Name: Pets Are the New Kids: Navigating Pet-Friendly Housing, Fair Housing Compliance, and Assistance Animals in Texas
Uploaded: 2026-10-27T16:16:14.557Z
Duration: 1 h 12 s
Description: Pets Are the New Kids: Navigating Pet-Friendly Housing, Fair Housing Compliance, and Assistance Animals in Texas

Transcript for "Pets Are the New Kids: Navigating Pet-Friendly Housing, Fair Housing Compliance, and Assistance Animals in Texas": So I guess they're coming in now. Welcome in, guys. Yes. Yeah. Welcome, everybody. We're gonna give another minute or two for folks to join. Ronnie, good to be with you here this morning. Hey. Thank you, John. Welcome in, guys. Yeah. We're gonna give it just a minute or two. Let everyone get connected, and we'll get started. Very good. Let's see. Hello, Patricia and Sonia and Trinity and Romero and Susan and Holly. Thanks for saying hello and and, Jana. Hope I say that right. And Martha, thanks for being with us this morning. See. Natalie, welcome. Christina. I have a sister, Christina, so that's easy. Christy, Debbie, Phyllis, Jen, Welcome in, guys. Karen? Yeah. Thanks, everybody. Alright. Looks like we've got multiple here. I've got a few more coming in here. I'll give it just another minute or so. that? Let you guys get connected. Yeah. Another minute or just. Yeah. another coming in. here. Yeah. Oh, she's... That's fine. Jeanette's got her dog, Izzy. Hello, Izzy. I'm glad you guys could join us today. Jeanette, at my office, we have a... We have about 50 dogs every day at our office. So it's, I walk up and down our aisles, and I really am there to pet the dogs, not not talk to the employees. Welcome in, guys. I think we got just about everybody here. Got a big crowd here. Yeah. Not too bad. Thank you guys for joining us. Hey, John. I think we can go ahead and get started. I'll make my announcement here. John, you can hear me. okay? Let... Let's. jump. in. Well, I just want to welcome in everybody. Thank you guys for joining us today for, pets are the new kids. I just wanted to thank the, we're... I'm with Texas Realtors, Ronnie. I'm. a little hiccup there, wanted, to thank our member think you try. it again. Oh, sorry. Welcome, everybody. It's Ronnie Kovar with Texas Realtors. I just wanted to thank our member benefits department as well as our leasing and property management committee, for partnering with Pet Screening and having John Bradford and his team come in today, to teach us about Pets Are The New Kids and his Pet Screening products. So thank you, John, for, coming in and presenting this with us today. No. You bet, Ronnie. Thank thank you for having me. And, Ronnie, appreciate you. And I'll move you off stage here, but thanks for the intro here. And, hello, everybody. This... It's John Bradford. I am coming to you from North Carolina. I used to live in Texas. I lived in Texas, right out of college. I worked for Exxon Mobil Corporation as an environmental engineer. So I was recruited out of college and came to the great state of Texas. I really enjoyed my time there. I lived in Houston, and the right... I guess, West U or Rice University area, and I used to commute to 800 Bell Street every day for work. I think that building's being converted into, maybe even housing now, I think. But it's been a long time. So great to be with all of you. You know, look, we're gonna talk about pets. I know we have... If I could pull all of you and say, how many pets do you have? I guarantee many of you would say, not only do you have a pet, but you have you have more than one pet. You have multiple pets. And, I'm here with Pet Screening, of course, and we've got pets all in the office. And today, we're gonna talk about how pets are the new kids. It really is amazing, the statistics about pets. They're wonderful. But, of course, pets, you know, you need to manage them. There's some, interesting fair housing compliance changes coming out of Washington, DC with the fair housing office, with our good friends at HUD. So we're gonna unpack some of that. In terms of question and answers, this platform has a q and a, like, little section. So if you have questions along the way, if you'll just put them there, then I'll save some time at the end and do my best to get to as many as possible. So, let me see if I can advance this slide. So, you know, well, let me tell you a little about myself before we talk about the agenda. So I am a professional property manager. I I don't do... I still have all my designations, but I used to run my own management company for about thirteen years, manage thousands of properties. I did single family residential, so I didn't necessarily do multifamily. And I I think today we have a blend of people that do multifamily. We have a blend of people that do single family, you know, residential houses, and then we have realtors that probably just help do a placement, resident placement, for the folks that hire them. But I am a professional property manager. I also, you know, for about, let's see, four elected terms, I served in the North Carolina House of Representatives. And that's only... I only share that with you. I know I'm not in the state of Texas, but North Carolina and Texas, we have a lot of similarities. We both typically align with federal law. So whatever the federal law is, our two states typically just adopt those policies. And so that's gonna be important as we start talking about the assistance animal side. But for the four elected terms that I serve were two year terms here in North Carolina. I was four elected terms. I carried all my state's tenant landlord law. So if any of you happen to be with a company that also does business multi jurisdictionally and if you have any assets in North Carolina, then the tenant landlord laws in which you operate under, I largely carried every one of those, and there really haven't been much changes. I left about two years ago, so I've been out of office for, this December will be two years. So there really hasn't been any drastic changes to the laws I put in place. But I share that with you because I am a property manager, so I I do what you... All of you do. So I understand, how tough this job can be and how complex it can be. But I also... Being a former legislator, I think, I'm not a lawyer, but I I I played one for a decade. So I really think about how to protect ourselves and how to protect the owners that hire us and then trust them to run their business. So that's a little bit about me, North Carolina. I'm a fast talking Southerner. I I I do talk fast, so I apologize. I will do my best to, go on medium speed today. But today, what are we gonna talk about? We're gonna talk about pets. We're gonna talk about the legal landscape around service animals and emotional support animals. And there's some, obviously, some changes, that are coming. We're gonna talk about, you know, compliance, some red flags and best practices, how do you handle a reasonable accommodation request, some of the HUD guidance and more recent news, and then we'll get to some q and a's, at at the end. We we have an hour. I don't know if we'll go an hour. I most certainly will try not to just, instruct for one hour, but I wanna really get to questions at the end. That's always, I think, the the best part. So let's talk about the difference between pet friendly or pet passionate. You know, I I I said if I could see all of you, if if I was in person with all of you in a big classroom, and I said, how many of you in here own pets? A large number of you would raise your hands. In fact, So I'm gonna say that again. There are more pets, American households, than kids under the age of 18. It just shows how prevalent pets are. 71% of American households, about 94,000,000 homes, approaching a 100,000,000 homes, have a pet. And what's interesting is not just one pet, it's 1.6 pets per home. So, like, I'm a two pet household with two dogs. We as well. We had a rescue cat. He passed away about six months ago. So at one point, we're a three pet household, but most affluent per household. 