24 CFR Part 100—Supplement to Notice of Fair Housing Accessibility Guidelines: Questions and Answers about the Guidelines
9.1 Q. If a building was used previously for a nonresidential purpose, such as a warehouse, office building, or school, and is being converted to a multifamily dwelling, must the building meet the requirements of the Fair Housing Act?
A. No, the Fair Housing Act applies to covered multifamily dwellings for first occupancy after March 13, 1991, and the Fair Housing Act regulation defines first occupancy as a building that has never before been used for any purpose. (See 24 CFR 100.201, for the definition of first occupancy, and also 24 CFR Ch. I, Subch. A, App. I.)
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