DISCLOSURE OF TENANT SELECTION CRITERIA PURSUANT TO
JUST HOUSING AMENDMENT INTERPRETIVE RULE 730.100
ICM PROPERTIES, INC., is an equal opportunity housing provider and does not discriminate on the basis of race, color, sex, gender identity, age, religion, disability, national origin, ancestry sexual orientation, marital status, parental status, military status, or source of income.
Rental applications are accepted or denied in compliance with applicable housing laws.
PRE-QUALIFICATION: VERIFICATION OF RENTAL, EMPLOYMENT, INCOME, AND CREDIT HISTORY
Upon completion of your rental application providing basic personal information, ICM processes each application using a commercially available, comprehensive, electronic tenant background search service which yields a Rental Score. No criminal background check is conducted at this stage of the application process. Pre-qualification includes the following evaluations:
- Rental Score. Applicants with a Rental Score below 400 are denied. Applicants with a Rental Score between 400 and 600 may require a guarantor and/or additional review of proof of income, employment history, or additional documentation. An applicant's "Rental Score" is determined from a mathematical analysis of information found in your consumer credit report, application, and previous rental history. The consumer credit report may include payment history, number and type of accounts, collection activity, outstanding debt, and inquiries. In addition, the rental scoring process may consider information such as income to rent ratio, previous eviction and subprime credit records. Note that your rental score does not include or otherwise reflect any criminal records.
- A collection action instituted on any judgment within the last four (4) years and which remains unpaid will result in denial.
- A bankruptcy filing within the last four (4) years will result in denial.
- Rental History.
- Applicant must have verifiable rental history.
- Evidence of evictions, abandonment, or rent left owing to a prior landlord within seven (7) years of application date are grounds for denial.
- A poor rental reference within the last two (2) years is grounds for denial.
- Income. ICM does not discriminate on the basis of the applicant's source of income. The applicant's gross monthly income from all sources must be at least three times the applicant's monthly rental obligation. If minimum income threshold is not met, the application may be denied unless another individual guarantees the applicant's obligations under the lease.
- All lease guarantors must complete an application. Upon completion of an application providing basic personal information, ICM processes each guarantor application using a commercially available, comprehensive, electronic tenant background search service to produce a Rental Score. The Rental Score as well as the combination of the proposed rent plus the proposed guarantor's own housing obligations must qualify.
- False information supplied in an application shall result in the application being denied.
CRIMINAL BACKGROUND CHECK
Every application that is pre-qualified is subject to a criminal background check. ICM uses a commercially available criminal background search service
ICM's application process does not consider criminal history older than three (3) years prior to the application date. Only evidence of criminal convictions, which excludes juvenile convictions will be considered in the application process upon receiving search results showing conviction(s) and will only be considered after timely receipt of information from the applicant disputing the accuracy and relevance of any convictions, at which time ICM will conduct an Individualized Assessment of the applicant's criminal conviction history and consider all factors relevant to an individual's criminal conviction history and whether that criminal conviction history negatively impacts the individual's ability to fulfill the responsibilities of tenancy, including, but not limited to:
- The nature, severity, and recency of the conduct underlying the individual's specific conviction(s);
- The nature of the individual's sentencing;
- The number of the individual's convictions;
- The length of time that has passed following the individual's most recent conviction;
- The age of the individual at the time of the most recent conviction;
- Evidence of rehabilitation;
- The individual's tenant history before and/or after the conviction;
- Whether the criminal conviction(s) was/were related to or a product of the applicant's disability; an
- If the applicant is a person with a disability, whether any reasonable accommodation could be provided to ameliorate any purported demonstrable risk.
If the Multi-State Sex Offender report returns a "match," the application will be denied.
ICM reserves the right to deny any application or continuing occupancy of any apartment on the basis of a current sex offender registration requirement pursuant to the Sex Offender Registration Act or similar law that is applicable in Chicago; a current child sex offender residency restriction; or when federal or state law mandates such denial.
YOUR RIGHTS AFTER A CRIMINAL BACKGROUND SEARCH
Section 42-38 of the Cook County Code of Ordinances gives you the right to dispute the accuracy and relevance of any conviction shown in a criminal background search and to provide mitigating information, including evidence of rehabilitation.
Before an owner may deny admission or continued occupancy on the basis of a conviction, the owner must first give the individual sufficient notice and an opportunity to dispute the accuracy and relevance of the conviction.
PROCEDURES
- Within five (5) days of obtaining a background check on an applicant, the housing provider must deliver a copy of the background check to the applicant. The housing provider must complete delivery in one of the following ways: (1) in person, (2) by certified mail, or (3) by electronic communication (e.g., text, email).
- Once a housing provider completes delivery, the applicant shall have an additional five (5) business days to produce evidence that disputes the accuracy or relevance of information related to any criminal convictions from the last three (3) years. Information is relevant if it affects the likelihood that the applicant poses a demonstrable risk to the personal safety and/or property of others. "Demonstrable risk" refers to the likelihood of harm to other residents' personal safety and/or likelihood of serious damage to property. When the applicant is a person with a disability, "demonstrable risk" must be based on (a) objective evidence and (b) a conclusion that any purported risk cannot be reduced or eliminated by a reasonable accommodation.
- A housing provider must either approve or deny an individual's housing application within three (3) business days of receipt of information from the applicant disputing or rebutting the information contained in the criminal background check.
- Any denial of admission or continued occupancy based on a conviction must be in writing and must provide the applicant an explanation of why denial based on criminal conviction is necessary to protect against a demonstrable risk of harm to personal safety and/or property.
- The written denial must also contain a statement informing the housing applicant of their right to file a complaint with the Commission.
COOK COUNTY COMMISSION ON HUMAN RIGHTS
Additional information and procedural rules may be obtained from the Cook County Commission on Human Rights: https://www.cookcountyil.gov/agency/commission-human-rights-0. The Commission may also be contacted at their office, located at 69 W. Washington Street, Suite 3040 Chicago, IL 60602, or via telephone at 312-603-1100.