Piedmont Housing Alliance (PHA) submits this comment in support of the Virginia Fair Housing Office’s proposed guidance regarding housing discrimination based on source of funds.  PHA is a developer, owner, and manager of over 600 rental apartments in the City of Charlottesville and Albemarle and Nelson Counties.  As a matter of policy and practice, PHA accepts housing choice vouchers not only as a valid source of income, but also as one of the most reliable sources of income.  Though nearly all of our residents have been impacted in some way during the pandemic, those residents with HCVs, or other guaranteed income sources, have been among the most stable.

PHA supports the Virginia Fair Housing Office’s guidance in providing clarity on the recent inclusion of Source of Funds as a protected category in Virginia’s Fair Housing Law for three primary reasons:

• The interpretation in the Fair Housing Office guidance is in-line with other jurisdictional interpretations.  
• This interpretation preserves the mission intent of the law.  Any other interpretation essentially opens the door to loopholes to avoid technical compliance.  The guidance ensures that landlords cannot impose income-to-rent ratio restrictions based on the contract rent rather than the tenant’s portion of that rent.  Were landlords allowed to deny voucher holders’ rental applications based on their incomes, voucher holders would be categorically excluded – thereby circumventing the entire purpose of the law.  Additionally, the guidance appropriately clarifies that general administrative burdens are not a valid basis for a landlord to deny a voucher holder’s rental application.  As a landlord, we can attest that claiming administrative burden is patently disingenuous. 
• Given the omnipresent legacy of racial and economic segregation in the Commonwealth, the new Source of Funds non-discrimination law must be enforced to the fullest extent possible to overcome the inertia of generations of discrimination.  

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