Illinois real estate exam study guide
Fair housing and ADA in property management: know which rule applies
A resident asks for a reserved parking space. Another needs grab bars. A visitor brings a service dog into the leasing office. These requests may involve the same property, but they do not all follow the same rule. Identify the housing, public space and funding before deciding what information to request or who pays.
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The short answer
Fair housing duties continue throughout advertising, screening, leasing, repairs, services and occupancy. The Fair Housing Act protects covered housing; ADA Title III can cover a leasing office open to the public. Public-entity programs may fall under ADA Title II, and recipients of federal financial assistance may have Section 504 duties. A policy exception is a reasonable accommodation; a physical change is a reasonable modification. Coverage, documentation, costs and animal rules depend on the applicable law. Illinois adds protections that a federal enforcement memo does not repeal.
Reviewed for October 2026. The PSI national broker outline includes fair housing and ADA compliance within Property Management. The broader category is three of the 100 scored national broker questions, not a separate three-question allocation for this page. These are original study exercises, not recalled PSI questions, a building-compliance certification or a validated readiness test. Property exemptions, local protections, program rules and individual circumstances can change the legal analysis.
Start with the place, program and request
- Identify the coverage. Ask whether the issue concerns covered housing, a public leasing office, a public-entity program or a federally assisted program. More than one law can apply. The word apartment does not automatically place every residential room under ADA Title III.
- Follow the resident through the whole tenancy. Apply lawful, consistent standards to advertising, availability, qualification, lease terms, maintenance, amenities, renewals and enforcement. A neutral-looking policy may still require a disability-related exception.
- Classify the requested change. A reserved-space exception changes a rule; installing grab bars changes the premises. Under the ordinary FHA modification rule, the resident generally pays. Section 504 can require the recipient to pay for necessary changes, subject to its standards and limitations.
- Ask for relevant information, not a medical file. When disability or disability-related need is not apparent or known, use the applicable limited-information process. Housing assistance-animal documentation and the ADA public-access two-question rule are different processes.
- Consider an effective response and record the reasons. Assess the particular request, alternatives, actual risks and applicable burden or fundamental-alteration standard. Do not substitute stereotypes, a blanket no-exceptions policy or a purchased certificate for the required analysis.
- Keep access, privacy and protection from retaliation in view. Address known discrimination and harassment within the manager's responsibility and power to correct it. Document legitimate decisions without penalizing a person for requesting an accommodation, reporting discrimination or helping someone exercise housing rights.
| Law or rule | Typical setting | Important distinction |
|---|---|---|
| Fair Housing Act | Covered housing, including terms, services and common areas | Reasonable accommodations, modifications and specified design requirements have different rules |
| Illinois Human Rights Act | Covered Illinois housing transactions and services | State protections extend beyond the federal seven protected classes |
| ADA Title III | A private leasing office open to the public | Public access and effective communication; ordinary residential units are not automatically public accommodations |
| ADA Title II | Services, programs or activities of a public entity | Identify the public entity and program, rather than assuming every private manager is covered |
| Section 504 | A recipient's federally assisted housing program or activity | Existing-program access is assessed as a whole; costs and alternatives differ from the ordinary FHA modification rule |
| Illinois Assistance Animal Integrity Act | Qualifying assistance-animal housing requests | Includes qualifying emotional-support animals; limited documentation and charge rules differ from ADA public access |
| HUD May 22, 2026 enforcement memo | FHEO animal-accommodation enforcement under the FHA | Trained-animal enforcement policy; it preserves private court actions and excludes ADA and Section 504 complaint processing |
The distinctions that matter
| Distinction | How it works | What to notice |
|---|---|---|
| Accommodation and modification | An accommodation adjusts a rule, policy, practice or service. A modification physically changes the premises. | Reserved-space policy exception: accommodation. Grab-bar installation: modification. Cost follows the applicable law, not just the name of the request. |
