I am writing in support of the guidance as drafted. 

I am a lifelong Richmond resident. I worked at HOME of Virginia for several years before source of funds was added as a protected class to the Virginia Fair Housing Law (VFHL). As Brenda Hicks wrote, HOME's mobility program was started in an attempt to increase housing access to voucher holders. Their housing counselors often had to do (and I'm sure still have to do) the hard work of breaking down unfair and discriminatory stereotypes about voucher holders. I frequently heard stories about clients who had found the perfect housing for their family, only to be told they needed to make 3x the rent to be able to live there, despite their voucher covering nearly all of the rent. 

Though I applaud Virginia for adding source of funds to its fair housing law, I believe that without the technical assistance provided by this guidance tenants and housing providers alike are left playing a guessing game about the possible application of the law.  The law is clear about very overt forms of discrimination, such as an ad that states 'no vouchers' or a landlord that tells an applicant they won't take vouchers, but is not explicit - to tenants OR landlords - about some other policies and practices that may be discriminatory. The questions answered by the guidance have been asked by a wide range of stakeholders in the last year. Essentially, without the guidance, landlords and tenants alike play a guessing game to obligations and rights, respectively. The lack of specificity in the law benefits landlords, not voucher holders, perpetuating an unfair and unjust power dynamic that continues to limit opportunities for lower income individuals in Virginia. Landlords can change their policies to keep voucher holders out, and there are few ways for prospective renters to understand what's happening 'behind the scenes.' 

Requiring that voucher holders make 3x the rent even if their voucher covers part or all of the rent effectively bars nearly all voucher holders and is discriminatory, and I applaud the guidance for providing clarification on this matter. 

I also applaud DPOR for addressing the 15 day exemption written into the law. Applying their own interpretation to when the 15 day period tolls and/or letting documents sit on their desks to run out the clock is another way that landlords could abuse their power and claim they 'tried' to voucher holders, while ultimately still discriminating against them. The guidance clarifies that landlords must engage in the process in good faith and that tenants do not toll the the clock when they are actively working with the housing authority to accurately complete an application. 

In working to hold landlords accountable for upholding fair housing, the number one question fair housing advocates hear from landlords is: "why couldn't you just tell me I was doing something wrong? I would've stopped." Guidance documents greatly increase transparency about how to follow the law, and can prevent years of litigation to establish the same standards. Landlords, this is your chance to uphold fair housing. What's wrong is clearly laid out. Listen up.