HUD HCV Guidebook § 2.1

Title VI of the Civil Rights Act of 1964 (Title VI) and HUD’s implementing regulations prohibit, on the basis of
race, color, or national origin, the exclusion from participation in, denial of the benefits of, and discrimination
under all programs and activities of recipients of Federal financial assistance, whether provided directly or
through a subrecipient.2 It applies to all HUD programs that are covered by this Guidebook as more
specifically explained in this chapter.

The discrimination prohibited by Title VI includes denying, restricting access to, or limiting participation in a
program or activity, housing, accommodations, facilities, services, financial aid, or other benefits, or providing
such benefits in a way that is different than how they are provided to others. It also includes subjecting a
person to segregation or separate treatment or restricting a person’s enjoyment of any advantage or privilege
enjoyed by others in connection with such benefits under the program or activity. It also prohibits treating a
person differently from others in determining if they satisfy any requirements or conditions, including
conditions of occupancy, admission, or eligibility. In addition, recipients may not utilize criteria or methods of
administration which have the effect of subjecting persons to discrimination, nor may they make siting
decisions with a discriminatory purpose or effect.

1 Several civil rights statutes apply to the HCV program, including the list provided in Section 1 of this Chapter. For a more
comprehensive list, including implementing regulations, PHAs should consult HUD’s Office of Fair Housing and Equal Opportunity’s
website, currently available at https://www.hud.gov/program_offices/fair_housing_equal_opp/fair_housing_and_related_law (last
accessed Jan. 23, 2024).
2 Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.; 24 CFR 1.2(f).

Fair Housing and Nondiscrimination Requirements                                                                               4
US Department of Housing and Urban Development                                                                        April 2025

Title VI applies to all aspects of a PHA’s operations and the administration of their programs and activities,
including but not limited to marketing, waitlist administration, tenant selection and admission, preferences3,
record-keeping, application of lease requirements, termination and meeting the needs of residents with
limited English proficiency. PHAs are encouraged to consult their local field office if questions arise.

HUD’s Title VI regulations also provide that recipients of Federal financial assistance have an affirmative
obligation to take steps to overcome the effects of discrimination based on race, color, or national origin. The
regulations also require, that even in the absence of prior discrimination, recipients must take affirmative
steps to overcome the effects of conditions which resulted in limiting participation by persons of a particular
race, color, or national origin.4 For additional types of discrimination prohibited by Title VI, see 24 CFR 1.4.