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HomeMy WebLinkAboutSt Joseph County AI - Compressed FinalBERKELEY COUNTY ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE FOR ST. JOSEPH COUNTY 2025-2029 City of South Bend City of Mishawaka St. Joseph County St. Joseph County Housing Consortium 2025 Analysis of Impediments to Fair Housing i Table of Contents Executive Summary ........................................................................................................ 1 I. Introduction ........................................................................................................... 14 II. Background Data .................................................................................................. 17 A. Population, Race, Ethnicity, and Religion ..................................................... 19 B. Households ................................................................................................... 47 C. Income and Poverty ...................................................................................... 62 D. Employment .................................................................................................. 78 E. Housing Profile .............................................................................................. 90 F. Financing....................................................................................................... 97 G. Household Types ........................................................................................ 115 H. Housing Problems ....................................................................................... 124 I. Cost Burden ................................................................................................ 132 J. Disabled Households .................................................................................. 139 III. Review/Update to Original Plan .......................................................................... 146 A. Summary of 2020 Impediments .................................................................. 146 IV. Impediments to Fair Housing 2025 ..................................................................... 154 A. Fair Housing Complaints ............................................................................. 154 B. Public Sector ............................................................................................... 180 C. Private Sector .............................................................................................. 227 D. Citizen Participation .................................................................................... 239 V. Actions and Recommendations ........................................................................... 247 A. Impediments to Fair Housing Choice .......................................................... 247 B. Activities and Recommendations to Affirmatively Further Fair Housing ...... 255 VI. Certification ......................................................................................................... 257 VII. Appendix ............................................................................................................. 258 A. Appendix A .................................................................................................. 258 B. Appendix B .................................................................................................. 258 Table of Contents 2025 Analysis of Impediments to Fair Housing Executive Summary 1 Executive Summary The St. Joseph County Housing Consortium is an entitlement community for the HOME Investment Partnership (HOME) Program. The Cities of South Bend and Mishawaka, Indiana are entitlement communities under the U.S. Department of Housing and Urban Development’s (HUD) Community Development Block Grant Program (CDBG) and together with the County of St. Joseph, Indiana comprise the St. Joseph County Housing Consortium. In accordance with the Housing and Community Development Act of 1974, as amended, each entitlement community must “affirmatively further fair housing.” In order to demonstrate that the entitlement community is “affirmatively furthering fair housing,” each community must conduct a Fair Housing Analysis which identifies any impediments to fair housing choice and what steps it will take to affirmatively further fair housing. HUD advises communities that the Analysis of Impediments to Fair Housing should also address the Fair Housing Act, Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, Section 109 of Title I of the Housing and Community Development Act of 1974, Title II of the Americans with Disabilities Act of 1990, Architectural Barriers Act of 1968, Age Discrimination Act of 1975, Title IX of the Education Amendments Act of 1972, Executive Order 11063, Executive Order 11246, Executive Order 12892, Executive Order 12898, Executive Order 13166, and Executive Order 13217. The HUD Fair Housing and Equal Opportunity (FHEO) Office has advised Federal entitlement communities to update their Analysis of Impediments (AI) to Fair Housing Choice to coincide with their Five Year Consolidated Plan, and then every five (5) years thereafter. As part of its Annual Action Plan, each City must additionally sign certifications every year stating that the Cities will affirmatively further fair housing. This means that the Cities will conduct an Analysis of Impediments to Fair Housing Choice (AI), take appropriate actions to overcome the effects of any impediments identified through the AI, and maintain records reflecting what analysis and corrective actions were taken. St. Joseph County previously prepared an Analysis of Impediments to Fair Housing Choice in 2020. The St. Joseph County Housing Consortium has prepared this 2025- 2029 Analysis of Impediments to Fair Housing Choice (AI) in cooperation with the City of South Bend and the City of Mishawaka. The findings produced through this analysis will be further addressed in each City’s FY 2025-2029 Five Year Consolidated Plan. This analysis focuses on the status and interaction of six (6) fundamental conditions within St. Joseph County: 2025 Analysis of Impediments to Fair Housing 2 The sale or rental of dwellings (public or private); The provision of housing brokerage services; The provision of financial assistance for dwellings; Public policies and actions affecting the approval of sites and other building requirements used in the approval process for the construction of publicly assisted housing; The administrative policies concerning community development and housing activities, which affect opportunities for minority households to select housing inside or outside areas of minority concentration; and Where there is a determination of unlawful segregation or other housing discrimination by a court or a finding of noncompliance by HUD regarding assisted housing in a recipient’s jurisdiction, an analysis of the actions which could be taken by the recipient to remedy the discriminatory condition, including actions involving the expenditure of funds made available under 24 CFR Part 570. The Fair Housing Act was originally passed in 1968 to protect buyers and renters from discrimination from sellers and landlords by making it unlawful to refuse to sell or rent property to persons included under the category of a protected class. The Fair Housing Act prohibits discrimination against persons based on their race, color, religion, sex, national origin, disability, or familial status in the sale, rental, and financing of housing. Executive Summary 2025 Analysis of Impediments to Fair Housing 3 As population shifts and economic trends grow, Fair Housing issues vary drastically between jurisdictions and regions. Therefore, the St. Joseph County Housing Consortium is taking a more efficient and proactive approach towards affirmatively furthering fair housing choice for County residents on both a local level and a regional level. The collaboration between the City of South Bend, Indiana, the City of Mishawaka, Indiana, and St. Joseph County has produced beneficial insight into the issues affecting the housing market of St. Joseph County. While certain fair housing issues are regional in scale, this AI strives to identify strategies and goals it can take to address the barriers that are impacting Fair Housing Choice for the County’s residents. The methodology employed to undertake this Analysis of Impediments included: Research: A review was performed of the City of South Bend’s, City of Mishawaka’s and St. Joseph County’s zoning ordinances. The most recent demographic data for the County was analyzed from the U.S. Census, which included general, demographic, housing, economic, social, and disability characteristics. THE PROTECTED CLASSES Race Color Religion SexNational Origin Disability Familial Status Executive Summary 2025 Analysis of Impediments to Fair Housing 4 A review of the U.S. Department of Housing and Urban Development Comprehensive Housing Affordability Strategy (HUD-CHAS) data was undertaken. A review of financial lending institutions through the Home Mortgage Disclosure Act (HMDA) database was completed. A review of the real estate and mortgage practices was undertaken. Home mortgage foreclosure data was also reviewed. Meetings/Interviews: Meetings were conducted with the following: ARC of Indiana Brightpoint St. Joseph County Area Planning Commission 1st Source Bank Northwest Bank Communitywide Credit Union Northern Indiana Minority Business Association St. Joseph County Continuum of Care United Way of St. Joseph County St. Joseph County Department of Health Housing Authority of the City of South Bend Housing Authority of the City of Mishawaka Habitat for Humanity of St. Joseph County Intend Indiana Indiana Health Centers South Bend Heritage Foundation Hurry Home Health Plus Indiana Veterans’ Administration Northern Indiana Healthcare System Youth Service Bureau St. Margaret’s House Salvation Army Kroc Center Center for the Homeless Cultivate Food Bank for Northern Indiana Portage County Trustee The Clubhouse Monroe Park Neighborhood Association Near Northwest Neighborhood, Inc Executive Summary 2025 Analysis of Impediments to Fair Housing 5 Goodwill Bridges Out of Poverty Dismas House Transpo Mishawaka Homeless Coalition YWCA North Central Indiana Surveys were sent to each housing, social service, and community development agency that was invited to the roundtable discussions. Follow up phone calls were made when an organization neither returned a survey nor attended a meeting. Analysis of Data: Low- and moderate-income areas were identified and mapped. Concentrations of minority populations were identified and mapped. Concentrations of owner-occupied and renter-occupied housing units were identified and mapped. Fair housing awareness in the community was evaluated. The locations of Housing Cost Burdens throughout the County were analyzed. The locations of CDBG and HOME expenditures throughout the area were analyzed. The Consortium’s Five Year Goals and Objectives were reviewed. Potential Impediments: Public sector policies that may be viewed as impediments were analyzed. Private sector policies that may be viewed as impediments were analyzed. The status of previously identified impediments was analyzed. Citizen Participation: Electronic copies of a fair housing survey were made available to neighborhood groups and citizens through SurveyMonkey.com. The online survey produced 195 responses in total, surveys were available in English and Spanish. See copy of survey form in the Appendix Section. The St. Joseph County Housing Consortium held two (2) Public Meetings to engage the public and local organizations/agencies and help identify issues impacting Fair Housing Choice. The First Public Meeting was held on Wednesday, August 7, 2024 at the South Bend Tech Resource Center in South Bend and the Second Public Meeting was held on Thursday, August 8, 2024 at the Mishawaka City Hall. Notices for the public meetings were published in the “The South Bend Tribune,” the local newspaper of general circulation in the area, and in the Spanish language newspaper, “El Puente,” and published on its digital publication site “webelpuente.com.” Executive Summary 2025 Analysis of Impediments to Fair Housing 6 The St. Joseph County Housing Consortium met with representatives from twenty-eight (28) local housing, community development, realtors, and social service organizations through a series of small group discussions. These were held with the following types of organizations: Local housing authorities Advocacy organizations Direct housing stakeholders Social service providers Office of Diversity and Inclusion Planning organizations Faith-Based Organizations Local fair housing advocacy organizations Transportation groups Banks/financial organizations The 2025-2029 Analysis of Impediments to Fair Housing Choice was made available on the City of South Bend’s website at https://southbendin.gov/department/community-investment/neighborhood- development/ and the City of Mishawaka’s website at http://mishawaka.in.gov/communitydevelopment, and a hardcopy was placed at the following locations beginning on November 27, 2024: The St. Joseph County Public Library (all branches) Mishawaka Public Library (all branches) Walkerton Public Library New Carlisle-Olive Township Public Library City of South Bend Department of Community Investment City of South Bend Office of the Clerk City of Mishawaka Planning Department The St. Joseph County Housing Consortium held two Public Hearings on the “draft” 2025-2029 Analysis of Impediments on Tuesday, December 10 in the City of South Bend and Wednesday December 11, 2024 in the City of Mishawaka. There were no public comments. Based on the data analysis and citizen participation process, the City staff in South Bend and Mishawaka identified the following issues impacting fair housing choice in St. Joseph County: Housing Opportunities: There is a lack of affordable housing in St. Joseph County that is decent, safe, and sanitary. Executive Summary 2025 Analysis of Impediments to Fair Housing 7 There is a lack of Federal and State funds for housing subsidies and the development of new affordable housing is not economically feasible for private developers. There is a lack of affordable rental units within the County. Rent has increased to the point where 46.0% of all rental households in the County are cost burdened. There is a lack of affordable housing units in areas of opportunity where low- income persons and households may move. There is a lack of financing to support the purchase of affordable starter homes. There is enough vacant land for infill housing, but a lack of financial incentives to develop affordable housing on the vacant land. Housing Choice: Housing units that are deteriorated and below code standards tend to be available at affordable rents. The special needs population in St. Joseph County, particularly in the City of South Bend, has grown. It is necessary to rehabilitate and construct housing units which are accessible to this growing population. There is a need to demolish vacant housing units which are a blighting influence on neighborhoods and prevent new housing developments. There are physical, economic, and social justice barriers that impede the development of new affordable and accessible housing in St. Joseph County. There is a lack of "mixed-income" housing being built in the County. Cost Burden: Approximately 14.2% of homeowners and 42.2% of renters in the County are cost overburdened of 30% or more. Seniors, on fixed income, cannot afford to make the repairs, alterations, and accommodations to their homes to make them accessible to their needs. Disability/Accessibility: There is a lack of housing in the County that is accessible and affordable for the elderly, the disabled, and persons with special needs. The denial by landlords to make reasonable modifications and accommodations limits the amount of accessible units in the County that are for rent for persons with special needs. Fair Housing: Zoning ordinances that were meant to prevent student rentals have been far- reaching, and have negatively affected protected classes. Tenants and homebuyers do not always file housing discrimination complaints when renting or buying a home. Persons with Limited English Proficiency (LEP) do not always have a fair housing choice. Executive Summary 2025 Analysis of Impediments to Fair Housing 8 There is a lack of cooperation on the part of landlords to address accessibility issues. There is a lack of awareness of tenants' rights, including what reasonable modifications and accommodations are. Access/Mobility: The lack of public transportation in the County is not convenient for work, health care, shopping, etc., which limits the choices where a low-income household can live. A lack of sidewalks in neighborhoods limits walkability for disabled and elderly residents of the County. Families and individuals have a right to live wherever they chose if affordable housing is available outside areas of concentration. Using these findings, the Cities of South Bend and Mishawaka developed the following impediments for the 2025-2029 Analysis of Impediments to Fair Housing Choice and defined specific goals and strategies to address each impediment. Impediment 1: Lack of Affordable Housing for Sale The median value and cost to purchase a single-family home in St. Joseph County that is decent, safe, and sound has increased significantly to over $165,700. For the City of South Bend it is over $113,800, and for the City of Mishawaka it is $128,200. This limits the choice of housing for lower-income households throughout the County and in both Cities. Goal: Development of for-sale, single-family homes for lower-income households will occur through new construction, infill housing, and the rehabilitation of vacant structures throughout St. Joseph County and the Cities of South Bend and Mishawaka. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka: 1-A: Support and encourage plans from both private developers and nonprofit housing providers to develop and construct new affordable housing that is for sale for lower-income households throughout the Cities and County. 1-B: Support homebuyer education and training programs to improve homebuyer awareness and increase the opportunities for lower-income households to become homebuyers by affirmatively furthering fair housing choice. Executive Summary 2025 Analysis of Impediments to Fair Housing 9 1-C: Provide funds for down payment and closing cost assistance to lower- income households. 1-D: Promote housing counseling programs for first-time homebuyers. Impediment 2: Affordable Rental Housing The current supply of rental housing is not necessarily affordable to lower-income households. The monthly housing cost for apartments has steadily increased to the point that 46.0% of all rental households in St. Joseph County, 49.0% of all rental households in South Bend, and 44.5% of all rental households in Mishawaka are considered cost burdened by 30% or more. Goal: The development of affordable rental housing will occur throughout the County and both Cities, especially for households whose income is less than 60% AMI, through new construction, the rehabilitation of vacant buildings, and the development of mixed-income housing, to reduce the number of lower-income households who are cost burdened. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  2-A: Support and encourage both private developers and nonprofit housing providers to develop plans for the construction of new affordable and mixed- income rental housing.  2-B: Support and encourage the rehabilitation of the existing housing stock and new housing which will be decent, safe, sound and affordable rental housing to lower-income households.  2-C: Support and encourage the rehabilitation of the existing housing stock and new housing which will be decent, safe, sound and affordable rental housing to lower-income households.  