HUD 935.2, Affirmative Fair Housing Marketing Plan

Affirmative Fair Housing
Marketing (AFHM) Plan –
Multifamily Housing

U.S. Department of Housing
and Urban Development
Office of Fair Housing and Equal Opportunity

1a. Project Name & Address (including County, City, State & Zip Code)

OMB Approval No. 2529-0013
(exp.)

1b. Project
Contract Number

1c. Number of
Units

1d. Census Tract

1e. Housing/Expanded Housing
Market Area

1f. Managing Agent Name, Address (including City, State & Zip Code), Telephone Number & Email Address

1g. Applicant/Owner/Developer Name, Address (including City, State & Zip Code), Telephone Number & Email
Address

1h. Entity Responsible for Marketing (check all that apply)
____ Owner

____ Agent

____ Other (specify)

Position, Name (if known), Address (including City, State & Zip Code), Telephone Number & Email Address

1i. To whom should approval and other correspondence concerning this AFHM Plan be sent? Indicate Address
(including City, State & Zip Code), Telephone Number & Email Address in addition to Name.

2a. Affirmative Fair Housing Marketing Plan (check all that apply)
_____________ Initial Plan / Date: _________________

Updated Plan / Date: _________________

Reason(s) for current update:
2b. HUD-Approved Occupancy of the Project (check all that apply)
____ Elderly
2c. Date of Initial Occupancy

____ Family

____ Mixed (Elderly/Disabled)

____ Disabled

2d. Advertising Start Date
Advertising should begin at least 90 days prior to initial occupancy.
Prior to Initial Occupancy: __________
To add to waiting list _______ (which currently has ________ individuals)_________
To reopen closed waiting list______ (which currently has_______ individuals)_______

Previous editions are obsolete

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form HUD-935.2A (5/2010)

3a. Demographics of Project and Marketing Area
Complete and submit Worksheet 1.
3b. Targeted Marketing Activity
Based on your completed Worksheet 1, indicate which demographic group(s) in the housing market area is/are least likely to apply for the
housing without special outreach efforts.
____ White

____ American Indian or Alaska Native

____ Native Hawaiian or Other Pacific Islander
____ Families with Children

_____ Asian

____ Hispanic or Latino

____ Black or African American
____ Persons with Disabilities

____ Other ethnic group, religion, etc. (specify) ______________________________

___________________________________________________________________________________________________________________
4a. Residency Preference
Is the owner requesting a residency preference? ___ Yes

___ No

(If yes, continue. If no, proceed to Block 4b.)

(1) ___ New ___ Revised ___ Continuation of existing preference
(2) Is the residency preference area:
The same as the AFHM Plan housing/expanded housing market area (as determined in Block 1d)? ___ Yes

___ No

The same as the residency preference area of the local PHA in whose jurisdiction the project is located? ___ Yes

___ No

(3) What is the geographic area for the residency preference?

(4) What is the reason for having a residency preference?

(5) How do you plan to periodically evaluate your residency preference to ensure that it is in accordance with the non-discrimination
and equal opportunity requirements in 24 CFR 5.105(a)?

Complete and submit Worksheet 2 when requesting a residency preference (see also 24 CFR 5.655(c)(1) for residency
preference requirements for Section 8 Project-Based Assisted Housing Programs). The requirements in 24 CFR 5.655(c)(1)
will be used by HUD as guidelines for evaluating residency preference requirements in other assisted housing programs,
consistent with the applicable HUD program requirements. See also HUD Occupancy Handbook (4350.3) Chapter 4, Section
4.6 for additional guidance on preferences.

4b. Proposed Marketing Activities: Community Contacts
Complete and submit Worksheet 3 to describe your use of community
contacts to market the project to those least likely to apply.

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4c. Proposed Marketing Activities: Methods
of Advertising
Complete and submit Worksheet 4 to describe your
proposed methods of advertising that will be used to
market to those least likely to apply. Attach samples of
advertisements, radio and television scripts, internet
advertisements and websites, brochures, etc.

form HUD-935.2A (5/2010)

5a. Fair Housing Poster
The Fair Housing Poster must be prominently displayed in all offices in which sale or rental activity takes place (24 CFR 200.620(e)).
Check below all locations when the AFHM Plan will be displayed.
____ Rental Office

____ Real Estate Office

____ Model Unit

____ Other (specify)

__________________________________________________________________________________________________________________
5b. Affirmative Fair Housing Marketing Plan (AFHM Plan)
The AFHM Plan must be available for public inspection at the sales or rental office (24 CFR 200.625). Check below all locations
where the AFHM Plan will be made available.
(Check all that apply)
____ Rental Office

