How to Write an (Approvable) Affirmative Fair Housing Marketing Plan (AFHMP)

AFHMPs submitted but not approved? MOR findings for not having an approved plan on file? Confusion about which race and ethnicity data to use? And now, with the Administration’s proposal to eliminate the AFHMP requirement, owners and agents are asking: Do we still need an AFHMP—and what does compliance look like right now?

This session cuts through the noise.

Despite proposed changes, many properties are still being cited for AFHMP deficiencies, and the Fair Housing Act obligations underlying affirmative marketing remain in place. This practical, plain-English session focuses on what housing providers must do today to stay compliant and defensible during this period of uncertainty.

Drawing on experience preparing and reviewing 500+ AFHMPs nationwide for HUD, RD, and state agencies, Gwen Volk walks participants through how to complete an approvable AFHMP. Attendees will learn how to use Census Bureau tools; select and interpret the correct demographic data; develop effective outreach strategies and community contacts; and work with HUD, RD, PBCAs, or state agencies.

The session also covers 5-year AFHMP reviews,how to document compliance when agencies are not actively reviewing plans, and how to respond to AFHMP-related MOR findings.

After this session, participants will be able to:

• Explain the current legal and regulatory status of AFHMP requirements, including how they interact with the Fair Housing Act and existing HUD program obligations.
• Distinguish between the Administration’s proposal to eliminate AFHMP requirements and the requirements that remain in effect unless and until formally rescinded.
• Respond accurately to common compliance questions arising from the proposal, including whether an AFHMP is still required, when approval is necessary, and how PBCAs are treating the issue during MORs.
• Identify when and why properties are still cited for lacking an approved AFHMP despite proposed regulatory changes.
• Prepare an approvable AFHMP using current HUD, RD, and applicable state agency expectations, including correct demographic data and marketing strategies.
• Navigate Census Bureau tools to obtain, analyze, and document race and ethnicity data for the marketing area.
• Conduct and document a 5-year AFHMP review in a manner that supports compliance when agency review or approval is delayed or unavailable.
• Assemble a defensible AFHMP file that demonstrates good-faith compliance during periods of regulatory uncertainty.

Participants will leave with clear, practical guidance on separating proposed changes from enforceable requirements - and a roadmap for AFHMP compliance that works in the real world.

Speaker(s)

Gwen Volk

Gwen Volk has worked in the affordable housing industry since 1983. She has been president and CEO of a Midwest property management company and chief compliance officer over a Dallas firm’s national portfolio. She has a Master’s degree in Business and is a Certified Property Manager through the Institute of Real Estate Management. Gwen holds certifications as a National Affordable Housing Professional – Executive Level, Specialist in Housing Credit Management, Housing Credit Certified Professional, Certified Professional of Occupancy, and in Fair Housing Compliance and has been a servant leader in the AHMAs, NAHMA and IREM throughout her career. Gwen is a nationally recognized expert in the tax credit, bond, HOME, and Section 8 programs and enjoys helping agents, owners, and managers make sense of it all.

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