2-D: Provide financial assistance in the form of development subsidies, so low- income households that are cost burdened, particularly households whose incomes are at or below 60% of AMI, are able to afford decent, safe, and sound housing.  2-E: Promote partnerships with the local housing authorities and private and nonprofit housing developers to construct additional Low Income Housing Tax Credit (LIHTC) multi-family rental housing in high opportunity areas of the County and Cities. Executive Summary 2025 Analysis of Impediments to Fair Housing 10 Impediment 3: Continuing Need for Accessible Housing Units As an older built-up environment, there is a lack of accessible housing units in St. Joseph County and the Cities of South Bend and Mishawaka. Since 41.5% of the County’s housing units, 60.6% of South Bend’s housing units, and 31.3% of Mishawaka’s housing units were built prior to 1960, these units were not constructed with accessibility features. It is estimated that 13.4% of the County’s overall population, 14.4% of South Bend’s population, and 16.4% of Mishawaka’s population is classified as disabled. Goal: Increase the number of accessible units for the physically disabled and developmentally delayed through new construction and rehabilitation of existing housing. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  3-A: Promote programs to increase the amount of accessible housing through rehabilitation of existing housing stock for homeowners and renters.  3-B: Encourage the development of new construction of accessible and visitable housing through financial or developmental incentives.  3-C: Continue to enforce ADA and Fair Housing requirements for landlords to make “reasonable accommodations” for tenants who are disabled.  3-D: Continue to promote programs and provide funds to assist elderly homeowners with accessibility improvements to their properties so they may remain in their own homes. Impediment 4: Fair Housing Education and Outreach There is a continuing need to educate persons about their rights under the Fair Housing Act and to raise community awareness to affirmatively further fair housing. Goal: All residents of St. Joseph County and the Cities of South Bend and Mishawaka will have an increased awareness and knowledge of their rights under the Fair Housing Act and the County and Cities will continue to affirmatively further fair housing, especially for low-income residents, minorities, and the disabled population. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka: Executive Summary 2025 Analysis of Impediments to Fair Housing 11  4-A: Continue to promote fair housing awareness through the media, seminars, and training, to provide educational opportunities for all persons to learn more about their rights under the Fair Housing Act, Americans with Disabilities Act, and visitability.  4-B: Continue to provide and distribute literature and informational material in English and Spanish concerning fair housing issues, an individual’s housing rights, and the landlords’ responsibilities to affirmatively further fair housing, including laws regarding reasonable modifications and accommodations.  4-C: Continue to support and provide funding for the South Bend Human Rights Commission to provide testing services, education, outreach, referrals, and assistance in addressing fair housing complaints that may arise in the County and Cities.  4-D: Continue to work with the local Board of Realtors to educate and promote fair housing.  4-E: Strive for better intergovernmental cooperation between state and local partners, as well as community groups, to effectively identify and address potential barriers to affordable housing choice. Impediment 5: Private Lending Practices The HMDA data for St. Joseph County indicates that there may be a disparity between the approval rates of home mortgage loans originated from minorities and those originated from non-minority applicants. Goal: Approval rates for all originated home mortgage loans will be fair, unbiased and equal, regardless of race, familial status, and location. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  5-A: The Cities and County should consider using Federal and State funding to provide housing or credit counseling to potential low- and moderate-income homebuyers in impacted neighborhoods to decrease the number of denials due to poor credit, debt-to-income ratios, or incomplete applications.  5-B: The Cities and County should consider entering into an agreement with Indiana Legal Services, Inc. to perform research to determine if any patterns of discrimination are present in home mortgage lending practices for minorities and other protected classes when they wish to purchase properties located in impacted areas of the Cities or County. Executive Summary 2025 Analysis of Impediments to Fair Housing 12  5-C: The Housing Consortium should consider using Federal and State funding to provide a higher rate of public financial assistance to potential homebuyers in impacted neighborhoods to improve the loan-to-value ratio, so that private lenders will increase the number of loans made in these areas. Impediment 6: Impacted Areas of Concentration There are specific areas throughout the two Cities and the County where the concentration of low-income persons exceeds 70% of the area’s population, and areas with concentrations of minority persons. Goal: Promote the de-concentration of low-income and minority areas that may exist within the Cities of South Bend and Mishawaka to reduce concentrations of low- income households and minorities, while preserving fair housing choice for both low- income and minority residents. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  6-A: Support, promote, and plan for affordable housing developments outside areas of low-income concentration, while still supporting the improvement of housing within concentrated areas.  6-B: Market and promote housing opportunities for both minority and low-income residents outside areas of low-income concentration.  6-C: Provide financial assistance to low-income households to provide them with a choice to reside outside areas of low-income concentration. Impediment 7: Economic Issues Affecting Housing Choice There is a lack of economic opportunities in the County and both Cities which prevents low-income households from improving their income and providing an opportunity to live outside areas of low-income concentration. Goal: The local economy will provide new job opportunities, which will increase household income, and thus promote fair housing choice and mobility. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka: Executive Summary 2025 Analysis of Impediments to Fair Housing 13  7-A: Strengthen partnerships that enhance local businesses, expand the tax base, and create a more sustainable economy for residents and businesses.  7-B: Support and enhance workforce development and skills training that results in increased job opportunities and a living wage.  7-C: Continue to support programming that enhances entrepreneurship and small business development, expansion, and retention within low- and moderate- income and minority neighborhoods.  7-D: Continue to promote and encourage economic development with local commercial and industrial firms to expand their operations and increase employment opportunities. Impediment 8: Public Policies That May Affect Housing Choice Public policies such as community comprehensive plans and zoning ordinances sometimes affect the location of affordable housing, special needs housing, and the development process of these types of housing. Goal: The local governing bodies will review their public policies, plans, and ordinances to affirmatively further fair housing and eliminate any barriers or obstacles to fair housing choice. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  8-A: The Cities and County should consider making source of income a protected class, which would prevent landlords from rejecting tenants based on their source of income, i.e. Housing Choice Vouchers.  8-B: South Bend should continue, and the Mishawaka and St. Joseph County should consider offering vacant lots that they have acquired to private developers at no cost to promote the development of single-family affordable housing, along with providing development subsidies and reducing development standards.  8-C: The local zoning ordinances were reviewed and should be brought into compliance with the Fair Housing Act, especially the definition of “Family” and in particular protective classes and being permitted uses in all residential zoning districts.  8-D: The municipalities will annually review their zoning and development ordinances to make sure they are in compliance with the Fair Housing Act and the Americans with Disabilities Act. Executive Summary 2020 Analysis of Impediments to Fair Housing Introduction 14 I. Introduction The City of South Bend, IN and the City of Mishawaka, IN are both entitlement communities under the U.S. Department of Housing and Urban Development’s (HUD) Community Development Block Grant (CDBG) Program. Additionally, the Cities of South Bend and Mishawaka joined with St. Joseph County to form a HOME Consortium and are eligible for the HOME Investment Partnership (HOME) Program. South Bend is also an entitlement community for the Emergency Solutions Grant (ESG) program. In accordance with the Housing and Community Development Act of 1974, as amended, each entitlement community must “affirmatively further fair housing.” In order to demonstrate that the entitlement community is “affirmatively further fairing housing,” the community must conduct a Fair Housing Analysis which identifies any impediments to fair housing choice and what steps it will take to affirmatively further fair housing. The HUD Fair Housing and Equal Opportunity (FHEO) Office has advised the Federal entitlement communities to prepare a new Analysis of Impediments to Fair Housing Choice to coincide with the Five Year Consolidated Plan, and then every five (5) years thereafter. HUD defines “fair housing choice” as: This Analysis of Impediments to Fair Housing Choice consists of the following six (6) conditions: -The sale or rental of dwellings (public or private); -The provision of housing brokerage services; -The provision of financial assistance for dwellings; -Public policies and actions affecting the approval of sites and other building requirements used in the approval process for the construction of publicly assisted housing; -The administrative policies concerning community development and housing activities, which affect opportunities of minority households to select housing inside or outside areas of minority concentration; and -Where there is a determination of unlawful segregation or other housing discrimination by a court or a finding of noncompliance by HUD regarding “The ability of persons, regardless of race, color, religion, sex, national origin, familial status, or handicap, of similar income levels to have available to them the same housing choices” 2020 Analysis of Impediments to Fair Housing Introduction 15 assisted housing in a recipient’s jurisdiction, an analysis of the actions which could be taken by the recipient to remedy the discriminatory condition, including actions involving the expenditure of funds made available under 24 CFR Part 570. HUD-FHEO suggests that communities conducting an Analysis of Impediments should consider the policies concerning “visitability,” in Section 504 of the Rehabilitation Act, the Americans with Disabilities Act, and the Fair Housing Act. Housing that is “visitable” means that it has the most basic level of accessibility that enables persons with disabilities to visit the home of a friend, family member, or neighbor. “Visitable” housing has at least one accessible means of ingress/egress, and all interior and bathroom doorways have as a minimum a 32-inch clear opening. Section 504 of the Rehabilitation Act (24 CFR Part 8), known simply as “Section 504,” prohibits discrimination against persons with disabilities in any program receiving Federal financial assistance. The Americans with Disabilities Act (42 U.S.C. 12131; 47 U.S.C. 155, 201, 218, and 225) (ADA) prohibits discrimination against persons with disabilities in all programs and activities sponsored by state and local governments. The Fair Housing Act requires property owners to make reasonable modifications to units and/or public areas in order to allow a disabled tenant to make full use of the housing unit. Additionally, property owners are required to make reasonable accommodations to rules or procedures to afford a disabled tenant the full use of the housing unit. In regard to local zoning ordinances, the Fair Housing Act prohibits local government from making zoning or land use decisions, or implementing land use policies that exclude or discriminate against persons of a protected class. The Cities of South Bend and Mishawaka previously prepared an Analysis of Impediments to Fair Housing Choice for St. Joseph County, Indiana in 2020. The Cities of South Bend and Mishawaka have prepared this 2025-2029 Analysis of Impediments to Fair Housing Choice (AI) as the member Cities of the St. Joseph County Housing Consortium. The findings produced through this analysis will be further addressed in each City’s FY 2025-2029 Five Year Consolidated Plan. The document is designed to act as a planning tool, providing the St. Joseph County Housing Consortium with the necessary framework to strategically address any identified impediments to fair housing choice over the next five (5) years and 2020 Analysis of Impediments to Fair Housing Introduction 16 continue to make modifications based on events and activities in the community during that time period. In order to affirmatively further fair housing, the Cities of South Bend and Mishawaka must look beyond the boundaries of St. Joseph County and coordinate fair housing with Elkhart County, IN and Cass County, MI including the Cities of Elkhart, IN and Niles, MI. Fair housing choice is the central goal of the AI, which stresses that opportunities should be available to low-income residents and members of the protected classes who may want to live in or around St. Joseph County. 2025 Analysis of Impediments to Fair Housing Background Data 17 II. Background Data Description – St. Joseph County St. Joseph County, commonly called St. Joe County by residents, is a county located in the U.S. State of Indiana. As of the 2020 US Census, the population was 272,912, making it the fifth-most populous county in Indiana. Formed in 1830, it was named for the St. Joseph River which flows through it toward Lake Michigan. The county seat is South Bend. St. Joseph County is part of the South Bend–Mishawaka, IN-MI, Metropolitan Statistical Area. Description – South Bend City South Bend is the county seat of, St. Joseph County, Indiana, on the St. Joseph River near its southernmost bend. As of the 2020 census, the city had a total of 103,453 residents; its Metropolitan Statistical Area had a population of 324,501 and Combined Statistical Area of 812,199. It is the fourth-largest city in Indiana, serving as the economic and cultural hub of Northern Indiana. The University of Notre Dame is located just to the north in the unincorporated neighborhood known as Notre Dame, Indiana, and is an integral contributor to the region's economy. The area was originally settled in the early 19th century by fur traders and was established as a city in 1865. The St. Joseph River shaped South Bend's economy through the mid-20th century. River access induced heavy industrial development such as that of the Studebaker Corporation, the Oliver Chilled Plow Company, Bendix Brakes, and other large corporations to locate in the City. The population of South Bend declined after 1960, when it had a peak population of 132,445. This was chiefly due to migration to suburban areas as well as the demise of Studebaker and other heavy industry. Today, the largest industries in South Bend are health care, education, small business, and tourism. Remaining large corporations include Crowe LLP, Honeywell, and AM General. The city population is slowly growing again, after losing population for nearly fifty years. The old Studebaker plant and surrounding area, now called “Ignition Park,” has been redeveloped as a technology center to attract new industry. The city has also been featured in national news coverage for former Mayor Pete Buttigieg, who has achieved recognition for his various economic development projects within the city, his position as the youngest mayor to be elected in a city 2025 Analysis of Impediments to Fair Housing Background Data 18 of more than 100,000 residents, and his essay in which he came out as the first openly gay executive in the State of Indiana. A candidate in the 2020 Democratic Presidential primary race, Buttigieg is now the US Secretary of Transportation. Description – Mishawaka City Mishawaka’s recorded history began with the discovery of bog iron deposits at the beginning of the 1830s. Settlers arriving to mine the deposits founded the town of St. Joseph Iron Works in 1831. Within a few years, the town had a blast furnace, a general store, a tavern, and about 200 residents. Business prospered, and in 1833 St. Joseph Iron Works, Indiana City, and two other adjacent small towns were incorporated to form the City of Mishawaka. In September 1872, a fire destroyed three quarters of Mishawaka’s business district. However, the citizens rebuilt and attracted new industry. Mishawaka grew through both industry and agriculture. In the late 19th century, Mishawaka became known as the "Peppermint Capital of the World", since the area's rich black loam soil produced great quantities of mint. The Dodge Manufacturing Company, Perkins Windmills, the American Simplex motor car company, and the Mishawaka Woolen and Rubber Company (later Ball Band, then Uniroyal) were some of the major manufacturers in the City. Ball Band (Uniroyal) flourished in the 1940s after a 1930s strike, but finally closed its Mishawaka location in 1997 in the face of cheaper imports. Overall, manufacturing in Mishawaka peaked in the 1940s and began a slow decline due to industrial restructuring and imports. The economic base shifted to retail services and smaller industry. In 1979, University Park Mall opened north of Mishawaka, and the City has also become a bedroom community for the surrounding area. However, manufacturing still takes place in Mishawaka. In 1990, AM General began producing the HMMWV “Humvee” or “Hummer” for the United States military in its Mishawaka plant. It also supplies parts and complete vehicles for other automotive manufacturers, like Mercedes-Benz and Ford Motor Company, and will build the Joint Light Tactical Vehicle for the US Army beginning in 2025. Mishawaka is also home to Mullen Automotive, an electric vehicle manufacturer on the AM General campus, and Lippert Components, a supplier of components for recreational vehicles and manufactured homes. 2025 Analysis of Impediments to Fair Housing Background Data 19 A. Population, Race, Ethnicity, and Religion Below is a graph of the relative population change of St. Joseph County, the City of South Bend, and the City of Mishawaka. Source: U.S. Census data, 1930 through 2020 Comparative Populations South Bend’s population increased from 102,073 people in 2010 to 103,453 people in 2020 (an increase of 1.4%). - Growing for the first time in fifty years, South Bend’s 2010-2020 growth rate is lower than both Mishawaka and St. Joseph County. Mishawaka’s population increased from 48,252 in 2010 to 51,063 people in 2020 (an increase of 5.8%). - From 2010 to 2020, Mishawaka’s population increased at a faster rate than South Bend, St. Joseph County, or the South Bend- Mishawaka MSA. St. Joseph County’s population increased from 266,931 in 2010 to 272,912 people in 2020 (an increase of 2.2%). 