Fair Housing and Sexual Harassment - Steps To Prevent Claims

- So, we want to welcome with me today, it's Kathi Williams. She's a partner in a law firm of Williams and Edelstein and she provides defense and preventative representation for the housing industry and all Civil Rights matters. Kathleen is a co-founder and partner of the Fair Housing Institute, which is a full-service training and consulting firm. So, we'd like to welcome, Kathi, welcome to episode number two. Are you excited? - Yeah, I am Jonathan. This is an important topic, so I think it's very timely, now that I've looked at the news this morning that we talk about it again. - Absolutely. Yeah. Seems to be one of the bigger topics overall. Last session, we dug into emotional support animals and that's been on the news, but sexual harassment has definitely been another major headline. So, that's what you deal with each and every day, so your insight is gonna be really valuable for all of us today. So, what we'd like to talk about is what does sexual harassment look like? How do we understand that in relation to housing providers. What are some practices? How can we avoid harassment claims, and towards the end, you and I were preparing and I'm really interested in hearing your feedback and your take on other types of harassment that are illegal with how it relates to protected categories. So, we've got a great session today and I look forward to hearing some feedback from all of our audience here. So, to get us going, everyone, we have prepared for you a little scenario to kinda give you a backdrop on some of the fabulous things Kathi's gonna share with us today. - I can't believe what Lucy just told me. I have to talk to our Property Manager. Hello, Lisa. I just heard something from a friend of mine whom I can't name. All I can say is that Tim, our maintenance guy, has another side to him. My friend told me that Tim walked by her yesterday and patted her on the rear and said, "nice butt." - Wow, I would never have thought he'd do something like that. - I know. I'm shocked. He has been here for such a long time. - Is your friend a resident? Would you mind sharing her name with me? - I don't think I can do that. My friend doesn't wanna get Tim in trouble and wants to just let it go. - Okay, well thanks for telling me. We'll just keep it between you and me. (chimes ringing) - So Kathi, what's your take on the little video? - Well, I would say, just like the people in our video, sometimes this is a pretty awkward conversation to have with anybody, including the employees that work for housing providers, and contrary to our video, this is not a topic that we should avoid or keep confidential because it has such serious legal ramifications. Now, while I'm talking about legal with you out there who are not aware, we are doing this training video for educational purposes only. This is not legal advice. I am an attorney, but I can't provide legal advice to hundreds of people out there, some of whom I probably know and some of whom I don't. So, just be aware. Don't count on what I tell you today as legal advice. You need to talk to your own lawyers if and when you have a need to, but in the meantime, let's talk about how to handle these claims and how to avoid them. We want to believe that this is obvious and everyone knows how to behave themselves at work, and so we want to believe that the training on sexual harassment isn't really necessary, but we only have to turn on the news or computers to realize that is not the case. This topic is as relevant today as it has ever been, and because it happens to be one of the most difficult, embarrassing, and extremely expensive Fair Housing and legal violation, it is really important that we talk about it and make sure we're clear on what it is and what it isn't, and maybe how to avoid it. - This is one of those things, Kathi, if you don't mind me interjecting, but is this one of those things that you see that is a once in a while case, or is it a very common challenge that housing providers are facing? - I think it's more common than any of us would really like to think. I have, in my career, had a number of Fair Housing cases that the topic was sexual harassment. They are one of the most difficult types of cases that I've ever dealt with, and I read the case law books regularly and it is shocking, sometimes, the cases that I find in those about situations with sexual harassment. Because of that fact, the Department of Justice and HUD has put together a task force where they are going around the country investigating claims of sexual harassment, and if the investigation shows that it is likely that it occurred, they are prosecuting these cases vehemently, and so far, both the awards in the court cases and the settlement amount of damages have been huge. So, this is a costly violation and one we don't wanna get involved with. - Right, so what would you recommend as a number one best practice, for everybody who's taking notes? What do people need to be paying attention to? - So, like we started out, I wanna keep emphasizing don't avoid this one. I get it that it's awkward. I get it that it's difficult, but don't avoid it. Just like any other housing management practice, it's important that employees be trained so that they can effectively address any claim if it arises, and avoid more serious claims, and those usually come from the fact that the initial claims were ignored, and I'm gonna give you lots of topics today in this webinar that can be used to do training in individual properties or in individual companies. - Yeah, yeah. Great point. Great point. Sometimes the training, at times, can get shoved under the rug a little bit, but it will cost us if we don't have something in place, and just because of the topic, it needs to be addressed. We