Affordable housing layer for Clara

How Clara handles applications, eligibility questions and everyday conversation at an affordable or voucher-assisted home — without loosening the fair-housing floor she already runs under. Documentation and approach only; nothing here is built. Hands off to the build agent in section I.

Parked 2026-09-13 — Fede: do it later; open PRs closed on his call, only #7867 merged (dark)  ·  written 2026-09-11 · research pass 2 the same evening  ·  triggered by Western Slope's go-live next week

A · Why now

Two of Western Slope's properties came back flagged affordable in the AppFolio account review — property-level flag, unit-level PBV tags, and payments coming in from a housing authority rather than the tenant, all confirmed straight from AppFolio's own API (not asked of the customer, per Fede's ruling — we research the rules ourselves):

• Courtyard Apartments ("Bunting Courtyard") — 27 units, 12 tagged as Project-Based Voucher (PBV) units. Correction from an earlier pass: this is not a mixed building with "mostly market-rate" residents — under the 2022 preservation deal (below), all 27 units are income-restricted; 12 of those are also PBV. Flagged for confirmation with Western Slope before go-live.
• Lincoln Apartments — 12 units, all income-restricted under the same 2022 deal.

Both properties trace to one event: in May 2022, GJHA sold Courtyard and Lincoln (39 units combined) to Headwaters Housing Partners in a preservation deal financed by CHAI Debt Capital, First Bank, and CHFA's Preservation Fund (CHFA was a gap lender here, not an owner or an LIHTC partner). The deal restricts occupancy at both properties to households at or under 60% of area median income, caps rent at 30% of income, runs for ten years (roughly through 2032), and keeps 12 project-based Section 8 units in place. Source: CHAI Funds press release, May 30, 2022. No LIHTC record was found for either property in HUD's LIHTC database or the National Housing Preservation Database — this is a deed-covenant restriction, not LIHTC; unverified against CHFA's own property list (the list PDFs could not be opened). Full citation in the appendix.

Ownership is confirmed, not inferred: Western Slope's own AppFolio property directory lists the owner of both Courtyard (2910 Bunting Ave, 27 units) and Lincoln (1303 N 15th St, 12 units) as Situs Headwaters One LLC, with a Denver-area (303) phone number — a Situs Group entity is the inference there, since Situs Group is our other design partner. Western Slope is the manager on both, per the same account. Supporting, not proof: the same AppFolio data shows Courtyard's 15 non-PBV units carry the same market rent as the PBV units and are tagged by bedroom count, not "market" — consistent with all 27 units being income-restricted.

On top of that, five of Western Slope's market-rate homes already have individual tenants paying with a housing choice voucher — a different situation from a designated affordable property, and one where the wrong sentence ("we don't take Section 8") is a fair-housing violation regardless of the building's own status.

B · What the law requires, in one page

Three layers apply to Western Slope's affordable homes: federal, Colorado state, and (where it exists) local. Full citations are in the appendix; this section is the floor Clara can never cross.

Federal

• Source of income (vouchers, benefits) is not a protected class federally — but is in Colorado (below), so treat it as protected everywhere Clara operates.^F1
• Project-based Section 8 (PBV) may not charge an application or screening fee.^F2 Housing Choice Voucher (tenant-based) landlords may charge a standard fee, but never a higher one for voucher holders.^F2
• A landlord cannot require an income multiple against the voucher holder's full rent — only against their own share.^F3
• Criminal-history, credit, and rental-history screening must be individualized, never a blanket ban — arrests without conviction can't be the sole reason for denial.^F4
• VAWA (2022) protects applicants and tenants from denial or eviction tied to domestic violence, sexual assault, dating violence, or stalking; self-certification (HUD-5382) is enough — no police report required.^F5
• Reasonable accommodation requests (disability) must be granted or denied by a trained human, never an algorithm.^F6
• Fair housing communications must be available in Spanish and other locally-common languages; English fluency can't be required for routine leasing contact.^F7
• HUD's May 2024 guidance: the Fair Housing Act applies fully to AI-driven screening and advertising, and the housing provider stays liable even when the AI is a vendor's.^F8

Colorado

• Source of income (vouchers, benefits, subsidy) is a protected class statewide (HB20-1332).^C1
• Minimum income requirement capped at 2× monthly rent, down from the old 3× standard (SB23-184).^C2
• Security deposits capped at 2× monthly rent; pet deposit capped at $300, pet rent at the greater of $35/month or 1.5% of rent (SB23-184, HB23-1068).^C3
• Late fees only after 7+ days late, capped at the greater of 5% of rent or $50; unpaid late fees alone can't be grounds for eviction (SB21-173).^C4
• Must accept a tenant-provided portable screening report if it's under 30 days old, and waive the separate screening fee if so (HB23-1099).^C5
• LIHTC properties (CHFA-administered) require a signed Tenant Income Certification before move-in, third-party income verification, student-status documentation, and an Affirmative Fair Housing Marketing Plan.^C6