| Ordinary FHA modification costs and Section 504 costs | An FHA resident generally pays for a reasonable physical modification. A Section 504 recipient generally must bear necessary access costs unless the applicable limitations are established. | A tenant-based voucher alone does not make the owner a Section 504 recipient. Other assistance can change that conclusion; do not stop at the voucher label. |
| Housing assistance animals and ADA service animals | Illinois housing law can protect a qualifying animal providing disability-related emotional support. ADA public access generally concerns a dog trained to do disability-related work or tasks, with a separate trained-miniature-horse provision. | Mere comfort is not an ADA task. That does not automatically defeat an Illinois housing accommodation request. No universal animal certificate decides either question. |
| HUD enforcement policy and the law governing every claim | The May 2026 memo directs FHEO reasonable-cause findings and recommended charges toward trained-animal requests. It is not an amendment to Illinois law or a final new regulation resolving every private lawsuit. | The memo does not control how HUD processes ADA or Section 504 complaints. Its training approach does not limit FHA enforcement to dogs; its footnote permits other trained species. |
| Existing-office barrier removal and new construction | Title III requires removal of existing architectural barriers where readily achievable, meaning easily accomplishable without much difficulty or expense. New construction and alterations have separate standards. | An old building is not automatically exempt. Nor does this mean every existing office must immediately be rebuilt to every new-construction specification. |
| Harassment and an ordinary disagreement | Unwelcome conduct can be quid pro quo when housing or a service is conditioned on submitting to it. A hostile environment involves conduct sufficiently severe or pervasive under the circumstances. | Severe or pervasive is not severe and pervasive. Third-party corrective responsibility also depends on knowledge or constructive knowledge and the power to correct; every neighbor dispute is not automatically an owner violation. |
Work through the facts
The office and the apartment
A private manager operates a leasing office open to prospective tenants. A resident asks whether that makes every apartment an ADA Title III public accommodation.
- Identify the public-facing rental business separately from the residential premises.
- The office can have Title III access duties.
- The apartments can still have FHA, state-law and, where applicable, other program obligations.
Answer: Do not extend the office's Title III classification automatically to every ordinary dwelling, or conclude that residential access has no protection.
A parking policy exception
At covered housing, a resident with a disability needs a feasible reserved space near the entrance. Management ordinarily assigns no spaces.
- The request changes a parking rule rather than installing a new structure.
- Apply the reasonable-accommodation analysis to equal use and enjoyment.
- A general first-come policy is not a complete answer to the request.
Answer: Evaluate the needed exception and effective alternatives. Do not deny solely because every tenant currently follows the same parking rule.
Grab bars and the correct payer
A covered resident requests necessary bathroom grab bars. Compare ordinary FHA housing with a program subject to Section 504.
- The work is a physical modification.
- Ordinary FHA rules generally place the cost on the resident.
- A Section 504 recipient generally bears necessary access costs, subject to its applicable limitations and effective alternatives.
Answer: Identify the program before assigning the bill. A voucher alone does not establish that the owner receives the federal assistance that triggers Section 504.
A 2026 memo is not a repeal of Illinois law
An Illinois manager reads HUD's trained-animal enforcement memo and announces that all emotional-support housing requests must be rejected.
- The memo addresses the specified FHEO FHA enforcement decisions.
- It preserves private court actions and expressly excludes ADA and Section 504 complaint processing.
- Illinois assistance-animal law separately recognizes qualifying disability-related emotional support.
Answer: The blanket rejection does not follow. Evaluate the actual state-law housing request and other applicable protections rather than treating an agency enforcement policy as a repeal.
The wrong paperwork at a public office
A visitor enters a public leasing office with a dog whose disability-related task is not apparent. Staff demand a diagnosis and an official service-animal certificate.
- For ADA public access, staff may ask whether the animal is required because of a disability and what work or task it is trained to perform.
- They may not require a diagnosis, task demonstration or certification.
- When the work or task and need are readily apparent, the permitted inquiries are unnecessary.
