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