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ACTION PLAN <br />ACTION 1 2010/11- 2014/15 CITY OF SANTA ANA CONSOLIDATED PLAN <br />A <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. The City has identified the <br />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 AI 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 />FHCOC will take the lead in addressing identified private sector impediments to fair housing. <br />The actions are: <br />■ The City will contract with the FHCOC to receive, Investigate and address housing <br />discrimination complaints filed by current or potential Santa Ana residents. For the <br />2014 -2015 Program Year, FHCOC projects and proposes to receive 10 allegations of <br />housing discrimination in Santa Ana that are sufficiently meritorious to warrant opening <br />a case file. Perhaps another 20 allegations will be addressed through counseling and <br />possible referral to the U.S. Department of Housing and Urban Development (HUD) or <br />the California Department of Fair Employment and Housing (DFEH). <br />Through the funding of FHCOC fair housing services, enforcement activities will be <br />undertaken that provide investigation and response to apparently meritorious <br />26 04/25/2014 <br />