Answer: Use the ADA public-access process. Do not replace it with the different documentation rules for an Illinois housing request.
A request for effective communication
A prospective tenant who is deaf needs effective communication during a complex lease discussion in the public leasing office. Staff insist the applicant bring a child to interpret.
- The appropriate aid depends on the nature, length, complexity and context of the communication.
- The business cannot require the person to bring an interpreter.
- Reliance on a minor is limited to an emergency involving an imminent threat when no interpreter is available; this routine discussion is not that exception.
Answer: Arrange effective communication under the applicable standard, consulting the individual where possible. A routine child-interpreter requirement is not an adequate policy.
Design requirements are not an elevator-only rule
A four-unit building was first occupied after March 13, 1991. The exercise supplies no applicable timing or site exception. It has no elevator.
- The FHA design-and-construction rule reaches covered multifamily buildings with four or more units.
- In a nonelevator building, covered ground-floor units are included.
- In an elevator building, the rule reaches all units, subject to the actual coverage requirements.
Answer: No elevator does not mean no FHA design requirements. These particular construction rules are not a blanket order to retrofit every older apartment.
A repair offered for an unwelcome favor
A manager conditions an ordinary repair on a tenant accepting unwelcome sexual conduct. The tenant agrees because the repair is urgent.
- A housing service is being conditioned on submission to unwelcome conduct.
- Acquiescence does not itself make the conduct welcome.
- The absence of a lost lease or a financial charge does not automatically defeat a harassment claim.
Answer: Recognize the quid pro quo problem. Do not turn an urgent resident's submission into permission for the manager's demand.
A harassment report and a nonrenewal threat
A tenant reports disability-based harassment by another resident. Management has corrective authority, knows the relevant facts and instead threatens to evict the reporting tenant for complaining.
- Third-party corrective duties require the relevant knowledge and power to correct, as stipulated here.
- Corrective action must not penalize the victim for the harassment.
- Threatening a person for exercising housing rights can raise a separate retaliation or interference issue.
Answer: Address the reported conduct within the manager's authority. An accommodation request or complaint is not a lawful reason by itself to punish the tenant.
Mistakes to avoid
- The same rule for everyone always satisfies fair housing. A disability-related reasonable accommodation may require an exception to an otherwise neutral policy.
- Every apartment is an ADA Title III public accommodation. Identify the public leasing office separately and apply the actual housing and program laws to the residential premises.
- The resident always pays for access. Ordinary FHA modification costs and Section 504 recipient obligations differ; policy accommodations are a separate question.
- All animal requests require certification or all require no documentation. Use the applicable housing or public-access rule. Neither a universal certificate requirement nor a universal no-information rule is correct.
- HUD's 2020 assistance-animal notice remains the current governing guidance. The 2013 and 2020 notices were withdrawn effective September 17, 2025. Read the May 2026 enforcement memo in its stated scope alongside applicable Illinois law.
- Hostile harassment must be severe and pervasive. The regulation uses severe or pervasive. Evaluate the circumstances and the separate responsibility of the person or provider involved.
- A complaint prevents every future lease-enforcement action. Do not retaliate. Legitimate, unrelated enforcement is not automatically forbidden, but the explanation must not disguise discrimination or punishment for protected activity.
Check your understanding
These are original teaching questions, not recalled or predicted PSI questions. Answer first, then explain why the other choices fail.
1. Which fact most directly identifies a potential ADA Title III issue at a private apartment property?
- A resident owns a television
- Every lease lasts one year
- The public is invited into its leasing office
- The building has three bedrooms
Show answer and explanation
Answer: C. The public is invited into its leasing office
A public-facing leasing office can be a public accommodation. That does not automatically make every residential unit one, or eliminate FHA and state housing duties.
2. A disability-related exception to an unassigned-parking policy is usually what type of request?
- A mortgage modification
- An amendment to zoning
- A request for a title transfer
- A reasonable accommodation
Show answer and explanation
Answer: D. A reasonable accommodation
The request changes a rule or service. Installing a physical feature would raise a modification question. Reasonableness and disability-related need still matter.