2025 Analysis of Impediments to Fair Housing Background Data 20 - The two-county Metro Area at large saw a population increase from 319,224 people in 2010 to 324,501 people in 2020 (an increase of 1.7%). From 2010 to 2020 St. Joseph County’s population increased at a faster rate than the two-county Metro Area overall (Cass County, MI lost population over the same period). The City of South Bend’s growth rate was lower than St. Joseph County, but Mishawaka had a much higher rate than the county or MSA. This suggests that the City of Mishawaka is experiencing faster growth than the surrounding areas. The following map illustrates the population density of St. Joseph County. It is most densely populated in South Bend, which has focused on maintaining an urban core and has a higher percentage of multi-family and small-lot single-family housing. Mishawaka has maintained a suburban density level, similar to the unincorporated Notre Dame, Georgetown, Roseland, Granger, and Gulivoire Park areas. Outside of the northeastern corner of the County, the population density is quite low. This rural area is often agricultural in nature. 2025 Analysis of Impediments to Fair Housing Background Data 21 2025 Analysis of Impediments to Fair Housing Background Data 22 Race – St. Joseph County The following table highlights the racial composition of St. Joseph County as shown in the 2013-2017 and 2018-2022 American Community Surveys. Race and Hispanic or Latino Population in St. Joseph County Race and Hispanic or Latino 2013-2017 ACS 2018-2022 ACS # % # % Total 268,613 - 272,388 - One race 260,171 96.9% 252,180 92.6% White alone 212,328 79.0% 201,310 73.9% Black or African American alone 34,814 13.0% 35,089 12.9% American Indian and Alaska Native alone 1,152 0.4% 827 0.3% Asian alone 5,822 2.2% 6,947 2.6% Native Hawaiian and Other Pacific Islander alone 273 0.1% 176 0.1% Some other race alone 5,782 2.2% 7,831 2.9% Two or More races 8,442 3.1% 20,208 7.4% Hispanic or Latino 22,423 8.3% 25,949 9.5% Source: 2013-2017 and 2018-2022 ACS The most common race identified in St. Joseph County in 2017 was White alone with 212,328 residents or 79.0% of the population. The second most common was Black or African American alone with 32,951 residents or 13.0% of the population. 22,423 residents or 8.3% of the population were Hispanic or Latino of any race. The most common race identified in St. Joseph County in 2022 was White alone with 201,310 residents or 73.9% of the population. The second most common was Black or African American alone with 35,089 residents or 12.9% of the population. 25,949 residents or 9.5% of the population were Hispanic or Latino of any race. The proportional representation of White residents in St. Joseph County from 2017 to 2022 fell by over 5.0 percentage points (5.1% or 11,018 persons). There were no other changes in proportional representation from 2017 to 2022 that were larger than 5.0 percentage points. 2025 Analysis of Impediments to Fair Housing Background Data 23 Race – South Bend City The following table highlights the racial composition of South Bend City as shown in the 2013-2017 and 2018-2022 American Community Surveys. Race and Hispanic or Latino Population in South Bend City Race and Hispanic or Latino 2013-2017 ACS 2018-2022 ACS # % # % Total 101,928 - 103,084 - One race 97,598 95.8% 92,352 89.6% White alone 64,363 63.1% 57,611 55.9% Black or African American alone 26,910 26.4% 26,141 25.4% American Indian and Alaska Native alone 481 0.5% 478 0.5% Asian alone 1,465 1.4% 2,102 2.0% Native Hawaiian and Other Pacific Islander alone 120 0.1% 60 0.1% Some other race alone 4,259 4.2% 5,960 5.8% Two or More races 4,330 4.2% 10,732 10.4% Hispanic or Latino 14,686 14.4% 16,873 16.4% Source: 2013-2017 and 2018-2022 ACS The most common race identified in South Bend in 2017 was White alone with 64,363 residents or 63.1% of the population. The second most common was Black or African American alone with 26,910 residents or 26.4% of the population. 14,686 residents or 14.4% of the population were Hispanic or Latino of any race. The most common race identified in South Bend in 2022 was White alone with 57,611 residents or 55.9% of the population. The second most common was Black or African American alone with 26,141 residents or 25.4% of the population. 16,873 residents or 16.4% of the population were Hispanic or Latino of any race. The proportional representation of White residents in South Bend from 2017 to 2022 fell by over 5.0 percentage points (7.2% or 6,752 persons), and Two or More races rose by over 5.0 percentage points (6.2% or 6,402 persons). There were no other changes in proportional representation from 2017 to 2022 that were larger than 5.0 percentage points. Race – Mishawaka City 2025 Analysis of Impediments to Fair Housing Background Data 24 The following table highlights the racial composition of Mishawaka City as shown in the 2013-2017 and 2018-2022 American Community Surveys. Race and Hispanic or Latino Population in Mishawaka City Race and Hispanic or Latino 2013-2017 ACS 2018-2022 ACS # % # % Total 48,582 - 50,899 - One race 46,676 96.1% 47,143 92.6% White alone 41,261 84.9% 40,571 79.7% Black or African American alone 3,517 7.2% 4,373 8.6% American Indian and Alaska Native alone 367 0.8% 90 0.2% Asian alone 947 1.9% 1,279 2.5% Native Hawaiian and Other Pacific Islander alone 65 0.1% 22 0.0% Some other race alone 519 1.1% 808 1.6% Two or More races 1,906 3.9% 3,756 7.4% Hispanic or Latino 3,066 6.3% 3,149 6.2% Source: 2013-2017 and 2018-2022 ACS The most common race identified in Mishawaka in 2017 was White alone with 41,261 residents or 84.9% of the population. The second most common was Black or African American alone with 3,517 residents or 7.2% of the population. 3,066 residents or 6.3% of the population were Hispanic or Latino of any race. The most common race identified in Mishawaka in 2022 was White alone with 40,571 residents or 79.7% of the population. The second most common was Black or African American alone with 4,373 residents or 8.6% of the population. 3,149 residents or 6.2% of the population were Hispanic or Latino of any race. The proportional representation of White residents in Mishawaka from 2017 to 2022 fell by over 5.0 percentage points (5.2% or 11,018 persons). There were no other changes in proportional representation from 2017 to 2022 that were larger than 5.0 percentage points. Ethnicity – St. Joseph County The following table highlights the ethnicities of St. Joseph County residents at the time of the 2013-2017 and 2018-2022 American Community Surveys. 2025 Analysis of Impediments to Fair Housing Background Data 25 Ethnicity and Ancestry in St. Joseph County ANCESTRY 2013-2017 ACS 2018-2022 ACS # % # % Total population 268,613 - 272,388 - American 17,656 6.6% 12,049 4.4% Arab 1,193 0.4% 1,581 0.6% Czech 1,130 0.4% 1,016 0.4% Danish 622 0.2% 485 0.2% Dutch 5,192 1.9% 4,093 1.5% English 16,981 6.3% 21,258 7.8% French (except Basque) 5,271 2.0% 4,487 1.6% French Canadian 913 0.3% 782 0.3% German 57,574 21.4% 52,608 19.3% Greek 1,019 0.4% 6,070 2.2% Hungarian 8,512 3.2% 6,070 2.2% Irish 32,672 12.2% 32,513 11.9% Italian 11,574 4.3% 11,071 4.1% Lithuanian 508 0.2% 596 0.2% Norwegian 1,983 0.7% 1,790 0.7% Polish 27,978 10.4% 23,764 8.7% Portuguese 337 0.1% 143 0.5% Russian 1,271 0.5% 1,366 0.5% Scotch-Irish 1,842 0.7% 1,860 0.7% Scottish 3,542 1.3% 3,865 1.4% Slovak 563 0.2% 435 0.2% Sub-Saharan African 2,952 1.1% 5,433 2.0% Swedish 3,446 1.3% 2,933 1.1% Swiss 1,008 0.4% 0,086 0.4% Ukrainian 654 0.2% 377 0.1% Welsh 1,361 0.5% 1,531 0.6% West Indian (excluding Hispanic origin groups) 560 0.2% 306 0.1% Source: 2013-2017 and 2018-2022 ACS The most common ancestral group identified in St. Joseph County in 2017 was German with 57,574 residents or 21.4 % of the population. The second most common was Irish with 32,672 residents or 12.2% of the population. 2025 Analysis of Impediments to Fair Housing Background Data 26 The most common ancestral group identified in St. Joseph County in 2022 was German with 52,608 residents or 19.3% of the population. The second most common was Irish with 32,513 residents or 11.9% of the population. There was no change in proportional representation in St. Joseph County from 2017 to 2022 that was larger than 5.0 percentage points. Ethnicity – South Bend City The following table highlights the ethnicities of South Bend City residents at the time of the 2013-2017 and 2018-2022 American Community Surveys. Ethnicity and Ancestry in South Bend City ANCESTRY 2013-2017 ACS 2018-2022 ACS # % # % Total population 101,928 - 103,084 - American 4,578 4.5% 4,473 4.3% Arab 287 0.3% 213 0.2% Czech 234 0.2% 223 0.2% Danish 178 0.2% 191 0.2% Dutch 1,335 1.3% 1,009 1.0% English 4,974 4.9% 5,641 5.5% French (except Basque) 1,925 1.9% 1,121 1.1% French Canadian 141 0.1% 295 0.3% German 16,215 15.9% 13,939 13.5% Greek 278 0.3% 266 0.3% Hungarian 2,755 2.7% 1,932 1.9% Irish 9,435 9.3% 10,013 9.7% Italian 3,581 3.5% 3,606 3.5% Lithuanian 103 0.1% 271 0.3% Norwegian 570 0.6% 641 0.6% Polish 8,196 8.0% 6,193 6.0% Portuguese 55 0.1% 32 0.0% Russian 374 0.4% 305 0.3% Scotch-Irish 565 0.6% 746 0.7% Scottish 1,070 1.0% 967 0.9% Slovak 150 0.1% 108 0.1% Sub-Saharan African 1,771 1.7% 3,027 2.9% Swedish 954 0.9% 615 0.6% Swiss 415 0.4% 212 0.2% 2025 Analysis of Impediments to Fair Housing Background Data 27 Ukrainian 290 0.3% 120 0.1% Welsh 484 0.5% 346 0.3% West Indian (excluding Hispanic origin groups) 133 0.1% 228 0.2% Source: 2013-2017 and 2018-2022 ACS The most common ancestral group identified in South Bend in 2017 was German with 16,215 residents or 15.9% of the population. The second most common was Irish with 9,435 residents or 9.3% of the population. The most common ancestral group identified in South Bend City in 2022 was German with 13,939 residents or 13.5% of the population. The second most common was Irish with 10,013 residents or 9.7% of the population. There was no change in proportional representation in South Bend City from 2017 to 2022 that was larger than 5.0 percentage points. Ethnicity – Mishawaka City The following table highlights the ethnicities of Mishawaka City residents at the time of the 2013-2017 and 2018-2022 American Community Surveys. Ethnicity and Ancestry in Mishawaka City ANCESTRY 2013-2017 ACS 2018-2022 ACS # % # % Total population 48,582 - 50,899 - American 4,896 10.1% 2,017 4.0% Arab 287 0.6% 391 0.8% Czech 63 0.1% 204 0.4% Danish 141 0.3% 54 0.1% Dutch 1,078 2.2% 1,126 2.2% English 3,066 6.3% 4,871 9.6% French (except Basque) 1,145 2.4% 940 1.8% French Canadian 258 0.5% 150 0.3% German 10,656 21.9% 10,662 20.9% Greek 214 0.4% 204 0.4% Hungarian 1,527 3.1% 1,108 2.2% Irish 5,954 12.3% 6,411 12.6% Italian 2,281 4.7% 2,559 5.0% Lithuanian 102 0.2% 50 0.1% Norwegian 421 0.9% 181 0.4% 2025 Analysis of Impediments to Fair Housing Background Data 28 Polish 4,362 9.0% 3,111 6.1% Portuguese 30 0.1% 62 0.1% Russian 366 0.8% 536 1.1% Scotch-Irish 366 0.8% 494 1.0% Scottish 925 1.9% 1,031 2.0% Slovak 35 0.1% 32 0.1% Sub-Saharan African 563 1.2% 858 1.7% Swedish 699 1.4% 376 0.7% Swiss 148 0.3% 299 0.6% Ukrainian 98 0.2% 67 0.1% Welsh 221 0.5% 418 0.8% West Indian (excluding Hispanic origin groups) 31 0.1% 25 0.0% Source: 2013-2017 and 2018-2022 ACS The most common ancestral group identified in Mishawaka City in 2017 was German with 10,656 residents or 21.9% of the population. The second most common was Irish with 5,954 residents or 12.3% of the population. The most common ancestral group identified in Mishawaka City in 2022 was German with 10,662 residents or 20.9% of the population. The second most common was Irish with 6,411 residents or 12.6% of the population. There was no change in proportional representation in Mishawaka City from 2017 to 2022 that was larger than 5.0 percentage points. Dissimilarity Index Another way to consider racial distribution in a community is to look at the dissimilarity indices for an area. Dissimilarity indices measure the separation or integration of races across all parts of the city, county, or state. The dissimilarity index is based on the data from the 2020 U.S. Census and was calculated as part of Brown University’s American Communities Project (https://s4.brown.edu/american-community-project/). The dissimilarity index measures whether one particular group is distributed across census tracts in the metropolitan area in the same way as another group. A high value indicates that the two groups tend to live in different tracts. It compares the integration of racial groups with the White population of the City or MSA on a scale from 0 to 100, with 0 being completely integrated and 100 being completely separate. A value of 60 (or above) is considered very high. It means that 60% (or more) of the members of one 2025 Analysis of Impediments to Fair Housing Background Data 29 group would need to move to a different tract in order for the two groups to be equally distributed. Values of 40 or 50 are usually considered a moderate level of segregation, and values of 30 or below are considered to be fairly low and are integrated. The dissimilarity numbers are low to moderate across the board from the 2020 Census, indicative of partial integration. However, when looking at the exposure index, the numbers reflect that neighborhoods are not as integrated as the index of dissimilarity indicates. Exposure indices refer to the racial/ethnic composition of the tract where the average member of a given group lives. For example, the average Hispanic in some metropolitan areas might live in a tract that is 40% Hispanic, 40% non-Hispanic white, 15% black, and 5% Asian. (Note that these various indices must add up to 100%.) These are presented in two categories: exposure of the group to itself (which is called the Index of Isolation) and exposure of the group to other groups. The isolation index is the percentage of the same-group population in the census tract where the average number of a racial/ethnic group lives. It can range from a lower number than zero (for a very small group that is quite dispersed) to 100 (meaning that group members are entirely isolated from other groups). It should be kept in mind that this index is affected by the size of the group -- it is almost inevitably small for smaller groups, and it is likely to increase over time if the group becomes larger. Indices of exposure to other groups also range from 0 to 100, where a larger value means that the average group member lives in a tract with a higher percentage of persons from the other group. These indices depend on two conditions: the overall size of the other group and each group's settlement pattern. NOTE: For minority groups with relatively small populations, the small size introduces some error into the calculation of the dissimilarity indices. More specifically, for populations under 1,000 people, the dissimilarity index may be high even if the population is evenly distributed across the City, MSA, or State. The following sections highlight the dissimilarity indices for various racial and ethnic groups, as compared to the White population in the South Bend- Mishawaka, IN-MI MSA, South Bend City, and Mishawaka City. 2025 Analysis of Impediments to Fair Housing Background Data 30 Dissimilarity and Exposure – South Bend-Mishawaka, IN-MI MSA Dissimilarity Index with Whites Isolation Index Exposure to Other Groups* White -- 76.9 10.3** Black 48.4 28.0 53.2* Hispanic 36.7 19.1 54.4* Asian 41.2 6.3 73.3* Source: Brown University Diversity and Disparities Project, 2020 U.S. Census * Exposure of minorities to White population **Exposure of White to Black population The Black/African American population is the largest single-race minority group in the South Bend-Mishawaka, IN-MI MSA, with approximately 13.8% of the population and a dissimilarity index of 48.4. The isolation index of White to White in the South Bend-Mishawaka MSA is 76.9, Black to Black is 28.0, Hispanic to Hispanic is 19.1, and Asian to Asian is 6.3. The exposure to other group indices for Black to White in the South Bend- Mishawaka MSA is 53.2, for White to Black is 10.3, for Hispanic to White is 54.4, and for Asian to White is 73.3. Dissimilarity Index in the South Bend-Mishawaka, IN-MI MSA Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data 2025 Analysis of Impediments to Fair Housing Background Data 31 Isolation Index in the South Bend-Mishawaka, IN-MI MSA Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data Exposure Indices in the South Bend-Mishawaka, IN-MI MSA: White and Black Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data 2025 Analysis of Impediments to Fair Housing Background Data 32 Exposure Indices in the South Bend-Mishawaka, IN-MI MSA: Hispanic and Asian Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data Dissimilarity and Exposure – South Bend, IN Dissimilarity Index with Whites Isolation Index Exposure to Other Groups* White -- 59.1 23.2** Black 38.8 37.2 40.8* Hispanic 46.3 27.7 38.0* Asian 24.9 3.9 58.4* Source: Brown University Diversity and Disparities Project, 2020 U.S. Census data The Black/African American population is the largest single-race minority group in South Bend, IN, with approximately 28.5% of the population and a dissimilarity index of 38.8. The isolation index of White to White in South Bend is 59.1, Black to Black is 37.2, Hispanic to Hispanic is 27.7, and Asian to Asian is 3.9. The exposure to other group indices for Black to White in South Bend is 40.8, for White to Black is 23.2, for Hispanic to White is 38.0, and for Asian to White is 58.4. 2025 Analysis of Impediments to Fair Housing Background Data 33 Dissimilarity Index in South Bend, IN Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data Isolation Index in South Bend, IN Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data 2025 Analysis of Impediments to Fair Housing Background Data 34 Exposure Indices in South Bend, IN: White and Black Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data Exposure Indices in South Bend, IN: Hispanic and Asian Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data 2025 Analysis of Impediments to Fair Housing Background Data 35 Dissimilarity and Exposure – Mishawaka, IN Dissimilarity Index with Whites Isolation Index Exposure to Other Groups* White -- 76.4 11.1** Black 23.5 16.2 70.8* Hispanic 12.6 6.6 74.0* Asian 39.9 8.6 69.9* Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data * Exposure of minorities to Whites **Exposure of Whites to Blacks The Black/African American population is the largest single-race minority group in Mishawaka, IN, with approximately 11.8% of the population and a dissimilarity index of 23.5. The isolation index of White to White in Mishawaka is 76.4, Black to Black is 16.2, Hispanic to Hispanic is 6.6, and Asian to Asian is 8.6. The exposure to other group indices for Black to White in Mishawaka is 70.8, for White to Black is 11.1, for Hispanic to White is 74.0, and for Asian to White is 69.9. Dissimilarity Index in Mishawaka, IN Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data 2025 Analysis of Impediments to Fair Housing Background Data 36 Isolation Index in Mishawaka, IN Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data Exposure Indices in Mishawaka, IN: White and Black Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data 2025 Analysis of Impediments to Fair Housing Background Data 37 Exposure Indices in Mishawaka, IN: Hispanic and Asian Source: Brown University Diversity and Disparities Project, 1980-2020 U.S. Census data Regional Dissimilarity Trends The Dissimilarity Index (DI) has trended downward throughout the MSA over the last 50 years, from high dissimilarity in 1980 to moderate segregation in 2020. However, a closer look at the Exposure and Isolation Indices exposes continued segregation. White-Black exposure in the overall MSA is still quite low at 10.3 out of 100, with White-Hispanic exposure of 6.7 and White-Asian exposure of 2.9, and White-White isolation is high at 76.9. The numbers are similar in Mishawaka, with a White-Black exposure index of 11.1, White-Hispanic exposure of 6, White-Asian exposure of 3.2, and a White-White isolation index of 76.4. South Bend is rather less segregated though, having a White-White isolation index of 59.1, a White- Black exposure index of 23.2, and White-Hispanic exposure of 12.6, though White-Asian exposure is only 2.5. These figures suggest that rural and suburban portions of the MSA are much more segregated than South Bend, Mishawaka, or the MSA average. 