New since Jan 2026

Four more Colorado laws, confirmed directly on leg.colorado.gov (accessed Sept 11, 2026):

• HB25-1249 (effective Jan 1, 2026) — tighter security-deposit rules: what a landlord may withhold from a deposit, and how the itemized return must be documented.^C7
• HB25-1236 (effective Jan 1, 2026) — an applicant may supply a portable screening report; a landlord may not require credit history from an applicant whose rent is subsidized, and may not force a single screening vendor. Matters to Clara directly: never ask a voucher holder for credit history.^C8
• HB25-1090 (effective Jan 1, 2026) — a quoted rent price must include every mandatory fee; no add-on fees revealed later. Clara's rent quote must be the all-in figure.^C9
• HB26-1196 (signed June 2, 2026, effective Jan 1, 2027) — written notice before screening, disclosing what data is pulled and the denial criteria. Not in force yet; design for it now so it's ready when it lands.^C10

Local

Other Colorado cities do stack a local layer on top of state law, which matters the day this design extends past Grand Junction: Denver adds its own source-of-income ordinance with fewer landlord exemptions plus an inclusionary-housing mandate; Boulder mandates 25% of new units affordable; Vail/Eagle County runs a deed-restricted workforce-housing program (InDEED); Longmont mandates 12% affordable in new developments.^L2

What Clara may / must not / hands to a human

C · What EliseAI does (and doesn't)

• EliseAI is the market leader in AI affordable-housing leasing — 500,000+ units, headline customers including WinnCompanies and Michaels Organization.
• It auto-detects a voucher mention mid-conversation and asks the approved unit size, no manual follow-up.
• It adapts income questions to how the applicant phrases them (hourly vs. annual) and asks about all income types, vouchers included.
• A dashboard shows qualified / unqualified / in-progress prospects and why each didn't qualify.
• Automated recertification outreach at 120/90/60/30 days before a LIHTC deadline.
• ADA/reasonable-accommodation requests are flagged to a human — EliseAI's own CXO is on record: "there's no interpretation for... compliance items like fair housing."
• What it does not publish: what it actually says when asked "do you take Section 8," how it handles VAWA disclosures, or any third-party fairness audit since HUD's May 2024 AI guidance. Two vendors (PERQ, SafeRent) were sued and settled for exactly this gap — AI that silently screened out voucher holders.
• What we take from it: auto-detect the voucher/program signal instead of asking the prospect to self-classify; keep a narrow, explicit escalation list (accommodation, VAWA, denial) rather than a general "when unsure, escalate"; and never ship a decline template the human hasn't approved. We do not adopt "adaptive income questioning" — Clara should not be running income math live at all (see the behaviour list, section G).

D · The rule model

Two things vary independently: jurisdiction (federal → state → local) and program (PBV, HCV, LIHTC, HOME, deed-restricted). Program changes the rules more than geography does — a PBV unit and an HCV tenant sitting in the same city follow different fee, screening, and rent rules.

Option: how many jurisdiction levels to store

The program axis

Program is a second, independent key on the same unit or property: PBV / HCV / LIHTC / HOME / deed-restricted / none. A rule set is keyed by (jurisdiction, program), not jurisdiction alone — the PBV application-fee ban is a program rule that applies in every jurisdiction; the 2× income cap is a Colorado jurisdiction rule that applies to every program.

How Western Slope resolves

Mapping onto Gera's registry classes

Registry class	Where this design uses it
Compliance floor	Protected classes stay untouched — this layer is not allowed to write or soften them. Same clamp already enforced in production by the fair-housing gate.
Parameter	Numeric jurisdiction rules that vary by property and inherit nearest-wins: income-cap multiple, deposit caps, late-fee cap, application-fee amount.
Identity	Program type (PBV / HCV / LIHTC / HOME / deed-restricted) — pinned, never inherited, same shape as asset_type today.

E · Keeping rules current

Secondary concern, kept short. Each rule set carries an effective date and a change log entry (what changed, citation, who reviewed it) rather than being edited in place — the same discipline the fair-housing protected-class list already uses ("a legal decision, not an editorial one").