59% of renters in The US have a pet. And it's because renters have less pets. It's because renters are not always disclosing all of their pets. So the difference... It should be 1.6 pets. We see about 1.2 pets actually reported in the world of rental housing. And then, of course, you know, 57% of rentals advertise being pet friendly, which I I think is a low statistic. I don't think it captures all the data. I don't find very many landlords that are not pet friendly any longer. Every now and then we come across a few, maybe in the New England area where it's, where it's really cold and so outdoor dogs aren't as common. And then where, you know, I think they call concrete jungles where there's so much concrete that there's not a lot of green space. Therefore, there's just not a lot of room for dogs to go to the bathroom. So what happens is they'll limit the size, they'll limit the quantity, they'll limit the breed, and therefore, there are more renters... Rental properties usually in New England that limit pets or don't allow pets because of the the geography situation. And then of course, pets are a big business, dollars 157,000,000,000, that's with a B, a year is spent on, you know, pets. I mean, anytime I go to a store, my wife goes to Target or Walmart or whatever, somehow we end up leaving with something for our dog. So, big business for sure. So that's kind of the point of the slide here. You know, you you know, we... We're at Pet Screening. We're full of puns here, so here's our positive PAW policy recommendations. You know, you know, forever, there's been breed restrictions, weight restrictions. What I do wanna say is I don't tell people how to run their business. It's your your management company. It's your property. Run it as you see fit. I will say there's less and less insurance companies that are having breed, requirements or breed limitations in the sense that if if you have an insurance policy that doesn't allow certain breeds, you might wanna shop around because there are insurance companies that have general liability policies that allow all kinds of breeds. But I will say there is no, real statistical proof that bigger dogs do more damage. Nuisance to the maintenance folks than the big dogs because they they're the ones that are always, you know, trying to lunge at them or biting their ankles. You know, so I would just say, look at your breed and weight restrictions. I mean, look, bigger dogs, I would say, sometimes they're the laziest of dogs. Of course, their their piles of poo are bigger. There's no ignoring that. But if you have responsible pet owners, they should pick up that poo and it shouldn't be a problem. You know, there's ways to, I think, evaluate pets to make sure, you know, things like, is that pet microchipped? If a pet is microchipped, it probably tells you it's a loving owner that actually wants to get their dog back or their cat back if it gets lost. And so little things like that can be great indicators for responsible pet owner. You know, exotic pets, I will say exotic pets are becoming more popular. Exotic would be things not dog or cat. Turtles are very popular. Now turtles live a long time. It's why a lot of turtles end up in zoos because people get turtles, but they live a hundred years and they hit people eventually give them away. You know, quantity of pets, you know, you know, how do you... If there's a difference between five giant dogs and maybe three medium sized dogs. So I think, you know, looking at quantity and size combined and determining what's best for the assets that you manage. Vaccination state, so making sure that, you know, and vaccinations, specifically rabies here. Making sure that every, that responsible pet owners understand that while that dog is living here or while that cat is living here, it must have its rabies How do you handle visiting cats? I mean, visiting pets are a big problem. Not... I mean, they're a wonderful thing, but what happens is, you know, you'll you'll lease to one person and then their girlfriend or boyfriend or partner comes over every weekend and brings their dog. And now that visiting dog, you have no record of it and that dog may not be vaccinated or that dog may cause damage or that dog may bite a neighbor. So how do you really manage visiting pets? Your SOPs standard operating procedures to cover any behavioral complaints, nuisance barking, maybe people that don't keep their dog on a leash at all times. You know, fines can be a great way to help people's moral compass. You know, when they see there's a big fine for not picking up their poop, then they would likely have a good chance of picking up their poop, especially if you make it known that they're on camera in common areas, you know, Hey, pick up your poop. We're watching you with cameras. Moral compass where people are more prone to do what they need to do and be more responsible. But having fines for either unauthorized pets or fines for people that don't pick up their poo if you, in fact, have proof of that. And there are companies out there that do the DNA testing, as well, and so they're popular for that exact reason. So, yeah, those are some things you can evaluate that's best for your business, and I just wanted to kinda unpack some of those. You know, why all this really matters? Well, I mean, there are real world consequences here. You know, there's, you know, there's, you know, there's there's household pets out here. And and when you think of all the household pets that are there, of the 70% that should be there, about 90% are gonna be ordinary pets. I know the slide says 91%, but I'll round up here, around down. 90% should be a typical dog or cat. And then about 10% should be a legitimate assistance animal. And I use the word legitimate to point out the difference between someone that says they have an assistance animal versus someone that doesn't. So if you just kind of were, you know... I think of that show, it was like American Idol where they would gather all the a big room and they would divide them up and they say, okay, if you're in this side of the room, you're moving ahead to Hollywood. If you're on the left side of the room, sorry, you're going home. If we were to take all of the furry critters in your communities or in the assets you manage and put them in one big room, side of the room and we'd say, Hey, guess what? You're all pets and you're paying pet fees and pet rent. And 10% of them would be, you know, assistance animals, legitimate assistance animals. That should be the breakdown. If you think you're unbalanced there and and and a lot of people are because a lot of folks sadly are bad actors and they say their dogs are type of assistance animal when really they're not and they don't meet the law, then you might see a ratio of eightytwenty or 70 fivetwenty five. And that's part of what that's part of the issue that pet screening helps solve. We've seen a lot of increase in reasonable accommodations. COVID, look, COVID was a a very interesting time for the whole world. I mean, I mean, could you imagine putting a mask back on? And I know some people still mask up, and that's their prerogative. But the point is there was a time when we all had to wear masks, and our kids wore masks. And some kids, that's all they... They were born into this world wearing a mask, and and they didn't know any different. But what we saw was a lot of people, you know, started having mental health issues. And so we've seen a real huge increase in the number of folks that have mental health issues and go to health care professionals and get diagnosed. Screening a decade ago because I saw a lot of people taking advantage of calling their pet a type of assistance animal. They were buying a vest off Amazon, slapping on their dog and calling it emotional support animal or calling it a service animal when it had no training. Pet screening, we've reviewed... This number is actually a little bit