Prohibited fair housing conduct, advertising, and ADA access

Neighborhood steering

An agent shows a family with children only suburban homes, despite their request for downtown listings that meet price and bedroom criteria.

1. The clients stated objective property criteria.
2. The agent substitutes an assumption based on familial status.
3. Available matching listings are withheld by location.

Answer: The pattern is steering based on familial status.

Panic-selling solicitation

An investor’s representative, seeking profit from resulting transactions, tells longtime owners to sell quickly because families of a different national origin are moving nearby and values will collapse.

1. The communication invokes protected-class entry.
2. It uses fear about value to induce sales.
3. The speaker expects profit from resulting transactions.

Answer: This is blockbusting.

Digital audience exclusion

For a covered, nonexempt Illinois apartment, an otherwise neutral ad excludes everyone over age 35 and profiles identifying households with children under 18. No lawful housing-program exception or other basis changes these facts.

1. The message and the audience settings need separate review.
2. Excluding households with children under 18 implicates familial status.
3. The over-35 cutoff also excludes people 40 and over, a protected Illinois housing age group.
4. Age is not thereby added to the federal FHA’s seven listed classes. An actual platform or program needs its own analysis.

Answer: The targeting creates discriminatory-advertising risk despite neutral wording.

Inaccessible leasing office

A leasing office open to the public has a step at its only entrance and refuses to consider a portable ramp or alternative accessible meeting method.

1. The office is a public-facing place of business.
2. Physical access and service alternatives require Title III analysis.
3. The provider cannot dismiss the request without evaluating readily achievable removal and reasonable modification.

Answer: The office must assess and provide the access required by ADA Title III rather than relying on the residential character of the property.

The listing that is still available

A covered apartment remains available. After learning an applicant’s religion, the manager says it has been rented, while continuing to offer it to other applicants.

1. Availability is actually unchanged.
2. The different information is supplied because of religion.
3. The rule also reaches protected false availability representations made to testers.

Answer: This is discriminatory false availability on the stated facts; not an ordinary inventory update.

A responsive school-data answer

A buyer asks about district boundaries and published school results. The agent provides accurate, relevant sources and their dates to clients equally, answers nonracial questions truthfully and does not omit matching homes because of a protected trait.

1. Objective information responds to the client’s criteria.
2. HUD’s April 24, 2026 letter rejects a categorical ban on this equal, consistent nonracial discussion.
3. Do not convert a rating into a guarantee of school placement, future results or neighborhood safety.
4. The letter is not an exemption from Illinois law or every other discrimination claim.

Answer: Do not label the stated information-sharing itself unlawful steering.

A repair offered only for a sexual favor

For covered housing, a manager makes a requested repair conditional on an unwelcome sexual favor. The tenant reluctantly complies to obtain the repair.

1. The demand is unwelcome and made a condition of a housing service.
2. Acquiescence does not automatically make the demand welcome.
3. The quid pro quo rule can apply without a series of prior incidents.

Answer: The stated conduct implicates quid pro quo harassment.

Required communication without a surcharge

At a covered brokerage office, a deaf client needs an effective communication aid for a lengthy, complex explanation. Assume an appropriate auxiliary aid is required and no applicable exception excuses it. The business proposes a special disability fee.

1. Communication must be effective for its actual nature, length and complexity.
2. A short written exchange that works for a simple greeting may be inadequate here.
3. The business cannot impose a surcharge on this client for the required access measure.

Answer: Provide the required effective aid without the proposed disability surcharge; no particular aid is approved by this exercise.

An alternative is not an escape from achievable removal

For an existing covered leasing office, assume a safe entrance correction is readily achievable. The operator offers only a phone call and says no entrance evaluation is necessary.

1. The existing architectural barrier has its own removal duty.
2. An alternative under Section 36.305 follows a demonstrated inability to achieve removal and must itself be readily achievable.
3. An offered phone call does not erase stipulated achievable barrier removal.

Answer: The operator must address the required barrier removal; an alternative is not a blanket substitute.

Landlord and business tenant

A covered brokerage rents office space. Its lease assigns entrance work to the building owner. The brokerage tells a visitor that the lease means it has no ADA obligations at all.

1. The regulation addresses both the building landlord and the operating tenant.
2. The lease can allocate responsibility as between those parties.
3. That private allocation does not erase the visitor’s public access rights.

Answer: Do not use the lease as a blanket defense to required access; the actual duties and cost allocation need their own review.

Design coverage is not every disability duty

Assume a covered four-unit building first occupied in 1996 has no elevator. A student says the FHA design provision therefore covers only the ground-floor units, so the owner can ignore every disability-related request involving other units.

1. The stated design-and-construction coverage applies to ground-floor units in this non-elevator building, along with applicable public and common-use areas.
2. An elevator building would place all units within the stated unit coverage.
3. The design provision is distinct from reasonable accommodation, modification and other applicable duties.
4. Do not infer that an upper-floor unit or an older building is outside every disability law.

Answer: The stated ground-floor design distinction does not eliminate all other disability-related obligations.

A uniform rule can still need revision

Assume an Illinois housing criterion has the prohibited discriminatory effect under Section 3-102(H), and a less discriminatory practice can serve the stated substantial, legitimate, nondiscriminatory interest. The provider relies only on applying the same rule to every applicant.

1. Uniform application does not answer the statutory effects test.
2. The stipulated facts supply the prohibited effect and less-discriminatory alternative.
3. The provision does not require treating every neutral criterion as unlawful; its actual conditions matter.
4. No private policy, data set or applicant is evaluated here.

Answer: On the stipulated facts, consistency alone does not make the criterion lawful.