2025 Analysis of Impediments to Fair Housing Background Data 38 2025 Analysis of Impediments to Fair Housing Background Data 39 2025 Analysis of Impediments to Fair Housing Background Data 40 2025 Analysis of Impediments to Fair Housing Background Data 41 Age – St. Joseph County The following chart illustrates age distribution in St. Joseph County at the time of the 2013-2017 and 2018-2022 American Community Surveys. As of 2022, youth under 20 years of age represented 26.9% of the population; 33.2% of the population is between 20 and 44 years of age; 23.7% of the population is 45 to 64; and 16.3% of the population is 65 years of age and older. The median age is 36.7 years of age. Source: 2013-2017 and 2018-2022 ACS Table DP05 Age – South Bend City The following chart illustrates age distribution in South Bend City at the time of the 2013-2017 and 2018-2022 American Community Surveys. As of 2022, youth under 20 years of age represented 29.5% of the population; 35.4% of the population was between 20 and 44 years of age; 21.4% of the population was 45 to 64; and 13.7% of the population was 65 years of age and older. The median age is 33.4 years of age. 2025 Analysis of Impediments to Fair Housing Background Data 42 Source: 2013-2017 and 2018-2022 ACS Table DP05 Age – Mishawaka City The following chart illustrates age distribution in Mishawaka City at the time of the 2013-2017 and 2018-2022 American Community Surveys. As of 2022, youth under 20 years of age represented 23.4% of the population; 38.0% of the population was between 20 and 44 years of age; 21.9% of the population was 45 to 64; and 16.7% of the population was 65 years of age and older. The median age is 35.8 years of age. 2025 Analysis of Impediments to Fair Housing Background Data 43 Source: 2013-2017 and 2018-2022 ACS Table DP05 2025 Analysis of Impediments to Fair Housing Background Data 44 2025 Analysis of Impediments to Fair Housing Background Data 45 Religion – St. Joseph County The U.S. Census does not collect data on the religious affiliations of the population in the United States. In an effort to better understand the religious affiliations of the residents of St. Joseph County, the County used the data made available by The Association of Religion Data Archives (ARDA). ARDA surveys the congregation members, their children, and other people who regularly attend church services within counties across the country. Although this data appears to be the most comprehensive data that is available, it is unfortunately not entirely complete as it does not accurately include traditional African American denominations. The total number of regular attendees was adjusted in 2010 (the most recent year for which data is available) to represent the population including historic African American denominations. However, the total value cannot be disaggregated to determine the distribution across denominational groups. The table below shows the distribution of residents of St. Joseph County across various denominational groups, and the percentage of the population which reported affiliation with a church. Religious Affiliation in St. Joseph County, 1980-2020 1980 1990 2000 2010 2020 # % # % # % # % # % Black Protestant 972 0.8% 8,973 7.5% * * 3,300 1.9% 8,304 7.6% Buddhism 0 0.0% 0 0.0% 0 0.0% 102 0.1% 0 0.0% Catholic 62,660 54.0% 62,723 52.7% 63,209 54.4% 52,666 30.1% 46,674 43.0% Evangelical Protestant 20,857 18.0% 20,264 17.0% 24,644 21.2% 27,734 15.9% 34,918 32.2% Hinduism 0 0.0% 0 0.0% 0 0.0% 25 0.0% 118 0.1% Islam 0 0.0% 0 0.0% 1,568 1.3% 1,116 0.6% 1,150 1.1% Jehovah’s Witnesses 0 0.0% 0 0.0% 0 0.0% 0 0.0% 2,056 1.9% Judaism 718 0.6% 1,800 1.5% 1,850 1.6% 1,518 0.9% 1,280 1.2% Latter-day Saints 519 0.4% 631 0.5% 1,106 1.0% 1,436 0.8% 1,383 1.3% Mainline Protestant 30,185 26.0% 24,612 20.7% 22,376 19.3% 85,517 48.9% 11,866 10.9% Orthodox 0 0.0% 0 0.0% 1,156 1.0% 1,226 0.7% 610 0.6% 2025 Analysis of Impediments to Fair Housing Background Data 46 Other Christians 0 0.0% 0 0.0% 106 0.1% 120 0.1% 106 0.1% Other Non- Christians 120 0.1% 117 0.1% 135 0.1% 166 0.1% 106 0.1% Total Adherents 116,031 48.0% 119,120 48.2% 116,150 43.7% 174,926 65.5% 108,571 39.8% Unclaimed: 125,586 52.0% 127,932 51.8% 149,409 56.3% 92,005 34.5% 164,341 60.2% Total Population 241,617 -- 247,052 -- 265,559 -- 266,931 -- 272,912 -- Source: The Association of Religion Data Archives The most common religious affiliation identified in St. Joseph County in 1980 was Catholic with 62,660 adherents, 54.0% of the churchgoing population and 25.9% of the County’s population. The second most common religious affiliation identified in St. Joseph County in 1980 was Mainline Protestant with 30,185 adherents, 26.0% of the churchgoing population and 12.5% of the County population. About 48% of the County’s population belonged to a church. The most common religious affiliation identified in St. Joseph County in 2020 was Catholic with 46,674 adherents, 43.0% of the churchgoing population and 17.1% of the County’s population. The second most common religious affiliation identified in St. Joseph County in 2020 was Evangelical Protestant with 34,918 adherents, 32.2% of the churchgoing population and 12.8% of the County’s population. About 40% of the County’s population belonged to a church. The changes in proportional representation of religious groups in St. Joseph County from 1980 to 2020 that were larger than 5.0 percentage points were the changes in Mainline Protestants, Catholics, and Evangelical Protestants. The number of Mainline Protestants in St. Joseph County decreased from 30,185 adherents in 1980 to 11,866 adherents in 2020, a proportional representation decrease of 15.1%. The number of Catholics decreased from 62,660 adherents in 1980 to 46,674 adherents in 2020, a proportional representation decrease of 11.0%. However, the number of Evangelical Protestants in the County increased from 20,857 in 1980 to 34,918 in 2020, a proportional representation increase of 14.2% 2025 Analysis of Impediments to Fair Housing Background Data 47 B. Households Household Tenure – St. Joseph County According to the 2013-2017 American Community Survey Five Year Estimates, there were 116,078 housing units in St. Joseph County. Of these housing units, 100,694 (86.7%) were occupied and 15,384 (13.3%) were vacant. Of the occupied housing units, 68,361 (67.9%) were owner- occupied and 32,333 (32.1%) were renter-occupied. According to the 2018-2022 ACS Five Year Estimates, there were 118,075 housing units in St. Joseph County. Of these housing units, 107,466 (91.0%) were occupied and 10,609 (9.0%) were vacant. Of the occupied housing units, 73,223 (68.1%) were owner-occupied and 34,243 (31.9%) were renter-occupied. From 2017 to 2022 there was an estimated 1,997 unit (1.7%) increase in the total number of housing units, a 6,772 unit (6.7%) increase in the number of occupied units, and a 4,775 unit (31.0%) decrease in the number of vacant units. The number of owner-occupied units increased by 4,862 units (7.1%) and renter-occupied units increased by 1,910 (5.9%). There were a number of significant changes (greater than 5.0 percentage points) changes in Household Tenure in St. Joseph County from 2017 to 2022. The number of occupied units grew by 6.7%, the number of vacant units fell by 31.0%, the number of owner-occupied units grew by 7.1%, and the number of renter-occupied units grew by 5.9%. This suggests that vacant houses are being reoccupied or replaced elsewhere in the County, and that occupants prefer to own rather than rent their housing units. 2025 Analysis of Impediments to Fair Housing Background Data 48 Source: 2013-2017 and 2018-2022 ACS chart B25009 Household Tenure – South Bend City According to the 2013-2017 American Community Survey 5-Year estimates, there were 47,280 housing units in South Bend City. Of these housing units, 39,025 (82.5%) were occupied and 8,255 (17.5%) were vacant. Of the occupied housing units, 22,335 (57.2%) were owner- occupied and 16,690 (42.8%) were renter-occupied. According to the 2018-2022 ACS 5-Year estimates, there were 46,514 housing units in South Bend City. Of these housing units, 40,559 (87.2%) were occupied and 5,955 (12.8%) were vacant. Of the occupied housing units, 23,731 (58.5%) were owner-occupied and 16,828 (41.5%) were renter-occupied. From 2017 to 2022 there was an estimated 766 unit (1.6%) decrease in the total number of housing units, a 1,534 unit (3.9%) increase in the number of occupied units, and a 2,300 unit (27.9%) decrease in the number of vacant units. The number of owner-occupied units increased by 1,396 units (6.3%) and renter-occupied units increased by 138 units (0.8%). 2025 Analysis of Impediments to Fair Housing Background Data 49 There were two significant changes (over 5.0 percentage points) in Household Tenure in South Bend City from 2017 and 2022. The number of vacant units decreased by 27.9%, and the number of owner-occupied units rose by 6.3%. This suggests that many vacant units have been demolished within the City, that others have been renovated or replaced, and that there is a strong preference toward purchasing housing rather than renting. There were no other significant changes. Source: 2013-2017 and 2018-2022 ACS chart B25009 Household Tenure – Mishawaka City According to the 2013-2017 American Community Survey 5-Year estimates, there were 24,363 housing units in Mishawaka City. Of these housing units, 20,568 (84.4%) were occupied and 3,795 (15.6%) were vacant. Of the occupied housing units, 10,334 (50.2%) were owner- occupied and 10,234 (49.8%) were renter-occupied. According to the 2018-2022 ACS 5-Year estimates, there were 25,415 housing units in Mishawaka City. Of these housing units, 23,191 (91.3%) were occupied and 2,224 (8.8%) were vacant. Of the occupied housing 2025 Analysis of Impediments to Fair Housing Background Data 50 units, 11,216 (48.4%) were owner-occupied and 11,975 (51.6%) were renter-occupied. From 2017 to 2022 there was a 1,052 unit (4.3%) increase in the total number of housing units, a 2,623 unit (12.8%) increase in the number of occupied units, and a 1,571 unit (41.4%) decrease in the number of vacant units. The number of owner-occupied units increased by 882 (8.5%) and the number of renter-occupied units increased by 1,741 (17.0%). There were several significant changes (over 5.0 percentage points) in Household Tenure in Mishawaka City from 2017 to 2022. The most significant change is the 41.4% decrease in vacant housing units over the last five years, along with a 12.8% increase in occupied units. Further, there was an 8.5% growth in owner occupancy, but there was a 17.0% growth in renter occupancy. This suggests widespread reoccupancy of old housing stock in Mishawaka, or possibly demolition and replacement, and that there is more elasticity in the rental market than in the homebuyer market. Source: 2013-2017 and 2018-2022 ACS chart B25009 2025 Analysis of Impediments to Fair Housing Background Data 51 2025 Analysis of Impediments to Fair Housing Background Data 52 2025 Analysis of Impediments to Fair Housing Background Data 53 2025 Analysis of Impediments to Fair Housing Background Data 54 2025 Analysis of Impediments to Fair Housing Background Data 55 Household Tenure by Race and Ethnicity – St. Joseph County The tables below compare homeowners and renters by race and ethnicity in St. Joseph County. Household Type by Race and Ethnicity in St. Joseph County Householder 2013-2017 ACS 2018-2022 ACS # % # % White alone 82,976 82.4% 84,723 78.8% Black or African American alone 12,460 12.4% 13,158 12.2% American Indian and Alaska Native alone 397 0.4% 372 0.3% Asian alone 1,921 1.9% 2,206 2.1% Native Hawaiian and Other Pacific Islander alone 43 0.0% 21 0.0% Some other race alone 1,446 1.4% 2,487 2.3% Two or more races 1,451 1.4% 4,499 4.2% Hispanic or Latino 4,809 4.8% 6,712 6.2% White alone, not Hispanic or Latino 79,897 79.3% 82,291 76.6% Source: 2013-2017 and 2018-2022 ACS table S2502 Household Tenure by Race and Ethnicity in St. Joseph County Householder 2013-2017 ACS 2018-2022 ACS Owner % Renter % Owner % Renter % White alone 61,305 89.7% 21,671 67.1% 62,719 85.7% 22,004 64.3% Black or African American alone 4,266 6.2% 8,194 25.3% 4,746 6.5% 8,412 24.6% American Indian and Alaska Native alone 212 0.3% 185 0.6% 244 0.3% 128 0.4% Asian alone 974 1.4% 947 2.9% 1,358 1.9% 848 2.5% Native Hawaiian and Other Pacific Islander alone 43 0.1% 0 0.0% 21 0.0% 0 0.0% Some other race alone 888 1.3% 558 1.7% 1,512 2.1% 975 2.8% Two or more races 673 1.0% 778 2.4% 2,623 3.6% 1,876 5.5% Hispanic or Latino 2,984 4.4% 1,825 5.6% 3,920 5.4% 2,792 8.2% White alone, not Hispanic or Latino 59,325 86.8% 20,572 63.6% 61,465 83.9% 20,826 60.8% Source: 2013-2017 and 2018-2022 ACS table S2502 Homeownership rates are increasing in the County. Homeowners represented 67.9% (68,361 households) of all households in 2017 and 68.1% (73,223 households) in 2022. In response, rental rates are 2025 Analysis of Impediments to Fair Housing Background Data 56 decreasing in the County, though the number of renters has increased. Renters represented 32.1% (32,333 households) of all households in 2017 and 31.9% (34,243 households) in 2022. There were not any significant shifts (greater than 5.0 percentage points) in Household Tenure from 2017 to 2022 in St. Joseph County. Household Tenure by Race and Ethnicity – South Bend City The tables below compare homeowners and renters by race and ethnicity in South Bend City. Household Type by Race and Ethnicity in South Bend City Householder 2013-2017 ACS 2018-2022 ACS # % # % White alone 26,555 68.0% 25,522 62.9% Black or African American alone 9,859 25.3% 9,912 24.4% American Indian and Alaska Native alone 191 0.5% 204 0.5% Asian alone 559 1.4% 796 1.96% Native Hawaiian and Other Pacific Islander alone 14 0.0% 10 0.0% Some other race alone 1,077 2.8% 1,857 4.6% Two or more races 770 2.0% 2,258 5.6% Hispanic or Latino 3,338 8.6% 4,272 10.5% White alone, not Hispanic or Latino 24,446 62.6% 24,293 59.9% Source: 2013-2017 and 2018-2022 ACS table S2502 Household Tenure by Race and Ethnicity in South Bend City Householder 2013-2017 ACS 2018-2022 ACS Owner % Renter % Owner % Renter % White alone 17,800 79.7% 8,755 52.5% 17,029 71.8% 8,493 50.5% Black or African American alone 3,262 14.6% 6,597 39.5% 3,704 15.6% 6,208 36.9% American Indian and Alaska Native alone 130 0.6% 61 0.4% 119 0.5% 85 0.5% 2025 Analysis of Impediments to Fair Housing Background Data 57 Asian alone 207 0.9% 352 2.1% 526 2.2% 270 1.6% Native Hawaiian and Other Pacific Islander alone 14 0.1% 0 0.0% 10 0.0% 0 0.0% Some other race alone 628 2.8% 449 2.7% 1,212 5.1% 645 3.8% Two or more races 294 1.3% 476 2.8% 11,131 4.8% 1,127 6.7% Hispanic or Latino 2,102 9.4% 1,236 7.4% 2,506 10.6% 1,766 10.5% White alone, not Hispanic or Latino 16,430 73.6% 8,016 48.0% 68.6% 16,290 47.6% 8,003 Source: 2013-2017 and 2018-2022 ACS table S2502 Homeownership rates are increasing in the City after a period of decline. Homeowners represented 57.2% (22,335 households) of all households in 2017 and 58.5% (23,731 households) in 2022. In response, rental rates have decreased in the City, though the number of renters has increased. Renters represented 42.8% (16,690 households) of all households in 2017 and 41.5% (16,828 households) in 2022. There were significant shifts (greater than 5.0 percentage points) in Household Tenure from 2017 to 2022 in South Bend City. The percentage of White householders dropped 5.1% over the period, and White owner- occupant householders in particular dropped 7.9% over the period. Other groups had smaller gains (less than 5.0 percentage points) which balanced this loss. There were no other significant shifts over this period. Household Tenure by Race and Ethnicity – Mishawaka City The tables below compare homeowners and renters by race and ethnicity in Mishawaka City. Household Type by Race and Ethnicity in Mishawaka City Householder 2013-2017 ACS 2018-2022 ACS # % # % White alone 18,260 88.8% 19,524 84.2% Black or African American alone 1,361 6.6% 1,698 7.3% American Indian and Alaska Native alone 84 0.4% 41 0.2% Asian alone 417 2.0% 560 2.4% Native Hawaiian and Other Pacific Islander alone 3 0.0% 5 0.0% Some other race alone 128 0.6% 313 1.3% Two or more races 315 1.5% 1,050 4.5% 2025 Analysis of Impediments to Fair Housing Background Data 58 Hispanic or Latino 678 3.3% 1,141 4.9% White alone, not Hispanic or Latino 17,797 86.5% 18,916 81.6% Source: 2013-2017 and 2018-2022 ACS table S2502 Household Tenure by Race and Ethnicity in Mishawaka City Householder 2013-2017 ACS 2018-2022 ACS Owner % Renter % Owner % Renter % White alone 9,887 95.8% 8,373 81.8% 10,286 91.7% 9,238 77.1% Black or African American alone 179 1.7% 1,182 11.6% 255 2.3% 1,443 12.1% American Indian and Alaska Native alone 30 0.3% 54 0.5% 20 0.2% 21 0.2% Asian alone 43 0.4% 374 3.7% 100 0.9% 460 3.8% Native Hawaiian and Other Pacific Islander alone 3 0.0% 0 0.0% 5 0.0% 0 0.0% Some other race alone 95 0.9% 33 0.3% 131 1.2% 182 1.5% Two or more races 97 0.9% 218 2.1% 419 3.7% 631 5.3% Hispanic or Latino 343 3.3% 335 3.3% 461 4.1% 680 5.7% White alone, not Hispanic or Latino 9,654 93.4% 8,143 79.6% 10,176 90.7% 8,740 73.0% Source: 2013-2017 and 2018-2022 ACS table S2502 Homeownership rates are decreasing in the City, though the number of homeowners has increased. Homeowners represented 50.2% (10,334 households) of all households in 2017 and 48.4% (11,216 households) of all households in 2022. In response, rental rates increased in the City. Renters represented 49.8% (10,234 households) of all households in 2017 and 51.6% (11,975 households) in 2022. There was one significant shift (greater than 5.0 percentage points) in Household Tenure from 2017 to 2022 in Mishawaka City. The percentage of White alone, not Hispanic or Latino renter-householders dropped 5.4% over the period. Hispanic and Latino renter-householders and other groups had smaller gains (less than 5.0 percentage points) which balanced this loss. There were no other significant shifts over this period. Families – St. Joseph County In 2017, there were a total of 100,694 households in St. Joseph County, of which 64,202 (63.8%) were family households and 36,492 (36.2%) were non-family households. In 2022, there were a total of 107,466 households, 2025 Analysis of Impediments to Fair Housing Background Data 59 of which 63,910 (59.5%) were family households and 43,556 (40.5%) were non-family households. The total number of households in St. Joseph County increased by 6,772 units from 2017 to 2022, as did the total number of non-family households (7,064 units or 19.4%), while the number of family households decreased by 292 units (0.4%) over the same period. A non- family household is defined as a householder living alone or with others not related by family. In 2022, non-family households comprised 40.5% of all households, married-couple family households comprised 42.5% of all households, female householders with no spouse present comprised 12.7% of all County households, and male householders with no spouse present comprised 4.3% of all County households. The chart below illustrates the breakdown of households by type in St. Joseph County as of 2022 using data from the 2018-2022 ACS. Source: 2018-2022 ACS Table B25011 Families – South Bend City In 2017, there were a total of 39,025 households in South Bend City, of which 22,755 (58.3%) were family households and 16,270 (41.7%) were non-family households. In 2022, there were a total of 40,559 households in South Bend City, of which 22,358 (55.1%) were family households and 18,201 (44.9%) were non-family households. The total number of 2025 Analysis of Impediments to Fair Housing Background Data 60 households in South Bend City increased