outdated. We've reviewed close to 3,000,000 reasonable accommodations for people seeking an assistance animal of some kind. And the one number that's been consistent for the ten years that I've been doing this professionally as a company is about four out of 10 actually meet the standard. So if you think about it, you know, think about 3,000,000 reviews that we've done. If it's four out of 10, 40%, that means 1,200,000 met, you know, met the standard and 2,800,000 did not. I mean, it's a huge... That's a... Or 1,800,000 did not. It's a huge disparity in the number of animals that are legitimate versus not legitimate. And so really making sure you know how to do this properly under the framework of the law is incredibly important, and that's really what, you know, Pet Screening has been doing for a decade. And we'll talk a little bit about that. So that's just some statistics here. You know, look, fair housing is changing. You know, I I launched Pet Screen in 2017. I started in the state legislature in 2015, and I was running a management company back in 2013. And so here's the then and now. We're in 2026. We're approaching 2027. From 2013 to 2000... From 2013 to basically 2000 and I would say, '19, there really wasn't a lot of changes. There was a guidance document out that was called the ESA white paper, the memo we call it from 2013. It was sort of the gospel. And when I launched Pet Screen in 2017, I remember I had to kind of follow that document because it was the only real relevant document out there that but it had a lot to be desired. There was a lot of areas where HUD was silent on. They didn't really say yes or no. What kind of animals were allowed or or what how old could a letter be from a healthcare provider, you know. So they just didn't take a firm position on a lot of areas. And so when I I started pet screening, we came to the stain... Saying, and we started making some, what I'd call, reasonable standards. We said all health care documents have to be at least a year or newer because in the world of health care, you go to a physical once a year, you go to a dentist twice a year. Annual standards that are very acceptable in the world of healthcare. So we started using a one year standard. So, pet screening started to really apply some, reasonable standards when there really were no there really no guiding principles other than just be reasonable. Term of legal art called the test of reasonableness. And so we really kind of helped build that. And then in 2020, HUD did make a change. They they made a document called the HUD notice twenty twenty-one, that stands for January. And they came in and made some very, I would say, some clarifying changes. They they they said no more reptiles. We used to have a lot of snakes. Down to only one. I don't... If I could pull all of you, I would say what kind of reptile was it? And, we don't have the time to to, like, play games here. I'd love to see what your answers would be. But if you could think what reptile made the cut in 2020. I'll give you the punchline. It was a turtle in 2020. I'll give you the punchline. It was a turtle. So a turtle was the only type of reptile that HUD actually recognized as a type of possible assistance animal. And that was in 2020. So from 2020 to really 2025, that was the document that was used. But in 2025, with the new administration under Trump, they actually rescinded most document, most documents and guidance they rescinded. Now even though the 2020 documents, guidance has been rescinded, HUD has advised pet screening directly to just continue to operate under that 2020 guidance despite the fact that it's been rescinded, because now they're going to go through a rulemaking process which will be starting. And if not, it may have already internally started. So So we're gonna see some changes coming. But in 2024, there was a lawsuit called the Loper Bright versus Raimondo. There, well, we're talking to a bunch of Texas folks here, so you know petroleum. And I told you I worked at ExxonMobil. There was an old doctrine called Chevron Petroleum Company. It was a lawsuit that happened years ago. Chevron, I think, is actually California based, if I recall. But nonetheless, petroleum, a lot of petroleum in Texas. So the Chevron doctrine was a doctrine that was that was basically in play for a long time. And what it said is that agencies, government agencies could use deference and meaning they they determined almost the rules and then the rules that they determine the courts were using that as sort of the gospel. So if an agency said it should be done one way even though the law may have been unclear or maybe the law you know, was, didn't say it at all, then the agency's guidance was interpreted as law by the courts, and that was called deference. But in '20, '24, under a new a new Supreme Court, it was rescinded. So the Chevron doctrine got overturned. And and this is kinda going deep, and I don't wanna go too deep here. But when that got thrown out, it basically said that agencies, their guidance is no longer to be used by the courts to... As as the gospel. In other words, what the the the rescission of the Chevron doctrine now says is laws can only be made by one body, and it's United States Congress and the United States Senate. And they make the laws, and the courts interpret the laws, but agencies don't get to play, you know, the law... They don't get to play lawmaker here. And so now there's a lot of reliance on a doctrine that was started in '23. So we're talking about, a 75 year old doctrine. It's called the Skidmore doctrine. And the Skidmore doctrine talks about agencies' persuasion. And so now what you're gonna see is the courts are gonna look to agencies. And in this world where we live in, we're talking about HUD. HUD is the agency of relevance to what we do, as an industry. There's a lot of agencies, department of transportation, you know, there's there's tons of departments. But in our world, it's really HUD. And so what's gonna happen is under the Skidmore doctrine, the courts will start to look towards the agencies and say, well, how persuasive is an agency? So what's happening is you're gonna see lawyers start to really try to use agency persuasion, but that means that it's a lot different than the way it used to be. So now HUD is now going through a new, set of, rule making guidance. Some of you may or may not remember, in 2025, there was a lawsuit out of a Louisiana federal court called Henderson versus five properties. And there was a federal judge there that ruled on... In the favor of the property manager. The property manager was charging rent for an emotional support animal. Now we all know that you you cannot charge fees to people with disabilities because you can't take someone with a disability and put them in an adverse financial situation. It's not... It's discriminatory. You just can't do that. You wouldn't charge someone with a wheelchair money for their wheelchair. That would be ridiculous. And so you can't charge people who have disabilities any money for the... That relates to their disabilities. Animals, in theory, are a type of assistive device, especially legitimate ones, that help them with their daily lives, if you will. But what the court... What the judge... The federal judge said in the Henderson versus five properties is that the individual, the the resident, that she did qualify for emotional support animal, but that she did not show proof that she could not afford rent. And it was the first case where they... The courts bifurcated the accommodation request and the need for an animal from the actual need for relief on the money side. Meaning, you might need an animal and you're welcome to have your animal, but you have the financial means to pay the fees. And so, you know, there's a lot of attention that's looking at that. And I think the current HUD administration is probably looking at that very closely. The point is there's some rulemaking that will come out, I would