Planning, Building & Development | Page 152

APPENDIX A. PROPOSED TIERED RECIPIENTS COMPLIANCE APPROACH FOR TO: Jodi Gingiss, Community Development Administrator Lake County Community Development Division FROM: Alicia Serrano, Vice President Applied Real Estate Analysis, Inc. SUBJECT: FUNDING PROPOSED TIERED-COMPLIANCE APPROACH FOR LAKE COUNTY FUNDING RECIPIENTS Applied Real Estate Analysis (AREA), Inc., has developed an initial framework for a tiered approach to fair housing compliance for CDBG, HOME, and ESG funding recipients. The goal of the tiered approach is to provide a framework to assist funding recipients to continue or expand existing activities related to affirmatively furthering fair housing. These recommendations are based in part on national fair housing best practices as well as the “Minimum Standards for a Fair Housing Action Plan” prepared by Chicago Area Fair Housing Alliance (CAFHA). While funding recipients may have a higher burden of proof, a key issue must be considered when implementing a tiered approach: Lake County must invest the resources for monitoring and compliance reviews. Ideally, the annual plans and progress reports would be input into a database and the fair housing liaison would then be able to review the information in a more effective manner. The proposed approach includes four tiers: Excelling (Tier I), Emerging (Tier II), Challenged (Tier III), and Non-Compliant (Tier IV). The initial proposed criteria for each of the tiers are presented in the following sections. Although a municipality may not possess all the criteria within a given tier, these criteria are intended to serve as a guide for assessing compliance with the HUD requirement to affirmatively further fair housing. The final implemented criteria should be developed in coordination with the funding recipients. PUBLIC COMMENT DRAFT 150 APPLIED REAL ESTATE ANALYSIS, INC. LAKE COUNTY, ILLINOIS