THE QUICKEST WAY TO CREATE RISK IS TO APPLY YOUR POLICIES DIFFERENTLY DEPENDING ON THE APPLICANT IN FRONT OF YOU.
Written into your standard screening policy, Applied to every single applicant, and Supported by a legitimate business reason, not an assumption about someone’s citizenship. So if you require an SSN, it must be: Be aware that some applicants may provide an Individual Taxpayer Identification Number (ITIN), which is issued by the IRS in lieu of an SSN. If this still allows a landlord to verify identity and screen the applicant per its standard procedure, then the lack of an SSN should not be disqualifying. However, failure to provide identification that enables a landlord to properly screen the applicant would be a legitimate reason for denial. State laws and housing programs may vary, which means a requirement that is permissible in one state could be restricted in another. This is why every conventional housing provider should periodically review state guidelines and consult legal counsel before putting any identification requirements in place. CONSISTENCY: YOUR COMPLIANCE SUPERPOWER If fair housing had a slogan, it might very well be: “Consistency is king.” The quickest way to create risk is to apply your policies differently depending on the applicant in front of you. Asking additional questions based on how someone looks, speaks, or the type of ID they provide, even unintentionally, can suggest discrimination based on national origin. A strong compliance strategy includes a clear, written screening policy; fair, neutral application of that policy; and regular training so staff understand precisely how to follow it. This consistency not only protects applicants, it protects you.
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