imagine probably in the new year, and it's going to make some changes. Now I will say that Pet Screening, we're very involved with that. We, you know, we have a lot of data. We help provide data when and where we can, because we we really understand this, and we've been do... Like I said, doing it for a decade. The the punchline to this is there's a lot of water at... What's the old saying? It's about as clear as mud. Right now, keep doing it the way you've been doing it. Pet screening continues the the way we've been doing it, under 2020 guidance because that is exactly the way mothership in DC have advised us to do it, knowing that there are some changes coming. Now, in the great state of Texas, I said this earlier, Texas typically lines up with federal law. Now, we have an election in a few days, so we will see what happens in your state. But usually, whatever comes out of DC, your state typically will just follow that. Meaning, you're not going to make things, more restrictive or even relax a standard. So whatever HUD comes out with I would fully expect your state to embrace that. Now, if I was talking to a bunch of property managers in California or Colorado or Hawaii or Oregon or New York, those states would have a different position because one thing that I think we're getting ready to see is a big difference between federal law and state law. If the federal law starts to change the definition of, say, emotional support animal, then states have sovereignty and states may come in and say, well, you know what? As a state, we're going to define an emotional support animal as this. And so now property managers will have to look at federal law first, state law second, and then maybe even down to municipalities. Austin, which is, I would say, a city that probably has a more relaxed ideology than the the greater state of Texas. You might see some changes through a municipal ordinance, for example. Does get a little complicated when you start going federal, state, local. The point is you just need to know where you operate and what set of rules should you be following is is is really, you know, the punchline for this slide. You know, look, on Memorial Day of this this year, as this was in May, there was a a document that got leaked to the New York Times, and it was an internal enforcement interpretation document. It was a document that was never supposed to even be released to the public. But, of course, someone within HUD released it to the New York Times, and HUD has embraced it. HUD never... You know, is not hiding from it. HUD was just like, well, this was an internal document explaining to our regional offices throughout The United States how we're gonna internally process complaints related to assistance animals, ESAs and service animals. And so once the document got leaked, it really started to create a lot of consternation. Like, oh, does that mean we can now no longer allow ESAs that are are that are not trained, for example? And the answer is no. That was an internal document. The Fair Housing Act has not changed. There's still a reasonable accommodation framework very much in place, disability protections, and doing case by case evaluations is still the way that you must do this. People with disabilities deserve an individualized treatment, and that's why it's a case by case evaluation. But there is a rule making period. So eventually, there will be some more publicly available documents and rules from HUD that will in fact apply. So the only thing that has changed right now is that we know HUD is doing some work, but that work is internal inside baseball, especially in the spirit of the World Series. Although the Brewers are doing really well, they've run three games to zero against the Tampa Bay, Stingrays. But I digress. The point is an internal document is an internal document. It was not for external consumption. So just sit tight. Of course, if you're a pet screening customer, you're in good hands. We do that for you. But I'm just letting you know, don't get too far ahead of your ski tips here thinking that the internal document is how you should apply changes because those are not, you know, for you publicly yet. So let's talk about the difference between a service animal and an ESA. You know, if you went to Home Depot tonight or Lowe's tonight or a movie theater tonight and you saw an animal while you're, at one of those establishments, that's a place of public accommodation. And so a a place of a public accommodation means the public is welcome, and, and cert... And that falls under the ADA, Americans with Disability Act. Now we're in housing, and housing, private housing, falls under HUD. And so HUD, of course, has its own set of rules related to assistance animals, and HUD has taken the assistance animals, at least back in 2020, and they bifurcated it into service animals and emotional support animals. Though service animals are really more for ADA, public accommodations, HUD took a position that we're going to sort of mirror the ADA and we're going to follow the two test rule for service animals, which just means that these animals must be trained for a task. There's only two questions permitted. No documentation is allowed. It's interesting. From 2013 to 2020, you used to be able to ask for documentation for service animals, and then it changed in 2020. So So the real question is under these new rules that might be coming, is there going to be an opportunity to go back to asking for documentation for service animals? And the reason that's fair game is because remember, we're talking about private housing under HUD. We're not talking about a public accommodation such as a movie theater or a department store. And so today, those service animals and emotional support animals, there are different review processes. Emotional support animals do not have to be trained. They can be trained, but they don't have to be trained today. You can ask for documentation. And and so all those, you know, things start to make it having two different ways of looking at two different types of of animals. Support animals versus service animals. Now if you're in California, California has a broader definition for service animals. It's just not limited to dogs. So could there be a service animal cat in California? Well, because the law says it's not limited just to dogs, that's not an impossibility. I mean, I think that's a very narrowly tailored thing to train a cat, but the California law doesn't say it's impossible. But that's an example of where their law they've made some different laws than say federal. And again, I think Texas might be... If I had to place a bet today, your state would probably continue to, just adhere to the federal guidance, whatever it may be. That's my speculation. That's what I would expect. So anyway, that's that's service animals, emotional support animals. I'm gonna advance the slide. Okay. So, look, fair housing goes all the way back. Right? I mean, it goes back... You have the civil rights act in '64, and then, in '68, there was an amendment. And then title eight was added, which we all know today as Fair Housing Act. And then in '88, more amendments came called the Amendments Act. We act, I should say. It, you know, there are certain federal protected classes, race, color, national national origin, religion, sex, familial status, disability. So disability... People with disabilities have protections. Right? But if you notice, there's one thing that's not on here and that's pets. Pets are not a federally protected class. Pets are a privilege. They are not an entitlement. Even California, has not made pets a protected class. So the point is property managers have the freedom and landlords have the freedom to determine if they want a pet, yes or no. They can decide how big they want the pet, how many they want. You can say yes or no to pets all day because, again, they're not a protected class and denying them on their face. Maybe you, maybe as a child, you had