT HAVE EXTENSIVE EXPERIENCE IN LENDING TESTING. THEY ARE TRAINERS FOR THE HUD FHIP FUNDED INVESTIGATIVE SUPPORT FOR TESTING AND ENFORCEMENT PROGRAMS (ISTEP). IN THIS CAPACITY THEY HAVE TRAINED HUNDREDS OF INVESTIGATIVE COORDINATORS ACROSS THE COUNTRY IN BEST PRACTICES FOR FAIR HOUSING TESTING IN SALES, LENDING, AND RENTALS. THEIR EXPERIENCE IS FURTHER DESCRIBED IN THE STAFF EXPERIENCE AND EXPERTISE SECTION. THE FHJC CURRENTLY EMPLOYS 8 INVESTIGATIVE COORDINATORS, INCLUDING A DIRECTOR OF INVESTIGATIONS (8 YEARS GENERAL TESTING EXPERIENCE), A NATIONAL PROJECTS AND INVESTIGATIONS COORDINATOR (6 YEARS GENERAL TESTING EXPERIENCE), AND A NATIONAL FIELD CONSULTANT (48 YEARS GENERAL TESTING EXPERIENCE), EACH OF WHOM SUPERVISES TESTING INVESTIGATIONS. THE FHJC ALSO EMPLOYS AN EVIDENCE MANAGER (4 YEARS OF EXPERIENCE) WHO PROVIDES SUPPORT TO THE INVESTIGATIVE COORDINATORS AND IS RESPONSIBLE FOR THE CONTROL, TRANSFER, MAINTENANCE, AND STORAGE OF ALL TESTING DATA AND EVIDENCE. MANY OF THESE STAFF MEMBERS HAVE DIRECT EXPERIENCE CONDUCTING LENDING AND SALES TESTING. THE FHJC HAS ALSO DEVELOPED WHAT IS LIKELY THE MOST PROFESSIONAL AND EXTENSIVE POOL OF TESTERS IN THE COUNTRY.; EXPECTED OUTCOMES: EXPECTED OUTCOMES: TO OVERCOME THE SIGNIFICANT EXISTING BARRIERS OF SYSTEMIC DISCRIMINATION AND SEGREGATION, THE FHJC USES EVIDENCE THAT REVEALS A PATTERN OF SYSTEMIC DISCRIMINATION TO BRING ENFORCEMENT ACTIONS AGAINST HOUSING PROVIDERS, REAL ESTATE AGENTS, AND LENDING INSTITUTIONS. ENFORCEMENT ACTIONS WILL INCLUDE FILING LAWSUITS AND ADMINISTRATIVE COMPLAINTS WITH LOCAL, STATE, AND FEDERAL AGENCIES. THE FHJC WILL ALSO PROVIDE INTAKE COUNSELING TO INDIVIDUALS WHO BELIEVE THEY HAVE BEEN DISCRIMINATED AGAINST IN THE LENDING CONTEXT, AND REFERRALS TO LEGAL COUNSEL IF APPROPRIATE. IF THESE INDIVIDUALS BRING THEIR OWN ENFORCEMENT ACTIONS, THE FHJC WILL BE AVAILABLE IF NEEDED. THE FHJC’S OUTREACH, SOCIAL MEDIA, AND WRITTEN MATERIAL DISTRIBUTED AS PART OF THIS PROJECT WILL ENSURE THAT ADVOCATES AND AFFECTED COMMUNITY MEMBERS UNDERSTAND THEIR FAIR HOUSING RIGHTS, KNOW HOW TO TAKE ADVANTAGE OF THE FHJC’S SERVICES, ARE ABLE TO ENGAGE IN SELF-ADVOCACY, AND ARE AWARE OF WHERE THEY CAN BRING AN ENFORCEMENT ACTION. THE FHJC COLLECTS EVIDENCE IN AN IMPARTIAL MANNER, DOCUMENTING THE EVERYDAY, UNVARNISHED BUSINESS OPERATIONS OF HOUSING PROVIDERS. AS SUCH, IT IS NOT POSSIBLE OR APPROPRIATE TO PREDICT OR ESTIMATE THE NUMBER OR NATURE OF ENFORCEMENT ACTIONS IT WILL FILE. THIS WOULD ALSO HAVE THE POSSIBLE EFFECT OF COMPROMISING ITS LAWSUITS. HOWEVER, IT IS PRUDENT TO NOTE THAT THE FHJC’S SERVICE AREA HAS A POPULATION OF OVER THIRTEEN MILLION PEOPLE, INCLUDING THE NATION’S LARGEST CITY. THE SCALE OF FAIR HOUSING INVESTIGATIONS IN