IREM submits comments on HUD's proposed animal regulations.(insession)(Institute of Real Estate Management)(Department of Housin

The Department of Housing and Urban Development (HUD) proposed revising its regulations that apply to animals in HUD-assisted housing, including public housing serving the elderly and disabled families. IREM submitted comments in December, 2007, expressing its concerns.

The language in the proposed rule is problematic. To date, the term "service animal" has been defined as "animals with specialized training to assist the disabled for specific purposes." The inclusion of the words "support" and "provide service to" creates ambiguity in terms of which animals will or will not be allowed to reside in HUD-assisted housing of the elderly and persons with disabilities. This ambiguity results in subjective decision making forced on property owners and managers that in turn causes potential for increased litigation. The rule would also open the door to anyone who wants a pet of any kind, by merely stating they need the animal for assistance, support or service without any verification.

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