a bad experience with an Australian shepherd. I'll pick an Aussies because I I have a or I had an Aussie. She passed away. But, but maybe you had a bad experience with them and you just say, I don't allow Australian shepherds at my property. You have the right to do that. And so it's up to you. So I just want to point out that pets are not a protective class. But people with disabilities are, which is why we have these protections around people who need their disability, who have a disability. But having a disability alone does not, in fact, give you the right to have an assistance animal. There are millions and millions of Americans, I mean, people across the world, but we're talking about federal law. So my focus here is The US. That have disabilities, but not every disability rises to the need of having an animal. And that's why under HUD, two things have to be true. You have to have a disability, one. So, yes, you have to have disability, and a condition, for example, is not a disability. A rash is a condition that is not a disability. So you must have a disability. You you... We never... You never, as property managers, get to inquire about what disability they have. That's none of your business. But you can't affirm that a disability does in fact exist. But then the second part of that is what is the disability related need? Like what need do you have for that animal? And both those things must be true. Now a few minutes ago, I was talking about SCOTUS, which is the Supreme Court of the United States. That's what SCOTUS stands for. But I talked about the Chevron deference doctrine and how it got overturned, and now there's weight under persuasion in the Skidmore versus Swift doctrine before. So some of that I get ahead of myself because I I do a lot of but the point is, you know, we've covered this in July 2025, Henderson versus five properties. That's the Louisiana court case. We talked about that. That was where the judge said, yes. You can charge Pat Rent because this person did not show that she had a knee... Or needed an accommodation for the financial side of it. Does anything like that. And then of course I talked that was adjudicated that supports that 2020 guidance. So even though that 2020 guidance is rescinded and I told you HUD advised Pet Screen to keep doing it the way we've been doing it. It wasn't necessarily because of the 2020 document itself. It's just because there's been a lot of case law and a lot of other things that have happened that give support to it up until a new set of rules come out, which, again, will probably be in the new year. So what is a reasonable accommodation? You know, look. A reasonable accommodation is is is when someone is asking you to reasonably accommodate them, and they're saying, hey. I need you to set something aside. So in in the world of pets, they're asking you to set aside a pet policy or a no pet policy and and then make an accommodation for them and their animal. Now a disabled person could be someone with a physical or mental impairment. Disabilities come in many shapes and sizes. They're not always physical. Not everybody, you know, is in a wheelchair or not everybody has a pair of dark glasses on with a cane that would indicate a, a c... Some eyesight type disability, like someone who's blind or legally blind. There are people who have what they call in... Invisible disabilities. Another word would be nonobvious, so it's not obvious. And then, disabilities. And so you can't always assume that someone just because they look okay, that they are okay. They could have some sort of mental disability. They must have substantial limitations. They must be either have a record or being regarded as being disabled, and then they must seek a reasonable accommodation. Just a, they don't get a hall pass just to move in and not tell you about it. They have to seek the accommodation. Now we know a lot of people, they think if they have an animal, it kind of gives them an all access pass. And that's just not true. They must seek a reasonable accommodation. Now when they seek that, though, then you... You know, what you're doing is is you're... They're asking you to make a change or an exception or an adjustment to your policy. So if you have a no pet policy and someone is asking you for an accommodation, what they're really saying is I need you to set aside your no pet policy and allow me to have my animal. Or maybe their dog is a, a 100 pound dog, maybe it's a a small Great Dane, and you have a 60 pound weight limit, but their Great Dane is their assistance animal, and they're saying, I'm asking you to set aside that 60 pound weight limit. And so that is why it's called a reasonable accommodation. And it is, in fact, necessary for the disabled community so that they can have an equal opportunity to use and enjoy that property. And so you can see, you know, Texas law defining disability, you know, you closely mirror, no surprise here, the disability definition. So it just... I think this is proof in the pudding as we say here in the South that you're mirroring the, the federal law of disability. So I think, again, it just points that Texas is likely going to do whatever the feds say do, which I think is... In my my personal experience, that's a good thing. It makes it clear because you don't have to worry about different rules. Excuse me. I sneezed. Bless me. I'm sorry. So common compliance mistakes. You know, one would be just, like, showing your frustration, going to Facebook on these forums, and talking about how frustrated you are around people with assistance animals. I would encourage you not to do that because those are records that could be admissible in a court. And if someone saw that you were on Facebook and some forum, you know, complaining about people with assistance animals and they're all fakers and they all go to the Internet and buy their letters, then, you know, you're starting to show predetermined bias, and you really wanna avoid that. So I would just say, you know, you don't wanna deny a request making assumption that it's not valid when in fact it really is valid. I think what what you need to do is make sure you follow a process consistently and do it all the time. Also, not requesting documentation at the wrong time. You cannot request documentation for a service animal currently. You know, you just cannot. In the in the past, before 2020, you could, but then it changed in 2020. And through today, you do not ask for any information regarding a service animal and housing. Again, maybe that'll change with the rules. We shall see. And then and then don't confuse an ESA with a pet. You know? You know, like, if we were a vacate... If y'all were doing vacation rentals or if any of you have vacation rentals, vacation rentals don't even fall under Fair Housing Act. And then vacation rentals, an ESA can be treated as a pet because ESAs are not a type of class of of animal in the world of vacation housing. But if you have two divisions in your company and you somehow apply the vacation rental standard to your long term rental standard, then you might find yourself accidentally charging an ESA fees. And right now, that'd be a no no. Now if you're in Louisiana, could you point to that Henderson, case with that federal judge? Perhaps. I would just say that that's one ruling. It's very narrowly tailored to that case. And I still would advise people to sit tight and let's see what HUD does. But these are again just some common compliance mistakes. Moving ahead here, documentation and verification, what to, you know, what is know, what is legally required, what are some red flags to watch for? You know, if you... If someone comes up with a certificate that looks like a sexy diploma or maybe a picture of a laminated, ID that looks like maybe a driver's license, those are those are, you know, those are not things that are recognized under the the... Under HUD or even recognized by the Department of Justice or even recognized by the