THIS AREA REMAINS WOEFULLY INADEQUATE AND THE FHJC’S LITIGATION PROGRAM IS ROBUST AND SUCCESSFUL. IN CONSIDERING THE EXPECTED OUTCOMES OF THIS PROJECT, PAST FHJC LAWSUITS ARE INSTRUCTIVE. IN FEBRUARY 2015, THE FHJC AND NINE BLACK, LATINO, ASIAN, AND WHITE TESTERS FILED A FEDERAL LAWSUIT AGAINST M&T BANK, THE 17TH LARGEST BANK IN THE UNITED STATES, ALLEGING THAT THE BANK WAS ENGAGED IN DISCRIMINATION BASED ON RACE AND NATIONAL ORIGIN. THE CASE, FHJC ET AL. V. M&T BANK ET AL., IS BELIEVED TO BE THE FIRST LAWSUIT FILED UNDER THE FEDERAL FAIR HOUSING ACT ALLEGING RACE AND NATIONAL ORIGIN DISCRIMINATION BASED PRIMARILY ON EVIDENCE COLLECTED THROUGH A PRE-APPLICATION MORTGAGE LENDER TESTING INVESTIGATION. IN AUGUST 2015, THE CASE WAS RESOLVED FOR A TOTAL MONETARY RECOVERY OF $485,000 AND EXTENSIVE INJUNCTIVE RELIEF, INCLUDING ADOPTING A BANK-WIDE POLICY PROHIBITING STEERING, POSTING ITS REVISED FAIR LENDING POLICY ON ITS WEBSITE, AND RETAINING A CONSULTANT TO REVISE ITS FAIR LENDING TRAINING FOR LOAN OFFICERS AND OTHER BANK EMPLOYEES. M&T LOAN OFFICERS IN THE FHJC’S SERVICE AREA ARE NOW PROVIDING WRITTEN ESTIMATES, UPON REQUEST, TO CONSUMERS CONCERNING LOAN AMOUNTS, LOAN PRODUCTS, HOME PURCHASE PRICES, INTEREST RATES, AND DOWN PAYMENT REQUIREMENTS. IN NOVEMBER 2016, THE FHJC FILED A SUIT AGAINST ULSTER SAVINGS BANK FOR LENDING DISCRIMINATION, ALSO BASED ON EVIDENCE GATHERED IN PRE-APPLICATION LENDING TESTING. THE FHJC CONDUCTED A TWO-YEAR TESTING INVESTIGATION, WHICH REVEALED THAT LOAN OFFICERS REPEATEDLY RECOMMENDED LOWER HOME PRICES AND LOAN AMOUNTS AND LESS FAVORABLE TERMS FOR BLACK APPLICANTS WHO PRESENTED BETTER QUALIFICATIONS—HIGHER INCOMES, MORE ASSETS, LESS DEBT, AND BETTER CREDIT SCORES—THAN THE WHITE TESTERS WITH WHOM THEY WERE MATCHED. IN THE 2017 LAWSUIT SETTLEMENT, ULSTER SAVINGS BANK AGREED TO EXTENSIVE INJUNCTIVE RELIEF.; INTENDED BENEFICIARIES: NTENDED BENEFICIARIES: THIS PROJECT WILL BENEFIT HOMEBUYERS IN THE NEW YORK CITY REGION WITH ANY CHARACTERISTIC THAT IS PROTECTED UNDER LOCAL, STATE, OR FEDERAL FAIR HOUSING LAWS. IN PARTICULAR, IT WILL FOCUS ON ELIMINATING DISCRIMINATION AGAINST PEOPLE WHO ARE BLACK, LATINO, OR ASIAN AMERICAN PACIFIC ISLANDER (AAPI) AND MENA (MIDDLE EASTERN AND NORTH AFRICAN) COMMUNITY MEMBERS, AS WELL AS IMMIGRANTS, ESPECIALLY THOSE WITH LIMITED ENGLISH PROFICIENCY (LEP). AMONG THESE GROUPS, THE FHJC SERVES COMMUNITIES THAT HAVE EXPERIENCED HISTORIC AND CONTINUING PATTERNS OF SEGREGATION, DISCRIMINATION, AND EXCLUSION IN HOUSING – ACROSS VARIOUS AND INTERSECTING LINES INCLUDING DISABILITY, LAWFUL SOURCE OF INCOME, SEX, SEXUAL ORIENTATION/GENDER IDENTITY, RELIGION, CITIZENSHIP/IMMIGRATION STATUS, FAMILIAL STATUS, AND AGE. MANY THEORIES HAVE BEEN ADVANCED