Emotional Support Animals After HUD's New Enforcement Memo

HUD’s latest guidance on emotional support animals has raised important questions for housing providers. But does it change the rules for approving or denying reasonable accommodation requests? And what should owners do differently - if anything?

HUD’s May 22, 2026, FHEO enforcement memorandum signals a significant shift in how HUD’s Office of Fair Housing and Equal Opportunity may approach Fair Housing Act complaints involving assistance animals. At the same time, the memo is not a regulation, does not amend the Fair Housing Act, and does not eliminate housing providers’ other compliance obligations.

For property owners and managers, the challenge is understanding what has changed, what remains uncertain, and how to make defensible decisions without overreacting to new enforcement guidance.

In this 90-minute practical training session, Gwen Volk will break down the new memo, explain which previous HUD assistance-animal guidance has been withdrawn, and examine what these developments may mean for everyday property management decisions.

We’ll explore the critical distinction between HUD/FHEO’s current enforcement approach and the obligations housing providers may continue to have under Section 504, the ADA where applicable, state and local laws, and private fair housing claims. We’ll also address unresolved questions involving pet fees, deposits, breed and size restrictions, and previously approved emotional support animals.

Most importantly, you’ll learn why treating the memo as a blanket authorization to deny ESA requests can create compliance concerns—and how to approach reasonable accommodation decisions thoughtfully while awaiting further clarification or formal rulemaking.

What You’ll Learn

During this session, we’ll take a closer look at:

• HUD’s May 22, 2026, ESA enforcement memo: What it says, what it signals, and what it does not establish.

• Withdrawal of prior HUD guidance: What the withdrawal of the 2013 and 2020 assistance-animal guidance means for housing providers.

• Enforcement guidance versus binding requirements: Why a memorandum is not the same as a regulation or formal rulemaking.

• Service animals versus emotional support animals: Understanding the distinction and why it matters when evaluating accommodation requests.

• Section 504 considerations: Why HUD-assisted properties must continue to evaluate applicable disability-related obligations.

• The unresolved compliance questions: What the memo leaves unclear about pet fees, pet deposits, breed and size restrictions, and existing ESA approvals.

• Avoiding blanket denials: Why relying solely on the memo to reject ESA requests may expose housing providers to continuing fair housing concerns.

• Practical steps for your property: How to review policies, update staff instructions, and strengthen reasonable accommodation procedures without making premature assumptions about the law.

Additional Benefits

Your registration includes:

• Live Q&A with Gwen Volk

• An interactive knowledge-check quiz

• Certificate of Participation

• Downloadable handouts for future reference

Who Should Attend

This session is designed for professionals responsible for housing operations, resident relations, and fair housing compliance, including:

• Property Managers

• Property Owners

• Maintenance Staff

• Leasing Consultants

Stay Informed. Make Better Decisions. Protect Your Compliance Process.

When HUD’s enforcement approach changes, the right response is not to make assumptions—it’s to understand the implications, recognize the remaining uncertainties, and ensure your team knows how to evaluate each request appropriately.

Join Gwen Volk for this timely 90-minute session and gain a clearer, more practical framework for navigating the evolving rules and expectations surrounding emotional support animal requests.

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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