ADA. There's no federal agency that recognizes any of those types of. You know? So I... One of those things, I know they went a lot and bought them. Maybe they used some other part of their life. I don't know. But what I do know is that an unacceptable type of document or certificate would... That you have proof. Digital kind of... We're seeing a lot of people use AI to take a 110 years old and update it to a 11 and reprint it, and you... It's been... Called health care providers and every... And And that's where we find the fraud because... And that's new. It was like it was ten years ago. So just making sure, you you know, are you checking that the documentation received is a legitimate? It's not hard to make official looking documents now with AI. Phone call to the healthcare providers to ask if it's legitimate, if it's if this is in fact, some of that personal knowledge of that patient is fair game. You should never inquire to the disability itself, of course. But that takes time. Of course, pet screening, we do that for you. Lot of healthcare providers that tell us that is not their signature, it's been forged. Or letterhead. We have people that use letterhead out of date because they didn't know that the practice updated their letterhead, but because they're using an old document and that's a big red flag, and health care providers will often catch that as well. So just, you know, the point here is how do you really know fact from fiction? And this is where just having a standardized process of doing this the same way every time is really, really important. And with AI, you know, it's not hard to go to AI and people to ask and get coached on what to say or do. And so, you know, you wanna just make sure that you do your thing the same every single time without violating someone's rights. And that's... You know, because that that will, you know, get you in trouble, and that's what you're trying to avoid. I'm a try and advance the slide here. This will go. Okay. Here we go. Give me one second. It's like a snafu here that... It's in the slot. Okay. I'm not sure why it's not going to the next slide. Give me a second. Bear with me, y'all. Oh, shoot. Okay. Here's an example of a letter where a lot of stuff's redacted. You know you know, how do you spot red flags? The the format of the letter is not really what's important here. I mean, we see a lot of providers that issue the same format of the same letters. What's really important, though, is that these health care providers have real personal knowledge of their patients. The point is how do you spot the red flags? You know, how do you... You know, that they just went to their mills. They're doing so many of these that there's not enough time in a day to actually do the number that they're doing. It's all because it's automated. Now pet screening, we just absolutely tech... Turn them down and say it's not it's not sufficient. But how do you apply correct response while making sure you stay fair housing compliant is key. I mean, these letters, if you don't... If you if you have a frontline person and they see a letter like this, they say, wow. This looks very official. This looks legitimate. And they might move ahead when if you would have actually done your diligence, you might have caught that, no. This is a mail letter, and this is from a a a company that just does these all the time. And and and and they're not and they're not credible. And so that's why you need to, you know, make sure that you are doing this. So some best practice and processes here. Remember, service animals, there's two questions only, for now. No paperwork. No documentation can be asked for. Questions will give answers that really indicate they have an emotional support animal. And when they do that, you have that in writing, and then you say, well, no. You don't have a service animal. You have an emotional support animal or a type of support animal. So that's a different pathway of which you can ask for documentation. And then, of course, you go down that review process. So just knowing which, you know, fork in the road to take at the right time, how do you make sure your team's trained to handle this? You know, how are you handling it as a company, any escalations? We often see at Pet Screening that some people get upset really fast. They they just... They've never been told no because they're so used to getting away with that ID card. And when you tell them no, they, like, act like they're a lawyer all of a sudden, and they're using AI to write these amazing paragraphs about how they're gonna sue you, and you're not HIPAA compliant, I would just tell you don't be rattled because the law provides you a permissible process. And as long as you follow that permissible process, there's nothing that they can say or do that would prevent you from being able to run your process. So don't get freaked out if they start dropping a bunch of legal jargon because, ChatGPT and these AI tools have really made a lot of new lawyers out there. And I kinda say that tongue in cheek, but but that's what they're doing. They're coming back with these amazing responses and trying to spook you into saying yes when the reality is you have every right to perhaps say no depending on the situation. You know, so again, do it consistently, understand how do you review each type, what are the outcomes. The interactive process is incredibly important here. That that means it's like a tennis match. They hit the ball to you, you hit the ball back. You always wanna hit the ball back. Even if hitting the ball back means you tell them that, hey. This letter is not from a credible provider online. You need to provide a... You need to provide different paperwork from a credible provider. At least you put the ball back in their court. What I don't recommend is when they hit the ball to you, you just go silent on them. Because if you go silent on them, then now you're not really participating in the interactive process. And the courts are gonna wanna see how were you interactive. Now the interactive process doesn't go into perpetuity. They don't get to take weeks at a time to respond to you. You have a business to run. So if they're not fast and responding to you, they let them know, hey, I need this sooner than later. And if I don't get it from you, I'm gonna have to move ahead. Because you're just showing how you were trying to work with them, but they were the ones who were slow rolling you. So, again, just having internal policies and process, in place is really important. You know, pet screening... And and look, this is... We... I don't come to these things to sell pet screening. We're a free service, you know, so I don't... There's really not much to sell here. I would just tell you that I started this to help property managers just like you navigate this. And and we don't cost property managers anything, but we've been around for a decade. We've done millions of these. And the point is, you know, we everyone. We've we screen folks who don't have pets. Why? We make sure people who don't have pets understand that they're not gonna have any visiting pets, because visiting pets can often be a big problem. Pet fostering, as noble as pet fostering is, Pet fostering should not be allowed in your properties unless you give them permission to do so because who do you how do you know the background of that dog or that cat? And so we have a no pet pa... A no pet profile, no animal profile to make sure that those people who don't have pets or animals understand that there's still understand that there's still rules that very much apply to them. So if they have their parents coming up for the weekend and their parents are bringing their dog, you know, they should inform you, the property manager, that's getting ready to happen. If in fact they don't, but then that dog bites a neighbor, at least if you have pet screening and you have the no pet, no animal profile on the record, then you'll have something to point