HUD HCV Guidebook § 7.1

As described throughout this chapter, various statutes, regulations and other authorities prohibit
discrimination because of race, color, religion, sex, national origin, familial status, disability, age, or status as
a survivor of domestic violence, sexual assault, dating violence, or stalking. All PHA employees need to be
aware of their responsibilities under civil rights and fair housing laws.

The PHA is responsible for promoting an internal culture that makes it clear that discriminatory practices,
including sexual harassment, will not be tolerated at any level by staff or residents. For example, comments
that stereotype an applicant or occupant based on ethnic background, that mimic an accent, or that jokingly
discuss a client’s perceived mental state are discriminatory. Though these are just a few examples,
discriminatory statements of any kind cannot be tolerated, and PHAs have an obligation to ensure they do not
occur or go unaddressed, if they do occur.

One way to promote ongoing awareness and competence is diversity and inclusion training for staff, providing
them with opportunities to challenge stereotypes and confront biases -- including implicit biases -- in a training
environment. Training on fair housing and civil rights laws more broadly is also important to promote
compliance since all PHA staff are obligated to comply with Federal fair housing and civil rights laws. Staff
and participants must be permitted to speak up if they observe harassing or other discriminatory conduct and
be assured that they will be protected from retaliation for doing so.

Beyond this, all policies, procedures, and practices must not discriminate because of any protected class.
PHA employees must ensure that they apply program rules, services, and procedures in a consistent
nondiscriminatory manner. PHAs must also consider the demographics of the people impacted – positively
and negatively – by policies and practices to ensure that none have an unjustified discriminatory effect.

Any aggrieved person may file a fair housing claim against the PHA. PHAs must ensure that all applicants and
tenants are aware that filing a complaint with HUD is their right, that they will not be subject to retaliation for
doing so, and how they may obtain more information about filing a complaint, including how to access HUD’s
complaint filing site linked below.153