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The Fair Housing Toolkit brings together available resources to help elected leaders, municipal planning, housing and redevelopment officials, developers, citizen board members, and other volunteers understand how to affirmatively further fair housing. Affirmative marketing tactics are most commonly relevant to affordable housing developers seeking to fill vacant units. The outreach resources provided here are directly relevant for networking and outreach efforts aimed at Civic Engagement. Insight regarding the target populations to be reached through affirmative marketing comes from fair housing goals identified through the planning process.
This section describes the requirements for affirmative marketing plans, presents resources for reaching a broad network of people and organizations to market available housing units and build connections with target populations within and beyond municipal borders.
What is the purpose of Affirmative Marketing?
The Fair Housing and Equity Assessment (FHEA) extensively documents racial and economic segregation that characterizes the Greater Boston region. According to the FHEA, Greater Boston remains one of the whitest major metropolitan regions in the US, with Black and Latino residents making up less than 5% of the population in 80% of MetroFuture cities and towns. According to Josephine Louie’s 2005 report “We don’t feel welcome here”, over one third of African Americans and Latinos in metro Boston would pioneer integration in all white neighborhoods. This same study demonstrated that while most people of all races indicate a preference for living in an integrated community, comfort levels differ about the ideal level of integration.
The concept of affirmative marketing is to conduct both broad and targeted outreach to contact those least likely to apply for available housing units. Housing developers and managers are responsible for creating and implementing such plans. Yet the obligation to affirmatively further fair housing extends these responsibilities.
Beyond the letter of the law, affirmative marketing and community outreach strategies are critical components to connect theoretical principles to affirmatively further fair housing with actual people. Plan implementation requires hands-on, on the ground outreach. Municipalities which have conducted an Assessment of Fair Housing (currently rule proposed by HUD) have the responsibility to require developers to adopt an affirmative marketing plan in line with the town’s identified housing needs for populations least likely to apply. Even without this assessment in place, municipalities should assist developers to create and implement a thorough plan to identify and reach such populations.
What are affirmative marketing requirements?
Different housing funding streams have distinct requirements for affirmative marketing. The following manuals provide guidance on plan requirements.
- HUD Regulation 24 CFR 200.600 and the HUD Handbook 4350.3: Occupancy Requirements of Subsidized Multifamily Housing Programs (see chapter 2),
- DHCD Affirmative Fair Marketing Plan Guidance,
- City of Boston Fair Housing Commission’s Affirmative Marketing Manual,
- CHAPA Tenant Selection Manual, and
- MassHousing Tenant Selection Plan Template.
How do I determine who is least likely to apply?
Determining who is least likely to apply should begin with outreach to potential target populations through civic networks. Several other sources of information from the municipality can provide this direction: the Assessment of Fair Housing or current Analysis of Impediments; the housing needs analysis in the Master Plan; the Consolidated Plan. Important to consider is whether these planning documents took into consideration regional population projections and an analysis of disparate impact.
Overcoming past patterns of urban/suburban segregation requires partnerships between urban and suburban municipalities and organizations. Engaging with the religious, cultural, social, and advocacy organizations in the region will help connect local housing opportunities with area needs.
Where do I find organizations serving target populations?
The networks below provide good starting places to find nearby local organizations serving people of color, immigrant groups, low income families, veterans, and other protected classes. These databases and member directories for organizations located nearby can provide contacts to support the proposed development. They may provide knowledge of local housing needs for their members, language assistance, and/or volunteers. At a minimum, these local organizations are useful places to advertise available housing.
In addition to national advocacy, the NAACP has local chapters across the country, including in many cities and towns in Massachusetts.
The Ma Immigrant & Refugee Advocacy Coalition (MIRA) serves as a good starting point for service and advocacy organizations serving the varied ethnic groups across the state. The MIRA map of member organizations will indicate organizations active in the local area and region.
The City of Boston’s Office of New Bostonians offers multiple resources, including a searchable online database of organizations and cultural groups serving immigrant populations in the region beyond Boston.
English as a Second or Other Language(ESOL) programs exist in private, public, and non-profit settings across the Commonwealth. Search for programs in your area to connect with residents whose primary language is other than English.
Veterans are a protected class in Massachusetts. All municipalities have a Veterans’ Services Officer to help individuals access needed services. In addition, the Massachusetts Department of Veterans’ Services provides detailed information on veterans housing programs.
Community Development Corporations (CDCs) and Community Housing Development Organizations (CHODOs) serve neighborhoods, municipalities, and regions throughout Massachusetts. Primarily developers of affordable housing, CDCs have wide ranging experience in community outreach and organizing to revitalize neighborhoods. Find the CDC for your region or serving a nearby urban center to start.
Faith based organizations throughout the region can provide leads on specific outreach and service programs they offer.
Where can I post notices of available housing?
The MA Access Housing Registry helps people find accessible and barrier free housing listings. The site offers flexible search functions along with information about subsidized housing and accessible housing. Organizations and individuals can register to list available properties. Massachusetts has a wide range of nonprofit social service agencies serving the needs of low-income residents.
