CAM Regulatory Framework and Compliance 3 — Questions and Answers
Question 1: The Fair Credit Reporting Act (FCRA) requires property managers to provide an 'adverse action notice' when:
- A unit is leased to a competing applicant
- An applicant is denied based on a consumer credit report (Correct answer)
- Rent is increased above the market rate
- A lease is not renewed for nonpayment
Correct answer: An applicant is denied based on a consumer credit report
FCRA requires an adverse action notice when a consumer report is used as a basis for denying housing, identifying the reporting agency used.
Question 2: Under the Violence Against Women Act (VAWA), a housing provider must:
- Evict any tenant who reports domestic violence
- Provide emergency housing for all victims
- Not evict a tenant solely because they are a victim of domestic violence (Correct answer)
- Waive rent for tenants who are VAWA-protected
Correct answer: Not evict a tenant solely because they are a victim of domestic violence
VAWA protects tenants from eviction or denial of housing solely on the basis of their status as a victim of domestic violence, dating violence, sexual assault, or stalking.
Question 3: A property manager who uses a criminal background screening policy that automatically rejects all applicants with any arrest record is most likely violating:
- The Patriot Act
- HUD's guidance on criminal history and fair housing (Correct answer)
- The Equal Pay Act
- Americans with Disabilities Act
Correct answer: HUD's guidance on criminal history and fair housing
HUD guidance warns that blanket exclusions based on arrest records may violate the FHA because arrests do not indicate guilt and disproportionately impact protected classes.
Question 4: Which federal law governs the handling of tenant security deposits in federally subsidized housing?
- Fair Housing Act
- Housing and Community Development Act
- State landlord-tenant statutes govern, not federal law (Correct answer)
- Uniform Residential Landlord Tenant Act
Correct answer: State landlord-tenant statutes govern, not federal law
Security deposit rules are primarily governed by state landlord-tenant statutes; there is no single federal law that universally governs deposits.
Question 5: The 'housing for older persons' exemption under the FHA (55+ communities) requires that at least what percentage of occupied units have a resident 55 or older?
- 51%
- 62%
- 75%
- 80% (Correct answer)
Correct answer: 80%
For the 55+ housing exemption to apply, at least 80% of occupied units must have at least one resident aged 55 or older.
Question 6: Under the ADA Title III, apartments are generally NOT required to comply because:
- Apartments are exempt from all accessibility laws
- ADA Title III applies to places of public accommodation, not private residential housing (Correct answer)
- Only HUD-funded housing must comply with ADA
- Apartment tenants waive ADA rights in their lease
Correct answer: ADA Title III applies to places of public accommodation, not private residential housing
ADA Title III covers places of public accommodation; private residential housing falls under the FHA's accessibility requirements instead.
Question 7: When a resident with a disability requests permission to install grab bars in the bathroom, this is classified as a:
- Reasonable accommodation
- Reasonable modification (Correct answer)
- Material alteration
- Capital improvement
Correct answer: Reasonable modification
Physical changes to a unit or common area requested by a disabled resident are 'reasonable modifications' under the FHA, distinct from 'reasonable accommodations.'
CAM Regulatory Framework and Compliance 3
The Fair Credit Reporting Act (FCRA) requires property managers to provide an 'adverse action notice' when: