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Trusted and affordable professionals serving developers, syndicators, managers, and owners in the affordable housing industry since 1994

Training | File Reviews | Utility Allowance Calculations 
Accessibility Assessments | CNAs | 
Industry Updates
Monthly News & Updates - September 2016

Editor's Letter

It is officially autumn and we are devoting this month’s newsletter to the topic of “Service Animals”.  Each month we respond to your questions and provide explanations for the common compliance issues we see in the field.  Whether we are training across the country, conducting tenant file reviews, or inspecting a property, there are always questions that arise from property managers or developers as to how to stay in compliance given “this or that” unique experience.  Even this month’s Question from a Client is unique:  Can a second service animal be had if the first service animal gets depressed?  Well, we answer that very question and give you more clarity on this topic throughout this addition.

Jeffrey Promnitz
Acting Executive Vice President

PS – It is nearly time to reschedule your Utility Allowance Calculations!  Please start preparing for the rescheduling process or if you’re a new customer inquire with us at 866-760-6000.

Assistance Animals vs. Pets

by Breana Thomas, Senior Training Specialist   

October is National Guide Dog Month!  To celebrate, we are going to discuss pets versus assistance animals and the myriad of guidelines that we must follow at our affordable housing communities in regards to these animals.

The Merriam-Webster dictionary defines a pet as:

A domesticated animal kept for pleasure rather than utility.”

When it comes to pets at our affordable housing properties, we are allowed to set very specific restrictions and policies.   For instance, we can have a “No Pet Policy” at most of our properties.  As with many provisions in the affordable housing world, there are also exceptions to the rule.  For instance, if a property was developed for the elderly and persons with disabilities, we cannot have a “No Pet Policy” and instead must apply the pet rules as outlined in the HUD Handbook 4350.3, primarily chapter 6.  We can however, limit the 
type of pet on these types of properties to a common household pet

The 4350.3 glossary defines a common household pet as:  

Fair Housing Design and Accessibility
Article 20

by Randy McCall, Senior Training Specialist

Overview: Seven basic requirements of fair housing accessibility  

Accessible Entrances & Property Routes 

Site Impracticality
Fair Housing Act Design Manual Chapter 1 Page 1.43 -1.50

In our last issue, we introduced you to the methods for determining if
a site is impractical to apply the Fair Housing Design requirements.  As previously stated, according to the Fair Housing Design Manual, there are two tests for determining site impracticality.  The two tests are the 1.) Individual Building Tests and the 2.) Site Analysis Tests
Going forward, we will define what these tests are and how to apply them.

Below is a flow chart that details when you must use either of the two tests:

Click HERE for rest of the article

Quizzle - Companion/Service Animals


1.  What is the maximum deposit that a property can require for an Assistance/Service Animal?

a.  $300

b.  $100

c.  Twice the amount of the rent

d.  $0

2.    Which of the following questions CAN be asked regarding an assistance animal?

a.  “What work or tasks has the animal been trained to perform?”

b.  “You don’t look disabled; why do you need that animal?”

c.  “What kind of disability do you have that requires an assistance animal?”

d.  “Is this animal required because of a disability?”

3.    What civil rights act(s) must be followed for a rental office?

a.  Americans with Disabilities Act (ADA)

b.  Fair Housing Act (FHAct)

c.  Section 504

d.  All of the above

4.    Sally, an applicant at your affordable housing community, states that she would like a reasonable accommodation for an assistance animal.  Her disability is not visible and none of the information on her application indicates that she is disabled (receiving disability).  What can you do?  

a.  Ask the applicant what their specific disability is and how the assistance animal will help them.

b. Ask the applicant to submit reliable documentation of a disability and their disability related need for an assistance animal.

c.   Ask your supervisor to deny the request because there was not sufficient information.

d.  Ask the applicant if the animal has documentation as a trained Service Animal.