by 1,532 units from 2017 to 2022, as did the total number of non-family households (1,931 units or 11.9%), while the number of family households decreased by 292 units (1.7%) over the same period. A non-family household is defined as a householder living alone or with others not related by family. In 2022, non-family households comprised 44.9% of all households, married-couple family households comprised 32.2% of all households, female householders with no spouse present comprised 18.2% of all South Bend households, and male householders with no spouse present comprised 4.8% of all South Bend households. The chart below illustrates the breakdown of households by type in South Bend City as of 2022 using data from the 2018-2022 ACS. Source: 2018-2022 ACS Table B25011 Families – Mishawaka City In 2017, there were a total of 20,568 households in Mishawaka City, of which 10,866 (52.8%) were family households and 9,702 (47.2%) were non- family households. In 2022, there were a total of 23,191 households, of which 11,439 (49.3%) were family households and 11,752 (50.7%) were non-family households. The total number of households in Mishawaka City increased by 2,623 units from 2017 to 2022, as did the total number of non- family households (2,050 units or 21.1%) and family households (573 units 2025 Analysis of Impediments to Fair Housing Background Data 61 or 5.3%) over the same period. A non-family household is defined as a householder living alone or with others not related by family. In 2022, non-family households comprised 50.7% of all households, married-couple family households comprised 32.7% of all households, female householders with no spouse present comprised 11.8% of all Mishawaka households, and male householders with no spouse present comprised 4.8% of all Mishawaka households. The chart below illustrates the breakdown of households by type in Mishawaka City as of 2022 using data from the 2018-2022 ACS. Source: 2018-2022 ACS Table B25011 2025 Analysis of Impediments to Fair Housing Background Data 62 C. Income and Poverty Household Income The median household income in St. Joseph County increased by 28.59% ($13,756) from $48,121 in 2017 to $61,877 in 2022. The median household income in the City of South Bend increased by 31.02% ($11,615) from $37,441 in 2017 to $49,056 in 2022. The median household income in the City of Mishawaka increased by 29.44% ($11,722) from $39,821 in 2017 to $51,543 in 2012. Household Income – St. Joseph County The table below compares the distribution of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Household Income in St. Joseph County Items 2013-2017 ACS 2018-2022 ACS Number of Households Percentage Number of Households Percentage Total Households 100,694 - 107,466 - Less than $10,000 7,763 7.7% 6,116 5.7% $10,000 to $14,999 5,244 5.2% 4,732 4.4% $15,000 to $24,999 12,479 12.4% 8,743 8.1% $25,000 to $34,999 11,142 11.1% 10,217 9.5% $35,000 to $49,999 15,078 14.9% 14,332 13.3% $50,000 to $74,999 18,729 18.6% 19,918 18.5% $75,000 to $99,999 11,851 11.8% 13,330 12.4% $100,000 to $149,999 11,522 11.4% 16,643 15.5% $150,000 to $199,999 3,290 3.3% 7,294 6.8% $200,000 or more 3,596 3.6% 6,141 5.7% Median Household Income $48,121 - $61,877 - Mean Household Income $66,247 - $84,995 - Source: 2013-2017 and 2018-2022 ACS Table DP03 Household Income – South Bend City The table below compares the distribution of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. 2025 Analysis of Impediments to Fair Housing Background Data 63 Household Income in South Bend City Items 2013-2017 ACS 2018-2022 ACS Number of Households Percentage Number of Households Percentage Total Households 39,025 - 40,559 - Less than $10,000 4,744 12.2% 3,536 8.7% $10,000 to $14,999 2,730 7.0% 2,404 5.9% $15,000 to $24,999 5,681 14.6% 4,027 9.9% $25,000 to $34,999 4,854 12.4% 4,416 10.9% $35,000 to $49,999 6,306 16.2% 6,346 15.6% $50,000 to $74,999 6,968 17.9% 7,325 18.1% $75,000 to $99,999 3,494 8.9% 4,642 11.4% $100,000 to $149,999 2,867 7.3% 5,004 12.3% $150,000 to $199,999 644 1.6% 1,586 3.9% $200,000 or more 737 1.9% 1,273 3.1% Median Household Income $37,441 - $49,056 - Mean Household Income $52,434 - $69,487 - Source: 2013-2017 and 2018-2022 ACS Table DP03 Household Income – Mishawaka City The table below compares the distribution of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Household Income in Mishawaka City Items 2013-2017 ACS 2018-2022 ACS Number of Households Percentage Number of Households Percentage Total Households 20,568 - 23,191 - Less than $10,000 1,456 7.1% 1,032 4.5% $10,000 to $14,999 1,173 5.7% 1,330 5.7% $15,000 to $24,999 3,354 16.3% 2,854 12.3% $25,000 to $34,999 3,114 15.1% 2,421 10.4% $35,000 to $49,999 3,723 18.1% 3,716 16.0% $50,000 to $74,999 3,789 18.4% 4,641 20.0% $75,000 to $99,999 1,955 9.5% 3,019 13.0% $100,000 to $149,999 1,475 7.2% 2,536 10.9% $150,000 to $199,999 311 1.5% 870 3.8% 2025 Analysis of Impediments to Fair Housing Background Data 64 $200,000 or more 218 1.1% 772 3.3% Median Household Income $39,821 - $51,543 - Mean Household Income $50,312 - $68,087 - Source: 2013-2017 and 2018-2022 ACS Table DP03 The U.S. Department of Housing and Urban Development (HUD) sets income limits that determine eligibility for assisted housing programs including the Public Housing, Section 8 project-based, Section 8 Housing Choice Voucher, Section 202 housing for the elderly, and Section 811 housing for persons with disabilities programs. HUD develops income limits based on Median Family Income estimates and Fair Market Rent area definitions for each metropolitan area, parts of some metropolitan areas, and each non-metropolitan county. The HUD Median Family Income in the South Bend-Mishawaka, IN HUD Metro FMR Area was $65,600 in 2019, which increased to $89,000 in 2024. The table below identifies the FY 2024 HUD Income Limits applicable to the South Bend-Mishawaka, IN HUD Metro FMR Area. South Bend-Mishawaka, IN-MI Metro Area Section 8 Income Limits for FY 2024 Income Category 1 Person 2 Person 3 Person 4 Person 5 Person 6 Person 7 Person 8 Person Extremely Low (30%) Income Limits $18,700 $21,400 $25,820 $31,200 $36,580 $41,960 $47,340 $52,720 Very Low (50%) Income Limits $31,150 $35,600 $40,050 $44,500 $48,100 $51,650 $55,200 $58,750 Low (80%) Income Limits $49,850 $57,000 $64,100 $71,200 $76,900 $82,600 $88,300 $94,000 Source: HUD Section 8 Income Limits The following table highlights the current low- and moderate-income population in St. Joseph County. The block groups that have a population of more than 51% low- and moderate-income are highlighted in the following 2025 Analysis of Impediments to Fair Housing Background Data 65 table. St. Joseph County has an overall low- and moderate-income population of 40.6%. Low- and Moderate-Income Population for St. Joseph County, IN TRACT BLOCK GROUP LOWMOD LOWMODUNIV LOWMODPCT 000100 1 575 720 79.90% 000100 2 330 675 48.90% 000100 3 375 745 50.30% 000200 1 445 1,020 43.60% 000200 2 910 1,095 83.10% 000200 3 970 1,000 97.00% 000200 4 605 1,165 51.90% 000301 1 440 740 59.50% 000301 2 25 190 13.20% 000301 3 695 1,070 65.00% 000302 1 825 1,500 55.00% 000302 2 650 1,085 59.90% 000400 1 415 530 78.30% 000400 2 530 690 76.80% 000400 3 790 965 81.90% 000500 1 730 1,270 57.50% 000500 2 445 675 65.90% 000600 1 485 730 66.40% 000600 2 830 895 92.70% 000600 3 135 265 50.90% 000700 1 145 590 24.60% 000700 2 555 1,510 36.80% 000800 1 170 1,050 16.20% 000800 2 120 590 20.30% 000900 1 210 525 40.00% 000900 2 410 540 75.90% 001000 1 745 1,370 54.40% 001000 2 760 1,040 73.10% 001000 3 350 420 83.30% 001000 4 335 755 44.40% 001100 1 410 905 45.30% 001100 2 305 650 46.90% 001100 3 590 1,090 54.10% 2025 Analysis of Impediments to Fair Housing Background Data 66 001100 4 545 1,435 38.00% 001200 1 155 795 19.50% 001200 2 25 610 4.10% 001200 3 105 775 13.50% 001300 1 665 1,530 43.50% 001300 2 225 570 39.50% 001400 1 200 355 56.30% 001400 2 465 910 51.10% 001400 3 280 450 62.20% 001400 4 510 1,730 29.50% 001500 1 340 565 60.20% 001500 2 530 770 68.80% 001500 3 835 1,165 71.70% 001500 4 860 975 88.20% 001600 1 365 1,255 29.10% 001600 2 220 1,075 20.50% 001700 1 375 515 72.80% 001700 2 435 620 70.20% 001900 1 165 280 58.90% 001900 2 320 555 57.70% 002000 1 345 570 60.50% 002000 2 765 845 90.50% 002100 1 305 530 57.50% 002100 2 820 985 83.20% 002200 1 615 795 77.40% 002200 2 670 815 82.20% 002200 3 455 570 79.80% 002200 4 425 865 49.10% 002300 1 355 440 80.70% 002300 2 630 740 85.10% 002400 1 835 1,190 70.20% 002400 2 790 900 87.80% 002400 3 695 820 84.80% 002500 1 545 770 70.80% 002500 2 765 1,295 59.10% 002600 1 1,020 1,450 70.30% 002600 2 1,125 1,625 69.20% 002600 3 850 1,155 73.60% 2025 Analysis of Impediments to Fair Housing Background Data 67 002700 1 775 975 79.50% 002800 1 750 1,395 53.80% 002800 2 735 980 75.00% 002900 1 595 1,000 59.50% 003000 1 250 340 73.50% 003000 2 835 1,260 66.30% 003100 1 815 1,115 73.10% 003100 2 330 580 56.90% 003100 3 140 260 53.80% 003100 4 555 815 68.10% 003100 5 430 615 69.90% 003200 1 310 760 40.80% 003200 2 180 1,035 17.40% 003200 3 360 1,480 24.30% 003200 4 365 1,245 29.30% 003200 5 145 575 25.20% 003300 1 445 775 57.40% 003300 2 1,065 1,525 69.80% 003300 3 320 815 39.30% 003400 1 225 535 42.10% 003400 2 495 830 59.60% 003400 3 715 1,105 64.70% 003400 4 760 1,000 76.00% 003500 1 900 1,160 77.60% 003500 2 890 1,560 57.10% 010100 1 585 875 66.90% 010100 2 310 485 63.90% 010100 3 235 625 37.60% 010100 4 410 615 66.70% 010201 1 595 750 79.30% 010201 2 410 1,115 36.80% 010201 3 490 1,680 29.20% 010202 1 600 855 70.20% 010202 2 530 620 85.50% 010300 1 605 655 92.40% 010300 2 745 2,100 35.50% 010300 3 1,805 2,190 82.40% 010300 4 600 900 66.70% 2025 Analysis of Impediments to Fair Housing Background Data 68 010300 5 215 465 46.20% 010400 1 445 1,390 32.00% 010400 2 375 980 38.30% 010400 3 250 910 27.50% 010500 1 245 820 29.90% 010500 2 375 1,245 30.10% 010500 3 410 920 44.60% 010600 1 300 465 64.50% 010600 2 165 445 37.10% 010600 3 370 1,230 30.10% 010600 4 375 765 49.00% 010700 1 320 940 34.00% 010700 2 195 710 27.50% 010700 3 160 445 36.00% 010700 4 450 715 62.90% 010700 5 865 1,380 62.70% 010800 1 380 1,070 35.50% 010800 2 280 640 43.80% 010800 3 555 1,845 30.10% 010800 4 190 1,020 18.60% 010901 1 50 785 6.40% 010901 2 460 1,335 34.50% 010901 3 535 2,220 24.10% 010902 1 695 1,890 36.80% 010902 2 270 1,455 18.60% 011001 1 395 1,865 21.20% 011001 2 160 490 32.70% 011002 1 255 1,840 13.90% 011002 2 155 415 37.30% 011002 3 435 2,475 17.60% 011100 1 350 445 78.70% 011100 2 715 1,520 47.00% 011100 3 360 485 74.20% 011100 4 55 85 64.70% 011100 5 200 830 24.10% 011203 1 570 830 68.70% 011203 2 265 330 80.30% 011203 3 115 280 41.10% 2025 Analysis of Impediments to Fair Housing Background Data 69 011303 1 900 1,800 50.00% 011303 2 85 480 17.70% 011303 3 440 865 50.90% 011303 4 315 1,380 22.80% 011303 5 295 1,205 24.50% 011304 1 270 2,325 11.60% 011305 1 265 2,080 12.70% 011305 2 700 2,265 30.90% 011306 1 45 440 10.20% 011306 2 170 925 18.40% 011306 3 210 1,380 15.20% 011307 1 545 1,085 50.20% 011307 2 0 865 0.00% 011307 3 75 565 13.30% 011308 1 130 1,300 10.00% 011308 2 250 1,260 19.80% 011308 3 375 1,920 19.50% 011309 1 105 595 17.60% 011309 2 585 1,230 47.60% 011309 3 490 1,005 48.80% 011310 1 380 1,430 26.60% 011310 2 490 605 81.00% 011310 3 450 795 56.60% 011403 1 135 3,045 4.40% 011403 2 780 1,690 46.20% 011403 3 80 835 9.60% 011404 1 165 1,165 14.20% 011404 2 140 2,090 6.70% 011404 3 180 1,130 15.90% 011404 4 90 2,275 4.00% 011405 1 190 910 20.90% 011405 2 220 1,165 18.90% 011405 3 495 1,780 27.80% 011406 1 290 1,585 18.30% 011406 2 510 2,415 21.10% 011406 3 310 1,570 19.70% 011501 1 1,055 1,760 59.90% 011501 2 940 1,245 75.50% 2025 Analysis of Impediments to Fair Housing Background Data 70 011501 3 735 1,210 60.70% 011503 1 270 1,635 16.50% 011503 2 315 835 37.70% 011504 1 340 1,525 22.30% 011505 1 215 810 26.50% 011505 2 840 1,240 67.70% 011505 3 240 1,000 24.00% 011506 1 825 1,490 55.40% 011506 2 1,735 3,425 50.70% 011602 1 1,185 3,470 34.10% 011602 2 470 1,125 41.80% 011602 3 405 1,935 20.90% 011602 4 605 1,255 48.20% 011603 1 315 2,125 14.80% 011603 2 235 2,480 9.50% 011604 1 95 1,645 5.80% 011604 2 115 1,570 7.30% 011701 1 375 2,995 12.50% 011701 2 620 1,095 56.60% 011703 1 170 255 66.70% 011703 2 430 1,390 30.90% 011703 3 1,160 1,665 69.70% 011703 4 350 760 46.10% 011704 1 150 1,590 9.40% 011704 2 945 1,550 61.00% 011704 3 135 900 15.00% 011801 1 225 1,460 15.40% 011803 1 135 1,020 13.20% 011803 2 230 1,175 19.60% 011803 3 500 1,210 41.30% 011804 1 355 825 43.00% 011804 2 235 1,530 15.40% 011900 1 450 1,235 36.40% 011900 2 540 1,310 41.20% 011900 3 400 1,395 28.70% 012000 1 630 1,540 40.90% 012000 2 315 935 33.70% 012000 3 495 1,115 44.40% 2025 Analysis of Impediments to Fair Housing Background Data 71 012000 4 30 750 4.00% 012100 1 210 1,210 17.40% 012100 2 295 735 40.10% 012100 3 455 755 60.30% 012100 4 140 1,145 12.20% 012200 1 140 1,010 13.90% 012200 2 340 880 38.60% 012200 3 420 1,130 37.20% 012300 1 425 1,175 36.20% 012300 2 200 1,145 17.50% 012300 3 405 720 56.30% 012300 4 240 645 37.20% 012400 1 275 1,240 22.20% 012400 2 190 835 22.80% Total Low-Mod 104,905 258,090 40.65% Source: HUD Exchange 2016-2020 ACS Low-Mod Block Group data The following maps illustrate relative income levels in St. Joseph County. The first map shows the poverty rate by block group. The second shows with concentrations of low- and moderate-income residents. These Census Block Groups that are above 51% low- and moderate-income. They are mostly concentrated in the City of South Bend, and partially concentrated in the City of Mishawaka. Finally, the third map shows low- and moderate- income block groups with an overlay of all majority-minority block groups. This map shows that every minority-majority block group in the region is also greater than 51% low- and moderate-income. 2025 Analysis of Impediments to Fair Housing Background Data 72 2025 Analysis of Impediments to Fair Housing Background Data 73 2025 Analysis of Impediments to Fair Housing Background Data 74 2025 Analysis of Impediments to Fair Housing Background Data 75 Family and Household Poverty – St. Joseph County In St. Joseph County, the percentage of all families living in poverty experienced a decrease from 12.6% in 2017 to 10.1% in 2022. The poverty rate for female-headed households with no spouse present fell from 36.6% in 2017 to 31.0% in 2022, and the poverty rate for such households with children under 18 fell from 48.6% to 39.9% over the same period. However, the percentage of female-headed households with no spouse present and with children under 5 years old increased from 55.3% in 2017 to 58.8% in 2022. Source: 2013-2017 and 2018-2022 ACS Table DP03 NOTE: the 2017 ACS uses the term “Female householder, no husband present”, while the 2022 ACS uses the term “Female householder, no spouse present”. This may result in a small variation when considering same-sex partnerships. 2025 Analysis of Impediments to Fair Housing Background Data 76 Family and Household Poverty – South Bend City The City of South Bend has a higher poverty rate than St. Joseph County as a whole, but its poverty rate also decreased from 20.2% in 2017 to 17.7% in 2022. The percentage of single mothers in poverty was high in the City of South Bend, but it fell slightly for both overall female-headed households and for those with children under 18 years. However, the percentage of female-headed households with no spouse present and with children under 5 years old increased substantially from 55.5% in 2017 to 64.0% in 2022. Source: 2013-2017 and 2018-2022 ACS DP03 2025 Analysis of Impediments to Fair Housing Background Data 77 Family and Household Poverty – Mishawaka City The City of Mishawaka had a larger decrease in poverty levels than the County as a whole from 2017 to 2022, decreasing by 4.1% to a poverty rate of 11.3% in 2022. The poverty rate for female-headed households with no spouse present decreased significantly by 7.7%, and female-headed households with no spouse present and children under 18 years had a larger decrease of 16.5%. However, the poverty rate of female-headed households with no spouse present and with children under 5 years old increased significantly from 47.0% in 2017 to 55.2% in 2022. Source: 2013-2017 and 2018-2022 ACS DP03 2025 Analysis of Impediments to Fair Housing Background Data 78 D. Employment Occupation – St. Joseph County In 2017, according to the 2013-2017 American Community Survey Estimates the total number of eligible workers (population 16 years and over) in St. Joseph County was 211,358 persons. 134,450 persons (63.6% of eligible workers) were in the labor force, 125,645 persons (59.4% of eligible workers) were employed, and 8,633 persons (4.1% of eligible workers) were unemployed. In 2022, according to the 2018-2022 ACS Estimates the total number of eligible workers (population 16 years and over) in St. Joseph County was 216,056 persons. 137,941 persons (63.8% of eligible workers) were in the labor force, 131,170 persons (60.7% of eligible workers) were employed, and 6,637 persons (3.1% of eligible workers) were unemployed. Workers in 2022 had a mean travel time to work of 21.3 minutes. According to the 2018-2022 American Community Survey, an estimated 32.3% (34,725 households) of households in St. Joseph County receive income from Social Security. The mean Social Security Income for 2022 was $22,375. The following charts outline the distribution of workers in St. Joseph County by occupation, class, and industry. 2025 Analysis of Impediments to Fair Housing Background Data 79 Source: 2018-2022 ACS able DP03 Source: 2013-2017 and 2018-2022 ACS table DP03 2025 Analysis of Impediments to Fair Housing Background Data 80 Source: 2018-2022 ACS table DP03 Worker Industry in St. Joseph County 2013-2017 ACS 2018-2022 ACS # % # % Civilian employed population 16 years and over 125,645 - 131,170 - Agriculture, forestry, fishing and hunting, and mining 461 0.4% 535 0.4% Construction 5,661 4.5% 6,574 5.0% Manufacturing 22,409 17.8% 22,343 17.0% Wholesale trade 3,687 2.9% 3,831 2.9% Retail trade 13,873 11.0% 14,065 10.7% Transportation and warehousing, and utilities 5,102 4.1% 6,366 4.9% Information 2,279 1.8% 1,982 1.5% Finance and insurance, and real estate and rental and leasing 5,987 4.8% 6,395 4.9% Professional, scientific, and management, and administrative and waste management services 9,871 7.9% 10,816 8.2% 2025 Analysis of Impediments to Fair Housing Background Data 81 Educational services, and health care and social assistance 35,877 28.6% 37,320 28.5% Arts, entertainment, and recreation, and accommodation and food services 11,110 8.8% 10,655 8.1% Other services, except public administration 5,621 4.5% 6,608 5.0% Public administration 3,707 3.0% 3,680 2.8% Source: 2013-2017 and 2018-2022 ACS table DP03 The following map illustrates the commercial hot spots within the County. 2025 Analysis of Impediments to Fair Housing Background Data 82 2025 Analysis of Impediments to Fair Housing Background Data 83 Occupation – South Bend City According to the 2013-2017 American Community Survey Estimates, the total number of eligible workers (population 16 years and over) in South Bend City in 2017 was 77,143 persons. 49,670 persons (64.4% of eligible workers) were in the civilian labor force, 45,211 persons (58.6% of eligible workers) were employed, and 4,459 persons (5.8% of eligible workers) were unemployed. According to the 2018-2022 ACS Estimates, the total number of eligible workers (population 16 years and over) in South Bend City in 2022 was 78,263 persons. 