____ Real Estate Office

____ Model Unit

____ Other (specify) ______________________________

___________________________________________________________________________________________________________________
5c. Project Site Sign
All Project Site Signs should include the Equal Housing Opportunity logo, slogan, or statement (24 CFR 200.620(f)). Check below all
locations where the Project Site Sign will be displayed. (Check all that apply)
____ Rental Office

____ Real Estate Office

____ Model Unit

____ Entrance to Project

____ Other (specify)

_____________
The size of the Project Site Sign will be __________ x __________.
The Equal Housing Opportunity logo or slogan or statement will be __________ x __________.

6. Evaluation of Marketing Activities
Explain the evaluation process you will use to determine whether your marketing activities have been successful in attracting
the group(s) least likely to apply, how often you will make this determination, and how you will make decisions about future marketing
based on the evaluation process.

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form HUD-935.2A (5/2010)

7a. Marketing Staff
What staff positions are/will be responsible for affirmative marketing?

7b. Staff Training and Assessment: AFHM Plan
(1) Has staff been trained on the AFHM Plan?

____ Yes

____ No

(2) Is there ongoing training on the AFHM Plan and Fair Housing Act issues in general?

____ Yes

____ No

(3) If yes, who provides it?

(4) Do you periodically assess staff skills, including their understanding of the AFHM Plan and their responsibilities to
use it?
_____Yes ____ No
(5) If yes, how and how often?

7c. Tenant Selection Training/Staff
(1) Has staff been trained on tenant selection in accordance with the project’s occupancy policy, including any
residency preferences? ____ Yes ____ No

(2) What staff positions are/will be responsible for tenant selection?

7d. Staff Instruction/Training: Samples and Dates
Please provide samples of AFHM/Fair Housing training, if any, provided/to be provided, to whom it was/will be provided,
and dates of past and anticipated training.

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form HUD-935.2A (5/2010)

________________________________________________________________________________________________________
8. Additional Considerations Is there anything else you would like to tell us about your AFHM Plan in order to ensure
that your program is marketed to those least likely to apply for the units and/or to be housed in them? Please attach
additional sheets, as needed.

________________________________________________________________________________________________________
9. Review and Update
By signing this form, the applicant/respondent agrees to review its AFHM Plan at least once every 5 years throughout
the life of the mortgage and to update it as needed in order to ensure continued compliance with HUD’s Affirmative Fair
Housing Marketing Regulations (see 24 CFR Part 200, Subpart M). I hereby certify that all the information stated
herein, as well as any information provided in the accompaniment herewith, is true and accurate. Warning: HUD will
prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010,
1012; 31 U.S.C. 3729, 3802).
________________________________________________________________________________________________________
Signature of person submitting this Plan & Date of Submission (mm/dd/yyyy)
________________________________________________________________________________________________________
Name (type or print)

Title & Name of Company
For HUD-Office of Housing Use Only
Reviewing Official:
Signature & Date (mm/dd/yyyy)

For HUD-Office of Fair Housing and Equal
Opportunity Use Only (check one)
_____ Disapproved
_____ Approved
Signature & Date (mm/dd/yyyy)

Name (type or print)

Name (type or print)

Title

Title

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form HUD-935.2A (5/2010)

