Fair Housing Advertising Checklist for Apartment and Multifamily Marketing Teams (Free Template)

What the checklist covers, and when to run it

The federal rule is short. 42 U.S.C. 3604(c) makes it unlawful to publish any notice, statement or advertisement for the rental of a dwelling "that indicates any preference, limitation, or discrimination" based on race, color, religion, sex, handicap, familial status or national origin. HUD's regulation, 24 CFR 100.75, says that reaches "all written or oral notices or statements", including flyers, brochures, signs, banners and applications. That is why this checklist is organized by channel, not by word list: the leasing phone script is as much in scope as the Zillow description. The rules behind each check are explained in the fair housing advertising guide for apartments.

The template has five check groups (copy, imagery, channel setup, logo and statement, sign-off and evidence) and one row per property, per channel. Run it on these triggers:

Before you start: one jurisdiction row per property

The seven federal classes are the floor, not the list you review against. States and cities add classes, and the commonest addition that shows up in apartment copy is source of income. Seattle's guidance for housing providers lists "Does not accept housing vouchers" and "No Section Eight" as violating language, and "Section 8 welcome" as acceptable (Seattle Office for Civil Rights). The same sentence on a property in another state needs that state's rule checked, which is the reason for a jurisdiction column.

For each property, record the address, state, city or county, and the protected classes in force there, from the protected classes by state table and the source of income laws by state table. Reviewers check copy against that row, not against memory.

Fixing the template is not the end. Brynson's analysis of 6,000 properties and 1.6M units found about 89% of communities described themselves differently across listing sites (apartment listing accuracy report), so a phrase removed from the website can keep running on an ILS that was never updated. Check every channel the template reached.

The 12 checks, with what fails each one

Each check has an ID that goes in the template's Check column. C1 to C5 are copy, C6 and C7 imagery, C8 and C9 channel setup, C10 to C12 scripts, briefs and the logo.

1. 01

   C1. Describe the unit, not the resident

   Flag any words about who should live there: "young professionals", "empty nesters", "perfect for singles", "mature community". Rewrite to features: "two bedrooms, home office nook, quiet floors". Seattle lists "Suits a single professional" as a violation (seattle.gov).

2. 02

   C2. Location and amenity wording

   Describe distances and places by what they are ("0.4 miles to the light rail"), not by who uses them. Flag neighborhood descriptions that characterise residents, and amenity copy that names a religion, nationality or age group as the audience. Full phrase lists are in fair housing words to avoid.

3. 03

   C3. Policies stated as rules about people

   Occupancy, guest and pet policies belong in the unit's terms, not in headlines like "no kids" or "adults only". Unless the property operates under the 55+ exemption (see 55+ apartment advertising), any reference to children is a familial status flag.

4. 04

   C4. Source of income

   Check the property's jurisdiction row before reviewing. "No vouchers", "No Section 8" and "employment income only" are flagged wherever source of income is protected; Seattle names "Does not accept housing vouchers" as a violation (seattle.gov).

5. 05

   C5. Disability and accessibility language

   Describe features ("step-free entry", "elevator to all floors", "roll-in shower in units 104 and 204"). Seattle lists "Accessible for people with disabilities" as acceptable. Flag statements about who can or cannot live there, such as "must be able to climb stairs", which can read as a limitation based on handicap under 24 CFR 100.75(c)(1).

6. 06

   C6. People in photos and video

   The rule names "photographs, illustrations, symbols" (100.75(c)(1)). Review the gallery as a set: if every person across the property's images appears to be of one race, age group or family type, flag it for a person to review and refresh. For projects in FHA programs, 24 CFR 200.620 requires that advertising depicting persons show majority and minority groups, including both sexes.

7. 07

   C7. AI-generated and virtually staged images

   Record whether each lifestyle image is a real photo, staged, or generated, and check the disclosure rules at the property's address in virtual staging disclosure laws. Generated people are reviewed under C6 like any model; AI copy is reviewed under C1 to C5 (see AI listing copy and fair housing).

8. 08

   C8. Paid channel setup

   For every live housing campaign: Meta special ad category set to housing, location radius of at least 15 miles, no ZIP codes and no lookalike audiences (Meta documentation); Google campaigns with no targeting by gender, age, parental status, marital status or ZIP code (Google Ads policy).

9. 09

   C9. Media mix

   24 CFR 100.75(c)(3) covers "selecting media or locations for advertising" that deny information to protected groups. Record which channels each property runs on and flag a property whose only paid channel is a narrow audience or publication, or whose ILS presence was cut without a reason on file.

10. 10

    C10. Instructions to agencies, ILS coordinators and staff

    Briefs, ad requests and internal messages count: 100.75(c)(2) covers preferences expressed to agents, brokers and employees. Add the agency brief and any ILS coordinator notes to the review, not only the published ad.

11. 11

    C11. Phone, tour and follow-up scripts

    Oral statements are in scope under 100.75(b). Review the leasing phone script, the tour talk track and email and text follow-up templates once a quarter, and whenever a new script is issued. Flag any line that describes the current resident mix.

12. 12

    C12. Logo or statement present and consistent

    Recommended on every channel; required in all advertising for projects in FHA programs under 24 CFR 200.620. Mark the row "required" or "recommended" from the property record so the reviewer does not have to decide.

The template: columns and how to fill them

Each row is one property, one channel, one check. These are the columns, with what a completed row looks like.

How to run the checklist for one property

Run these steps in order. For a portfolio, do step 1 once for every property, then batch steps 2 to 8 by template.

1. 1

   Fill the jurisdiction row

   Record the property's address, state and city, and the protected classes in force there from the state table. Mark whether it is a project in an FHA program covered by 24 CFR 200.620, which makes the logo check required.

2. 2

   Inventory every live asset

   List each ILS listing, website page, Google and Meta campaign, social account, email and text template, print piece and script that names the property. Any channel you cannot open is marked not reviewed.

3. 3

   Run the copy checks

   Apply checks C1 to C5 to every text asset and record the exact words for each flag.

4. 4

   Run the imagery checks

   Apply C6 and C7 to the full gallery on each channel, as a set, and record which images are photos, staged or generated.

5. 5

   Confirm paid channel setup

   Apply C8 and C9 to every live campaign and save a dated screenshot of the targeting settings.

6. 6

   Check scripts, briefs and the logo

   Apply C10 to C12 to agency briefs, leasing scripts and every channel's footer or profile.

7. 7

   Record, fix and sign off

   The compliance reviewer marks pass or flag, approves the rewrite and signs the row with name and date. Capture the asset before and after the change.

8. 8

   Re-check on the live channel

   Confirm the fix on every channel the template reached, including ILSs, and record the re-check date. Set the next review from the trigger table.

Channel by channel: what to check and where it fails

Platform settings for paid channels are covered in depth in Meta and Google housing ad rules for apartments. The checklist only records that each campaign was set up correctly and who confirmed it.

The Equal Housing Opportunity logo and statement

For most market-rate apartment advertising, the logo is a recommended practice, not a federal requirement in the advertising rule. 24 CFR 100.75 prohibits discriminatory content but does not require a logo, and HUD removed its advertising guidelines (former 24 CFR Part 109) from the CFR in 1996 as nonbinding guidance (61 FR, April 1, 1996). Seattle's guidance recommends using "the Equal Housing Opportunity logo or slogan" (seattle.gov).

Two federal rules do require something:

• Projects in FHA programs. HUD's affirmative fair housing marketing rules (24 CFR Part 200, Subpart M) apply to FHA subsidized and unsubsidized multifamily projects of five or more units (200.615). For those, 24 CFR 200.620 requires that all advertising include "the Department-approved Equal Housing Opportunity logo or slogan or statement", that advertising depicting persons show majority and minority groups and both sexes, and that a sign with the logo, slogan or statement be posted on the project site. Mark the logo check as required on those rows.
• The fair housing poster. 24 CFR 110.10 requires covered persons to post and maintain a fair housing poster at any place of business where the dwelling is offered for rental and at the dwelling itself. That is a leasing office and property check, not an ad check, but it belongs on the same sweep.

Template rule: use the logo or the words "Equal Housing Opportunity" consistently across the website footer, ILS profile where the field exists, print and signage, so its absence on one channel is never the question.

Sign-off and evidence: what to keep

Every flag needs the exact words or image, the change, dated captures before and after, and a named reviewer. Retention periods, capture formats and legal hold are covered in apartment compliance evidence retention; link the evidence column there, not to a folder of screenshots.

Assign three roles: a preparer (marketing or the agency) who fills in the rows, a reviewer (compliance) who decides pass or flag, and an escalation contact (counsel) for anything that turns on a state or city rule the reviewer is unsure of. Agencies and ILS coordinators fill rows; they do not sign them off, so no one approves their own copy. Their briefs are reviewed too, because 100.75(c)(2) reaches preferences expressed to agents and employees as well as to renters (check C10).

Frequently asked questions