49,334 persons (63.0% of eligible workers) were in the civilian labor force, 46,624 persons (59.6% of eligible workers) were employed, and 2,710 persons (3.5% of eligible workers) were unemployed. Workers in 2022 had a mean travel time to work of 20.4 minutes. According to the 2018-2022 American Community Survey, an estimated 12,114 households (29.9%) in South Bend City receive income from Social Security. The mean Social Security Income for 2022 was $19,517. The following charts outline the distribution of workers in South Bend City by occupation. Source: 2018-2022 ACS table DP03 2025 Analysis of Impediments to Fair Housing Background Data 84 Source: 2013-2017 and 2018-2022 ACS table DP03 Source: 2013-2017 and 2018-2022 ACS table DP03 2025 Analysis of Impediments to Fair Housing Background Data 85 Worker Industry in South Bend City 2013-2017 ACS 2018-2022 ACS # % # % Civilian employed population 16 years and over 45,211 - 46,624 - Agriculture, forestry, fishing and hunting, and mining 93 0.2% 166 0.4% Construction 1,628 3.6% 2,293 4.9% Manufacturing 7,909 17.5% 7,737 16.6% Wholesale trade 1,285 2.8% 1,267 2.7% Retail trade 5,081 11.2% 4,941 10.6% Transportation and warehousing, and utilities 1,570 3.5% 2,201 4.7% Information 1,094 2.4% 764 1.6% Finance and insurance, and real estate and rental and leasing 1,916 4.2% 1,974 4.2% Professional, scientific, and management, and administrative and waste management services 3,813 8.4% 3,812 8.2% Educational services, and health care and social assistance 12,796 28.3% 13,150 28.2% Arts, entertainment, and recreation, and accommodation and food services 4,787 10.6% 4,656 10.0% Other services, except public administration 2,082 4.6% 2,439 5.2% Public administration 1,157 2.6% 1,224 2.6% Source: 2013-2017 and 2018-2022 ACS table DP03 Occupation – Mishawaka City According to the 2013-2017 American Community Survey Estimates, the total number of eligible workers (population 16 years and over) in Mishawaka City in 2017 was 38,431 persons. 25,290 persons (65.8% of eligible workers) were in the civilian labor force, 23,697 persons (61.7% of eligible workers) were employed, and 1,593 persons (4.1% of eligible workers) were unemployed. According to the 2018-2022 ACS Estimates, the total number of eligible workers (population 16 years and over) in Mishawaka City in 2022 was 41,353 persons. 27,595 persons (66.7% of eligible workers) were in the 2025 Analysis of Impediments to Fair Housing Background Data 86 labor force, 25,685 persons (62.1% of eligible workers) were employed, and 1,910 persons (4.6% of eligible workers) were unemployed. Workers in 2022 had a mean travel time to work of 21.5 minutes. According to the 2018-2022 American Community Survey, an estimated 7,298 households (31.5%) in Mishawaka City receive income from Social Security. The mean Social Security Income for 2022 was $20,390. The following charts outline the distribution of workers in Mishawaka City by occupation. Source: 2018-2022 ACS table DP03 2025 Analysis of Impediments to Fair Housing Background Data 87 Source: 2013-2017 and 2018-2022 ACS table DP03 Source: 2018-2022 ACS table DP03 2025 Analysis of Impediments to Fair Housing Background Data 88 Worker Industry in Mishawaka City 2013-2017 ACS 2018-2022 ACS # % # % Civilian employed population 16 years and over 23,697 - 25,685 - Agriculture, forestry, fishing and hunting, and mining 15 0.1% 22 0.1% Construction 903 3.8% 835 3.3% Manufacturing 4,103 17.3% 4,902 19.1% Wholesale trade 722 3.0% 726 2.8% Retail trade 3,751 15.8% 2,771 10.8% Transportation and warehousing, and utilities 1,083 4.6% 1,326 5.2% Information 239 1.0% 399 1.6% Finance and insurance, and real estate and rental and leasing 1,072 4.5% 1,399 5.4% Professional, scientific, and management, and administrative and waste management services 1,764 7.4% 2,152 8.4% Educational services, and health care and social assistance 5,928 25.0% 6,771 26.4% Arts, entertainment, and recreation, and accommodation and food services 2,334 9.8% 2,254 8.8% Other services, except public administration 1,185 5.0% 1,214 4.7% Public administration 598 2.5% 914 3.6% Source: 2013-2017 and 2018-2022 ACS table DP03 Unemployment Rate – St. Joseph County The unemployment rate for St. Joseph County is shown below with the unemployment rate in the State of Indiana and nationally. 2025 Analysis of Impediments to Fair Housing Background Data 89 Comparative Unemployment Rates Source: Bureau of Labor Statistics In the five years prior to the COVID pandemic, the national unemployment rate was between half a percentage point and a full point above that of the State of Indiana and St. Joseph County. During the worst of the pandemic, unemployment in St. Joseph County spiked to nearly 20%, 5.3 percentage points above the national rate; in the immediate aftermath, both the State and the County had lower unemployment. However, trends suggest that between July 2022 and July 2024, the unemployment rate in St. Joseph County has increased about half a percentage point above the Indiana unadjusted unemployment rate and about 1 percentage point above the national unadjusted unemployment rate. The County’s unemployment rate is increasing at a faster rate than the national average and is at 5.6% as of July 2024. 2025 Analysis of Impediments to Fair Housing Background Data 90 E. Housing Profile Slightly more than half of the County’s housing stock (52.4%) was built prior to 1970, which coincides with the County’s growth and decline. Only 5.2% of its housing stock was built after 2009. The oldest housing stock in the region is within the City of South Bend; approximately 25.8% of the City’s housing stock was built prior to 1939 and over two-thirds (69.8%) was built prior to 1970. The following chart illustrates the year that housing structures were built in St. Joseph County based on the 2018-2022 American Community Survey. Housing Profile – St. Joseph County The following table chart details the year that housing structures were built in St. Joseph County as of 2017 and 2022. Year Structure Built in St. Joseph County Housing Profile 2013-2017 ACS 2018-2022 ACS # % # % Total Housing Units 116,078 - 118,075 - Built 2020 or later - - 423 0.4% Built 2010 to 2020 1,738 1.5% 5,672 4.8% Built 2000 to 2009 10,181 8.8% 10,144 8.6% Built 1990 to 1999 15,425 13.3% 13,570 11.5% Built 1980 to 1989 10,841 9.3% 11,804 10.0% Built 1970 to 1979 16,133 13.9% 14,635 12.4% Built 1960 to 1969 12,515 10.8% 12,776 10.8% Built 1950 to 1959 15,660 13.5% 18,147 15.4% Built 1940 to 1949 12,637 10.9% 10,388 8.8% Built 1939 or earlier 20,948 18.0% 20,516 17.4% Source: 2013-2017 and 2018-2022 ACS The majority of housing units in St. Joseph County are 1-unit detached structures, comprising 87,374 units (74.0% of the total). The following graph illustrates the composition of the housing stock in St. Joseph County as of 2022. 2025 Analysis of Impediments to Fair Housing Background Data 91 Source: 2018-2022 ACS table DP04 Housing Profile – South Bend City The following table chart details the year that housing structures were built in South Bend City as of 2017 and 2022. Year Structure Built in South Bend City Housing Profile 2013-2017 ACS 2018-2022 ACS # % # % Total Housing Units 47,280 - 46,514 - Built 2020 or newer - - 111 0.2% Built 2010 to 2019 782 1.7% 1,818 3.9% Built 2000 to 2009 2,065 4.4% 2,256 4.9% Built 1990 to 1999 3,177 6.7% 3,152 6.8% Built 1980 to 1989 2,799 5.9% 2,171 4.7% Built 1970 to 1979 4,739 10.0% 4,548 9.8% Built 1960 to 1969 5,521 11.7% 4,289 9.2% Built 1950 to 1959 8,561 18.1% 10,316 22.2% Built 1940 to 1949 7,079 15.0% 5,837 12.5% Built 1939 or earlier 12,557 26.6% 12,016 25.8% Source: 2013-2017 and 2018-2022 ACS table DP04 2025 Analysis of Impediments to Fair Housing Background Data 92 The majority of housing units in South Bend City are 1-unit detached structures, comprising 33,257 housing units (71.5% of the total). The following graph illustrates the composition of the housing stock in South Bend City as of 2022. Source: 2018-2022 ACS table DP04 As the result of the 2013 “1,000 Houses in 1,000 Days” Initiative, a total of 1,122 properties was addressed. This includes over 400 houses that were repaired and had 689 demolished, resulting in vacant lots by the end of the program in 2015. The City utilized Indiana’s Unsafe Building Law to demolish the majority of properties, so it did not have ownership at the time of demolition. The City has pursued ownership of vacant lots in targeted geographies to help support urban infill development and productive reuse of the land. Housing Profile – Mishawaka City The following table chart details the year that housing structures were built in Mishawaka City as of 2017 and 2022. 2025 Analysis of Impediments to Fair Housing Background Data 93 Year Structure Built in Mishawaka City Housing Profile 2013-2017 ACS 2018-2022 ACS # % # % Total Housing Units 24,363 - 25,415 - Built 2010 or newer - - 55 0.2% Built 2010 or newer 166 0.7% 1,997 7.9% Built 2000 to 2009 2,779 11.4% 2,469 9.7% Built 1990 to 1999 4,143 17.0% 2,960 11.6% Built 1980 to 1989 2,557 10.5% 3,345 13.2% Built 1970 to 1979 4,359 17.9% 3,676 14.5% Built 1960 to 1969 1,939 8.0% 2,964 11.7% Built 1950 to 1959 2,214 9.1% 2,330 9.2% Built 1940 to 1949 2,082 8.5% 1,350 5.3% Built 1939 or earlier 4,124 16.9% 4,269 16.8% Source: 2013-2017 and 2018-2022 ACS table DP04 A plurality of housing units in Mishawaka City are 1-unit detached structures, comprising 12,701 housing units (49.97% of the total). The following graph illustrates the composition of the housing stock in Mishawaka City as of 2022. 2025 Analysis of Impediments to Fair Housing Background Data 94 Source: 2018-2022 ACS table DP04 As shown in the previous charts, single unit detached houses remain the most prevalent type of housing in the County by a wide margin. The number of 1-unit attached and 5 to 9-unit dwellings increased by about 1,000 structures each. 1-unit detached and 3 to 4-unit structures each saw about 400 units added, while the 10 to 19-unit category saw a decrease of about 700 units. All other housing types remained relatively constant. The median value of owner-occupied homes in St. Joseph County according to the 2013-2017 American Community Survey was $118,600 compared to $93,900 in the City of Mishawaka and $81,100 in the City of South Bend. The 2018-2022 American Community Survey estimates that the median value of owner-occupied homes in St. Joseph County, the City of Mishawaka, and the City of South Bend have increased to $165,700, $128,200, and $113,800 respectively. The latest available data from real estate listings presented a very different picture of home values in the County; according to Zillow, the median list price of a home in the South Bend-Mishawaka, IN-MI MSA was $203,300 as of December 31, 2022, and has climbed further to $244,933 as of August 31, 2024. 2025 Analysis of Impediments to Fair Housing Background Data 95 The following table outlines the number of building permits filed annually for the South Bend-Mishawaka IN-MI Core Base Statistical Area (CBSA). Units Authorized by Building Permits, South Bend-Mishawaka, IN-MI CBSA YEAR Total Single Family 2 Units 3-4 Units 5+ Units 2023 422 364 40 0 18 2022 742 429 4 0 309 2021 492 489 3 0 0 2020 555 555 0 0 0 2019 428 428 0 0 0 2018 738 419 0 3 316 2017 959 479 0 0 480 2016 405 337 2 0 66 2015 524 380 0 0 144 2014 512 342 2 0 168 2013 500 268 2 0 230 2012 642 219 4 0 419 2011 467 238 0 3 226 2010 383 238 4 9 132 2009 348 299 2 10 37 2008 830 400 0 23 407 Source: SOCDS Building Permits Database, HUD The following graph lays out the above data visually. 2025 Analysis of Impediments to Fair Housing Background Data 96 Source: SOCDS Building Permits Database, HUD The South Bend-Mishawaka, IN-MI MSA has seen variable total numbers of new units constructed. There were peaks in 5+ Unit Multi-Family home permits in 2010-2015, 2017-2018, and 2022, with few to no structures of that size permitted in the intervening years. The number of Single-Family structures grew relatively steadily between 2012 and 2020 but has decreased between 2021 and 2023. Almost no 2 Unit or 3-4 Unit structures were constructed over the last 15 years in the MSA. An average of 65.8% of new units each year for the last fifteen years were for single family units. The year with the highest number of units authorized was 2017 and the year with the highest number of single-family units was 2020. There has been a slow decrease in the number of single-family units permitted since 2020, but the number of multi-family units has fluctuated. This data suggests that the South Bend-Mishawaka, IN-MI MSA housing market recovered from the 2008-2009 market collapse but was impacted by the COVID pandemic. 2025 Analysis of Impediments to Fair Housing Background Data 97 F. Financing Owner Costs – St. Joseph County The median selected monthly owner cost for owner-occupied housing units with a mortgage was $1,011 in 2017 and $1,203 in 2022, an increase of 19.0%. The median for owner-occupied housing units without a mortgage was $348 in 2017 and $435 in 2022, an increase of 25.0%. The following table illustrates mortgage status and selected monthly owner costs according to the 2013-2017 and 2018-2022 American Community Survey estimates. Selected Monthly Owner Costs in St. Joseph County Selected Monthly Owner Costs 2013-2017 ACS 2018-2022 ACS # % # % Housing units with a mortgage 43,612 - 45,317 - Less than $500 1,382 3.2% 639 1.4% $500 to $999 20,036 45.9% 14,380 31.7% $1,000 to $1,499 14,299 32.8% 16,673 36.8% $1,500 to $1,999 4,985 11.4% 7,634 16.8% $2,000 to $2,499 1,510 3.5% 2,994 6.6% $2,500 to $2,999 615 1.4% 1,569 3.5% $3,000 or more 785 1.8% 1,428 3.2% Median (dollars) $1,011 - $1,203 - Housing units without a mortgage 24,749 - 27,906 - Less than $250 5,374 21.7% 2,665 9.5% $250 to $399 9,790 39.6% 9,052 32.4% $400 to $599 6,924 28.0% 10,388 37.2% $600 to $799 1,781 7.2% 3,790 13.6% $800 to $999 529 2.1% 1,075 3.9% $1,000 or more 351 1.4% 936 3.4% Median (dollars) $348 - $435 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates selected monthly owner costs as a percentage of income according to the 2013-2017 and 2018-2022 American Community Survey estimates. 2025 Analysis of Impediments to Fair Housing Background Data 98 Selected Monthly Owner Costs as a Percentage of Household Income (SMOCAPI) in St. Joseph County Owner Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Housing units with a mortgage (excluding units where SMOCAPI cannot be computed) 43,399 - 45,099 - Less than 20.0 percent 24,679 56.9% 26,911 59.7% 20.0 to 24.9 percent 6,395 14.7% 6,549 14.5% 25.0 to 29.9 percent 3,584 8.3% 3,228 7.2% 30.0 to 34.9 percent 2,206 5.1% 2,393 5.3% 35.0 percent or more 6,535 15.1% 6,018 13.3% Not computed 213 - 218 - Housing units without a mortgage (excluding units where SMOCAPI cannot be computed) 24,410 - 27,756 - Less than 10.0 percent 13,041 53.4% 14,784 53.3% 10.0 to 14.9 percent 4,716 19.3% 4,907 17.7% 15.0 to 19.9 percent 2,395 9.8% 2,585 9.3% 20.0 to 24.9 percent 1,388 5.7% 1,355 4.9% 25.0 to 29.9 percent 785 3.2% 1,087 3.9% 30.0 to 34.9 percent 510 2.1% 381 1.4% 35.0 percent or more 1,575 6.5% 2,657 9.6% Not computed 339 - 150 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates owner-occupied housing costs as a percentage of household income according to the 2013-2017 and 2018- 2022 American Community Survey estimates. Owner-Occupied Housing Costs as a Percentage of Household Income in St. Joseph County Owner Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Owner-Occupied Housing Units 68,361 67.9% 73,223 68.1% Less than $20,000 6,625 9.7% 5,660 7.7% Less than 20 percent 1,181 1.7% 347 0.5% 20 to 29 percent 976 1.4% 940 1.3% 30 percent or more 4,468 6.5% 4,373 6.0% $20,000 to $34,999 9,695 14.2% 7,882 10.8% 2025 Analysis of Impediments to Fair Housing Background Data 99 Less than 20 percent 4,176 6.1% 2,928 4.0% 20 to 29 percent 1,966 2.9% 1,824 2.5% 30 percent or more 3,553 5.2% 3,130 4.3% $35,000 to $49,999 9,950 14.6% 8,507 11.6% Less than 20 percent 4,922 7.2% 4,376 6.0% 20 to 29 percent 3,415 5.0% 2,031 2.8% 30 percent or more 1,613 2.4% 2,100 2.9% $50,000 to $74,999 14,487 21.2% 13,705 18.7% Less than 20 percent 10,088 14.8% 8,756 12.0% 20 to 29 percent 3,544 5.2% 3,735 5.1% 30 percent or more 855 1.3% 1,214 1.7% $75,000 or more 27,052 39.6% 37,101 50.7% Less than 20 percent 24,464 35.8% 32,780 44.8% 20 to 29 percent 2,251 3.3% 3,689 5.0% 30 percent or more 337 0.5% 632 0.9% Zero or negative income 552 0.8% 368 0.5% Source: 2013-2017 and 2018-2022 American Community Survey table B25106 HUD defines a housing cost burden as a household that pays over 30 percent or more of its monthly income on housing costs. In 2017, 10,826 units (15.8%) of owner-occupied households were cost burdened. In 2022, 11,449 units (15.6%) of owner-occupied households were cost burdened. Owner Costs – South Bend City The median selected monthly owner cost for owner-occupied housing units with a mortgage was $905 in 2017 and $1,061 in 2022, an increase of 17.2%. The median for owner-occupied housing units without a mortgage was $337 in 2017 and $415 in 2022, an increase of 23.1%. The following table illustrates mortgage status and selected monthly owner costs according to the 2013-2017 and 2018-2022 American Community Survey estimates. Selected Monthly Owner Costs in South Bend City Selected Monthly Owner Costs 2013-2017 ACS 2018-2022 ACS # % # % Housing units with a mortgage 13,684 - 13,760 - Less than $500 508 3.7% 197 1.4% 2025 Analysis of Impediments to Fair Housing Background Data 100 $500 to $999 7,867 57.5% 5,903 42.9% $1,000 to $1,499 4,023 29.4% 5,313 38.6% $1,500 to $1,999 784 5.7% 1,279 9.3% $2,000 to $2,499 262 1.9% 398 2.9% $2,500 to $2,999 100 0.7% 433 3.1% $3,000 or more 140 1.0% 237 1.7% Median (dollars) $905 - $1,061 - Housing units without a mortgage 8,651 - 9,971 - Less than $250 2,211 25.6% 1,285 12.9% $250 to $399 3,336 38.6% 3,370 33.8% $400 to $599 2,271 26.3% 3,605 36.2% $600 to $799 507 5.9% 1,168 11.7% $800 to $999 159 1.8% 240 2.4% $1,000 or more 167 1.9% 303 3.0% Median (dollars) $337 - $415 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates selected monthly owner costs as a percentage of income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Selected Monthly Owner Costs as a Percentage of Household Income (SMOCAPI) in South Bend City Owner Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Housing units with a mortgage (excluding units where SMOCAPI cannot be computed) 13,608 - 13,633 - Less than 20.0 percent 6,978 51.3% 7,199 52.8% 20.0 to 24.9 percent 2,089 15.4% 2,185 16.0% 25.0 to 29.9 percent 1,262 9.3% 916 6.7% 30.0 to 34.9 percent 842 6.2% 947 6.9% 35.0 percent or more 2,437 17.9% 2,386 17.5% Not computed 76 (X) 127 (X) Housing units without a mortgage (excluding units where SMOCAPI cannot be computed) 8,515 - 9,934 - Less than 10.0 percent 4,132 48.5% 4,917 49.5% 10.0 to 14.9 percent 1,715 20.1% 1,777 17.9% 15.0 to 19.9 percent 974 11.4% 860 8.7% 2025 Analysis of Impediments to Fair Housing Background Data 101 20.0 to 24.9 percent 535 6.3% 607 6.1% 25.0 to 29.9 percent 324 3.8% 622 6.3% 30.0 to 34.9 percent 179 2.1% 117 1.2% 35.0 percent or more 656 7.7% 1,034 10.4% Not computed 136 (X) 37 (X) Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates owner-occupied housing costs as a percentage of household income according to the 2013-2017 and 2018- 2022 American Community Survey estimates. Owner-Occupied Housing Costs as a Percentage of Household Income in South Bend City Owner Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Owner-Occupied Housing Units 22,335 57.2% 23,731 58.5% Less than $20,000 2,831 12.7% 2,618 11.0% Less than 20 percent 584 2.6% 174 0.7% 20 to 29 percent 403 1.8% 506 2.1% 30 percent or more 1,844 8.3% 1,938 8.2% $20,000 to $34,999 3,882 17.4% 3,153 13.3% Less than 20 percent 1,646 7.4% 1,184 5.0% 20 to 29 percent 809 3.6% 900 3.8% 30 percent or more 1,427 6.4% 1,069 4.5% $35,000 to $49,999 3,858 17.3% 3,409 14.4% Less than 20 percent 1,851 8.3% 1,479 6.2% 20 to 29 percent 1,430 6.4% 1,037 4.4% 30 percent or more 577 2.6% 893 3.8% $50,000 to $74,999 5,049 22.6% 4,633 19.5% Less than 20 percent 3,653 16.4% 3,084 13.0% 20 to 29 percent 1,194 5.3% 1,117 4.7% 30 percent or more 202 0.9% 432 1.8% $75,000 or more 6,503 29.1% 9,754 41.1% Less than 20 percent 6,065 27.2% 8,832 37.2% 20 to 29 percent 374 1.7% 770 3.2% 30 percent or more 64 0.3% 152 0.6% Zero or negative income 212 0.9% 164 0.7% Source: 2013-2017 and 2018-2022 American Community Survey table B25106 