OVER THE YEARS ABOUT WHAT TRANSPIRES WHEN EQUALLY QUALIFIED CONSUMERS OF DIFFERENT RACES AND NATIONAL ORIGINS CONTACT LENDERS TO SEEK FINANCING TO PURCHASE A HOME. TESTING IS ONE OF THE FEW INVESTIGATIVE TECHNIQUES THAT CAN BE USED TO OBSERVE EXACTLY WHAT OCCURS AT THE PRE-APPLICATION STAGE OF A MORTGAGE LENDING TRANSACTION. BECAUSE OF THE INSIDIOUS NATURE OF DISCRIMINATORY LENDING PRACTICES, IT IS OFTEN DIFFICULT FOR CONSUMERS OF DIFFERENT RACES AND NATIONAL ORIGINS TO KNOW IF LOAN OFFICERS ARE PROVIDING THE SAME LEVEL OF ASSISTANCE, SERVICE, TREATMENT, AND FINANCING INFORMATION WITHOUT SOME TYPE OF COMPARISON. TESTING IS THE ONLY INVESTIGATIVE TOOL THAT CAN PROVIDE A MEANINGFUL COMPARISON AT THE PRE APPLICATION STAGE OF A MORTGAGE LENDING TRANSACTION. THE WORK OF THE FHJC IN THIS AREA HAS BEEN GROUND-BREAKING AND SINCE LITTLE LENDER TESTING IS CONDUCTED NATIONALLY, IT HAS PROVIDED A FRAMEWORK FOR HOW TO DEVELOP MORTGAGE LENDING CASES BASED PRIMARILY ON TESTING EVIDENCE AT THE PRE-APPLICATION STAGE RATHER THAN SOLELY RELYING ON DATA OBTAINED AFTER AN INDIVIDUAL HAS APPLIED. THIS PROCESS HAS UNVEILED VALUABLE INSIGHTS INTO LENDER PRACTICES THAT HAVE NOT BEEN WIDELY RESEARCHED OR INVESTIGATED BY FAIR LENDING ENFORCEMENT AGENCIES. THE NEW YORK CITY REGION HAS ONE OF THE MOST DIVERSE POPULATIONS IN THE UNITED STATES, AND YET, HOUSING DISCRIMINATION AND RESIDENTIAL SEGREGATION ARE DEEPLY PERVASIVE. BY APPLYING A DISSIMILARITY INDEX TO 2020 CENSUS DATA, RESEARCHERS HAVE SHOWN THAT NEW YORK CITY IS ONE OF THE MOST SEGREGATED METROPOLITAN REGIONS IN THE COUNTRY. IT REMAINS ONE OF SIX METROPOLITAN REGIONS WITH A SEGREGATION INDEX ABOVE 80. OF THE 50 METROPOLITAN AREAS IN THE NATION WITH THE LARGEST BLACK, LATINO, AND AAPI POPULATIONS, THE NEW YORK REGION RANKS AS ONE OF THE MOST SEGREGATED AREAS FOR ALL THREE GROUPS. THIS PROJECT WILL BENEFIT PEOPLE OF COLOR WHO LIVE IN SEGREGATED COMMUNITIES AND ALLOW THEM TO LIVE WITHOUT PENALTY IN NEIGHBORHOODS OF THEIR CHOICE. FURTHERMORE, THIS PROJECT WILL BENEFIT ALL RESIDENTS OF THE NEW YORK CITY REGION. HOUSING DISCRIMINATION DOES IMMENSE HARM NOT ONLY TO FAMILIES AND INDIVIDUALS, BUT TO ENTIRE COMMUNITIES. HOUSING DISCRIMINATION NOT ONLY RESTRICTS HOUSING CHOICE BUT ALSO PERPETUATES RESIDENTIAL SEGREGATION. SEGREGATION OFTEN LEADS TO FURTHER DISENFRANCHISEMENT, AS COMMUNITIES OF COLOR, BASED ON THE ZIP CODES TO WHICH THEY ARE CONFINED, FACE ADDITIONAL BARRIERS IN THEIR ACCESS TO HEALTHCARE, EDUCATION, TRANSPORTATION, AND EMPLOYMENT. THIS PROJECT WILL HELP ADDRESS THIS LEGACY OF HISTORICAL DISCRIMINATION.; SUBRECIPIENT ACTIVITIES: NONE

