Fair Housing Promise and Policy

Updated December 7, 2024

Piazza & Associates, Inc, is an Administrative Agent for affordable housing.  As such, it is responsible for processing applications for compliance to affordable housing regulations for rental and sale units throughout the State of New Jersey.  These affordable units are not owned, operated, managed or sold by Piazza & Associates, Inc., which relies on the owners, sellers, managers, leasing and real estate agents and landlords to screen applications for their own specific units under the terms and conditions of their own selection policies.  For example, Piazza & Associates, Inc. does not screen for credit or make a determination as to an applicant’s qualifications based on a credit report, which is the responsibility of the leasing agent, manager, landlord, etc.

With respect to its responsibility to review, evaluate and process applications for adherence to the parameters of the affordable housing programs it administers, it is the policy and promise of Piazza & Associates, Inc. to comply with the Federal Fair Housing Act, the New Jersey Law Against Discrimination (LAD), N.J.S.A. § 10:5-1 to -49, and the Fair Chance in Housing Act (FCHA).

LAD:

In compliance with the LAD, Piazza & Associates, Inc. ensures that all housing, as well as all terms, conditions, and privileges associated with such housing, are available to all persons without regard to actual or perceived race, creed, religion, color, national origin, nationality, ancestry, pregnancy or breastfeeding, sex, gender identity or expression, sexual orientation, familial status (defined as having care or custody of a child under age 18 or being pregnant), disability, liability for service in the Armed Forces of the United States, marital status, civil union status, or domestic partnership status. The LAD also prohibits housing discrimination based on the source of lawful income used for rental or mortgage payments (including Section 8 housing choice vouchers, COVID-19 Emergency Rental Assistance Program (CVERAP), State Rental Assistance Programs (SRAP), temporary rental assistance (TRA), Eviction Prevention Program (EPP), unemployment benefits, child support, alimony, and supplemental security income.

This policy means that, among other things, the owners and operators of Piazza & Associates, Inc. do not discriminate against persons in any aspect of the sale, rental, or occupancy of housing on the basis of their actual or perceived membership in an LAD-protected category or their association with someone who is a member of an LAD-protected category, or their source of lawful income. Specifically, they do not and will not:

  1. Refuse to sell or rent, refuse to negotiate the sale or rental of, or otherwise make housing unavailable to any person on the basis of an LAD-protected category;
  2. Discriminate against any person in the terms, conditions, or privileges of sale, rental, or occupancy, including cost of rental, on the basis of an LAD-protected category;
  3. Make, print, or publish any statement, including print advertisements and online postings, expressing any preference for, limitation of, or discrimination based on an LAD-protected category;
  4. Steer persons away from their desired housing, or represent that a neighborhood is changing in a way that could lower property values, increase crime, or lower the quality of public services, including schools, because of an LAD-protected category;
  5. Refuse to approve an applicant to rent to a prospective tenant or discourage a prospective tenant from renting because they plan to pay with Section 8 housing choice vouchers, COVID-19 Emergency Rental Assistance Program (CVERAP), SRAP (State Rental Assistance Program), TRA (temporary rental assistance), Eviction Prevention Program (EPP), or any other subsidy or voucher provided by federal, state, or local rental-assistance programs; or other sources of income including unemployment benefits, child support, alimony, and supplemental security income; or express any such limitation or refusal in any printed advertisement, oral or written statement, or online posting (for example, statements like “No Section 8,” “TRA not accepted,” or “This property not approved for Section 8” are all prohibited);
  6. Condition a person’s housing, or any of the terms, conditions, or privileges thereof, on acceptance of unwanted sexual advances or requests for sexual favors, or engage in unwanted, harassing conduct of a sexual nature that creates an intimidating, hostile, or offensive housing environment, or permit others to do so;
  7. Engage in unwanted, harassing conduct based on any LAD-protected category that creates an intimidating, hostile, or offensive housing environment, or permit others to do so;
  8. Undertake any of the actions listed in subsections (A) through (I) based on the person’s perceived membership in an LAD-protected category or their association with someone who is an actual or perceived member of an LAD-protected category;
  9. Impose unreasonable occupancy restrictions to prevent families with children from moving in;
  10. Refuse to grant reasonable accommodations and reasonable modifications to a person with a disability as explained further in Addendum A;
  11. Selectively inquire about, or request information about and/or documentation of, a prospective tenant’s or buyer’s immigration or citizenship status because of the person’s actual or perceived national origin, race, or ethnicity;
  12. Fail to account for a person’s receipt and use of rental assistance (such as Section 8 housing choice vouchers, SRAP, or TRA, EPP, unemployment benefits, child support, alimony, or supplemental security income) when applying minimum income requirements to a person’s rental application (any minimum income requirement, financial standard, or income standard must be calculated based only on the portion of the rent to be paid by the tenant, rather than the entire monthly rent);
  13. Violate the S. Department of Housing and Urban Development’s April 2016 Guidance by imposing blanket exclusions on all individuals with any prior arrest or conviction; or
  14. use criminal history as a pretext for intentionally discriminating on the basis of race or national origin.

