Ban Door-to-Door Solicitations, with One Exception
Most sites ban door-to-door solicitations for the protection and comfort of residents. But HUD says you must allow this practice in one specific situation—for resident organizers. Here's a look at what you can and cannot do, and how to make sure your policy doesn't violate HUD rules.
Why Ban Makes Sense
Banning door-to-door solicitations at your site helps you in two key ways. First, it protects your residents from crime and injury. Door-to-door solicitations can create security risks. It's difficult to monitor outsiders roaming around your site and to know whether their solicitation activity is even legitimate. And even if residents want to go door-to-door with something as seemingly innocent as selling Girl Scout cookies, you still must consider possible risks. You don't want your residents put into a situation where an unexpected knock at the door causes them concern for their safety.
Residents at sites for the elderly are particularly vulnerable to solicitation by questionable individuals. In fact, con men often target the elderly with their scams. It's your responsibility to protect all your residents against such activity to the best of your ability.
Banning door-to-door solicitations also helps to shield your residents against a common nuisance and protect their privacy. Most people don't want to be bothered at home. Eliminating the chance of an unwanted knock at the door demonstrates to your residents that you respect their privacy and want to prevent annoying intrusions.
The Activity You May Not Ban
HUD's rule on resident participation says you must let organizers—whether they are residents or nonresidents—help your residents organize and operate a resident organization [CFR, Title 24, Chapter IX, Part 964]. According to the rule, you must permit the organizers access to your site to do such things as:
Distribute leaflets to residents and place leaflets under doors and in common areas; and
Approach residents and conduct door-to-door surveys to poll residents and offer information about resident organizations.
If the organizer doesn't live at your site, you may require that a resident accompany the organizer while he or she is at your site. But, HUD says, you can do this only if you have a “consistently enforced written policy” against solicitations. Absent such a policy that bans door-to-door solicitations, you must give nonresident organizers the same access and privileges you extend to other nonresidents who come to your site.
Make It a House Rule
A good way to ensure that you have a consistently enforced written policy is to develop a house rule on solicitations. Your rule, like our Model Policy: Adopt House Rule to Ban Solicitations, should make the following points:
No door-to-door solicitation is permitted at your site. Make it clear that this applies to residents as well as outsiders.
Show that you will cooperate with residents who want to sell items or solicit for charity by inviting them to contact you for alternatives to going door-to-door. These can include posting a sign on a billboard in a common area or a site-sanctioned event such as a craft-fair or merchants mart where residents can sell items.
Make the exception for resident organizers. Specify in the house rules what activities are permitted—that they may canvass residents door-to-door to determine interest in organizing or offer information, post information, and distribute leaflets.
Outline conditions for resident organizers, such as how and when they can canvass residents, that nonresidents must be accompanied by a resident, and any limits on the number of times they may canvass. Even though organizers have the right to canvass under the HUD rule, your residents also have the right not to be bothered after they've made their preference known.
Request that residents report any unauthorized solicitations.
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|Adopt House Rule to Ban Solicitations|