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Housing Voucher & Subsidy Compliance Policy

Quick-reference deck: Housing Voucher & Subsidy Compliance

Applies to: all employees, leasing agents, property managers, and third-party contractors interacting with applicants or tenants.

California requirement (Wonoak)

This policy is grounded in California's Fair Employment and Housing Act (FEHA), Gov. Code §12955, as amended by SB 329 and SB 222, which prohibit discrimination based on lawful source of income — including housing vouchers, subsidies, and rental assistance. It applies to Wonoak (CA). Texas (NYLA) source-of-income rules differ; confirm applicable law before applying this policy outside CA.

Purpose​

Ensure all company personnel comply with California source-of-income protections when interacting with applicants and tenants who use housing assistance.

Policy statement​

The Company shall treat all applicants and tenants uniformly, regardless of whether they use a housing subsidy — including Section 8 Housing Choice Vouchers, VASH vouchers, Rapid Rehousing subsidies, or any other public or private rental-assistance program. These subsidies constitute lawful income and must be evaluated as part of the applicant's income for qualification.

The Company shall not deny housing, impose different terms, advertise selectively, or apply different screening standards based on the use or non-use of a housing subsidy.

Procedures​

1. Application screening​

  • Screen all applicants using the Company's standard criteria: credit review, rental history, income verification, and background checks where permitted.
  • If an applicant has a voucher or subsidy:
    • Include the voucher amount as part of the applicant's income.
    • Apply income requirements only to the tenant's share of the rent, not the full contract rent.
    • Verify the applicant's portion for accuracy.
  • Staff may not impose higher income requirements, additional deposits, or different approval thresholds on voucher holders.

2. Communication guidelines​

Use only approved script language for voucher-related questions.

Staff may never state or imply
  • "We don't accept Section 8."
  • "We don't participate in vouchers."
  • "We prefer non-voucher applicants."
  • Or any similar language.

3. Advertising​

No listing, online ad, or printed material may contain phrases such as:

  • "No Section 8"
  • "No vouchers"
  • "Income must be 3x the rent" — unless clearly stated as 3x the tenant's portion

All advertising must be accurate, neutral, and fair-housing compliant.

4. Denial of an application​

  • A voucher holder may only be denied for lawful, non-voucher-related reasons — adverse credit, negative rental history, or inability to verify income.
  • Document denials clearly, referencing only legitimate screening criteria. See the denial script.

5. Training requirements​

All leasing staff and property managers must complete annual fair-housing training covering voucher compliance, communication standards, and California source-of-income protections.

Enforcement​

Any employee or contractor who violates this policy may be subject to disciplinary action, up to and including termination. Violations can expose ownership and management to legal liability, so strict compliance is required.

Acknowledgment​

All staff must sign an acknowledgment confirming receipt and understanding of this policy.