I read it very thoroughly. It is my understanding, just as you said. However, if you deny someone based on their criminal background and they file a complaint of discrimination this is what the April 4th Guidelines states: "A housing provider must, however, be able to prove through reliable evidence that its policy or
practice of making housing decisions based on criminal history actually assists in protecting
resident safety and/or property. Bald assertions based on generalizations or stereotypes that any
individual with an arrest or conviction record poses a greater risk than any individual without
such a record are not sufficient to satisfy this burden."
In the past, we have looked at the criminal background first and denied applicants based on this. Now, if they pass credit and rental history, we will only look at the criminal background.
Also: "A housing provider with a more tailored policy or practice that excludes individuals with
only certain types of convictions must still prove that its policy is necessary to serve a
“substantial, legitimate, nondiscriminatory interest.” To do this, a housing provider must show
that its policy accurately distinguishes between criminal conduct that indicates a demonstrable
risk to resident safety and/or property and criminal conduct that does not."
This is the statement where we decided to not request photo ID with the application, but verify their identity after they have been approved, or at lease signing:
"By delaying consideration of
criminal history until after an individual’s financial and other qualifications are verified, a
housing provider may be able to minimize any additional costs that such individualized
assessment might add to the applicant screening process."