| Summary: | The Affirmative Fair Housing Marketing Plan (AFHMP) is a set of regulations passed by the U.S. Department of Housing and Urban Development (HUD) to govern the sharing of information about applications for low-income rental housing in accordance to the Fair Housing Act. Collaborators of this work at Camfield Estates, a low-income housing development in Boston, MA, communicated concerns over the regulations’ efficacy as well as desires for increased autonomy in the process of tenant selection and application marketing. The purpose of the research conducted was to describe, using social science and statistical methods, the limitations of the AFHMP regulations that are pertinent to low-income developments, to amplify any voiced concerns of Camfield Estates that may also help other low-income developments, and offer suggestions for improvements for the AFHMP regulations to align with their original goal.
Qualitative interviews of low-income housing developers, development residents and staff, and HUD New England Compliance staff to identify the following limitations of the AFHMP which prevent effective enforcement of fair housing goals: (1) that there is significant administrative burden, for both filers and HUD staff, in maintaining and checking for policy compliance, (2) that guidelines for when to file updates were underdefined, (3) that guidelines for how to conduct the analysis to determine groups least likely to apply to a property were underdefined, and (4) that both stakeholders at low-income developments and HUD New England Compliance demonstrated interest in extending affirmative marketing to improve outcomes for those with intersectional identities, such as to address the difficulties of accessing housing while being single, male, and Black. A quantitative analysis of AFHMP, resident, and census data for Camfield Estates was conducted to study the first, second, and third concern in context.
Recommendations for immediate changes that would respect Camfield Estates’ concerns of autonomy and wouldn’t significantly increase cost of administrative burden for HUD are made, including: (1) that the AFHMP form be simplified to reduce administrative burden, to reduce room for error in the analysis of groups least likely to apply to the development, and to reduce barriers to updating marketing strategy more frequently if needed, (2) that greater flexibility should be allowed in determining affirmative marketing strategy, perhaps by allowing qualitative, free-form response, and (3) that developers should themselves determine the groups least likely to apply to the development, and HUD should send out a memo banning other agents like housing authorities from limiting developers with pre-completed, read-only analysis on forms. A recommendation is also made for space to be allowed for a link to a survey on newest AFHMP forms for further work to be conducted by approved researchers. To support a long-term feedback mechanism for policy relevance, an exploration of adaptive regulations to govern fair marketing is presented.
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