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Privacy Policy

I. PURPOSE

The purpose of these Program Policies and Procedures is to establish consistent standards for the administration of
affordable housing communities managed by AM Realty, LLC. These policies are designed to ensure compliance with
federal, state, and local housing regulations, promote fair and equitable housing opportunities, and provide uniform
guidance to property management staff.

All AM Realty employees are responsible for administering housing programs in accordance with these policies and
applicable regulatory requirements.

II. FAIR HOUSING POLICY

AM Realty is committed to providing equal housing opportunities and complying with all federal, state, and local fair
housing laws.
No applicant, resident, guest, or prospective resident shall be discriminated against based upon race, color, religion, sex,
national origin, disability, familial status, or any other protected classification recognized by applicable law.

All leasing, admissions, occupancy, transfer, and resident service decisions shall be made in a fair, consistent, and
non-discriminatory manner.

Fair Housing requirements apply to:
● Marketing and advertising
● Application processing
● Screening procedures
● Waiting list administration
● Occupancy standards
● Transfers
● Reasonable accommodations
● Lease enforcement
● Resident services

III. REASONABLE ACCOMMODATIONS AND MODIFICATIONS

AM Realty recognizes its obligation to provide reasonable accommodations and reasonable modifications to qualified
individuals with disabilities.

A reasonable accommodation is a change, exception, or adjustment to a rule, policy, practice, or service that may be
necessary for a person with a disability to have an equal opportunity to use and enjoy a dwelling.

A reasonable modification is a structural change made to a dwelling or common area to allow a person with a disability
full enjoyment of the premises.

Requests may be made verbally or in writing and may be submitted by the resident, applicant, family member,
caregiver, guardian, or another authorized representative.

Employees receiving a request shall immediately notify property management.

Management shall review all requests promptly and shall respond as quickly as practical but generally no later than ten
(10) business days.

If a disability and disability-related need are not readily apparent, management may request reliable documentation
necessary to verify eligibility for the accommodation. Management shall not request medical diagnoses, treatment
records, or information unrelated to the accommodation request.

Approved accommodations shall be implemented promptly.

No fees, deposits, pet rent, pet fees, or additional charges shall be assessed for approved service animals or assistance
animals.

IV . SECTION 504 COMPLIANCE

AM Realty complies with Section 504 of the Rehabilitation Act of 1973 and applicable accessibility requirements.

Management shall ensure:
● Equal access to programs and services.
● Availability of accessible units.
● Reasonable accommodations during the application process.
● Effective communication with persons with disabilities.
● Effective communication with persons with disabilities.
● Priority utilization of accessible units by individuals requiring accessibility features.

V . LIMITED ENGLISH PROFICIENCY (LEP)

AM Realty will take reasonable steps to ensure meaningful access to housing opportunities for persons with Limited
English Proficiency.

Staff may utilize:
● Translation services
● Language interpretation services
● Bilingual staff when available
● Written translations of key documents when appropriate

VI. VIOLENCE AGAINST WOMEN ACT (V A W A)
AM Realty shall comply with all applicable requirements of the Violence Against Women Act.

Applicants and residents shall not be denied housing, evicted, or otherwise penalized solely because they are victims of
domestic violence, dating violence, sexual assault, or stalking.

All V A W A-related information shall be maintained in a secure and confidential manner.
Management may request supporting documentation as permitted by law and program regulations.

VII. APPLICANT ELIGIBILITY

Applicants must satisfy all applicable eligibility requirements established by the property, funding source, and
regulatory agencies.

Eligibility determinations may include:
● Household composition verification
● Income eligibility determination
● Asset verification
● Student eligibility review
● Rental history verification
● Credit screening
● Criminal background screening
● Program-specific eligibility requirements

All information provided by applicants is subject to verification.

VIII. INCOME VERIFICATION PROCEDURES

Household income must be verified prior to move-in and at recertification intervals required by applicable program
regulations.

Acceptable verification methods include:
● Written third-party verification
● Employer verification
● Benefit award letters
● Tax returns
● Bank statements
● Other documentation deemed reliable by management

Management shall utilize the most current income limits and regulatory guidance applicable to the property.

IX. STUDENT ELIGIBILITY

When student eligibility restrictions apply, management shall verify compliance prior to move-in.
Households consisting entirely of full-time students must satisfy at least one applicable regulatory exception before
occupancy approval may be granted.
Documentation supporting eligibility exceptions shall be maintained in the applicant file.

X. OCCUPANCY STANDARDS

Occupancy standards shall be applied consistently and without discrimination.

Unit assignments shall consider:
● Household size
● Bedroom size
● Accessibility requirements
● Approved reasonable accommodations

Occupancy determinations shall comply with applicable fair housing requirements and regulatory guidance.

XI. WAITING LIST ADMINISTRATION

Properties shall maintain waiting lists when demand exceeds available units.

Waiting lists shall include:
● Applicant Name
● Date and time of application
● Bedroom size eligibility
● Accessibility requirements
● Preference status
● Contact information

Applicants shall be selected in chronological order based upon completed application date and time, subject to
regulatory preferences and accessibility requirements.
Management shall periodically update waiting lists and may remove applicants who:
● Request removal
● Fail to respond to management inquiries
● Fail to provide requested updates
● No longer meet eligibility requirements

XII. SCREENING PROCEDURES

Management may conduct screening activities that include:

A. Rental History Review

Applicants must demonstrate satisfactory rental history.
Factors reviewed may include:
● Lease compliance
● Payment history
● Housing-related judgments
● Outstanding balances owed to prior housing providers

B. Credit Screening
Credit reviews may consider:
● Payment history
● Collection activity
● Bankruptcy history
● Rental obligations
● Overall credit-related risk factors

Lack of established credit shall not serve as the sole basis for denial.

C. Criminal Background Screening

Criminal screening shall be conducted in accordance with applicable federal, state, and local requirements.

Management shall conduct individualized assessments whenever required by policy or law and shall consider
mitigating circumstances, rehabilitation efforts, and disability-related accommodations when applicable.

Arrests not resulting in conviction shall not serve as the sole basis for denial.

XIII. APPLICANT NOTIFICATION

Applicants shall receive written notification of approval, denial, or conditional approval.

Denial notices shall include:
● Specific reason for denial
● Appeal procedures
● Consumer reporting agency information when applicable
● Reasonable accommodation information when applicable

XIV . UNIT TRANSFER PROCEDURES

Residents may request transfers for:
● Household size changes
● Medical necessity
● Accessibility needs
● Approved accommodations
● Management-approved operational reasons

Transfer requests shall be documented and reviewed by management.

XV . RECORDKEEPING

Management shall maintain complete and accurate records supporting:
● Eligibility determinations
● Income certifications
● Screening decisions
● Waiting list administration
● Accommodation requests
● V A W A documentation
● Compliance activities

Records shall be maintained in accordance with AM Realty Record Retention Policies.

XVI. POLICY REVIEW

These policies shall be reviewed periodically and revised as necessary to ensure continued compliance with regulatory
requirements and operational best practices.