YWCA USA Comments on HUD’s Harmful Proposed Rule

YWCA USA submits these comments on the proposed rule published at 84 FR 42854 (8/19/2019), RIN 2529-AA98, with the title, “HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard.” (Proposed Rule). The existing Disparate Impact Rule is a critical tool in combatting discriminatory housing policies that appear neutral on their face but often have a devastating impact on members of a protected class. The Proposed Rule would impose a drastically higher burden of proof that would fundamentally weaken this longstanding enforcement tool to the detriment of women of all identities— particularly women of color and domestic violence survivors. We strongly oppose any changes to HUD’s existing Disparate Impact Rule and urge HUD to withdraw the Proposed Rule in its entirety.