to and say, hey. You you know, your honor, judge, jury, they knew they could not have a visiting pet, but they did it anyway, and it's not our fault. We... They knew the rules. Platform and there's no cost to the individual who doesn't have a pet or an animal. We don't charge them anything. We just want them to answer a couple of questions to acknowledge those policies. Of course, we screen dogs and cats, make sure we understand their sex, breed, size, weight, make sure they understand the rules. And and and and that's very important because if it's a poodle, we wanna make sure you see it's a poodle. That way, if you don't allow certain type of dog, and let's say you don't allow German Shepherds. I I think German Shepherds are great dogs. I don't wanna pick on them, but that is a dog sometimes that's not allowed. But if someone says they don't have a that it's not a German Shepherd, but then they upload a picture of a poodle, they're really lying. But our we will get them on the record saying they have a poodle. So if the German Shepherd bites someone and then you say, wait a minute, that dog that bit someone is not the dog you uploaded a picture of, you can imagine how that protects you and the owners that entrust you to run there. How can you stop them from lying? And the answer is you can't. But but we get them on a legal record saying we're not lying. And, therefore, if they do lie, it's very hard for them to get away from the way they, actually were not honest going through pet screening. Of course, assistance animals, we make sure in every instance that these, whether it's a service animal or a emotional support amount that it meets the law, we we run the process for you, but we keep you involved with the interactive process. We never, you never completely step out, although we do a lot of the heavy lifting. The point is you must always be a part of that interactive process, but but we built this in a way that allows you to maintain that while we're carrying most of the water. You know, we, and so, anyway, all this, all following hub guidelines, etcetera. You know, look. When you do this right, it takes a long time. If you're doing it right, it probably takes every bit of, two hours over a few days of calling a health care provider and get waiting on hold, going back and forth, and that adds up. And so we know that your time is money, and you should be working on other parts of your business. And so, you know, pet screening, our whole goal here is to give you time back. And if you're using lawyers, attorneys, great resources. But I will tell you, not every attorney knows this really well. Even the best attorneys that do eviction law don't really know reasonable accommodation law. I know this because a good friend of mine, Harry Heist in Florida, if any of you do business in Florida, Harry is one of the foremost authorities on eviction law in Florida. But Harry exclusively tells people use pet screening because even he knows that that's just just a very specialty area. So, and you're probably paying that lawyer where at pet screening, we don't cost you anything. We're so confident in our work that we have our assistance animal compliance guarantee. We literally will cover your legal fees and any fines up to a million dollars if we say an animal does not, in fact, meet the standard. And then for some reason, they lawyer up and and if Pet Screening got it wrong, then we will cover your legal fees and and settlements and regulatory fines up to a million bucks, which is a lot of money. And this is not like, an insurance policy. This is something... We don't buy insurance for this. This is something that we just back up with our own money. So you can trust that we know what we're doing. We've done, like I said, 3,000,000 of these, even though the slide says 2,500,000. And we've never been found at fault of violating any regulatory rule or law anywhere, and that's because we know this so very well. So when you're using Pet Screen, you have really trusted partners, kind of the punchline here. You know, we are a streamlined pet and animal policy management platform, and there's lots of resources you can go to. This is my last slide. The point of it is Pet Screening, whether you use us or not, you're welcome to reach out to me at any time to, be a resource. I mean, I'm a property manager. I... I'm not actively managing properties that did sell my company, but I maintain my designations. And, you know, I'm here to help you no matter what. I... That's what property managers do. We look out for each other. Unit, the United States military is pet training. We're on 20 bases in country, mobile home parks, senior housing, student housing, multifamily housing, single family housing, build to rent. The point of is it's a roof over someone's head and there's a rental going on. Chances are, seven rentals in the country uses our company, and I'm very proud of that. So all that to be said, I'm gonna go to Q and A here, because I, you know, we've got about ten minutes left, and I'm gonna go here. I see a few. Can an owner ask for an additional bite insurance policy for an ESA that is a restricted breed? Well, what you don't want to do, Stephanie, is solely make people the systems animals by, insurance policy because what you're doing then is you're you're picking on them and you're redlining them and you're saying, hey, You're... You have a disability, so I'm gonna make you pay to have insurance because your breed is a type of breed that I don't tech. Hey. If you if you require bite insurance for every dog, for... Whether it's a pet or an animal for every breed, then it's a little more defensible. But I would not only require it for someone that has an ESA. You would be... You could perhaps run a foul of, being discriminatory. If a landlord does not want animals pets in the house, does that also mean no? Remember, if under the federal law, even a no pet property must willing to allow a service or assistance animal. Now, I think Krishna is the is the person who asked this. If there was a duplex and the the two units are exactly the same and they're both vacant And someone was applying for unit a, and that's a no pet property, and unit b allowed pets, then if they applied for unit a, it would be... And you... It would be within your right. So you know what? A, we can't do because the owner doesn't allow it, but I got a prop a unit right across the hallway that's just like it. And I can put you there because you're making a reasonable comment and not much is changing. It's it's 15 feet across the hall, same same parking, same etcetera. So as long as you're showing reasonably accommodate them. But if it's the only property you have and that's the one that works for them, a no pet policy alone is not going to allow you to say no to a legitimate assistance animal. If a tenant is... This is from Crystal. If a tenant is six months into their lease, an ESA letter was accepted upon signing of the lease, apartment sent him notice to get an updated letter if the current will expire. If he does not provide them, a letter, could they evict him? And can they do this since in the middle of his lease? Well, you wouldn't evict them as much as you would say, just remove the animal. Because the eviction is without the person, the accommodation is about the the animal needed for the person. So if someone's letter expired and you ask them to get updated documentation and they didn't do it, you would have grounds to say, well, look. If you can't show us that you still need this animal and have the documentation to support it, then really you have two choices. One, if it's a pet friendly property, you would start charging them pet rent because it's no longer an animal, it's now a pet, and you would start charging pet rent. If it's a no pet property, then you could ask them to then remove the animal. And then if they would not remove the animal, then you would move to a nonmonetary summary ejectment process. I would just encourage