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Pattern-or-Practice Cases and Systemic Enforcement

13 minPRO
5/6

Key Takeaways

  • DOJ settlements routinely reach $1M–$5M+ with multi-year monitoring and mandatory reforms.
  • Three or more HUD complaints within two years create pattern-or-practice investigation risk.
  • Prevention requires centralized policies, training, record keeping, disparate impact analysis, and independent audits.
  • Systematic prevention costs $10K–$30K/year—negligible compared to seven-figure enforcement exposure.
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Test Your Knowledge

1.What distinguishes a pattern-or-practice case from an individual discrimination complaint?

2.What are the most common red flags that trigger systemic enforcement investigations?

3.What is the most effective systemic prevention strategy for a multi-property operation?