PURPOSE: THE FHJC PROPOSES TO CONDUCT THE ELIMINATING RACE AND NATIONAL ORIGIN DISCRIMINATION PROJECT, AS DETAILED BELOW. A. PURPOSE THE MISSION OF THE FHJC IS TO ELIMINATE HOUSING DISCRIMINATION; CREATE OPEN, ACCESSIBLE, AND INCLUSIVE COMMUNITIES; AND STRENGTHEN ENFORCEMENT OF FAIR HOUSING LAWS.; ACTIVITIES TO BE PERFORMED: ACTIVITIES TO BE PERFORMED THIS PROJECT WILL REACH COMMUNITIES AT RISK OF FACING HOUSING DISCRIMINATION THROUGH FIVE MEASURES THAT TOGETHER COMPRISE A WELL-THOUGHT OUT, STRATEGIC PLAN. FIRST, THE FHJC WILL RESEARCH, CREATE, AND PUBLISH A SERIES OF SIX NEWSLETTERS, EACH WHICH WILL TELL THE STORY OF A DIFFERENT PERSON’S “MY FAIR HOUSING STORY.” SUBJECTS OF THESE NEWSLETTERS WILL INCLUDE FHJC COMPLAINANTS, PARTNERS, AND TESTERS. NEWSLETTERS WILL BE AVAILABLE ONLINE, THROUGH SOCIAL MEDIA PLATFORMS, AND WILL BE SENT TO THE FHJC’S NEWSLETTER LIST OF NEARLY 3,000 PEOPLE. SECOND, THE STORIES BROUGHT TO LIFE AS PART OF THIS PROJECT WILL BE POSTED ON THREE DIFFERENT SOCIAL MEDIA PLATFORMS, ASSISTED BY A $3,000 BUDGET TO BEST TARGET ADS TO PEOPLE UNFAMILIAR WITH FAIR HOUSING LAWS. THIRD, THIS PROJECT WILL PROMOTE THE FHJC’S WIDE VARIETY OF PLAIN-LANGUAGE FACT SHEETS, WHICH ARE AVAILABLE ONLINE AND WILL BE DISTRIBUTED IN HARD COPY AT IN-PERSON EVENTS. FOURTH, THE FHJC WILL REACH OUT TO 75 NONPROFIT ORGANIZATIONS THAT SERVE POTENTIAL COMPLAINANTS IN THE FHJC’S 12-COUNTY SERVICE AREA, INCLUDING CIVIL RIGHTS ORGANIZATIONS SERVING PEOPLE OF COLOR, INDIVIDUALS WITH DISABILITIES, IMMIGRANTS, AND THOSE EXPERIENCING HOUSING INSECURITY. ADVOCATES AT THESE ORGANIZATIONS, AND THEIR CLIENTS, WILL BE MADE AWARE OF THIS PROJECT, WAYS TO COMMUNICATE INFORMATION ABOUT FAIR HOUSING RIGHTS TO THE PEOPLE THEY SERVE, AND RESOURCES AVAILABLE VIA THE FHJC AND ENFORCEMENT AGENCIES, INCLUDING HUD.; EXPECTED OUTCOMES: C. EXPECTED OUTCOMES TO ENSURE ITS WORK BENEFITS UNDERSERVED COMMUNITIES, THE FHJC WILL TARGET ITS OUTREACH ACTIVITIES TO BENEFIT PEOPLE OF COLOR TO WHO LIVE IN HISTORICALLY SEGREGATED AREAS. THE FHJC WILL ENGAGE IN MULTI-PRONGED EFFORTS TO BENEFIT COMMUNITIES OF COLOR, INCLUDING ITS DETAILED KNOWLEDGE OF ITS SERVICE AREA, AVAILABLE GOVERNMENT DATA, ITS VAST HISTORY OF SUCCESSFUL OUTREACH EFFORTS, AND MEDIA CONNECTIONS. THE SERVICES AVAILABLE THROUGH THIS PROJECT WILL BE SHARED VIA THE FHJC’S LARGE NETWORK OF COMMUNITY PARTNERSHIPS, STRONG RELATIONSHIP WITH GOVERNMENT AGENCIES, FREQUENTLY VISITED WEBSITE, EXTENSIVE SOCIAL MEDIA CONNECTIONS (INCLUDING PAID ADVERTISING), AND REGULAR NEWSLETTERS. ALL INFORMATION AND SERVICES WILL BE PROVIDED IN ENGLISH, SPANISH AND CHINESE, AND OTHER LANGUAGES, AS NECESSARY. THIS PROJECT WILL GEOGRAPHICALLY TARGET TOWNS, CITIES AND NEIGHBORHOODS THAT HAVE FACED ONGOING RACIAL SEGREGATION AND DISCRIMINATION. TOGETHER, THESE ACTIVITIES WILL REACH MANY THOUSANDS OF INDIVIDUALS