3. Who generally pays for a reasonable physical modification under the ordinary FHA rule, before considering Section 504 or other applicable law?
- Always HUD
- Only the real estate broker
- Always every other tenant
- The resident requesting it
Show answer and explanation
Answer: D. The resident requesting it
The ordinary FHA rule generally places physical-modification cost on the resident. Section 504 can place necessary access costs on a covered recipient, so coverage must be checked.
4. Does a tenant-based voucher alone establish that the owner is a Section 504 recipient?
- Yes, but only for parking
- Only if the tenant has a dog
- No; identify any other applicable federal assistance
- Yes, in every case
Show answer and explanation
Answer: C. No; identify any other applicable federal assistance
IDHR distinguishes tenant-based voucher participation alone from receipt of federal financial assistance that triggers recipient duties. Other program assistance may change the result.
5. For an ADA public-access dog whose task and need are not apparent, which inquiry is permitted?
- Require a demonstration of the task
- Demand a government certificate
- Ask whether it is required because of disability and what work or task it is trained to perform
- Demand the visitor's full medical history
Show answer and explanation
Answer: C. Ask whether it is required because of disability and what work or task it is trained to perform
The ADA permits those two limited inquiries when needed. It does not permit demanding a diagnosis, certification or task demonstration.
6. An animal provides comfort but has no trained disability-related task. Which statement is accurate?
- A purchased vest decides the issue
- It can never qualify for any housing protection
- Mere comfort does not satisfy the ADA task rule; Illinois housing law has a separate assistance-animal analysis
- It automatically qualifies as an ADA service dog
Show answer and explanation
Answer: C. Mere comfort does not satisfy the ADA task rule; Illinois housing law has a separate assistance-animal analysis
ADA public access and Illinois housing accommodation are different rules. A qualifying housing emotional-support animal is not automatically an ADA public-access service animal.
7. What does HUD's May 22, 2026 animal memo do?
- Repeal the Illinois Assistance Animal Integrity Act
- Eliminate all private housing lawsuits
- Make every federal housing animal rule identical to Title III
- Direct specified FHEO FHA enforcement decisions toward trained-animal requests, with stated exclusions and limits
Show answer and explanation
Answer: D. Direct specified FHEO FHA enforcement decisions toward trained-animal requests, with stated exclusions and limits
The memo concerns the agency enforcement process described in it. Private court actions remain, and ADA and Section 504 complaint processing are expressly excluded. It does not amend Illinois law.
8. A covered Illinois housing assistance-animal request qualifies under the applicable law. Which charge policy is improper?
- Using the ordinary process for actual animal-caused damage
- Charging a special pet deposit simply for the qualifying assistance animal
- Considering documented animal-specific facts
- Assessing the actual request
Show answer and explanation
Answer: B. Charging a special pet deposit simply for the qualifying assistance animal
Illinois law prohibits treating the qualifying assistance animal as a pet for pet fees, pet rent or a pet deposit, and prohibits special insurance requirements. Actual damage can be handled through the ordinary applicable process.
9. For a covered multifamily nonelevator building first occupied after March 13, 1991, with no applicable exception supplied, which units does the FHA design rule reach?
- No units because there is no elevator
- Only the top-floor unit
- Covered ground-floor units
- Only units occupied by wheelchair users
Show answer and explanation
Answer: C. Covered ground-floor units
The rule reaches ground-floor units in covered nonelevator buildings with four or more units. Elevator buildings have a different all-unit coverage rule. Actual timing and site qualifications matter.
10. What does readily achievable mean for existing Title III architectural barrier removal?
- No duty for any old building
- Immediate reconstruction of every apartment
- Whatever a manager prefers
- Easily accomplishable without much difficulty or expense
Show answer and explanation
Answer: D. Easily accomplishable without much difficulty or expense
The existing-barrier standard differs from new-construction and alteration standards. Age alone is not a blanket exemption, and the standard is not an automatic whole-building reconstruction order.