Source	Cadence	What to watch
HUD PIH notices	Monthly/quarterly	Payment standards, EIV, HOTMA updates
CHFA eNews + compliance manual	Monthly, plus July 1 policy effective date	Income/rent limits, LIHTC compliance changes
GJHA administrative/annual plan	Effective July 1	Waitlist procedure, payment standards, PBV terms
Colorado legislature	Session Jan–May, new law effective July 1	Any new HB/SB touching tenant screening, deposits, fees, source of income

A lightweight quarterly check (does anything in the change log need a bump) plus an annual full review is enough — this is not a daily-monitoring problem, since none of these sources move faster than monthly.

F · Runtime: how Clara switches path

How it fits together

No new parallel system. This reuses the extension points the fair-housing gate and knowledge stack already have (full list in the appendix):

• Detection — the AppFolio sync writes the property's program flag and, for a mixed building like Courtyard, the unit-level PBV tag, onto the Property/Unit record. A conversation resolves its property (and unit, once known) the same way it does today; the program tag rides along.
• Knowledge injection — the affordable-program fact lives in PropertyKnowledge.leasePolicy beside the existing voucher-acceptance fact, flowing through the same two renderers that already serve text/email and voice from one record — no new plumbing.
• Voice directive — the existing per-property dynamic-variable slot (used today for the multi-property triage prototype) carries the affordable-program script variant as a separate fact variable, not a text-gated sentence (the known ElevenLabs gotcha: a conditional sentence around an unset variable renders as dead text).
• What changes in behaviour — income-multiple questions apply only to the tenant's own share, never the full rent; PBV properties quote no application fee; availability language becomes waitlist language, not vacancy language; screening statements state individualized review, never a bright-line rule; "we accept vouchers" becomes the default answer everywhere, including the five voucher-holder market-rate homes.
• Where Clara still helps — explains the program and the process in plain language, takes a name for waitlist interest, books a tour where the program allows it, and answers in Spanish directly. The fair-housing gate's floor is unchanged: it cannot be loosened by anything in this layer.

G · The compact behaviour list

This is the deliverable a prompt would actually carry — short, imperative, nothing else.

1. Always answer "do you accept vouchers/Section 8" with yes, at every property and every market-rate home.
2. Never state whether a specific person is eligible, qualifies, or doesn't.
3. Never do income math live. State that a limit exists; never compute or confirm against a number the caller gives.
4. At a PBV unit, state there is no application or screening fee. Never quote one.
5. Never require or imply an income multiple against total rent for a voucher holder — only their own share.
6. Describe screening as individualized review, never a bright-line rule (no "any felony," "any eviction," "must earn 3×").
7. For a waitlisted or full unit, use waitlist language ("I can add your name to the interest list") — never invent availability or a date.
8. On any reasonable-accommodation request (disability, service animal), explain the right and route to a human immediately — never evaluate.
9. On any VAWA-related disclosure (domestic violence, stalking, assault), stop, explain the self-certification protection, and route to a human — never ask for proof.
10. Answer directly in Spanish for routine leasing questions; never defer a Spanish speaker to a human for something English speakers get answered live.
11. Never mention a caller's protected-class status, program type, or unit assignment to anyone but that caller.
12. When unsure which of the above applies, hand to a human rather than guess.

Example exchanges

H · Testing and scoring

Extends the existing fair-housing gate rather than building a parallel one — exact files are in the appendix.

• Gate — a new policy variant (or a widened appliesTo gate) on the same outbound-safety framework, scoped by the property/unit's program tag, same shape as today's capability/audience gate.
• Judge and evals — the fair-housing eval suite and its fast-tier regression lane gain an affordable-housing dimension: red-before/green-after cases for each behaviour-list line, using the existing judge and dataset shape.
• Harness — the voice comprehensive harness's fair-housing scenario files gain affordable-specific scenarios (voucher on market-rate, PBV income question, waitlist, VAWA disclosure, accommodation request), following the shape already used for adversarial fair-housing probing.
• Corpus — a scrubbed set of Western Slope guest-card conversations that actually touched Courtyard, Lincoln, or a voucher holder, used as real-world red cases (no customer PII retained — names and identifying detail stripped per the no-PII-in-fixtures rule).
• Topic labeling — no voucher/Section-8/affordable topic label exists today; this is a gap to fill alongside the eval work, not an extension of an existing one.

I · Build plan for the handoff agent

A chain of small, dark, mergeable-on-their-own PRs, each one concern, each ≤300 lines, each with its own proof. No step turns anything on for a customer — that's Fede's call, separately, after Willows testing.