- Multiservice CAP Agencies provide information and assistance to low income households throughout the state.
- Independent Living Centers are regional agencies in Massachusetts serving people with disabilities.
- Housing Consumer Education Centers provide information for home seekers and property owners.
- Member organizations of the Regional Housing Network of Massachusetts develop housing and provide housing related services.
- MA Coalition for the Homeless is a network of housing advocates. The coalition can provide information about member organizations that service local communities. The coalition also provides direct service to the homeless.
- HomeStart assists individuals and families to move from shelters to permanent housing.
Additional steps for effective outreach:
- Advertise through local and regional newspapers, newspapers that serve racial and ethnic groups, newspapers for families with children, and other groups protected under fair housing laws. Kidon Media lists national and statewide ethnic newspapers.
- Post outreach materials in area laundromats, ethnic groceries and restaurants, and at area religious institutions.
- Connect with health centers, clinics and emergency rooms: they are excellent sources for qualitative data on area needs as well as locations for distributing outreach materials.
- Include educational institutions on your outreach list. School social workers and parent-teacher organizations are good sources for spreading information among parents. The community college and universities nearest to the housing development will have student supports as well as student government, cultural groups, and advocacy groups.
A broad based resource, Guidestar ,provides online listings of all IRS registered nonprofit organizations. Zip codes, the key to Guidestar searches, can be used for the development’s location as well as neighboring municipalities to see what other resources exist close by.
What elements are required for a thorough Affirmative Marketing Plan?
DHCD presents the following Requirements for Outreach and Marketing as outlined in their Affirmative Fair Marketing Plan Guidance .
Marketing should attract residents outside the community by extending to the regional statistical area as well as the state and must meet the following requirements:
- Advertisements should be placed in local and regional newspapers, and newspapers that serve minority groups and other groups protected under fair housing laws. Notices should also be sent to local fair housing commissions, area churches, local and regional housing agencies, local housing authorities, civic groups, lending institutions, social service agencies, and other non-profit organizations.
- Affordable units in the Boston Metropolitan Statistical Area (MSA) must be reported to the Boston Fair Housing Commission’s Metrolist (Metropolitan Housing Opportunity Clearing House). Such units shall be reported whenever they become available (including upon turnover).
- Accessible units must be listed with MassAccess (see https://www.chapa.org or https://www.massaccesshousingregistry.org) whenever they become available (including upon turnover).
- Affordable rental and affordable ownership units, whether or not they are accessible, must also be listed with MassAccess whenever they become available (including upon turnover). Where applicable, all MassAccess data input fields relating to accessible and adaptable status and accessibility features must be completed. Available affordable ownership units must also be listed with the Massachusetts Affordable Housing Alliance website (see https://www.mahahome.org or https://www.massaffordablehomes.org)
- Marketing should also be included in non-English publications based on the prevalence of particular language groups in the regional area. To determine the prevalence of a particular language by geographical area, see for example https://www.lep.gov/demog_data/demog_data.html.
- All marketing should be comparable in terms of the description of the opportunity available, regardless of the marketing type (e.g., local newspaper vs. minority newspaper). The size of the advertisements, including the content of the advertisement, as well as the dates of the advertising unless affirmative advertising occurs first, should be comparable across regional, local, and minority newspapers.
- All advertising and marketing materials should indicate resident selection by lottery or other random selection procedure, where applicable.
- All advertising should offer reasonable accommodations in the application process.
- Advertisements should run a minimum of two times over a sixty day period and be designed to attract attention. Marketing of ownership units should begin approximately six months before the expected date of project occupancy.
- Pursuant to fair housing laws, advertising/marketing must not indicate any preference or limitation, or otherwise discriminate based on race, color, disability, religion, sex, familial status, sexual orientation, gender identity, national origin, genetic information, ancestry, children, marital status, or public assistance recipiency. This prohibition includes phrases such as “active adult community” and “empty nesters”. Exceptions may apply if the preference or limitation is pursuant to a lawful eligibility requirement.
- All advertising and marketing materials portraying persons should depict members of classes of persons protected under fair housing laws, including majority and minority groups as well as persons with disabilities.
- The Fair Housing logo and slogan (“Equal Housing Opportunity”) should be included in all marketing materials. The logo may be obtained at HUD’s website at: https://www.hud.gov/library/bookshelf11/hudgraphics/fheologo.cfm ¹
As noted above, plan requirements are determined by the project funding source and therefore may vary from these presented by DHCD.
While specific to a subsidized development in Boston, this Affirmative Fair Housing Marketing Plan provided by Maloney Properties demonstrates a comprehensive system for affirmative marketing and a tenant selection process designed to affirmatively further fair housing. The plan includes a specific Language Assessment Plan.
¹ Massachusetts Department of Housing and Community Development. DHCD Guidelines: Affirmative Fair Housing Marketing Plans. 2009.