How does the Assessment of Fair Housing (AFH) compare to the Analysis of Impediments (AI)?

Date Published: September 2016

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Perhaps most notably, the AFH is a standardized form that program participants will use to conduct their analysis and submit to HUD for review and acceptance or nonacceptance. Program participants will also be provided with data and tools to inform the analysis. Guided by the Assessment Tool, program participants will analyze the fair housing issues specific to their jurisdiction and region, and set priorities and goals that will be used to establish strategies and actions in subsequent planning processes.

While the full regulatory requirements for the new AFH process are primarily located at 24 CFR Part 5, a few key requirements include:

  • While the AI consisted of program participants providing certification that they will conduct an AI that was subject to monitoring by HUD, under the AFFH Rule, program participants will have to submit an AFH to HUD no less than every 5 years.
  • HUD will provide an Assessment Tool template, accompanied by data and mapping tools, to complete the AFH.
  • The AFH will be deemed accepted after 60 calendar days after the date that HUD receives the AFH, unless on or before that date HUD provides the program participant with notification that HUD does not accept the AFH.
  • Having an accepted AFH is a precondition to Consolidated Plan or Public Housing Agency (PHA) Plan approval.
  • The AFH is subject to the same community participation requirements applicable to the Consolidated Plan or PHA Plan, though updated to incorporate requirements related to the AFH, and that community participation process must occur during the development of the program participant’s AFH.
  • Consolidated Plans, Annual Action Plans, and PHA Plans must include strategies and actions to affirmatively further fair housing consistent with the goals and priorities in the AFH.

Tags: AFFH Assessment of Fair Housing - General