11. Which phrase correctly states the hostile-environment harassment threshold in the FHA regulation?
- Sufficiently severe or pervasive under the circumstances
- Severe and pervasive in every case
- Only physical injury
- Only a lost security deposit
Show answer and explanation
Answer: A. Sufficiently severe or pervasive under the circumstances
The regulation uses severe or pervasive. An economic loss or physical or psychological injury is not required for the unwelcome conduct to create the prohibited environment.
12. A manager knows of discriminatory third-party conduct and has power to correct it. What should the manager avoid?
- Recording relevant facts
- Addressing conduct within the manager's control
- Taking appropriate corrective action
- Penalizing the victim instead of correcting the harassment
Show answer and explanation
Answer: D. Penalizing the victim instead of correcting the harassment
The regulation identifies knowledge or constructive knowledge and corrective power for third-party responsibility. Corrective action cannot be used to penalize the victim. The actual legal relationships and facts still matter.
13. Must a routine leasing-office applicant who is deaf bring a child to interpret?
- Yes, because communication is never an ADA issue
- Yes, whenever staff are busy
- No; the business cannot require the applicant to bring an interpreter, and the minor exception is narrowly limited
- Yes, unless the child is under six
Show answer and explanation
Answer: C. No; the business cannot require the applicant to bring an interpreter, and the minor exception is narrowly limited
Effective communication depends on context. A minor may be relied on only in the specified emergency with an imminent threat and no available interpreter, not as the office's ordinary solution.
14. A tenant requests an accommodation. What follows about unrelated lease violations?
- Every later enforcement action is automatically prohibited
- Do not retaliate; legitimate unrelated enforcement requires its own lawful basis
- The manager may punish the request if another violation exists
- Every accommodation request is a lease breach
Show answer and explanation
Answer: B. Do not retaliate; legitimate unrelated enforcement requires its own lawful basis
Protected activity is not a reason to threaten or punish the tenant. It also does not automatically excuse every unrelated lease obligation. Disguised retaliation is not made lawful by its label.
15. Which statement about existing Section 504 program access is accurate?
- Every room must always receive the identical physical alteration
- The owner can require every applicant to waive access
- A budget objection automatically ends every duty
- The program must be accessible when viewed in its entirety, with applicable limitations and effective alternatives considered
Show answer and explanation
Answer: D. The program must be accessible when viewed in its entirety, with applicable limitations and effective alternatives considered
Section 8.24 addresses the existing program as a whole. An established fundamental alteration or undue financial and administrative burden does not erase the obligation to take other feasible actions that provide access.
16. If an ADA service animal is out of control and its handler does not take effective action, what may happen?
- Staff must exclude the person permanently
- Every housing accommodation automatically terminates
- The animal may be removed, but the person must still have the opportunity to obtain services without it
- The animal can never be removed
Show answer and explanation
Answer: C. The animal may be removed, but the person must still have the opportunity to obtain services without it
The ADA removal rule is specific. Proper animal exclusion does not justify denying the individual the opportunity to receive services without the animal, and it does not decide a separate housing request.
17. Which statement about Illinois housing protection is sound?
- Illinois adds protected grounds, so check state and applicable local law as well as federal law
- The landlord can waive every state protection in a lease
- A federal agency memo automatically repeals broader state protection
- Only the federal seven classes can ever matter
Show answer and explanation
Answer: A. Illinois adds protected grounds, so check state and applicable local law as well as federal law
Illinois protects additional grounds, including source of income and sexual orientation, including gender-related identity, under the applicable state-law provisions. Federal coverage is not the whole Illinois analysis.
18. A resident installed reasonable FHA bathroom grab bars. Which end-of-tenancy condition matches the regulation's example?
