POLICIES
In compliance with the Fair Chance in Housing Act, N.J.S.A. 46:8-52 to -64 (FCHA), Glassboro A3 Victoria Urban Renewal, Glassboro A4 Main Urban Renewal, Glassboro 220 Urban Renewal, LLC(“Landlord”) will not inquire into applicants’ criminal histories on initial application materials, or otherwise consider applicants’ criminal records in any way, until after a conditional housing offer has been made, except for convictions of drug-related criminal activity for the manufacture or production of methamphetamine on the premises of federally assisted housing, or if the applicant is subject to a lifetime registration on a state sex offender registry.
If Landlord does review an applicant’s criminal history after a conditional offer, specific restrictions apply. Landlord must conduct an individualized analysis of an applicant’s criminal record and may only deny housing if withdrawing a conditional offer is necessary to fulfill a substantial, legitimate, and nondiscriminatory interest.
Landlord will not consider certain types of criminal histories at all, including arrests or charges that did not result in a criminal conviction, expunged convictions, convictions erased through executive pardon, vacated and otherwise legally nullified convictions, juvenile adjudications of delinquency, and sealed records.
If Landlord chooses to consider an applicant’s criminal history after a conditional offer, it will only consider:
Convictions for murder, aggravated sexual assault, kidnapping, arson, human trafficking, sexual assault, endangering the welfare of a child in violation of N.J.S.2C:24-4(b)(3);
Convictions for any crime that requires lifetime state sex offender registration;
Any 1st degree indictable offense, or release from prison for that offense, within the past 6 years;
Any 2nd or 3rd degree indictable offense, or release from prison for that offense, within the past 4 years; or
Any 4th degree indictable offense, or release from prison for that offense, within the past 1 year; or
Convictions of drug-related criminal activity for the manufacture or production of methamphetamine on the premises of federally assisted housing or if the applicant is subject to a lifetime registration on a state sex offender registry (if not previously known to Landlord prior to the conditional offer).
If Landlord finds one of the aforementioned records in the applicant’s criminal history, Landlord will conduct an individualized assessment based on the following factors to determine whether withdrawal of a conditional offer would fulfill a substantial, legitimate, and nondiscriminatory interest:
Nature and severity of the offense(s)
Applicant’s age at the time of the offense(s);
How recently the offense(s) occurred;
Any information the applicant provided in their favor since the offense(s);
If the offense(s) happened again in the future, whether that would impact the safety of other tenants or property; and
Whether the offense(s) happened on, or was connected to, property that the applicant had rented or leased.
Notwithstanding the above, if the Landlord is made aware of a drug-related criminal activity for the manufacture or production of methamphetamine on the premises of federally assisted housing it need not make such an individualized assessment because under the FCHA, the Landlord is entitled to disapprove of an application for these reasons.
If Landlord intends to consider criminal history as provided for under the FCHA after a conditional offer, they will not accept application fees before disclosing that fact to the applicant, and offering the applicant an opportunity to provide evidence of potential inaccuracies in their criminal record, other evidence of rehabilitation, or mitigating factors. This requirement can be fulfilled using the Model Disclosure Statement on DCR’s website, found at https://www.njoag.gov/wp-content/uploads/2021/12/Model-Disclosure-Statement_12.14.21.pdf.
If Landlord withdraws a conditional offer based on an applicant’s criminal record, it must explain in writing their justification for doing so, which can be fulfilled using the Model Notice of Withdrawal on DCR’s website, found at https://www.njoag.gov/wp-content/uploads/2021/12/Model-Notice-of-Withdrawal_12.15.21.pdf. An applicant can then request the information the housing provider relied upon, and can submit mitigating information or inaccuracies related to aspects of their criminal record which may be considered under the FCHA, which the housing provider must then consider.
The Landlord will not discriminate against those with criminal records in any advertising, notices, or publications.
The Landlord will not require applicants to submit to drug or alcohol testing, or to provide information from a treatment facility.
If the Landlord utilizes any vendor or outside person or entity to conduct a criminal record check on their behalf, the Landlord shall take reasonable steps to ensure that the vendor or outside person or entity is conducting the criminal record check consistent with the requirements of the FCHA. The Landlord will be liable under the FCHA for relying on a criminal history inquiry conducted by a vendor or outside person or entity that is conducted in violation of the FCHA if it failed to take reasonable steps to ensure compliance. Specifically, if the Landlord receives a criminal history inquiry conducted by a vendor or outside person or entity that is conducted in violation of the Act in that it reveals a record that is not permitted to be considered under the Act, the Landlord must show that it did not rely on that information in making a determination about the applicant’s tenancy.
Any agent, employee, or designee of the Landlord who fails to comply with this policy will be subject to appropriate disciplinary action. Please report any violation of this policy to Lisa Cicchitti at (609) 656-4421.
You cannot and will not be subjected to retaliation for making a complaint under this policy or for attempting to exercise your rights under this policy, the LAD, or the FCHA.
Any action taken by Landlord in violation of the requirements laid out in this policy may constitute a violation of the LAD and/or the FCHA. Any tenant or applicant who believes that the Landlord has violated any of the above may contact the New Jersey Division on Civil Rights at www.NJCivilRights.gov or (866) 405-3050. A complaint must be filed with the New Jersey Division on Civil Rights within 180 days of the allegedly discriminatory conduct. DCR has a number of fair housing fact sheets that are available at https://www.nj.gov/oag/dcr/housing.html.
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