you to really try to work with them and explain to them. If you don't get updated documentation, then you're gonna have to pay pet fees. And then... Because at this point, the pet's already there... Or the animal's already there. So converting it from an animal to a pet seems like a more reasonable process than to just say remove your animal altogether. But it's your business to run. So it could it lead to eviction? Perhaps, but that's a little bit further down the path. You should need to document, document, document. Alright. Can you look into your crystal ball? Alright, Christine, I will track you. Look into your crystal ball and tell us how the new HUD guidelines will affect us property managers in Texas, specifically disallowing all animals except for dogs. Well, first of all, I don't think the new guidance is going to limit it to dogs only. I don't think that's gonna happen. I think what will happen is they're going to be looking at animals that are trained only. So an ESA that is untrained would no longer qualify as a type of ESA, which means you could charge them pet fees. Now the real question is, if it's a trained ESA, isn't that really a service animal? Well, yes. But service animals now are pretty much limited to dogs, and that's where I think the departure is is that, dogs... I don't think there are limits to dogs. They're... They they probably would allow other types of animals. So I think the the thing to watch is gonna be training versus untraining. And then, and then if we get our way, we hope that service animals, you can get back to asking for proof that it really is a service animal because, it's not hard to just know how to answer these questions correctly by going to AI and say, hey, AI. How do I answer these two questions and give the perfect answer? Because if they give you the perfect answer, even if they give Pet Screen the perfect answer, we don't know where they got those answers. And short of us knowing it came from AI, which by the way, we do see people that put in AI answers and they forget to take out the prompts. And so we obviously reject those folks. But if they're smart enough to remove the prompts and and and put in a Word document, change the font, and stick it in, it it looks like their answer. So, we'll see. Let's look here. So that was crystal. That was my crystal ball for now. Hope that helped. Phyllis, what if you accepted a tenant with a pet and it... And took a nonrefundable and then three months later, the, the tenant sends you a letter for an ESA? Do you have to return a portion of the nonrefundable pet fee? So, you know, it's it's really up to you. I think if you have the nonrefundable pet fee and it's already... You're already holding it and you've already collected it, I don't think you have a burden to necessarily refund it right away. I mean, it might be the right thing to do. I don't think the law says you have to. It's as long as you don't administer something new from that point forward. So all the pet rent you collected up to that point would be fair game to keep. You don't have to refund that pet rent. But from that moment forward that it's determined to, in fact, be a legitimate ESA, then you would no longer collect pet rent, obviously, because if it's a legitimate assistance animal, because it is possible for someone to get into a car accident and all of a sudden have a disability, like a mobility disability because of a car accident, and they might need a dog for mobility for the next six months while they're healing. Scenario. But, but that you wouldn't have to refund all the pet fees. So if you were holding a non refundable pet fee, you would not be required to give it back. If you wanted to prorate it and say, well, you're six months into your lease, I'll give you six months back. Again, that's a nice thing to do. I'm not... I don't know if that's require... I don't think that's a requirement under the law. So I hope that answered your question, Phyllis. And, of course, always, I'm not a lawyer. Feel free to ask your lawyers. This is just John Bradford with a lot of experience talking. What else do we have? Okay. I've answered that one. I've answered this one. I've answered that one. Letters from urgent care providers. How do you ask for established relationship? Well, an urgent care provider, I mean, that's the business they're in. And we all would agree in urgent care is someone that's not going to see someone repeatedly. But you can still have the right, Stephanie, to call that urgent care provider and and make sure, one, it's a legitimate practice, two, that that urgent care provider does have history of... And knowledge that that person did in fact come in and see them and that the document is in fact legitimate. And I think if it meets all those tests, the fact that the urgent care provider saw them for once and only once doesn't doesn't run afoul of, like... Because right now, there's no requirement for established relationship. In other words, established relationship could be they established it by going to that facility under urgent situation and sought the care they need. Is is that alone enough to be alone as established relationship? And and under HUD guidelines right now, there is no, specificity around or they must have a preexisting relationship with a provider for x amount of weeks or x amount of months. So an urgent care provider is very much fair game, at least, is the way it is now. So I answer your question. So I I I believe it or not, I think I answered all the questions here, and we are... Got three minutes left. So, let's look here. Yeah. So, during the busy season... Well... Yeah. So let's talk about pet screening. It can take several days to verify. Remember, we're calling the health care providers y'all. We're waiting on health care providers. I can't push the health care provider... Providers along any faster than they're willing to respond. So pet screening, if we're taking a few days, it's often because the healthcare providers have not gotten back to us. So that's we get to our reviews the same exact day they come in. So the point is calling healthcare providers and they are not the the Veterans Administration is notorious slow. So sometimes you may have to, Melanie, make a temporary accommodation. If it's a VA, especially if you're down in like San Antonio, there's a lot of military presence. Accommodation because the VA can take two weeks to get back. But what you need to do is move ahead. So a lot of our clients might make a temporary accommodation, grant the request, but still at Pet Screening continue to contact the VA so, you know, even though it does take sometimes a few days to verify, just know that a lot of times it's because of other reasons. Sometimes it's that your your applicants are taking slow to respond. The beauty is the interactive process. We date stamp everything so you can see how long it might take your request or your applicant to come back to us. And that's why I said they don't get a right to hold your property hostage. We have sort of a ten day rule policy. If they go silent for ten days, then they've abandoned the request. And that's kind of marrying something. So anyway, I am out of time here. Look, my, I'm gonna put, in the chat, I'm gonna put my email. It's very simple. John, john,@petscreening.com. I mean, how easy can that be? So please reach out to me anytime. John and Petz, how do I spell that right? I got fat fingers. So john@petscreening.com. If you're a Pet Screening customer, we appreciate you very, very much for your business. If you're not a Pet Screening customer, we'd love to serve you. We integrate with everybody. Entrada, you already have folio, build them. It doesn't matter. If there's a PMS out there, we rent and buy, we we integrate with them. So we make it easy. Thanks. Thanks so much, for joining, and this concludes today's session. And I hope you all have a wonderful, wonderful work week. And, and I love Texas. So have a great day. Thanks, guys.