- Always remove the internal wall blocking as well
- Never require any interior restoration under any circumstances
- Reasonable removal of bars and wall repair may be required, but removal of the internal blocking is unreasonable
- Double the ordinary security deposit
Show answer and explanation
Answer: C. Reasonable removal of bars and wall repair may be required, but removal of the internal blocking is unreasonable
The modification regulation distinguishes reasonable interior restoration from unnecessary removal of useful concealed reinforcement. Wear and tear is excepted, and increased security deposits are prohibited; qualified restoration escrow conditions are a separate issue.
Common questions
Does fair housing end when the lease is signed?
No. Covered decisions about repairs, services, amenities, lease terms, renewals and enforcement can raise fair housing issues during occupancy. Lawful screening at move-in does not excuse discriminatory service later. Coverage, exceptions and the facts of the particular conduct still matter.
Do the ADA and Fair Housing Act apply to the same places?
They can overlap, but their coverage is different. A private public-facing leasing office can be covered by ADA Title III, while ordinary residential units are not automatically public accommodations. The FHA and Illinois housing protections can still apply to the dwellings and their services. Public-entity programs and federal assistance can add Title II or Section 504 obligations.
What is the difference between an accommodation and a modification?
An accommodation changes a rule, policy, practice or service, such as a necessary reserved-space exception. A modification physically changes the premises, such as installing grab bars. A request can involve both. Identify the change and the applicable law before deciding documentation, costs or restoration conditions.
Who pays for a disability-related physical change?
Under the ordinary FHA modification rule, the resident generally pays. Section 504 can require a covered recipient to pay for necessary access, subject to its applicable limitations and alternatives. A tenant-based voucher alone does not establish recipient status. Do not use that distinction to ignore other federal assistance, state or local obligations or a separate design violation.
Can management require medical records for every request?
No blanket medical-file requirement follows. When disability or the related need is not apparent or known, the applicable housing rule may permit limited supporting information. Illinois assistance-animal law specifies documentation requirements and alternatives and does not permit demanding a specific diagnosis. ADA public-access animal inquiries are a different, narrower process. Handle relevant information discreetly and do not collect unrelated medical detail.
Are emotional-support animals protected in Illinois housing in October 2026?
A qualifying disability-related assistance animal can include an emotional-support animal under Illinois law. That is not automatic approval for every pet or every purchased letter. Evaluate the statutory disability-related need, permissible information and animal-specific facts. Do not reject every request simply because the animal lacks ADA-style task training.
What changed in HUD animal guidance?
HUD withdrew its 2013 and 2020 notices effective September 17, 2025; the withdrawal notice was published April 6, 2026. Its May 22, 2026 memo directs specified FHEO FHA enforcement decisions toward trained-animal accommodation requests. It preserves private court actions and excludes how HUD processes ADA and Section 504 complaints. It does not amend Illinois law or establish a final new regulation deciding every housing claim.
Does the HUD memo limit FHA enforcement to trained dogs?
No. The memo adopts a training focus for the specified enforcement decisions, but its footnote permits other trained species. Do not import the entire ADA dog definition into every FHA or Illinois housing question. The program, claim and applicable law must still be identified.
Can an Illinois housing provider charge pet rent for a qualifying assistance animal?
The Illinois assistance-animal statute prohibits pet fees, pet rent and a pet deposit for a qualifying assistance animal and prohibits special insurance requirements for it. Actual animal-caused damage remains subject to the ordinary applicable process. A request can still require an individual assessment under the relevant documentation, denial and reasonable-accommodation rules.
What can a leasing office ask about an ADA service dog?
When the need and trained work are not readily apparent, ask whether the dog is required because of a disability and what work or task it is trained to perform. Do not demand a diagnosis, certificate or task demonstration. Training can be performed by the individual; a professional training certificate or vest is not required. The separate miniature-horse provision has its own trained-work and assessment conditions.
Can an old building ignore access barriers?
Age alone is not an exemption. Existing Title III architectural barriers must be removed where readily achievable, a standard based on accomplishing the work without much difficulty or expense. New construction and alterations have different requirements, and technical safe harbors and other qualifications can matter. This guide does not certify a site or prescribe ramp dimensions.
