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2010/11-2014-15 CITY OF SANTA ANA CONSOLIDATED PLAN 1 2013/14 <br />ACTION PLAN <br />characteristics." Of particular concern as an impediment to fair housing choice is the <br />occurrence of hate crimes at or adjacent to housing. <br />4. Unfair Lending: This impediment refers to underwriting, marketing or pricing that <br />discriminates because of race or ethnicity, gender, age, marital status, source of income, <br />or another protected characteristic of a potential or actual borrower. It also includes the <br />practice of 'redlining', where borrowers are treated adversely or denied on the basis of <br />where they live or the location of a property they wish to finance. An evaluation of <br />2008 Home Mortgage Disclosure Act (HMDA) data found there was disparity in loan <br />approval/denial rates among racial and ethnic minority borrowers, in particular, <br />Hispanic applicants had higher loan denial rates than White, Non-Hispanic borrowers. <br />5. Zoning Policies and Practices: Federal and state laws, related to funding or planning <br />requirements, oblige all local governments to affirmatively further fair housing (AFFH) <br />opportunities. One way to accomplish AFFH is to implement zoning policies and <br />practices that address the needs of persons with disabilities and other special needs <br />populations. This can include making reasonable accommodations in building, land use, <br />and housing requirements or policies when they are necessary to afford disabled <br />persons an equal opportunity to use and enjoy a dwelling. <br />6. City has identified the following impediments: <br />¦ Lack of supportive and transitional housing zoning regulations <br />¦ Lack of reasonable accommodation ordinance <br />¦ Lack of visitability and universal design regulations in the Municipal Code <br />Actions to Address Identified impediments: The following have been identified in the Al as <br />actions that may be taken to address identified impediments to fair housing in collaboration <br />with the FHCOC, lending institutions, real estate associations, and other service agencies: <br />¦ The City will contract with the FHCOC to receive, investigate and address housing <br />discrimination complaints filed by City residents. Compile an Annual Report on housing <br />discrimination complaints filed with the FHCOC, DFEH and HUD. The report will include <br />housing discrimination complaints unique to the City as well as those of the entire <br />County. The Annual Report will describe emerging trends within the City and County. <br />Through the funding of FHCOC fair housing services, enforcement activities will be <br />undertaken that provide investigation and response to allegations of illegal housing <br />discrimination. Complaints that cannot be conciliated are referred to the U.S. <br />Department of Housing and Urban Development (HUD), DFEH, or to a private attorney, <br />as appropriated and as directed by the complainant. <br />DRAFT 04/22/2013 29 <br />29A-34