Public reporting burden for this collection of information is estimated to average six (6) hours per initial response, and four (4) hours
for updated plans, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data
needed, and completing and reviewing the collection of information. This agency may not collect this information, and you are not
required to complete this form, unless it displays a currently valid Office of Management and Budget (OMB) control number.
Purpose of Form: All applicants for participation in FHA subsidized and unsubsidized multifamily housing programs with five or
more units (see 24 CFR 200.615) must complete this Affirmative Fair Housing Marketing Plan (AFHMP) Form as specified in 24
CFR 200.625, and in accordance with the requirements in (24 CFR 200.620). The purpose of the AFHMP is to help applicants in
developing an AFHM program to achieve a condition in which individuals of similar income levels in the same housing market area
have a like range of housing choices available to them regardless of their race, color, national origin, religion, sex, disability, or
familial status. The AFHMP helps owners/agents (respondents) effectively market the availability of housing opportunities to
individuals of both minority and non-minority groups that are least likely to apply for occupancy in the housing project (See AFHMP,
Block 3b).
An AFHM program, as specified in this Plan, shall be in effect for each multifamily project throughout the life of the mortgage (24
CFR 200.620(a)). The AFHMP, once approved by HUD, must be available for public inspection at the sales or rental offices of the
respondent (24 CFR 200.625) and may not be revised without HUD approval. This form contains no questions of a confidential
nature.
Applicability: The form and worksheets must be completed and submitted by all FHA subsidized and unsubsidized multifamily
housing projects.
INSTRUCTIONS
Send completed form and worksheets to: your
local HUD Office. Attention: Director, Office of
Housing.
Part 1- Applicant/Respondent and Project
Identification.
Blocks 1a, 1b, 1c, 1g, 1h, and 1i are
self-explanatory.
Block 1d – Respondents may obtain the Census
tract number from a local planning office,
Community Development Block Grant
Consolidated Plan, or another official source such
as the U.S. Census Bureau (www.census.gov).
Block 1e – A housing market area is the area
from which a multifamily housing project
owner/agent may reasonably expect to draw a
substantial number of its tenants.
If a housing market area is not demographically
diverse in terms of race, color, national origin,
religion, sex, disability, or familial status, an
expanded housing market area may be used.
An expanded housing market area is a larger
geographic area that may provide additional
diversity. Respondents should indicate the
housing or expanded housing market area in
which the housing is/will be located, e.g., “City of
__________” for housing market area, or “City of
__________” and “County of __________” for
expanded housing market area.

Previous editions are obsolete

Block 1f - The applicant should complete this Block only if a Managing Agent
(the agent cannot be the applicant) is implementing the AFHMP.
Part 2-Type of AFHMP
Block 2a – Respondents should indicate the status of the AFHMP, e.g., initial
or updated, as well as the date of the AFHMP. Respondents should also
provide the reason(s) for the current update, if applicable, whether the up
date is based on the five-year review or mid-term revisions due to changes in
local demographics or other conditions.
Block 2b – Respondents should identify all groups HUD has approved for
occupancy in the subject project, in accordance with the contract, grant, etc.
Block 2c – Respondents should specify the date the project was/will be first
occupied.
Block 2d – Respondents should indicate when this revised advertising began
or will begin and whether the advertising will be used to add to and/or reopen
the waiting list. (NOTE: Advertising should begin at least 90 days prior to
initial occupancy). In the case of existing projects, respondents should also
specify how many individuals were or are on the waiting list at the time the
advertising began or will begin.

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form HUD-935.2A (5/2010)

Part 3-Demographics and Marketing Area.
“Least likely to apply” means that there is an identifiable
presence of a specific demographic group in the housing
market area, but members of that group are not likely to
apply for the housing without targeted outreach, including
marketing materials in other languages for limited English
proficient individuals, and alternative formats for persons
with disabilities. Reasons for not applying can include, but
are not limited to, insufficient information about housing
opportunities, language barriers, or transportation
impediments.
Block 3a – Using Worksheet 1, the respondent should
indicate the demographic composition of the project,
waiting list, census tract, and housing market area. The
respondent compares the demographics of its existing
project, waiting list (or any maintained list of interested
housing applicants), with the demographics of the census
tract and the larger housing market area to determine if
there needs to be affirmative marketing to those least
likely to apply. If the housing market area is not
demographically diverse in terms of race, color, national
origin, religion, sex, disability, or familial status, an
expanded housing market area should be designated to
enhance the diversity of individuals applying for housing
opportunities. The applicable housing market area or
expanded marketing area should be shown in Block 1e.
Wherever possible, demographic statistics should be
obtained from a local planning office, Community
Development Block Grant Consolidated Plan, or another
official source such as the U.S. Census Bureau
(www.census.gov).
Compare groups within rows/across columns on
Worksheet 1 to identify any under-represented group(s)
relative to the surrounding housing market area, i.e., those
group(s) “least likely to apply” for the housing without
targeted outreach and marketing. If there is a particular
group or subgroup with members of a protected class that
has an identifiable presence in the housing market area,
but is not included in Worksheet 1, please specify under
“Other.”
Block 3b – Using the information from the completed
Worksheet 1, respondents should identify the
demographic group(s) least likely to apply for the housing
without special outreach efforts.

