HUD has entered into a Voluntary Compliance Agreement (VCA) with Allied Jewish Apartments (AJA), a Denver housing provider, under which AJA will create 20 fully accessible units by June 30, 2009; develop a plan to create eight accessible hearing and vision-impaired units within three years; implement procedures to use those units for people needing the accessible features; revise its admissions policy to eliminate the independent living requirement, medical assessments, and mandatory release of medical information; implement reasonable accommodation policies; and eliminate deposits for assistive animals.

AJA's portfolio includes 400 assisted elderly/disabled units in three buildings. The buildings are located in a prime upscale area near downtown Denver and are within walking distance of shopping, free community-based entertainment, and other desirable amenities.

FHEO identified concerns related to discrimination on the bases of race, national origin, and religion and found AJA to be in non-compliance with Title VI in several program areas. For example, 29.67 percent of Denver's elderly population consists of racial minorities or those of Hispanic origin. However, only 4.1 percent of AJA's residents were racial minorities or of Hispanic origin despite the buildings' proximity to ethnically diverse communtiies with significant representation of African-American and Hispanic residents.

Half of AJA's residents are Russian immigrants -- a far higher percentage than represented in Denver's population. In addition, 12.1 percent of the Denver population speaks Spanish at home and does not speak English very well, and yet AJA's Limited English Proficiency Plan only served those whose primary language is Russian.