5.    Which of the following animals can be an approved “service animal” for ADA purposes? (Select all that apply.)

a.   Cat

b.   Dog

c.   Miniature Horse

d.   Canadian Grey Squirrel

6.    Mary Jones is a disabled tenant who lives in an LIHTC (Tax Credit) property where pets are not allowed.     Ms. Jones tells her site manager that she needs to get a dog to help her with her hearing disability.  What should the manager next steps be?

a.  Require that Mary put the request in writing; verify the hearing loss as a disability; verify the need for the dog as a reasonable accommodation.

b.  Deny the request because it is a no pet property and LIHTC properties are not required to make exceptions.

c.   Ask Mary to put her request in writing, but act either way; do not verify the hearing loss as a disability because it is obvious; verify the need for the dog as a reasonable accommodation, but do not require the dog to have formal training.

d.  Because Mary did not use the term Reasonable Accommodation, the manager is not required to do anything.

7.    There is a difference between a “Service Animal” and an “Assistance     Animal”. 

True     or     False

Click HERE for the Questions and Answers

Question from a Client

Angela from Missouri

Question:  I have a tenant who sent us a reasonable accommodation request for a companion animal.  She indicated that the request is for her current companion animal. She stated that her current companion animal gets depressed often and that having another companion animal for it will help the companion animal.  Should I grant this request?

Click HERE for the answer

Getting to Know Us!
David Bell
Inspections Dept. Manager
314-336-4857 direct line
866-760-6000 Toll Free

David joined Zeffert & Associates in February 2008 and has held several different positions in his tenure with us.  Most recently, he served as the Report Writer for the department and prepared handicap accessibility transition plans and capital needs assessments.  Working closely with all Associates in the department, he is very knowledgeable in this line of work.

We are happy to announce the promotion of David Bell as the Inspections Department Manager.  

Zeffert's Training Calendar

Click on the topic for more information or to register online
MOR (Management Occupancy Reviews) Webinar 
                 1 1/2 hour Webinars and Full Day Training
Topic Location
October 4-6 LIHTC with HCCP exam
Sponsored by Columbia Housing Authority
Columbia, MO
October 11 LIHTC/Qualifying Households Springfield, MO
October 13 LIHTC/Qualifying Households Wichita, KS
October 18 LIHTC/Qualifying Households
Little Rock, AR
October 20 LIHTC/Qualifying Households
Shreveport, LA
October 25 LIHTC/Qualifying Households Columbus, OH 
October 25  Farm Labor 
Sponsored by OR AHMA
Boardman, OR
October 25  Practical Fair Housing in the 21st Century
Sponsored by OR AHMA
Boardman, OR
October 27 LIHTC/Qualifying Households  Pittsburgh, PA  
October 27-28 Managing RD Compliance 
Sponsored by OR AHMA

Salem, OR 
November 1  MOR (Management Occupancy Review) -
Preparing for MOR
November 8 LIHTC/Qualifying Households  Greenville, SC
November 8 HOME Funds Compliance Workshop
Sponsored by ADOH
Phoenix, AZ
November 10  LIHTC/Qualifying Households Charlotte, NC
November 10-11  HOME Rental Compliance
Sponsored by IHCDA
Fort Wayne, IN
November 15 LIHTC/Qualifying Households  Jackson, MS 
November 17  LIHTC/Qualifying Households  Nashville, TN
November 17  MOR Training (Management Occupancy Review) Preparedness
Sponsored by OR AHMA
Salem, OR 
November 29-Dec.1 LIHTC with HCCP exam Buena Park, CA 
December 6  LIHTC/Qualifying Households        Birmingham, AL
December 8 LIHTC/Qualifying Households  Atlanta, GA 
December 13 LIHTC/Qualifying Households Oklahoma City, OK
December 15  LIHTC/Qualifying Households  Dallas, TX 
Dec. 13-15 LIHTC with HCCP exam  St. Louis, MO
*** For any questions or concerns, please contact Susan Barnett...314-336-4853 direct.

Zeffert Provides Utility Allowances!

We have been calculating utility allowances for more
than 20 years and have grown to become the
provider in the country.

Our automated systems and large databases make
our reports cost-effective.

Can we calculate your property's utility allowance for less than it would cost to do it yourself? 

Call us to find out!

Martha McBroom
314-336-4847 direct line
866-760-6000 Toll Free

Discounted Package Program
If you need more than one of our services then let us offer them at a discount in one package.
  • Training
  • File reviews
  • Capital Needs Assessments
  • Accessibility Assessments
  • Transition Plans
  • Utility Allowance Calculations    

Click HERE for more information

Contact us by calling 1-866-760-6000 or visit our website at

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