Respondents should use Worksheet 2 to show how the
percentage of the eligible population living or working in
the residency preference area conforms to that of the
occupancy of the project, waiting list, and housing market
area. The latter percentages would be the same as those
shown on completed Worksheet 1.
Block 4b – Using Worksheet 3, respondents should
describe their use of community contacts to market the
project to those least likely to apply. This table should
include the name of a contact person, his/her address,
phone number, previous experience working with the
target population(s), the approximate date contact
was/will be initiated, and the specific role the community
contact will play in implementing the AFHMP.
Block 4c – Using Worksheet 4, respondents should
describe their proposed method(s) of advertising to
market to those least likely to apply. This table should
identify each media option, percentage of the
readers/listeners/users/ members/etc. who are members
of the targeted population(s), language(s) into which the
material(s) will be translated, alternative format(s) that will
be used to reach persons with disabilities, and logo(s) that
will appear on the various materials (as well as their size).
Part 5- Availability of the Fair Housing Poster,
AFHMP, and Project Site Sign.
Block 5a - The Fair Housing Poster must be prominently
displayed in all offices in which sale or rental activity takes
place (24 CFR 200.620(e)). Respondents should indicate
all locations where the Fair Housing Poster will be
displayed.
Block 5b – The AFHMP must be available for public
inspection at the sales or rental office (24 CFR 200.625).
Respondents should indicate all locations where the
AFHMP will be available.
Block 5c – The Project Site Sign should display the Equal
Housing Opportunity logo or slogan or statement (24 CFR
200.620(f)). Respondents should indicate where the
Project Site Sign will be displayed, as well as the size of
the Sign and the size of the logo, slogan or statement.

Part 4 - Marketing Program and Residency Preference
(if any).
Block 4a – A residency preference is a preference for
admission of persons who reside or work in a specified
geographic area (see 24 CFR 5.655(c)(1)(ii)).
Respondents should indicate whether a residency
preference is being requested, and if so, respondents
should specify if it is new, revised, or continuing. If a
respondent wishes to implement a residency preference,
it should state the preference area (and provide a map
delineating the precise area) and state the reason for
having such a preference. The respondent must ensure
that the preference is in accordance with the
non-discrimination and equal opportunity requirements in
24 CFR 5.105(a) (see 24 CFR 5.655(c)(1)).

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form HUD-935.2A (5/2010)

Part 6 -Evaluation of Marketing Activities.

Part 8-Additional Considerations.

Respondents should explain the evaluation process to be
used to determine if they have been successful in
attracting those groups identified as least likely to apply.
Respondents should also explain how they will make
decisions about future marketing activities based on the
evaluations.

Respondents should describe their efforts not previously
mentioned that were/are planned to attract those groups
least likely to apply for the subject housing without special
outreach efforts.

Part 7-Marketing Staff and Training.

By signing, the respondent assumes responsibility for
implementing the AFHMP, and for reviewing and updating
the Plan at least once every 5 years, and more frequently
if local conditions or project demographics significantly
change. HUD may monitor the implementation of this
AFHMP at any time, and may also request modification in
its format and/or content, when deemed necessary.
Respondents should notify their local HUD Office of
Housing if they plan revisions to the AFHMP marketing
strategy after HUD approval has occurred.

Block 7a - Respondents should identify staff positions that
are/will be responsible for affirmative marketing.
Block 7b - Respondents should indicate whether staff has
been trained on the use of the AFHMP and specify
whether there is ongoing training on the AFHMP and Fair
Housing Act issues in general. Show who provides the
training. In addition, respondents should specify whether
they periodically assess staff members’ skills in relation to
the AFHMP and staff responsibilities to use the Plan. They
should state how often they assess employee skills and
how they conduct the assessment.
Block 7c - Respondents should indicate whether staff has
been trained on tenant selection in accordance with the
project’s occupancy policy, including residency
preferences (if any). Respondents should also identify
those staff positions that are/will be responsible for tenant
selection.
Block 7d - Respondents should include copies of any
written materials related to staff training, and identify the
dates of past and anticipated training.

Part 9-Review and Update.

Notification of Intent to Begin Marketing for Initial
Occupancy. No later than 90 days prior to the initiation of
rental marketing activities, the respondent with an
approved AFHMP must submit notification of intent to
begin marketing. The notification is required by the
AFHMP Compliance Regulations (24 CFR 108.15). The
Notification is submitted to the Office of Housing in the
HUD Office servicing the locality in which the proposed
housing will be located. Upon receipt of the Notification of
Intent to Begin Marketing from the applicant, the
monitoring office will review any previously approved plan
and may schedule a pre-occupancy conference. Such
pre-occupancy will be held prior to initiation of sales/rental
marketing activities. At this conference, the previously
approved AFHM plan will be reviewed with the applicant to
determine if the plan, and/or its proposed implementation,
requires modification prior to initiation of marketing in
order to achieve the objectives of the AFHM regulation
and the plan.
OMB approval of the Affirmative Fair Housing Marketing
Plan includes approval of this notification procedure as
part of the AFHMP. The burden hours for such notification
are included in the total designated for this AFHMP form.