Which apartment buildings have FHA design-and-construction requirements?
The rule generally covers multifamily buildings with four or more units first occupied after March 13, 1991: all units in elevator buildings and ground-floor units in nonelevator buildings. The regulation has timing, site and other qualifications. Its seven features concern accessible entrances and common areas, usable doors, a route into and through the unit, accessible controls, bathroom-wall reinforcement, and usable kitchens and bathrooms. A local permit determination is not conclusive proof of federal compliance.
Is every disagreement between neighbors illegal harassment?
No. Identify the protected basis, unwelcome conduct and applicable quid pro quo or severe-or-pervasive standard. A provider's responsibility for third-party conduct also depends on the relevant knowledge and power to correct; agency liability has separate rules. Do not promise that every neighbor disagreement creates liability or that a manager is always protected simply by denying personal knowledge.
Can a landlord enforce the lease after a fair housing complaint?
A complaint does not automatically suspend every unrelated lease obligation. But a provider must not coerce, threaten, intimidate, interfere with or punish someone for exercising protected housing rights or helping another person exercise them. Evaluate the actual basis, timing and evidence. A neutral-sounding explanation is not a defense if it disguises retaliation.
Which protected classes should an Illinois candidate learn?
The federal FHA protects race, color, religion, national origin, sex, familial status and disability. Illinois housing law adds grounds, including source of income, sexual orientation including gender-related identity, immigration status and age 40 or older, among others. Use the current IDHR list and the applicable statutory provisions, exemptions and local law rather than assuming that the federal seven are an exhaustive Illinois list.
Must a resident undo every physical modification when leaving?
No. Under the FHA regulation, a provider may impose qualified reasonable interior restoration conditions, ordinary wear and tear excepted, and cannot simply increase the usual security deposit. Its grab-bar example permits reasonable bar removal and wall repair but not removal of the internal blocking. Its widened-door example generally does not justify narrowing the door again. A qualified restoration escrow has its own conditions; this is not a general permission for extra pet or disability deposits. Section 504 and other applicable obligations still require separate analysis.
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Official sources and scope
Read the law that applies to the place and program. HUD's May 2026 animal memo concerns specified federal enforcement decisions, preserves private court actions and excludes ADA and Section 504 complaint processing. It does not repeal Illinois assistance-animal protections. The withdrawn 2020 notice is not presented as current guidance. The design rules and practical examples here do not certify a building, resolve a particular request or replace a review of statutory exemptions and applicable local law.
- PSI Illinois Candidate Information Booklet dated June 24, 2026
- 310 ILCS 120/5, assistance animal, housing provider, and therapeutic relationship definitions
- 310 ILCS 120/10, documentation, denial, charges, and insurance rules
- 775 ILCS 5/3-102.1, Illinois disability accommodation requirements
- Illinois Department of Human Rights, current assistance-animal guidance
- HUD withdrawal notice, 91 FR 17291-17292, published April 6, 2026; withdrawal effective September 17, 2025
- 42 USC 3604: covered housing discrimination, accommodations, modifications and design
- 42 USC 3617: coercion, intimidation, threats and interference
- FHA reasonable accommodations
- FHA modifications and restoration limits
- FHA design and construction
- 24 CFR100.7: direct and vicarious liability
- 24 CFR100.600: quid pro quo and hostile-environment harassment
- HUD FHEO animal-accommodation enforcement memorandum, May22,2026
- DOJ: ADA service animals
- ADA policy changes and service-animal rules
- ADA effective communication and auxiliary aids
- ADA existing architectural barrier removal
- DOJ Germantown Falls leasing-office ADA settlement
- ADA Title II statutory program protection
- 24 CFR8.24: existing housing program accessibility
- IDHR: accommodation and modification costs
- IDHR current housing rights and protected grounds
This is exam preparation, not advice for a specific transaction. State law and the applicable facts control. Our editorial and corrections process explains how to report an issue.