gotta have the courage to be able to face it because it's real. - Absolutely. - So, if you could help us out, talking to people, sometimes a little bit of confusion when it comes it sexual harassment in an office environment versus what we deal with when it comes to Fair Housing. So, can you give us a little bit tighter definition of sexual harassment and how it relates to housing? - Sure, in housing, just like employment, we have two different definitions or types of sexual harassment. The first one, which is maybe the most severe, is what we call quid pro quo, that means you give me something, I give you something, and this is the type of behavior where we have demands for sex, and with the idea that you give me what I want, meaning for instance some kind of sexual behavior, and in return, I'll allow you to live in your apartment or I'll make it easier for you to live in your apartment by receiving extra benefits for services. So, that's the first type of sexual harassment. The second type is what we call hostile environment, and that is maybe a more common type of sexual harassment, and also a little bit more general type of harassment, and this is conduct based on statements, gestures, pictures, text messages that creates an environment where a resident feels unsafe to live there and doesn't feel comfortable continuing to live in their home. - Okay. So, that ... When you think of how people can connect the dots, so to speak, how does that lead over into a Fair Housing violation? Is that a fair question? - Sure. The thing about when these events happen, for instance in the beginning with our scenario with the maintenance employee kinda groping one of the residents, it's hard to know whether that would be quid pro quo or environment. For sure, it would be a harassing environment because that resident is gonna be pretty uncomfortable walking in the hall, in case she might pass the maintenance employee again. A couple of things, just general points about thinking about what activities or what behavior may cause a violation under the Fair Housing Act, be aware that if a resident, for instance, acquiesces in a demand for sex, but does so even though maybe she cooperates, it wasn't willing, and in that case there is still a violation. So usually, those kind of cases are not gonna happen with a maintenance employee. That's usually gonna happen with, for instance, a property manager or a supervisor. In that case, even though there is a sexual contact, that doesn't mean the person might still be a victim of sexual harassment, and still have a case against the property. Another just general statement that I always like to make is beware that sexual harassment can occur even if one person is not coming on to another person, even if they're not trying to get them in a sexual relationship. If they are indeed just harassing them, if they are belittling them and bullying them because of that person's sexual orientation or gender identity. That is also sexual harassment and usually that's what we call a harassing environment case. - Wow. Wow. That's heavy stuff, that's for sure. So, a lot to think about. A lot of different scenarios for everyone who's on the show, the webinar today, you really gotta put that into role playing environment, think of your community, think of all the different potential situations and environments that your team may be faced with and really talk so they'll be able to relate to it. So, to simplify it, with just a little bit more, Kathi, this slide really, you're a lawyer, you've gone to school for all of this, you deal with this everyday. How can we simplify it a little bit when it comes to the legal perspective? What do we need to know? - You know, when these cases go to court there are all kinds of issues with the facts and how they apply to the law. What HUD has done is created regulations to try to explain how the facts will apply to the law in housing discrimination, and this is the citation to the regulations, for those of you who are keeping, for instance, a resource book on various Fair Housing topics. There are several points that the regulations make. One is that the decision of whether behavior rises to the level of being a violation of the law is gonna depend on a lot of things. One thing it is gonna depend on is how the victim interprets the behavior. So for instance, in the second bullet point there, what that is talking about is if I am a stand-offish, reserved, timid, withdrawn person, my interpretation of flirting by a maintenance employee or grabbing my arm, or as in the scenario, even patting me on the butt, might be horrible and abusive. Those behaviors to someone else maybe wouldn't be, but what the law says is we take the victim where that person is. We don't make assumptions that, well, everyone should have known that that was just the maintenance employee being flirtatious. That wasn't really his intent to discriminate, but none of that matters. If I'm offended, if it severely upsets me, then that's the problem under the law, and so that's one thing the regulation is pointing out there. - Right, right. So, take it seriously. There's a lot of components to it and none of it should ever be ignored, and I think we touch on that a little bit more in the show in just a minute when it comes to you've got a lot of great points coming up on how to avoid and protect ourselves, but really having a good understanding of the law is definitely a huge help, but being in a position, I think we've got the point. Don't ignore it. It's there, it can happen, and as a company, it's not addressed that we have a firm stand and policies, and so on, then that's the culture that we could be bringing across to our team, and by extension, that touches the residents. - Yeah, and Jonathan, pull it back to the screen before. I wanna