#	PR	Proof
1	Data: add program/affordable fields to the Property and Unit records, wire the AppFolio mapper to actually populate them from the raw property/unit response instead of dropping them in the untyped catch-all	A synced Western Slope property shows the correct program tag on Courtyard's 12 PBV units and Lincoln's 12 units; unit test on the mapper
2	Rule sets + resolver: versioned rule sets keyed by (jurisdiction, program), effective dates, the nearest-wins + floor-clamp resolution logic	Resolver test proving Western Slope resolves to US → CO → GJHA program facts with no Grand Junction local layer
3	Knowledge injection: affordable-program fact in PropertyKnowledge.leasePolicy, flowing through both existing renderers	A written fact appears in both the text/email prompt block and the voice injection cache for a test property
4	Prompt lines: the 12-line behaviour list, gated behind the per-property program switch, on both text/email and voice	Behaviour-list eval cases pass on a program-tagged test property, unaffected on a non-tagged one
5	Gate/eval extension: affordable dimension on the fair-housing judge, evals, and harness scenarios; the topic label	Red-before/green-after on the new eval cases; harness run showing the new scenarios
6 (later phase)	Human-compliance flag: post-transfer extraction check against the behaviour list, flag shape, yellow-dot/evidence-gated notification wiring	A scripted non-compliant transferred-call transcript produces the flag; a compliant one doesn't

J · Decisions for Fede

1. Rule-model shape

2. Program-axis granularity: store the raw fact now?

Gera's model already answers the granularity question — program resolves at the unit, reserved in condition {program | ...}, row 1.12 of his design — so this is no longer "which level." It's whether to start capturing the fact before the overlay that reads it ships.

3. Does Clara ever state income limits numerically?

4. Does Clara take waitlist interest, or only point to GJHA?

5. Is the human-compliance flag (section H) in scope for phase 1?

K · Appendix

Research digests, citations, and extension points (collapsed — expand to read)

Federal citations (F1–F8)

1. F1 — Source of income not federally protected: Fair Housing Act, 42 U.S.C. §3601 et seq.; 24 CFR Part 100. Accessed Sept 2026.
2. F2 — PBV application-fee ban: 24 CFR 983.253; HUD Non-Rent Fees Chart (Feb 2024). HCV fee rules: 24 CFR 982.
3. F3 — Income multiple limited to tenant's own share: 24 CFR 982.301–982.310.
4. F4 — Individualized criminal/credit screening: HUD Office of General Counsel Guidance, April 4, 2016.
5. F5 — VAWA 2022: 24 CFR Part 5, Subpart L; HUD Form HUD-5382.
6. F6 — Reasonable accommodation, human-only: 24 CFR 8.11; 24 CFR 100.204.
7. F7 — LEP/language access: Fair Housing Act; Title VI, 42 U.S.C. §2000d; Executive Order 13166.
8. F8 — HUD AI/algorithm guidance: HUD Press Release 24-098, May 2, 2024.

Colorado citations (C1–C10)

1. C1 — Source of income protected class: HB20-1332, C.R.S. 24-34-502, effective Jan 1, 2021.
2. C2 — Income cap 2× rent: SB23-184.
3. C3 — Deposit caps: SB23-184 (security deposit); HB23-1068, effective Jan 2024 (pet deposit/rent).
4. C4 — Late fee cap and 7-day rule: SB21-173, C.R.S. 38-12-105, effective Oct 1, 2021. (HB20-1141 is a related, earlier tenant-protection bill on a different topic — not to be confused with the source-of-income bill HB20-1332 above or with SB21-173's late-fee rule.)
5. C5 — Portable screening reports: HB23-1099.
6. C6 — LIHTC/CHFA compliance: CHFA Multifamily Program Compliance Manual 2024; IRC §42(g).
7. C7 — Security-deposit withholding/itemized-return rules: HB25-1249, effective Jan 1, 2026. Confirmed on leg.colorado.gov, accessed Sept 11, 2026.
8. C8 — Portable screening report acceptance; no forced credit history for subsidized-rent applicants; no forced single vendor: HB25-1236, effective Jan 1, 2026. Confirmed on leg.colorado.gov, accessed Sept 11, 2026.
9. C9 — All-in mandatory-fee rent quoting: HB25-1090, effective Jan 1, 2026. Confirmed on leg.colorado.gov, accessed Sept 11, 2026.
10. C10 — Pre-screening written notice (data pulled, denial criteria): HB26-1196, signed June 2, 2026, effective Jan 1, 2027 — not yet in force. Confirmed on leg.colorado.gov, accessed Sept 11, 2026.

