Fair Housing Manual

for New Home Sales & Leasing

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1. Introduction

McWilliams|Ballard (McWB) is committed to equal housing opportunity. This manual outlines the responsibilities and best practices for all employees and contractors involved in the leasing and sale of new homes. Compliance with the Fair Housing Act and related laws is not only a legal requirement but a core part of our values.

2. Fair Housing Act Overview

The Fair Housing Act prohibits discrimination in housing based on:

  • Race

  • Color

  • Religion

  • National Origin

  • Sex (including gender identity and sexual orientation)

  • Disability

  • Familial Status

Some states or municipalities may protect additional classes (e.g., source of income, age, marital status). Always check local laws.

3. Protected Classes

McWB prohibits discrimination or harassment based on:

  • Federal protections listed above

  • State-specific protections such as source of income, age, domestic violence survivor status

  • Local additions which vary by region

4. Prohibited Practices

All McWB staff must avoid:

  • Refusing to lease or sell based on a protected class

  • Applying different terms or conditions based on protected class

  • Falsely denying availability

  • Steering applicants to or away from certain communities

  • Making discriminatory statements or using exclusionary marketing

  • Failing to provide reasonable accommodations

5. Leasing Practices

A. Application & Screening

  • Use consistent, published criteria (credit, income, background checks)

  • No selective enforcement based on protected class

  • Avoid overly restrictive policies that may have disparate impacts

B. Touring Homes

  • Never make assumptions or comments about an applicant’s ability to live in a certain community

  • Offer equal access to all available homes

C. Lease Terms

  • Security deposits, pet policies, and lease lengths must be applied equally

  • Adjustments or exceptions must be documented and reviewed by management

D. Disability Accommodations

  • Tenants may request accommodations (e.g., service animals, accessible parking)

  • Staff must respond in writing within 10 business days

E. Ongoing Tenancy

  • Maintenance and repair services must be provided equitably

  • No retaliation for exercising Fair Housing rights

F. Terminations & Evictions

  • All notices must follow legal standards and be based on documented lease violations

  • Never base termination decisions on protected class or retaliation

6. Sales Practices

  • Avoid steering or selective disclosures

  • Use consistent contract procedures

  • Don’t comment on neighborhood demographics

  • All buyers must receive access to the same information and opportunities

7. Marketing & Advertising Compliance

  • Use inclusive, non-discriminatory language and images

  • Avoid phrases like “no children,” “Christian community,” or similar exclusions

  • Include the Equal Housing Opportunity logo on all materials

8. Handling Reasonable Accommodations

  • Allow modifications to accommodate disability when reasonable

  • Do not require extra deposits for service animals

  • Always evaluate requests on a case-by-case basis

9. Record Keeping & Complaint Procedures

  • Keep applications, leases, and related documents for a minimum of 3 years

  • Document all accommodation requests and responses for 5 years

  • Maintain a complaint log and document resolutions

10. Training & Accountability

  • All new hires must complete Fair Housing training within 30 days

  • Annual refresher training is required for all staff

  • Supervisors must monitor compliance and take corrective action when necessary

11. Sample Forms & Notices

  • Rental Application Template

  • Reasonable Accommodation Request Form

  • Equal Housing Opportunity Marketing Statement

  • Fair Housing Complaint Intake Form

  • Lease Non-Discrimination Addendum