A Nevada apartment complex has a policy requiring all applicants to provide a Social Security number. A qualified foreign national with a taxpayer identification number (ITIN) is denied. This policy may violate:

Explanation

Policies that appear neutral but have a disproportionate impact on members of a protected class may violate fair housing law under the 'disparate impact' theory. A blanket SSN-only policy disproportionately affects foreign nationals (national origin protected class). HUD's guidance suggests landlords must consider equivalent identification like ITINs. The policy may be defensible if there is a legitimate, non-discriminatory business necessity — but must be the least restrictive means. Nevada Fair Housing applies these federal disparate impact standards.