Local citations (L1–L2)

1. L1 — Grand Junction/Mesa County has no local mandate layer: single-pass search, not independently re-verified, cross-checked against Grand Junction Municipal Code and the "At Home in GJ" voluntary program (non-regulatory). Grand Junction's Resolution 45-25 (Aug 2025) is a voluntary fee-waiver incentive for 60–90% AMI rentals, not a mandate — https://www.gjcity.org/1459/Affordable-Housing-Incentive-Program. Accessed Sept 11, 2026.
2. L2 — Denver source-of-income ordinance (eff. Jan 1, 2019) and Inclusionary Housing Ordinance; Boulder Inclusionary Housing Ordinance and Permanently Affordable Housing program; Vail InDEED workforce-housing program; Longmont Inclusionary Housing Ordinance. All accessed Sept 11, 2026.

GJHA contact/waitlist citations

1. GJHA address and phone: 8 Foresight Circle, Grand Junction, CO 81505, (970) 245-0388. HCV waitlist open: gjha.org/housing-programs/housing-choice-vouchers. Accessed Sept 11, 2026.
2. PBV waitlist for Capital Terrace and Courtyard (2- and 3-bedroom), open, no predetermined closing date: affordablehousingonline.com listing 113909, last updated Dec 3, 2025. Accessed Sept 11, 2026.

Property-history citation

1. Preservation deal, May 2022 — GJHA sold Courtyard ("Bunting Courtyard") and Lincoln Apartments (39 units combined) to Headwaters Housing Partners; financed by CHAI Debt Capital, First Bank, and CHFA's Preservation Fund (CHFA as gap lender). Occupancy ≤60% AMI, rent ≤30% of income, 10-year term, 12 PBV units retained. CHAI Funds press release, May 30, 2022: https://chaifunds.com/2022/05/30/weave-closes-loan-to-preserve-two-properties-in-grand-junction/. Accessed Sept 11, 2026.

Research gaps and inferences (labeled)

• Unverified against CHFA's list. Lincoln Apartments' and Courtyard's restriction is the 2022 deed covenant above, not LIHTC — no LIHTC record was found for either property in HUD's LIHTC database or the National Housing Preservation Database. CHFA's own compliance-list PDFs could not be opened to cross-check directly. Worth a direct GJHA or CHFA confirmation before phase-1 rules go live, specifically on whether either property carries any separate LIHTC layer on top of the covenant.
• Fact, not inference (2026-09-11 sync). Ownership per Western Slope's own AppFolio directory: both properties are held by Situs Headwaters One LLC (Denver-area phone); Western Slope is the manager on both. That the LLC is a Situs Group entity — our other design partner — is an inference, not confirmed against the county assessor or the Secretary of State.
• Estimate/unverified. Current Mesa County HCV payment standards (dollar amounts) were not found in public sources; GJHA direct contact would be needed before quoting any dollar figure — which is exactly why decision 3 above recommends never quoting a number.
• Vendor research gap. No vendor (EliseAI, Yardi, RealPage, Entrata, AppFolio, Funnel, Zuma) publishes what its AI actually says when asked "do you accept Section 8" or how it handles a VAWA disclosure — the behaviour list in section G had to be built from the law directly, not from vendor precedent.

Extension points used by this design

1. PropertyKnowledge.leasePolicy — add an affordable-program fact beside the existing voucher-acceptance fact; flows through the same text/email and voice renderers with no new plumbing.
2. The KB-conditional-exception pattern already used for the voucher-acceptance carve-out in the leasing prompt rules — the template for any new narrow, fact-gated affordable-housing carve-out.
3. The outbound-safety policy's applicability gate — the seam to scope a new policy variant to affordable-housing properties, same shape as today's capability/audience gate.
4. The per-property/per-call voice directive variable pair — the designed mechanism for injecting a scripted directive without a prompt-file merge; must be a separate fact variable, never a variable-gated sentence (renders as dead text otherwise).
5. The Property record and the AppFolio mapper types — currently no program/affordable field exists on either side; this is where ingestion starts (build plan PR 1).
6. Gera's key-registry IDENTITY class, and the reserved-but-unbuilt condition {program | leaseFormId | unitType | assetTypes} attribute for regulated stock — the architecturally intended home for this once the org/property model ships (see the open ruling in section D).
7. The gate registry — where a new affordable-housing gate/alert gets registered and drift-pinned, mirroring the existing fair-housing-judge row.
8. Topic labeling — no voucher/Section-8/affordable topic exists; a labeler bucket needs to be created from scratch, not extended.

Access dates for all vendor and legal research: September 11, 2026. Full research briefs (federal, Colorado, vendor landscape, and the fair-housing code inventory this design builds on) are held alongside this session's working notes, not republished here in full to keep this page to a single read.