2025 Analysis of Impediments to Fair Housing Background Data 102 HUD defines a housing cost burden as a household that pays over 30 percent or more of its monthly income on housing costs. In 2017, 4,114 units (18.4%) of owner-occupied households were cost burdened. In 2022, 4,484 units (18.9%) of owner-occupied households were cost burdened. Owner Costs – Mishawaka City The median selected monthly owner cost for owner-occupied housing units with a mortgage was $931 in 2017 and $1,125 in 2022, an increase of 20.8%. The median for owner-occupied housing units without a mortgage was $356 in 2017 and $422 in 2022, an increase of 18.5%. The following table illustrates mortgage status and selected monthly owner costs according to the 2013-2017 and 2018-2022 American Community Survey estimates. Selected Monthly Owner Costs in Mishawaka City Selected Monthly Owner Costs 2013-2017 ACS 2018-2022 ACS # % # % Housing units with a mortgage 6,662 - 7,275 - Less than $500 206 3.1% 58 0.8% $500 to $999 3,763 56.5% 2,574 35.4% $1,000 to $1,499 1,942 29.2% 3,032 41.7% $1,500 to $1,999 492 7.4% 1,053 14.5% $2,000 to $2,499 123 1.8% 200 2.7% $2,500 to $2,999 76 1.1% 121 1.7% $3,000 or more 60 0.9% 237 3.3% Median (dollars) $931 - $1,125 - Housing units without a mortgage 3,672 - 3,941 - Less than $250 663 18.1% 314 8.0% $250 to $399 1,512 41.2% 1,452 36.8% $400 to $599 1,204 32.8% 1,412 35.8% $600 to $799 191 5.2% 581 14.7% $800 to $999 68 1.9% 171 4.3% $1,000 or more 34 0.9% 11 0.3% Median (dollars) $356 - $422 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 2025 Analysis of Impediments to Fair Housing Background Data 103 The following table illustrates selected monthly owner costs as a percentage of income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Selected Monthly Owner Costs as a Percentage of Household Income (SMOCAPI) in Mishawaka City Owner Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Housing units with a mortgage (excluding units where SMOCAPI cannot be computed) 6,610 - 7,254 - Less than 20.0 percent 3,333 50.4% 4,029 55.5% 20.0 to 24.9 percent 1,100 16.6% 1,048 14.4% 25.0 to 29.9 percent 758 11.5% 750 10.3% 30.0 to 34.9 percent 382 5.8% 354 4.9% 35.0 percent or more 1,037 15.7% 1,073 14.8% Not computed 52 - 21 - Housing units without a mortgage (excluding units where SMOCAPI cannot be computed) 3,617 - 3,931 - Less than 10.0 percent 1,483 41.0% 1,815 46.2% 10.0 to 14.9 percent 944 26.1% 679 17.3% 15.0 to 19.9 percent 477 13.2% 451 11.5% 20.0 to 24.9 percent 228 6.3% 279 7.1% 25.0 to 29.9 percent 96 2.7% 105 2.7% 30.0 to 34.9 percent 126 3.5% 44 1.1% 35.0 percent or more 263 7.3% 558 14.2% Not computed 55 - 10 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates owner-occupied housing costs as a percentage of household income according to the 2013-2017 and 2018- 2022 American Community Survey estimates. Owner-Occupied Housing Costs as a Percentage of Household Income in Mishawaka City Owner Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Owner-Occupied Housing Units 10,334 50.2% 11,216 48.4% Less than $20,000 1,073 10.4% 1,114 9.9% Less than 20 percent 197 1.9% 35 0.3% 2025 Analysis of Impediments to Fair Housing Background Data 104 20 to 29 percent 137 1.3% 158 1.4% 30 percent or more 739 7.2% 921 8.2% $20,000 to $34,999 1,898 18.4% 1,318 11.8% Less than 20 percent 867 8.4% 445 4.0% 20 to 29 percent 421 4.1% 313 2.8% 30 percent or more 610 5.9% 560 5.0% $35,000 to $49,999 1,921 18.6% 1,586 14.1% Less than 20 percent 873 8.4% 845 7.5% 20 to 29 percent 743 7.2% 390 3.5% 30 percent or more 305 3.0% 351 3.1% $50,000 to $74,999 2,452 23.7% 2,136 19.0% Less than 20 percent 1,714 16.6% 1,193 10.6% 20 to 29 percent 636 6.2% 848 7.6% 30 percent or more 102 1.0% 95 0.8% $75,000 or more 2,883 27.9% 5,031 44.9% Less than 20 percent 2,586 25.0% 4,456 39.7% 20 to 29 percent 245 2.4% 473 4.2% 30 percent or more 52 0.5% 102 0.9% Zero or negative income 107 1.0% 31 0.3% Source: 2013-2017 and 2018-2022 American Community Survey table B25106 HUD defines a housing cost burden as a household that pays over 30 percent or more of its monthly income on housing costs. In 2017, 1,808 units (17.5%) of owner-occupied households were cost burdened. In 2022, 2,029 units (18.1%) of owner-occupied households were cost burdened. According to www.zillow.com, as of August 31, 2024 the median value for a two-bedroom housing unit in the City of South Bend was $121,743, $147,748 in the City of Mishawaka, and $137,141 for St. Joseph County. However, the average home value for a house in South Bend is $180,086, in Mishawaka is $197,087, and in St. Joseph County as of September 30, 2024 is $212,118. Foreclosures and Evictions The City of South Bend’s foreclosure rates had historically been some of the highest in the United States. When the foreclosure crisis occurred in 2008, South Bend’s foreclosure rates peaked, but other Cities overtook South Bend. Evictions from foreclosure and nonpayment of rent in St. Joseph County had fallen to 1,155 in 2019 and 864 in 2020. However, 2025 Analysis of Impediments to Fair Housing Background Data 105 following the COVID pandemic the number of evictions has risen sharply. In 2021, cases nearly doubled, and in 2022 there were triple the evictions as in 2020. They dipped slightly in 2023, but if the eviction rate from January to May 2024 remains constant, the number of evictions will nearly equal that of 2022. The below graph illustrates the trend in eviction cases in St. Joseph County. Source: Foreclosure and Eviction Analysis Tool, via City of South Bend Evictions are scattered across the County, but by far the most are taking place in the northwest, southwest, and southeast portions of South Bend, the city of Mishawaka overall but in particular its northwest corner, and in hot spots on the outskirts of the Notre Dame area. The below map illustrates these trends. 2025 Analysis of Impediments to Fair Housing Background Data 106 Source: Foreclosure and Eviction Analysis Tool, via City of South Bend As illustrated, the urban areas of St. Joseph County have the highest number of eviction filings, and South Bend has historically made up a large percentage of those evictions due to foreclosure or lease violations. While foreclosures negatively impact a community, it offers a chance for the County and non-profit housing agencies to purchase homes and resell them to low-income households. The Consortium can prioritize such sales and be on the lookout for absentee property owners that lack the incentive to invest in their community. 2025 Analysis of Impediments to Fair Housing Background Data 107 Renter Costs – St. Joseph County The median gross rent for renter-occupied households was $743 in 2017 and $969 in 2022, an increase of $226 (30.4%). The following table illustrates gross rent according to the 2013-2017 and 2018-2022 American Community Survey estimates. Gross Rent in St. Joseph County Gross Rent 2013-2017 ACS 2018-2022 ACS # % # % Occupied units paying rent 30,214 - 32,803 - Less than $500 5,197 17.2% 2,831 8.6% $500 to $999 19,699 65.2% 14,866 45.3% $1,000 to $1,499 4,374 14.5% 12,182 37.1% $1,500 to $1,999 671 2.2% 1,900 5.8% $2,000 to $2,499 197 0.7% 786 2.4% $2,500 to $2,999 35 0.1% 83 0.3% $3,000 or more 41 0.1% 155 0.5% Median (dollars) $743 - $969 - No rent paid 2,119 - 1,440 - Source: 2013-2017 and 2018-2022 American Community Survey The following table illustrates monthly gross rent as a percentage of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Gross Rent as a Percentage of Household Income in St. Joseph County Rental Cost as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Rental Units paying rent 28,905 - 32,248 - Less than 15 percent 3,994 13.8% 4,435 13.8% 15 to 19 percent 3,858 13.4% 4,586 14.2% 20 to 24 percent 3,828 13.2% 3,733 11.6% 25 to 29 percent 3,717 12.9% 3,727 11.6% 30 to 34 percent 2,293 7.9% 2,705 8.4% 35 percent or more 11,215 38.8% 13,062 40.5% Not computed 3,428 - 1,995 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 2025 Analysis of Impediments to Fair Housing Background Data 108 The following table illustrates monthly renter costs as a percentage of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Monthly Renter Costs as a Percentage of Household Income in St. Joseph County Renter Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Renter-Occupied Housing Units 32,333 32.1% 34,243 31.9% Less than $20,000 9,680 29.9% 7,788 22.7% Less than 20 percent 204 0.6% 87 0.3% 20 to 29 percent 912 2.8% 615 1.8% 30 percent or more 8,564 26.5% 7,086 20.7% $20,000 to $34,999 7,333 22.7% 6,775 19.8% Less than 20 percent 522 1.6% 315 0.9% 20 to 29 percent 2,486 7.7% 975 2.8% 30 percent or more 4,325 13.4% 5,485 16.0% $35,000 to $49,999 4,856 15.0% 5,604 16.4% Less than 20 percent 1,478 4.6% 875 2.6% 20 to 29 percent 2,885 8.9% 2,269 6.6% 30 percent or more 493 1.5% 2,460 7.2% $50,000 to $74,999 3,983 12.3% 6,048 17.7% Less than 20 percent 2,793 8.6% 2,400 7.0% 20 to 29 percent 1,100 3.4% 3,021 8.8% 30 percent or more 90 0.3% 627 1.8% $75,000 or more 3,053 9.4% 6,033 17.6% Less than 20 percent 2,855 8.8% 5,344 15.6% 20 to 29 percent 162 0.5% 580 1.7% 30 percent or more 36 0.1% 109 0.3% Zero or negative income 1,309 4.0% 555 1.6% No cash rent 2,119 6.6% 1,440 4.2% Source: 2013-2017 and 2018-2022 American Community Survey table B25106 HUD defines a housing cost burden as a household that pays over 30 percent or more of its monthly income on housing costs. In 2017, 13,508 renter-occupied units (41.8%) were cost burdened, and in 2022, 15,767 renter-occupied units (46.0%) were cost burdened. In 2017, 15.8% of owner-occupied households were cost burdened while 41.8% of renter-occupied households were cost burdened. In 2022, 15.6% 2025 Analysis of Impediments to Fair Housing Background Data 109 of owner-occupied households were cost burdened while 46.0% of renter- occupied households were cost burdened. Renter Costs – South Bend City The median gross rent for renter-occupied households was $741 in 2017 and $958 in 2022, an increase of $217 (29.3%). The following table illustrates gross rent according to the 2013-2017 and 2018-2022 American Community Survey estimates. Gross Rent in South Bend City Gross Rent 2013-2017 ACS 2018-2022 ACS # % # % Occupied units paying rent 15,679 - 16,280 - Less than $500 3,253 20.7% 1,491 9.2% $500 to $999 9,952 63.5% 7,906 48.6% $1,000 to $1,499 2,032 13.0% 5,599 34.4% $1,500 to $1,999 335 2.1% 958 5.9% $2,000 to $2,499 80 0.5% 225 1.4% $2,500 to $2,999 16 0.1% 29 0.2% $3,000 or more 11 0.1% 72 0.4% Median (dollars) $741 - $935 - No rent paid 1,011 - 548 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates monthly gross rent as a percentage of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Gross Rent as a Percentage of Household Income in South Bend City Rental Cost as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Rental Units paying rent 14,707 - 15,922 - Less than 15 percent 1,742 11.8% 1,965 12.3% 15 to 19 percent 1,852 12.6% 1,962 12.3% 20 to 24 percent 1,811 12.3% 1,870 11.7% 25 to 29 percent 1,883 12.8% 1,882 11.8% 30 to 34 percent 1,114 7.6% 1,328 8.3% 2025 Analysis of Impediments to Fair Housing Background Data 110 35 percent or more 6,305 42.9% 6,915 43.4% Not computed 1,983 - 906 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates monthly renter costs as a percentage of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Monthly Renter Costs as a Percentage of Household Income in South Bend City Renter Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Renter-Occupied Housing Units 16,690 42.8% 16,828 41.5% Less than $20,000 5,580 33.4% 4,471 26.6% Less than 20 percent 183 1.1% 79 0.5% 20 to 29 percent 590 3.5% 243 1.4% 30 percent or more 4,807 28.8% 4,149 24.7% $20,000 to $34,999 3,793 22.7% 3,302 19.6% Less than 20 percent 323 1.9% 122 0.7% 20 to 29 percent 1,214 7.3% 533 3.2% 30 percent or more 2,256 13.5% 2,647 15.7% $35,000 to $49,999 2,305 13.8% 2,871 17.1% Less than 20 percent 649 3.9% 512 3.0% 20 to 29 percent 1,358 8.1% 1,284 7.6% 30 percent or more 298 1.8% 1,075 6.4% $50,000 to $74,999 1,863 11.2% 2,645 15.7% Less than 20 percent 1,343 8.0% 839 5.0% 20 to 29 percent 478 2.9% 1,476 8.8% 30 percent or more 42 0.3% 330 2.0% $75,000 or more 1,166 7.0% 2,633 15.6% Less than 20 percent 1,096 6.6% 2,375 14.1% 20 to 29 percent 54 0.3% 216 1.3% 30 percent or more 16 0.1% 42 0.2% Zero or negative income 972 5.8% 358 2.1% No cash rent 1,011 6.1% 548 3.3% Source: 2013-2017 and 2018-2022 American Community Survey table B25106 HUD defines a housing cost burden as a household that pays over 30 percent or more of its monthly income on housing costs. In 2017, 7,419 2025 Analysis of Impediments to Fair Housing Background Data 111 renter-occupied units (44.2%) were cost burdened, and in 2022, 8,243 renter-occupied units (49.0%) were cost burdened. In 2017, 18.4% of owner-occupied households were cost burdened while 44.2% of renter-occupied households were cost burdened. In 2022, 18.9% of owner-occupied households were cost burdened while 49.0% of renter- occupied households were cost burdened. Renter Costs – Mishawaka City The median gross rent for renter-occupied households was $730 in 2017 and $979 in 2022, an increase of $249 (34.1%). The following table illustrates gross rent according to the 2013-2017 and 2018-2022 American Community Survey estimates. Gross Rent in Mishawaka City Gross Rent 2013-2017 ACS 2018-2022 ACS # % # % Occupied units paying rent 9,829 - 11,603 - Less than $500 1,436 14.6% 853 7.4% $500 to $999 6,930 70.5% 5,327 45.9% $1,000 to $1,499 1,194 12.1% 4,345 37.4% $1,500 to $1,999 200 2.0% 576 5.0% $2,000 to $2,499 21 0.2% 431 3.7% $2,500 to $2,999 18 0.2% 32 0.3% $3,000 or more 30 0.3% 39 0.3% Median (dollars) $730 - $979 - No rent paid 405 - 372 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates monthly gross rent as a percentage of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. 2025 Analysis of Impediments to Fair Housing Background Data 112 Gross Rent as a Percentage of Household Income in Mishawaka City Rental Cost as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Rental Units paying rent 9,626 - 11,487 - Less than 15 percent 1,360 14.1% 1,472 12.8% 15 to 19 percent 1,301 13.5% 1,930 16.8% 20 to 24 percent 1,495 15.5% 1,268 11.0% 25 to 29 percent 1,217 12.6% 1,455 12.7% 30 to 34 percent 826 8.6% 988 8.6% 35 percent or more 3,427 35.6% 4,374 38.1% Not computed 608 - 488 - Source: 2013-2017 and 2018-2022 American Community Survey table DP04 The following table illustrates monthly renter costs as a percentage of household income according to the 2013-2017 and 2018-2022 American Community Survey estimates. Monthly Renter Costs as a Percentage of Household Income in Mishawaka City Renter Costs as a % of Income 2013-2017 ACS 2018-2022 ACS # % # % Renter-Occupied Housing Units 10,234 49.8% 11,975 51.6% Less than $20,000 2,784 27.2% 2,250 18.8% Less than 20 percent 0 0.0% 0 0.0% 20 to 29 percent 180 1.8% 293 2.4% 30 percent or more 2,604 25.4% 1,957 16.3% $20,000 to $34,999 2,694 26.3% 2,571 21.5% Less than 20 percent 150 1.5% 67 0.6% 20 to 29 percent 1,082 10.6% 391 3.3% 30 percent or more 1,462 14.3% 2,113 17.6% $35,000 to $49,999 1,760 17.2% 2,108 17.6% Less than 20 percent 556 5.4% 265 2.2% 20 to 29 percent 1,061 10.4% 755 6.3% 30 percent or more 143 1.4% 1,088 9.1% $50,000 to $74,999 1,312 12.8% 2,455 20.5% Less than 20 percent 939 9.2% 1,210 10.1% 20 to 29 percent 347 3.4% 1,080 9.0% 30 percent or more 26 0.3% 165 1.4% 2025 Analysis of Impediments to Fair Housing Background Data 113 $75,000 or more 1,076 10.5% 2,103 17.6% Less than 20 percent 1,016 9.9% 1,860 15.5% 20 to 29 percent 42 0.4% 204 1.7% 30 percent or more 18 0.2% 39 0.3% Zero or negative income 203 2.0% 116 1.0% No cash rent 405 4.0% 372 3.1% Source: 2013-2017 and 2018-2022 American Community Survey table B25106 HUD defines a housing cost burden as a household that pays over 30 percent or more of its monthly income on housing costs. In 2017, 4,235 renter-occupied units (41.4%) were cost burdened, and in 2022, 5,323 renter-occupied units (44.5%) were cost burdened. In 2017, 17.5% of owner-occupied households were cost burdened while 41.4% of renter-occupied households were cost burdened. In 2022, 18.1% of owner-occupied households were cost burdened while 44.5% of renter- occupied households were cost burdened. The FY 2024 HUD Fair Market Rents and Low and High HOME Rent Limits for the South Bend-Mishawaka, IN HUD Metro FMR Area are shown in the table below. Fair Market Rents (FMR) and HOME Rent Limits for the South Bend-Mishawaka, IN HUD Metro FMR Area FY 2024 Rent Fair Market Rents Low HOME Limit High HOME Limit Efficiency $689 $689 $689 One-Bedroom $862 $834 $862 Two-Bedroom $1,017 $1,001 $1,017 Three-Bedroom $1,267 $1,157 $1,267 Four-Bedroom $1,354 $1,291 $1,354 Five-Bedroom $1,557 $1,424 $1,557 Six-Bedroom $1,760 $1,557 $1,760 Source: U.S. Department of Housing and Urban Development Fair Market Rents (FMRs) are primarily used to determine payment standard amounts for HUD assisted housing. The High HOME Rent Limit for an area is the lesser of the Section 8 Fair Market Rent (FMR) for the area or a rent equal to 30% of the annual income of a family whose income equals 65% of the area median income, as determined by HUD. The Low HOME Rent Limit for an area is 30% of the annual income of a family whose income equals 50% of the area median income, as determined by HUD, 2025 Analysis of Impediments to Fair Housing Background Data 114 capped by the High HOME Rent Limit. HUD’s Economic and Market Analysis Division calculates the HOME rents each year using the FMRs and the Section 8 Income Limits. The area median rent was estimated to be $969 according to the 2018-2022 ACS data. However, according to Zillow the South Bend-Mishawaka, IN-MI MSA median rent was $1,189 on December 31, 2022, and has since climbed to $1,309 on August 31, 2024. The average rents posted commercially exceed the area median rent by over $300 and exceed the FY 2025 fair market rents (for a 2-bedroom apartment) by over $200. The rental market in St. Joseph County is competitive and assisted rental housing units do not disproportionately impact the market forces dictating rents in the area. 2025 Analysis of Impediments to Fair Housing Background Data 115 G. Household Types Based on a comparison between the 2017 and 2022 population, St. Joseph County had a 1.4% increase in its population (3,775 persons). However, the County had an increase of 6.7% households, meaning that there are more and smaller households than in prior years. The populations of the Cities of South Bend and Mishawaka and of St. Joseph County have grown over the last five years. However, there are neighborhoods of the City of South Bend and the City of Mishawaka with poor housing stock. When demolished, the poor housing stock has generally not been replaced. Between 2017 and 2022 the area median income increased by 68% from $48,121 to $80,842. This increase in median income represents a change in nominal dollars and not a change in real dollars. In order to calculate the change in real dollars, the Consumer Price Index is used to calculate the inflation rate for a given period. Between 2017 and 2022, the cumulative inflation rate was approximately 20.4%, meaning that the $48,121 median income in 2017 would be $57,934.19 if it were expressed in terms of 2022 dollars. The increase in median income in St. Joseph County has exceeded the rate of inflation, but more examination is needed to ascertain the income spread between low- and high-income households. St. Joseph County Demographics, 2017-2022 Demographics 2017 2022 % Change Population 268,613 272,388 +1.41% Households 100,694 107,466 +6.73% Household Median Income $48,121 $80,842 +68.00% Source: 2013-2017 and 2018-2022 American Community Survey table DP03 Note: According to the U.S. Census Bureau the following notes were issued in regard to the CHAS (Comprehensive Housing Affordability Strategy) and the discrepancies in adding up the totals in the following tables. As with the CHAS 2000 and all