IN THE FHJC’S SERVICE AREA. PEOPLE WHO PARTICIPATE IN THE PROJECT AND/OR ARE OTHERWISE REACHED BY THESE OUTREACH EFFORTS WILL BE BETTER ABLE TO PROTECT THEIR FAIR HOUSING RIGHTS. THEY WILL BE PROVIDED WITH A NEWLY FOUND ABILITY TO EFFECTIVELY SELF-ADVOCATE, ACCESS RESOURCES MADE AVAILABLE BY THE FHJC AND KNOW HOW TO ENFORCE THEIR RIGHTS THROUGH GOVERNMENT ENFORCEMENT AGENCIES. D. INTENDED BENEFICIARIES THIS PROJECT IS DESIGNED TO BENEFIT PEOPLE WHO IDENTIFY AS PEOPLE OF COLOR, WITH AN EMPHASIS PLACED ON BLACK, LATINO, ASIAN AMERICAN AND PACIFIC ISLANDERS (AAPI) AND MENA (MIDDLE EASTERN AND NORTH AFRICAN) COMMUNITY MEMBERS, AS WELL AS IMMIGRANTS, ESPECIALLY THOSE WITH LIMITED ENGLISH PROFICIENCY (LEP). INTERSECTIONAL DISCRIMINATION WILL BE ADDRESSED. SPECIAL ATTENTION WILL BE PAID TO REACHING COMMUNITIES WHO HAVE FACED HISTORIC AND ONGOING PATTERS OF RACIAL SEGREGATION AND HOUSING DISCRIMINATION. THE NEW YORK CITY REGION HAS ONE OF THE MOST DIVERSE POPULATIONS IN THE UNITED STATES, AND YET, HOUSING DISCRIMINATION AND RESIDENTIAL SEGREGATION ARE DEEPLY PERVASIVE. BY APPLYING A DISSIMILARITY INDEX TO 2020 CENSUS DATA, RESEARCHERS HAVE SHOWN THAT NEW YORK CITY IS ONE OF THE MOST SEGREGATED METROPOLITAN REGIONS IN THE COUNTRY. IT REMAINS ONE OF SIX METROPOLITAN REGIONS WITH A SEGREGATION INDEX ABOVE 80. OF THE 50 METROPOLITAN AREAS IN THE NATION WITH THE LARGEST BLACK, LATINO, AND ASIAN POPULATIONS, THE NEW YORK REGION RANKS AS ONE OF THE MOST SEGREGATED AREAS FOR ALL THREE GROUPS.; INTENDED BENEFICIARIES: THIS PROJECT WILL BENEFIT PEOPLE OF COLOR WHO LIVE IN SEGREGATED COMMUNITIES AND ALLOW THEM TO LIVE WITHOUT PENALTY IN NEIGHBORHOODS OF THEIR CHOICE. THIS PROJECT WILL ALSO HELP EDUCATE PEOPLE ABOUT FAIR HOUSING PROTECTIONS FOR PEOPLE FACING HARASSMENT FROM HOUSING PROVIDERS. THIS IS ESPECIALLY IMPORTANT IN THE FACE OF RISING ANTISEMITISM AND ISLAMOPHOBIA, WHICH THIS PROJECT WILL HELP TO DIRECTLY ADDRESS. THIS INITIATIVE WILL GIVE PEOPLE WHO SUSPECT THEIR FAIR HOUSING RIGHTS HAVE BEEN VIOLATED THE TOOLS TO SELF-ADVOCATE AND/OR BENEFIT FROM THE FHJC’S ASSISTANCE. WHEN SELF-ADVOCACY IS NOT SUFFICIENT, PEOPLE WILL BE GIVEN ACCESS TO RESOURCES THAT INCLUDE CONNECTIONS WITH THE FHJC’S INVESTIGATIVE EFFORTS, ASSISTANCE WITH REASONABLE ACCOMMODATIONS AND MODIFICATIONS, NETWORK OF COOPERATING ATTORNEYS, AND REFERRALS TO HUD AND OTHER ADMINISTRATIVE AGENCIES. THE FHJC IS EXPERIENCED AT REFERRING COMPLAINANTS TO ATTORNEYS AND ADMINISTRATIVE AGENCIES, INCLUDING HUD. THE ORGANIZATION HAS MAINTAINED THOROUGH, EXTENSIVE, AND ESTABLISHED PROTOCOLS TO GUIDE THE REFERRAL PROCESS.; SUBRECIPIENT ACTIVITIES: NONE

FAIR HOUSING ORGANIZATION INITIATIVES

EDUCATION AND OUTREACH INITIATIVES

EDUCATION & OUTREACH