1. An agent selects neighborhoods for a buyer based on the buyer's religion. What is this?

1. Blockbusting
2. Redlining
3. Discriminatory false availability
4. Steering

2. For profit, a broker pressures owners to sell by predicting value loss when a protected group moves in. What is this?

1. Steering of a housing seeker
2. Redlining of credit access
3. Blockbusting
4. Discriminatory false availability

3. Which ad is most appropriate?

1. No children
2. Two-bedroom unit with step-free entrance
3. Perfect for young couples
4. Christian home only

4. Which law most directly governs public access to a brokerage office?

1. ADA Title III
2. Section 504 solely because every private office receives federal aid
3. The FHA’s covered multifamily design provision alone
4. ADA Title II solely because every private brokerage is a public entity

5. A provider punishes a tenant for filing a fair housing complaint. What conduct is implicated?

1. Lender redlining based on neighborhood composition
2. Blockbusting through demographic-change representations
3. Retaliation
4. Ordinary consistent enforcement for a stipulated independent lawful reason

6. A manager falsely tells an applicant a covered unit has been rented because of the applicant’s religion, while it remains available. Which conduct is most directly shown?

1. A completed blockbusting sale
2. A permitted property feature description
3. Discriminatory false availability
4. Ordinary market-price analysis

7. Must a blockbusting attempt produce an actual profit to fall within the federal rule?

1. Yes, the owner must complete a sale
2. Yes, only a paid commission proves it
3. No, if profit was a factor in the prohibited inducement
4. No, because the rule has no profit element at all

8. Which statement correctly describes housing ad review?

1. An equal housing logo overrides discriminatory text
2. A platform’s housing category guarantees legal delivery
3. Neutral wording cures every audience restriction
4. Review the message and distribution for unlawful protected preference or exclusion

9. For an ordinary covered Illinois rental, an over-35 audience cutoff excludes people 40 and over. Which age distinction is correct?

1. Every adult age is a separate federal FHA class
2. The credit-law age rule automatically replaces every housing rule
3. Only people exactly 35 are protected by Illinois housing law
4. Age 40 and over is protected in Illinois housing; age is not one of the FHA’s seven listed classes

10. An agent truthfully shares relevant nonracial school and crime information equally and consistently, without protected-class direction. What does HUD’s April 24, 2026 letter say about a categorical ban?

1. It guarantees every neighborhood is safe
2. There is no categorical FHA ban merely because those topics are discussed
3. Every such discussion is illegal steering
4. It repeals every Illinois discriminatory-effects rule

11. For existing covered public accommodations, which standard directly governs architectural barrier removal?

1. Any requested alteration regardless of resources
2. Readily achievable, based on the applicable difficulty, expense and resources
3. Undue burden as the identical test for all ADA duties
4. An automatic exemption for every pre-1991 building

12. An existing covered office demonstrates barrier removal is not readily achievable. What follows under Section 36.305?

1. Use alternative methods when they are readily achievable
2. All alternatives must be provided regardless of feasibility
3. Any offered alternative always satisfies every duty
4. Every service can be denied automatically

13. Assume an auxiliary aid is required at a covered office and no applicable exception excuses it. May the business add a special disability surcharge for that aid?

1. Yes, every aid must be paid by the disabled client
2. Only if the client previously complained
3. Yes, if the lease assigns the cost to the business
4. No, the required access measure cannot be charged to the client as that surcharge

14. Which describes hostile-environment housing harassment under the stated regulation?

1. Any disagreement regardless of protected basis or severity
2. Only repeated physical contact
3. Unwelcome protected conduct sufficiently severe OR pervasive, judged in context
4. Only conduct causing physical injury

15. A manager makes a repair conditional on an unwelcome sexual favor. Does the tenant’s reluctant acquiescence automatically defeat quid pro quo harassment?

1. Yes, repairs are outside housing services
2. No, an unwelcome demand can remain quid pro quo despite acquiescence
3. No, because every repair request establishes harassment
4. Yes, every acquiescence is consent for this rule

16. Does a private office lease assigning entrance work to the landlord erase the operating brokerage’s public ADA obligations?

1. Yes, if the business has few employees
2. No; the parties’ private allocation does not erase the visitor’s access rights
3. Yes, every cost clause binds the visitor
4. Yes, tenants can never be public accommodations

17. Under the usual FHA terminology, what is adding grab bars to a covered dwelling as a reasonable disability-related physical change?

1. Only an ADA public-office policy change
2. Automatic proof the entire building violates every design standard
3. A federal housing age exemption
4. A physical reasonable modification, distinct from a policy accommodation

18. Assume a covered four-unit apartment building was first occupied in 1996 and has no elevator. Which units fall within the stated FHA multifamily design-and-construction coverage?

1. Ground-floor units, with applicable public and common-use requirements
2. No units because it is not new in 2026
3. All units solely because any building has four units
4. Only the top floor because it is hardest to reach

19. A uniform Illinois housing criterion is stipulated to have a prohibited discriminatory effect, and the legitimate goal can be served by a less discriminatory practice. Does applying the rule to everyone automatically satisfy Section 3-102(H)?

1. Yes, identical wording is a complete defense
2. No, because every uniform criterion is unlawful
3. Yes, only intentional statements can ever matter under Illinois law
4. No; the stated less-discriminatory-alternative condition matters

20. For third-party housing conduct under the stated direct-liability rule, which combination matters?

1. The provider knew or should have known AND had power to correct the discriminatory conduct
2. Every neighbor disagreement automatically creates owner liability
3. A signed lease alone regardless of control, knowledge or conduct
4. The provider’s subjective dislike of the complainant, without any other facts