FCHA

In compliance with the FCHA, Piazza & Associates, Inc. affirms that they will not inquire into applicants’ criminal histories on initial application materials, or otherwise consider applicants’ criminal records in any way., until after a conditional housing offer has been made, except for convictions of drug-related criminal activity for the manufacture or production of methamphetamine on the premises of federally assisted housing, or if the applicant is subject to a lifetime registration on a state sex offender registry.

Nothing about the FCHA requires landlords or housing providers to consider a person’s criminal record in housing. If a housing provider does review an applicant’s criminal history after a conditional offer, specific restrictions apply. A housing provider must conduct an individualized analysis of an applicant’s criminal record and may only deny housing if withdrawing a conditional offer is necessary to fulfill a substantial, legitimate, and nondiscriminatory interest.

Making affordable housing opportunities equally accessible for all persons is our mission and our vocation.  Any agent, employee, or designee of Piazza & Associates, Inc. who fails to comply with this policy will be subject to appropriate disciplinary action. Please report any violation of this policy to Frank Piazza Jr. at FPiazza@PiazzaNJ.com or 609-786-1100, ext. 301.  You cannot and will not be subjected to retaliation for making a complaint under this policy or for attempting to exercise your rights under this policy, the LAD, or the FCHA.

Any action taken by Piazza & Associates, Inc.’s agent, employee, or designee in violation of the requirements laid out in this policy may constitute a violation of the LAD and/or the FCHA. Any applicant who believes that any owner, agent, employee, or designee of Piazza & Associates, Inc. has violated any of the above may contact the New Jersey Division on Civil Rights at www.NJCivilRights.gov or (866) 405-3050. A complaint must be filed with the New Jersey Division on Civil Rights within 180 days of the allegedly discriminatory conduct. DCR has a number of fair housing fact sheets that are available at https://www.nj.gov/oag/dcr/housing.html.

Addendum A: Reasonable Accommodations and Modifications for Persons with a Disability

In most cases, physical accommodations will be the responsibility of the owner, seller, landlord or manager, which has control over the subject property.   Although Piazza & Associates, Inc. (“P&A”) does not have control over the physical accommodations of the affordable homes, P&A will grant reasonable accommodations to its rules, policies, practices, procedures, or services when such accommodations are possible and necessary to afford a person with a disability an equal opportunity to use and enjoy a dwelling and when the accommodation will not cause an undue hardship to or conflict with the responsibility to make affordable units open to the general public as required by law.    If P&A cannot grant the requested accommodation or modification because it does not have control over the physical property, we will refer your request to the owner, landlord, manager, as appropriate.  Generally, P&A is unable to grant priority access to one property to accommodate an applicant who is unable to acquire an accessible unit at another property.

To request a reasonable accommodation or reasonable modification, contact Frank Piazza Jr. at FPiazza@PiazzaNJ.com or 609-786-1100, ext. 301. To process your request, P&A may require supporting documentation from a  treating doctor or mental health professional to confirm that you have a disability as defined by the LAD and that the requested accommodation or modification is necessary to provide you with an equal opportunity to use and enjoy the dwelling. All requests and information related to a request, including medical information, will be kept confidential unless disclosure is required by law.

P&A will make a prompt decision on your request and will provide that decision in writing. If P&A cannot grant the requested accommodation or modification, we will refer your request to the owner, landlord, manager, as appropriate.  You cannot and will not be subjected to retaliation for requesting an accommodation or modification under this policy or for attempting to exercise your rights under this policy or under the LAD. Any person who believes a request for an accommodation or modification has been unlawfully denied or unreasonably delayed may contact the New Jersey Division on Civil Rights at www.NJCivilRights.gov or 1-866-405-3050. A complaint must be filed with the New Jersey Division on Civil Rights within 180 days of the housing provider’s denial of the accommodation request.

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