make one additional point there. - Sure. - And this is something for supervisors. See the second point? It's basically saying what the reg says, is just like the perpetrator of sexual harassment. If a person is in charge and could have made the harassment stop because they had the authority to do so, but failed to do so, for instance, because they ignore it, because they don't wanna deal with it, because they don't know how to deal with it. That person, under the Fair Housing Act, is also liable for illegal harassment. So, that's one reason supervisors have got to take this very seriously. It's not just the perpetrator that's gonna be in trouble. - Right. Right. Very good. So, that kinda circles back to maybe other parts of training. We know a lot of Property Management companies take into account leadership training, emotional intelligence type training. Those kind of all co-relate to being able to deal with something as heavy as the topic we're discussing today. So, let's jump the topic just for a minute, Kathi. What are some similarities that you see between sexual harassment in employment and in housing? What's your take on that? - Yeah, and that's, again, one of the important parts of making sure housing providers understand that while there are differences, for instance there are differences in laws. As an employer of a housing management company, for instance, is covered by the Equal Employment Opportunity Act, which is often called Title Seven of the Civil Rights laws. So, they are covered to make sure their employees don't discriminate. Under the Fair Housing Act, because sex is a protected category, then in a housing context, no one is permitted to sexually harass another person in housing. So, we have two different, excuse me, we have two different laws, but a lot of the case laws, a lot of the definition is the same, and housing providers are covered by both. They are covered as employers, they are covered as housing providers, and therefore, it's kinda double, it's doubly necessary that they address this topic, and that they address it on both levels, both as employers, and as housing providers. They need a plan how to avoid these claims from arising, and they need a plan for how to deal with them if and when they do, both on the employment context and the housing context. What I found is that large companies that have HR, Human Relations Departments, are well aware of employment discrimination and sexual harassment under that ... They are ... under the housing context. So, it's just important to remember that it could come from either side, if you will, of those companies. - Awesome, awesome. So, for everyone on the call today, go ahead and share your comments in the chat. We'd love your feedback. This is some golden explanation of what we're facing, but we'd love to hear you feedback. What do you think of it so far? Again, we wanna thank everyone for being here today. So, that kinda closes up this particular point, and if I can kind of close it out with how important it is that everybody knows exactly what the difference is, and what the scenarios that they may be facing. Make sure that there's something in place to handle these situations quickly, and make it part of, not only your new hire orientation, but it's something that should be discussed regularly, whether it be online training, your annual training that you do for your team, and other follow ups. So, all good items. Take a look at that Policies and Procedures manual and see, does it specifically address the two different types of sexual harassment that they could be facing and how do they relate? What is your policy, how do they handle those particular situations? Okay. So, let's get into our next section here. Who can make these claims? What individuals are typically involved, Kathi, in making claims against property management companies? - So, what we see in housing cases is a lot of the claims come up one of three ways. First is a resident or a resident's guest accuses an employee, or sometimes a contractor of the property management company, of sexually harassing them. Another way it arises, and you know what? This is surprising how often I hear about this. I conduct a lot of training of maintenance employees, and in that training, they talk to me frequently about the fact that it is the residents sometimes who are coming on to maintenance employees. So, sometimes the claims arise by an employee who is being sexually harassed by residents, and then finally, and we really need to remember this one, residents who accuse another resident of sexual harassment is something management has got to look at, just the way they look at any other claim of sexual harassment, and I'll explain more about that in just a little bit. - Okay, very good. Yeah, we knew this was gonna be meaty stuff and we're running close to our 30 minutes already, but we'll get through it. So, the first best practice you referred to was to not avoid it. So, second best practice we wanna share with everyone is to talk about and encourage good behavior. What are your thoughts on that, Kathi? - Well, there are a number of ways to talk about this, and as we said, sometimes this is the awkward part is talking about it. Well, encouraging employees to be friendly, but not friends, with residents and with co-workers and avoid engaging in the kind of behavior that we all recognize is flirtatious. Sometimes some people think being flirtatious is somehow like being complimentary to the person that were flirting with, and if you're out in a bar, that might be the case. If you are working in a multi-family housing environment, an employee is flirting with the resident, that is not innocent, and that could lead to these kinds of very, very difficult cases. So, they just need to remember where you work is not where