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form HUD-935.2A (5/2010)

Worksheet 1: Determining Demographic Groups Least Likely to Apply for Housing Opportunities
(See AFHM Plan, Block 3b)

In the respective columns below indicate the percentage of each demographic group for the project (if occupied), waiting list (for existing
projects), census tract, housing market area, and expanded housing market area (if the latter is needed to create a more diverse housing
market area in terms of race, color, national origin, religion, sex, disability, or familial status).
Wherever possible, statistics should be obtained from a local planning office, Community Development Block Grant Consolidated Plan, or
another official source such as the U.S. Census Bureau (please see http://factfinder.census.gov. Under Decennial Census, click “Get
Data”. Choose SF3, then detailed tables).
If there is a significant under-representation of any demographic group in the project and/or on its waiting list relative to the surrounding
housing market area, then those groups(s) that are under-represented will be considered “least likely to apply” without targeted outreach and
marketing, and will be so identified in Block 3b of the AFHM Plan. See Part 3 of the Form HUD-935.2A Instructions for further guidance.
Maps showing both the Housing Market Area and Expanded Housing Market Area should also be attached.
Project %
Demographic
Characteristics
White

American Indian
or Alaskan
Native
Asian

Black or African
American

Native Hawaiian
or Other Pacific
Islander
Hispanic or
Latino

Persons
with Disabilities

Families with
Children

Other

Waiting List %

Census Tract %

Housing Market Area %

Expanded Housing Market
Area% (if used)

Worksheet 2: Establishing a Residency Preference Area (See AFHM Plan, Block 4a)
Complete this Worksheet if you wish to continue, revise, or add a residency preference, which is a preference for admission of persons
who reside or work in a specified geographic area (see 24 CFR 5.655(c)(1)(ii)). If a residency preference is requested, the preference
must be in accordance with the non-discrimination and equal opportunity requirements contained in 24 CFR 5.105(a). This Worksheet
will help show how the percentage of the population in the residency preference area conforms to that of the occupancy of the project,
waiting list, and housing market area. See 24 CFR 5.655 (c)(1) for residency preference requirements for Section 8 Project-Based
Assistance Programs. Attach a map specifying the area for which the residency preference is requested.
Demographic
Characteristics

White

American Indian or
Alaskan Native
Asian

Black or African
American

Native Hawaiian or
Other Pacific
Islander
Hispanic or Latino

Persons with
Disabilities

Families with
Children

Other (specify)

Project %
(as determined
in
Worksheet 1)

Waiting List %
(as determined
in Worksheet
1)

Census Tract
%
(as determined
in Worksheet
1)

Housing Market
Area % (as
determined
in Worksheet 1)

Expanded
Housing Market
Area %
(if needed and as
determined in
Worksheet 1)

Residency
Preference Area
% (if applicable)

Worksheet 3: Proposed Marketing Activities – Community Contacts (See AFHM Plan, Block 4b)
For each targeted marketing population designated as least likely to apply in Block 3b, identify at least one community contact
organization you will use to facilitate outreach to the group. This could be a social service agency, religious body, advocacy group,
community center, etc. State the names of contact persons, their addresses and phone numbers, their previous experience working with
the target population, the approximate date contact was/will be initiated, and the specific role they will play in assisting with the affirmative
fair housing marketing program.

Targeted Population(s)

Community Contact(s), including required information

Worksheet 4: Proposed Marketing Activities – Methods of Advertising (See AFHM Plan, Block 4c)
Complete the following table by identifying your targeted marketing population(s), as indicated in Block 3b, as well as
the methods of advertising that will be used to market to that population. For each targeted population, state the means
of advertising that you will use, as applicable to that group. In each block, in addition to specifying the media that will be
used (e.g., name of newspaper, television station, website, location of bulletin board, etc.), state any language(s) in
which the material will be provided, identify any alternative format(s) to be used (e.g., Braille, large print, etc.), and
specify the logo(s) (as well as size) that will appear on the various materials. Attach additional pages, if necessary.

Targeted Population(s)→
Methods of Advertising ↓

Newspaper

Radio Stations

TV Stations

Electronic Media (e.g.,
internet advertisements,
websites, etc.)
Bulletin Boards

Brochures, Notices, Flyers

Other (specify)

Targeted Population:

Targeted Population:

Targeted Population: