What requirements apply to rental offices that are not covered by the Fair Housing Acts design and construction requirements?
If the buildings are not covered by the Fair Housing Act’s design and construction requirements (for example, because they were built for first occupancy before March 13, 1991), the Fair Housing Act’s general requirements of non-discriminatory treatment and reasonable accommodations apply. If a rental office is not accessible, a person with a disability must still be accommodated. In addition, rental offices that serve the public must comply with the access requirements of the ADA, Title III (that is, if they are constructed for first occupancy after January 26, 1993), they must be constructed to comply with ADAAG; if constructed before that date, architectural barriers must be removed if doing so is “readily achievable.” 36 U.S.C. 36.401. A housing provider is covered by Section 504 of the 1973 Rehabilitation Act if the provider is a recipient of federal financial assistance. Section 504 requires that “programs and activities” such as a rental office be accessible. When physical acces
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