you find your date, it's not where you find your sexual partners. Go somewhere else. And likewise, avoid the kind of physical contact, the hugging, rubbing shoulders, all of that, the patting on the bottom that we talked about in the beginning. When claims arise, you've got to look at them, you've got to process them immediately. So, when we say be friendly, not friends, a little more explanation. Don't socialize with your residents after you get off work, if you work there. That's pretty important and sometimes those kinds of social interactions can lead to, down the road, claims of sexual harassment. The only acception I would make to that general rule is if an employee lives where they work. If they do, I think it's unreasonable to ask them not to socialize with their neighbors. So otherwise, I think once people are off work, they need to leave the property and not hang around and watch football games and drink beer and go to the pool with their residents. Likewise, it's a good practice to avoid dating people that you work with for the reasons that we're talking about, and under no circumstances should you get involved with either someone who is your supervisor, or someone who's your subordinate, because that is the probably biggest issue, at least under Employment Discrimination law. - Right. And we're seeing a lot of the definitions of this being addressed in different environments. Like even with social networking, social media, text messages. All of those come into play as far as the law's definition of how sexual harassment can be applied. So, it's not just something. Right, Kathi? It's not just necessarily you're one on one with someone. Even digital options can definitely play a role in these types of situations. - That's a really good point, Jonathan. A lot of cases come down to text messages. It's shocking how many cases come down to text messages, and people think they can delete them, and there are experts out there, like you, Jonathan, that can recover those deleted text messages, and those are used frequently in these kind of cases. - Right. So, there's a lot that we can do to protect ourselves. You've heard it mentioned, everyone on the call here, boy, how important it is to make sure we train our team and that we keep ourselves up to date with what's going on, if we're the managers or leaders of our organization. Make sure that there's sexual harassment statements that are signed by all of your employees each and every year, and then when we get into another phase of how we can protect ourselves, the opening scene that we use there, Kathi, it kinda touched on, but we'll keep this a little bit quiet. So, why is that just a no-no? What's your thoughts? - You know, I've had a number of cases in my career when, for whatever reason, the manager or property agreed to keep something quite for various reasons. Sometimes it was because the resident asked them to because they thought it would be too embarrassing, and that has always turned out to be a terrible decision. So, if anyone starts a conversation, "well, will you just keep this between us," be aware that you cannot agree to that as a housing provider employee until you've heard what it's about, and if it's about something that could be illegal, you absolutely have to report it. You cannot keep it confidential, and you just need to be very clear about this. The other thing I would say that is really necessary and it's something that a lot of companies are lacking is it needs to be pretty well known, who do I go to if I have a complaint that I think is sexual harassment. Now, whether it is or not, ... at that point, irrelevant claim like that, and that should be clearly identified in your company, because otherwise, people don't know, and therefore, sometimes don't raise it. Both, again, in the employment context or in the housing context. - Right. Right. Good points. Good thoughts. So, protect ourselves, some nice thoughts on the next couple of slides that really help us to avoid claims, and some best tips when dealing. This one talks about, you know this situation. This is where almost some common sense comes into play. Fill out those forms. If you're a maintenance person, you're going to a home of a resident and they're not dressed properly, excuse yourself, don't do anything that would compromise you and your employment or the resident, and then we get into what other items can help our audience avoid claims. What's your thoughts when it comes to children that are home alone and social banter that a property management professional would have with a resident? What are some tips, Kathi, that you can share? - Well again, and this is the kind of thing that some people, unfortunately, think that is common sense, and it isn't. I can tell you from training thousands and thousands of housing professionals, people have different views on this, so it needs to be clearly stated that if a maintenance employee walks into an apartment, or if they're in there working and someone walks out naked, what should they do? And don't assume it's clear on that. What should they do? And then, what should they do? They should leave, obviously, right? And then, they should write it up. It might be an accident, might never happen again with that resident, but if it does, the second time, let's not assume it's an accident, and from then on, that employee needs to have someone else there before they go into a unit. I've had too many residents who have set up an employee or set up management for these kind of allegations by arranging to show up in their birthday suit when an employee is in their apartment. So, you're not protecting the resident, you're protecting the employee. That should never be forgotten. Going into an apartment when a child is home alone is very dangerous, and again, we're not just trying to protect the children, we're trying to protect the employees. So, even if the parents say, "oh, go ahead. It's okay. My son is there. I'm not home from work. Go ahead and go in and do the work." There needs to be a process where either you don't go in and you reschedule or you have another employee with you so it is not one employee and one or more children under age in the apartment at the same time. And then, of course, again, maybe what should be common sense, you can't assume that when you are joking around the property, in the elevator, in the parking lot, that that is not going to be overheard by someone, and unfortunately, it often is. So, when people are on the job, they need to just avoid that behavior and they should be reminded that they need to do that. - Right. Excellent tips. I'm glad you brought that out. Sometimes, everyone's version of common sense is a little bit different. So, as leaders, that's a great summary. Don't assume that common sense is just a common thread amongst all of our team. We need to make sure that things are clearly identified. So, powerful point. And at the same time, we can't forget certain things. So, we don't wanna differentiate between a potential claim by a resident versus someone who works with us. Right, Kathi? We need to document everything. Everything has to be the exact same policy when it comes to how things are investigated and cared for. You can't weigh one higher than the other. Correct? - Absolutely. And just don't forget, if a resident comes in complaining about another resident's sexual behavior, that should be treated exactly like any other sexual harassment claim. Housing Management likes to step away from those because they're awkward and who knows who said what to whom? But it is still a claim that has to be investigated. It has to be documented, and a full and fair investigation needs to occur, regardless of, I guess, what we call the perpetrator. Who that perpetrator is is not as important as how it is handled once the notification is made to Property Management. - Right, right. Very good. So, we're really going over time, Kathi, so I just wanna share something with the audience real quick and then we're gonna cover one other main point and then take a couple questions. This is gonna be available on our website. Some of these points that are on the next couple of slides about handling claims. Great bullet point. Maybe you're taking a picture right now, but we know you guys have a schedule that you're trying to .... We wanna get to our final main point today, and ... you can summarize this section for us, Kathi, and we know that some of these other slides will be helpful to all of our ... even after our session today. So, illegal harassment due to the other protected categories. Take it away. Sum it up. What is that? What does that mean? - Okay. So just like sex is a protected category, so is race, color, national origin, religion, familial status, and disability, and of course, sex. Just like sex, all of those people with all of those various protected categories are protected under the Fair Housing Act from being harassed because of their protected category. If something like that arises in your property, and if it is made known to any employee, and I do mean any employee of the property, the property is legally obligated to follow the kind of procedures we've been talking about. Don't avoid it. Look into it. Investigate it. Find out what you can find out. Document that you looked into it, and then make a determination, and sometimes you cannot decide whether it occurred or not. That is a determination. Don't avoid making that because sometimes ... even after you ... you don't know whether it occurred or not, but that in itself is both a decision and will mitigate damages if that resident turns around and sues you because you didn't make what that person is claiming (audio cuts out) illegal harassment stop. Your obligation is to do your best to look into it and take appropriate action once you do. It is not good enough to say, "call the police." Please, understand that. It's fine if you wanna tell residents that, but that in no way alleviates your obligation to make illegal harassment stop if it's going on in your property. And just remember that contractors are also covered by all this, so their harassment, it can be imputed to you as the management company because you brought them onto the property. So, you're always responsible for their behavior. - All right. Well, that's awesome. So, I mean, it sounds like even this one subtopic, we probably can do a whole webinar just on that. There's a lot of material, but maybe we'll get this on a future webinar when we can go into this in a little bit more detail. So, great show, Kathi. It's ... I learned a lot again, and you and I have been talking about this, getting ready for this webinar for months now, going over this material. You can leave reviews on our Facebook page, on Google, you can give us a review, or email us, at us, whatever. We'd love to hear your feedback on how valuable you find these sessions. So, to kind of wrap it up, I think this is what we put together, Kathi, is some tips and a nice summary. Don't ignore it, train your people, make sure that they know how to, the court claims, take everything seriously, and make sure that you investigate ... one of those things, well, why do we go through fire drills ... Kathi, any concluding ... statements to our audience today? - No, I don't think so. I hope you recognize this is a complex issue. I guess we didn't quite make it, but the reason we have ongoing training is so that we can address the various details in the next training we do. So, I hope you'll feel free to ask you questions. Jonathan, are we gonna have time for any questions? I know we're running over time. - So, I've got a couple here, and again, for those who need to jump off the call, thank you. Kathi and I and the team at the Fair Housing Institute, we really, really appreciate you taking time out of your day to be with us, 'cause it shows how important this topic is to you, as it is to us, to make sure we provide education, and again, we appreciate all of those who are customers, and if you're not right now, if you're interested in online courses, please visit FairHousingInstitute.com. So, here's a couple of questions that came in. The first one, it's gonna take me a minute to read it. What's your recommendation when the accounts of the two parties in the recent complaint are significantly different, there are no witnesses, and the accused had a minor and ... about nearly three years earlier? Does this warrant the dismissal requested by the complainant? That's a long question. I don't know if you wanna answer that one today or do you wanna answer that in the blog? (laughing) - I would just say that the very fact that there was a prior complaint concerns me and should concern you from the possibility or the chances of liability. So, you just have to do your best, and don't forget to ask the other employees. Sometimes they have information that they don't come forward with unless you sit down and talk to them, and make sure no one has additional information, and sometimes you have to pull that out of them if they're not willing. 'Cause they don't wanna get in the middle of something, so if you've done all that, then all you can do is explain your determination in writing to the claimant and tell them you're gonna keep your eyes open and that the claimant should come back to you if there is any further problems. That's the best you can do sometimes. - Yeah. Very good. And see one or two others here, Kathi. Let's see, what is this one. Oh, how does one file a complaint if they are not the manager of the property? Thank you, Karen, for the question. - That goes to the issue that all companies need to have a procedure and a person that everyone knows to go to, and a secondary person, in case the person who is being accused is that named person. So, everybody needs to know where to go. Do they go to HR? Do they go to the Property Manager? Do they go to the regional? That needs to be made clear and it sounds like, in your situation, it is not clear, and that's unfortunate and maybe that's an issue that should be raised with whoever is at the very top of your company. - Right. Okay, very good. Thank you. And then the last one, explain the difference between sexual harassment and creating a hostile environment. - Well, sexual harassment can be a hostile environment. Just be aware of that. That's one of the definitions. So, you can have a hostile environment that occurs because of sexual conduct and comments and pictures and text, or you can have a hostile environment caused by racial harassment, for instance. Both are illegal under the Fair Housing Act. - Very good. Very good. Okay, and I think one more just came in. Let's see if I can read this one. Gotta put my glasses on, Kathi. (laughing) Let's see. What if a resident comes outside with no shirt on a regular basis. I've asked them to please put on a shirt, take offense to this, and it sounds like also some of the residents take offense. - Oh, you know what? That's a tough one, because as we know, men frequently go shirtless, and that's not uncommon, and I don't think that's viewed, in general, as inappropriate dress for men, and that's very different for women, but if you have house rules that describe appropriate dress in common areas, and you, in those rules, state that going shirtless, whether you're a male or a female is inappropriate, then that would be something that you can enforce. I think that would have to be a written rule, however, before it's something you can enforce. - Good. One more, and then we're gonna close it off for today. Again, need to get my glasses. So, what do you do about post men and UPS workers who sexually harassment you? It took me a minute to read the question. So, I guess that question is having to do with people who are outside of our residents and outside of the staff of the property management company. The question is, what's the best procedure? - Yeah. I don't think there is a formal procedure, but I think that's the kind of thing that should be raised with the company, either the U.S. Post Office service or the UPS service, and the best way to get their customer service people is online, and the more specific the information you can give them, the better. I assure you that if you use the name of the person, the address that that person is serving, I strongly believe that those companies are gonna get that person and talk to them. So, I would address it with the corporation customer service online who you can reach via the computer. - Right, right. Okay. Well, fantastic, Kathi. Thank you again. It's always fun to get on these webinars. Our second episode, and we had well over 300 people today, so that's awesome and fantastic how many people are just loving this education, and great feedback and great questions. Just to kind of wrap it up, we'll be in a blog post with a recorded version, and more than likely a transcript of the call today, the episode. ... if you wanna be able to take enough notes. So, just be on the lookout for your email and a link that will take you to that post. So again, thank you, everyone for being here today. We'll have another webinar coming up in a couple of months. So, we'll announce that soon. Kathi, we had a great time, and we look forward to our next episode of the Fair Housing Institute Providing Education. All right, everyone. Have a great afternoon. Have a great week.

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