other special tabulations of Census data, the Census Bureau requires that the CHAS data be rounded. The rounding scheme is as follows: 0 remains 0; 1-7 rounds to 4; 8 or greater rounds to 2025 Analysis of Impediments to Fair Housing Background Data 116 nearest multiple of 5. This causes discrepancies when adding up smaller geographies and when adding up data within CHAS tables. Consider a city where the CHAS data indicate that there were 4 renter households with extremely low income and 4 owner households with extremely low income. One might be tempted to conclude that there are 8 total households with extremely low income. If another CHAS table indicates that there are actually a total of 15 extremely low income households, that would appear to be contradictory. This situation is the result of rounding. The County could have 6 renter households with extremely low income and 7 owner households with extremely low income, which is a total of 13 extremely low income households; but all of these numbers would be rounded, to 4, 4, and 15. Number of Households Table 0-30% AMI >30-50% AMI >50-80% AMI >80-100% AMI >100% AMI Total Households * 13,040 12,190 18,450 11,975 50,665 Small Family Households * 3,245 3,055 5,095 4,240 25,090 Large Family Households * 780 630 1,315 1,020 4,050 Household contains at least one person 62-74 years of age 3,145 3,270 4,435 2,895 12,215 Household contains at least one person age 75 or older 2,560 2,735 2,835 1,100 3,605 Households with one or more children 6 years old or younger * 1,835 1,635 2,445 2,250 6,945 Source: 2017-2021 CHAS tables 1, 5, 7, 13 Of all households, less than half (47.7%) have a higher income than the HUD Area Median Income (AMI) for the South Bend-Mishawaka, IN-MI, MSA. Over half of both small and large family households are above 100% AMI, but at least half of households with any seniors (especially over age 75) or any children age 6 or younger are below the AMI. The remaining 52.3% of total households make less than the AMI, with the largest remaining group (17.4% of total households) making between 50-80% of AMI. The median gross household income in the South Bend MSA as of 2021 was $58,596, which means that 30% of AMI is $17,579 and 50% of AMI is $29,298. HUD defines affordable housing as paying no more than 30% of income on rent, so low-income households should only be spending 2025 Analysis of Impediments to Fair Housing Background Data 117 between $440 and $732 per month for their housing to be considered affordable. The following table further highlights that the largest housing problem in the South Bend/Mishawaka, IN-MI MSA is housing affordability. According to the 2018-2022 ACS data, an estimated 48.9% of all renter households are cost burdened by 30% or more in the County, and an estimated 15.7% of all owner households are cost burdened by 30% or more. Approximately 18.7% of owner-occupied households with a mortgage are cost burdened by 30% or more, compared to only 10.9% of owner-occupied households without a mortgage. Housing Problems (Households with one of the listed needs) Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Over all* 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Over -all* Substandard Housing - Lacking complete plumbing or kitchen facilities 185 145 25 10 495 85 35 30 50 325 Severely Overcrowded - With >1.51 people per room (and complete kitchen and plumbing) 95 40 80 75 355 0 15 20 10 65 Overcrowded - With 1.01-1.5 people per room (and none of the above problems) 210 160 170 45 790 35 45 215 45 615 Housing cost burden greater than 50% of income (and none of the above problems) 4,575 1,790 250 60 6,695 3,040 790 320 185 4,380 Housing cost burden greater than 30% of income (and none of the above problems) 940 2,760 2,575 360 6,770 920 1,815 1,850 765 5,890 Zero/negative Income (and none of the above problems) 860 0 0 0 860 390 0 0 0 390 Source: 2017-2021 CHAS table 3 *Overall includes households above 100% AMI not depicted in the table The following tables illustrate the discrepancies between homeowners and renters regarding housing problems and severe housing problems. There are more owner-occupied housing units than renter-occupied units (68.5% to 31.5%), but renters face a much higher rate of housing problems. 2025 Analysis of Impediments to Fair Housing Background Data 118 Housing Problems: Lacks kitchen or complete plumbing, overcrowding, or cost burden Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall Having 1 or more of four housing problems 6,000 4,900 3,100 550 15,095 4,085 2,700 2,435 1,050 11,280 Having none of four housing problems 860 1,360 4,150 3,220 17,580 845 3,230 8,765 7,155 61,120 Negative household income, none of the other housing problems 860 0 0 0 860 390 0 0 0 390 Source: 2017-2021 CHAS table 5 Severe Housing Problems: Lacks kitchen or complete plumbing, severe overcrowding, or severe cost burden Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall Having 1 or more of four severe housing problems 5,065 2,140 525 190 8,330 3,165 890 585 285 5,390 Having none of four severe housing problems 2,660 4,125 6,725 3,580 25,210 2,155 5,045 10,620 7,920 67,400 Source: 2017-2021 CHAS table 2 Nearly 3,000 more renter-occupied households have severe housing problems than owner-occupied households, with 33.0% of all renters having severe problems as compared to 8.0% of owners. Cost Burdened Greater Than 30% Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall Small family (2-4 persons) 330 855 650 75 1,920 95 590 565 125 1,605 Large family (5 or more persons) 25 255 4 0 284 90 40 75 135 405 2025 Analysis of Impediments to Fair Housing Background Data 119 Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall Elderly family (2 persons, at least one age 62 or over) 4 75 170 10 259 100 155 345 110 830 Elderly non-family 555 795 465 70 1,940 420 740 455 85 1,760 Other, non-family households 120 925 1,300 205 2,640 225 295 440 310 1,340 Total need by income 1,034 2,905 2,589 360 7,043 930 1,820 1,880 765 5,940 Source: 2017-2021 CHAS table 7 For those cost burdened by more than 30%, renters are more likely to be highly affected; renter-occupied households are much more likely to be cost burdened than owners. Cost Burdened Greater Than 50% Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Overall Small family (2-4 persons) 1,560 565 25 0 2,150 800 135 4 10 964 Large family (5 or more persons) 355 20 0 0 375 200 35 40 4 283 Elderly family (2 persons, at least one age 62 or over) 35 50 35 20 144 245 75 95 0 435 Elderly non-family 915 530 25 40 1,520 1,175 325 130 120 1,750 Other, non-family households 2,060 670 170 0 2,900 655 225 50 230 1,170 Total need by income 4,925 1,835 255 60 7,089 3,075 795 319 364 4,602 Source: 2017-2021 CHAS table 7 For those who are cost burdened by more than 50%, renters are more highly affected than owners based on the total number of households. 2025 Analysis of Impediments to Fair Housing Background Data 120 Overcrowding Conditions: Greater than 1 but less than 1.5 persons per room Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Over -all 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Over -all Single family households 210 145 120 20 695 35 45 175 175 450 Multiple, unrelated family households 0 4 50 4 58 4 0 35 35 74 Other, non-family households 0 10 0 20 30 0 0 0 0 0 Total need by income 210 160 170 45 790 35 45 215 215 615 Source: 2017-2021 CHAS table 10 Renter-occupant households are more affected overall by overcrowding conditions than are owner-occupant households. Severe Overcrowding Conditions: Greater than 1.5 persons per room Renter Owner 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Over -all 0- 30% AMI >30- 50% AMI >50- 80% AMI >80- 100% AMI Over -all Single family households 95 40 10 75 285 0 15 4 0 39 Multiple, unrelated family households 0 0 10 0 10 0 0 15 10 25 Other, non-family households 0 0 55 0 55 0 0 0 0 0 Total need by income 95 40 80 75 355 0 15 20 10 65 Source: 2017-2021 CHAS table 10 Renter-occupied households are much more likely to experience severe overcrowding than are owner-occupied households. The following three (3) maps illustrate census tracts where there is overcrowding for Extremely Low-, Low-, and Moderate-Income Households.  Percentage Extremely Low-Income Households with Overcrowding  Percentage Low-Income Households with Overcrowding  Percentage Moderate-Income Households with Overcrowding 2025 Analysis of Impediments to Fair Housing Background Data 121 2025 Analysis of Impediments to Fair Housing Background Data 122 2025 Analysis of Impediments to Fair Housing Background Data 123 2025 Analysis of Impediments to Fair Housing Background Data 124 H. Housing Problems A household is considered to have a housing problem if it meets one of the four (4) HUD designated housing problems; The four housing problems are: lacks complete kitchen facilities; lacks complete plumbing facilities; has more than one person per room; and is cost burdened greater than 30%. The following tables illustrate the disproportionate needs of households in St. Joseph County: 0%-30% of Area Median Income (Extremely Low Income) Housing Problems* Has one or more of four housing problems Has none of the four housing problems OR cost burden not computed Jurisdiction as a whole 10,085 2,955 White 6,220 1,700 Black / African American 2,655 810 Asian 125 45 American Indian, Alaska Native 25 4 Pacific Islander 0 0 Hispanic 590 245 Source: 2017-2021 CHAS table 1 *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30% The following map illustrates the location by Census Tract where extremely low-income households have severe housing problems. 2025 Analysis of Impediments to Fair Housing Background Data 125 2025 Analysis of Impediments to Fair Housing Background Data 126 30%-50% of Area Median Income (Low Income) Housing Problems* Has one or more of four housing problems Has none of the four housing problems OR cost burden not computed Jurisdiction as a whole 7,600 4,590 White 4,980 3,565 Black / African American 1,790 430 Asian 125 35 American Indian, Alaska Native 44 0 Pacific Islander 0 4 Hispanic 485 390 Source: 2017-2021 CHAS Table 1 *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30% The following map illustrates the location by Census Tract where low- income households have severe housing problems. 2025 Analysis of Impediments to Fair Housing Background Data 127 2025 Analysis of Impediments to Fair Housing Background Data 128 50%-80% of Area Median Income (Moderate Income) Housing Problems* Has one or more of four housing problems Has none of the four housing problems OR cost burden not computed Jurisdiction as a whole 5,535 12,915 White 3,750 10,075 Black / African American 960 1,350 Asian 205 190 American Indian, Alaska Native 30 25 Pacific Islander 0 4 Hispanic 345 1,035 Source: 2017-2021 CHAS table 1 *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30% The following map illustrates the location by Census Tract where moderate- income households have severe housing problems. 2025 Analysis of Impediments to Fair Housing Background Data 129 2025 Analysis of Impediments to Fair Housing Background Data 130 80%-100% of Area Median Income (Medium Income) Housing Problems* Has one or more of four housing problems Has none of the four housing problems OR cost burden not computed Jurisdiction as a whole 1,600 10,375 White 1,160 8,150 Black / African American 235 805 Asian 30 180 American Indian, Alaska Native 0 15 Pacific Islander 0 0 Hispanic 125 930 Source: 2017-2021 CHAS table 1 *The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30% The racial composition of households in St. Joseph County according to the 2018-2022 American Community Survey was 73.9% White; 12.9% African American/Black; 2.6% Asian; 0.3% American Indian and Alaska Native; 0.1% Native Hawaiian or Pacific Islander; 2.9% Some Other Race; and 7.4% Two or More Races. The Hispanic or Latino population of any race was 9.5% of the County’s population. The following racial or ethnic groups are disproportionately impacted by 10% or more in the specified AMI category versus the category average: Disproportionate Housing Problem Impact by AMI and Race or Ethnicity Category Households per AMI category Households with 1 or more of 4 housing problems Number Percent Number Percent 30-50% of AMI: 12,490 - 7,600 62.3% Black / African American 2,220 17.8% 1,790 80.6% Asian 160 1.3% 125 78.1% American Indian, Alaska Native 44 0.4% 44 100.0% 50-80% of AMI: 18,450 - 5,535 30.0% Black / African American 2,310 12.5% 960 41.6% Asian 395 2.1% 205 51.9% 2025 Analysis of Impediments to Fair Housing Background Data 131 Category Households per AMI category Households with 1 or more of 4 housing problems Number Percent Number Percent American Indian, Alaska Native 55 0.3% 30 54.5% Source: 2017-2021 CHAS table 1 There were no groups disproportionately impacted by 10% or more than the overall percentage of households with one or more housing problems within either the 0-30% AMI or 80-100% AMI categories. However, the incidence of households with one or more housing problems within the 0-30% AMI category is extremely high and may reveal disparities on a closer geographic examination. 2025 Analysis of Impediments to Fair Housing Background Data 132 I. Cost Burden Overall, there is a shortage of decent, affordable housing in St. Joseph County. Many of the County’s lower income households are paying more than 30% of their total household income on housing related costs. The following table illustrates the housing cost burden for various racial and ethnic groups, both overall and for owner- and renter-occupied households. Housing Cost Burden, St. Joseph County Housing Cost Burden <30% 30-50% >50% No / negative income (not computed) Total All Households 80,565 12,985 11,525 1,273 106,330 White 65,410 8,830 7,365 680 82,285 Black / African American 6,705 2,555 2,825 400 12,480 Asian 1,880 265 170 49 2,355 American Indian / Alaska Native 150 35 60 4 255 Pacific Islander 30 0 0 0 30 Hispanic / Latino 4,565 820 600 65 6,050 Other Race (includes 2 or more) 1,825 480 505 75 2,880 Owner-Occupied 62,025 5,940 4,430 403 72,790 White 52,975 4,720 3,580 310 61,585 Black / African American 3,415 640 365 50 4,470 Asian 1,310 55 90 4 1,455 American Indian / Alaska Native 135 15 10 4 165 Pacific Islander 30 0 0 0 30 Hispanic / Latino 2,995 310 225 35 3,565 Other Race 1,165 200 160 0 1,520 Renter-Occupied 18,540 7,045 7,095 870 33,540 White 12,435 4,110 3,785 370 20,700 Black / African American 3,290 1,915 2,460 350 8,010 Asian 570 210 80 45 900 American Indian / Alaska Native 15 20 50 0 90 Pacific Islander 0 0 0 0 0 2025 Analysis of Impediments to Fair Housing Background Data 133 Housing Cost Burden <30% 30-50% >50% No / negative income (not computed) Total Hispanic / Latino 1,570 510 375 30 2,485 Other Race 660 280 345 75 1,360 Source: 2017-2021 CHAS table 9 Many more renter-occupied households than owner-occupied households were cost burdened by 30 to 50%, and a great deal many more renter- occupied households were cost burdened by more than 50%. The difference was especially disproportionate in some racial and ethnic groups. In Other Race (not Hispanic or Latino) households, 34.2% were disproportionately burdened by at least 30%, and 46% of all Other Race renter-occupied households were disproportionately burdened by at least 30%. 37.3% of all American Indian/Alaska Native households were burdened by at least 30%, with 77.8% of all renter-occupied households disproportionately burdened by at least 30%. 43.1% of Black/African American households were disproportionately burdened by at least 30%, and 54.6% of their renter-occupied households were burdened by at least 30%. In contrast, a relatively low 19.7% of all White households were burdened by at least 30%. The following four (4) maps illustrate census tracts where there are housing cost burdens for all households, Extremely Low, Very Low, and Low Income Households.  Housing Cost Burden  Percentage Extremely Low Income Households with Severe Cost Burden  Percentage Low Income Households with Severe Cost Burden  Percentage Moderate Income Households with Severe Cost Burden 2025 Analysis of Impediments to Fair Housing Background Data 134 2025 Analysis of Impediments to Fair Housing Background Data 135 2025 Analysis of Impediments to Fair Housing Background Data 136 2025 Analysis of Impediments to Fair Housing Background Data 137 2025 Analysis of Impediments to Fair Housing Background Data 138 A total of 7,365 White households were considered severely cost burdened by greater than 50%, which is 63.9% of the total cases of households that were considered cost burdened by greater than 50%. This number is below the 77.4% of total households that the White category comprises. A total of 2,825 Black/African American households were considered severely cost burdened by greater than 50%, which is 24.5% of the total cases of households that were considered cost burdened by greater than 50%. This number is above the 11.7% of total households that the Black/African American category comprises. A total of 170 Asian households were considered severely cost burdened by greater than 50%, which is 1.5% of the total cases of households that were considered cost burdened by greater than 50%. This number is slightly lower than the 2.2% of total households that the Asian category comprises. A total of 60 American Indian/Alaska Native households were considered severely cost burdened by greater than 50%, which is 0.5% of the total number of households that were considered cost burdened by greater than 50%. This number is above the 0.2% of total households that the American Indian/Alaska Native category comprises. None of the 30 Pacific Islander households in St. Joseph County were considered cost burdened or severely cost burdened. A total of 600 Hispanic households were considered severely cost burdened by greater than 50%, which is 5.2% of the total number of households that were considered cost burdened by greater than 50%. This number is slightly below the 5.7% of total households that the Hispanic category comprises. A total of 505 Other Race households were considered severely cost burdened by greater than 50%, which is 4.4% of the total number of households that were considered cost burdened by greater than 50%. This number is above the 2.7% of total households that the Other Race category comprises. 2025 Analysis of Impediments to Fair Housing Background Data 139 J. Disabled Households Disabled Population – St. Joseph County The following table includes the 2013-2017 and 2018-2022 American Community Survey estimates for the number of disabled individuals in St. Joseph County. The total population of disabled persons in St. Joseph County is estimated to be 36,230 persons, 13.4% of the County’s population. The two most common disability types are ambulatory difficulties and independent living difficulties. Disabled Persons in St. Joseph County Disability Status of the Civilian Non- Institutional Population 2013-2017 ACS 2018-2022 ACS # % # % Total Civilian Population 266,134 - 269,860 - Total Population with a disability 36,454 13.7% 36,230 13.4% Population under 5 years 171 1.0% 66 0.4% With a hearing difficulty 132 0.8% 51 0.3% With a vision difficulty 59 0.3% 15 0.1% Population 5 to 17 years 3,237 6.9% 3,321 7.2% With a hearing difficulty 384 0.8% 271 0.6% With a vision difficulty 396 0.8% 502 1.1% With a cognitive difficulty 2,761 5.9% 2,561 5.5% With an ambulatory difficulty 410 0.9% 447 1.0% With a self-care difficulty 556 1.2% 495 1.1% Population 18 to 34 years 4,621 7.2% 6,120 9.1% With a hearing difficulty 660 1.0% 532 0.8% With a vision difficulty 639 1.0% 1,415 2.1% With a cognitive difficulty 3,200 5.0% 3,736 5.5% With an ambulatory difficulty 956 1.5% 1,341 2.0% With a self-care difficulty 787 1.2% 675 1.0% With an independent living difficulty 2,231 3.5% 2,531 3.8% Population 35 to 64 years 14,818 14.9% 12,864 13.3% With a hearing difficulty 3,493 3.5% 2,605 2.7% With a vision difficulty 2,651 2.7% 2,324 2.4% With a cognitive difficulty 5,606 5.7% 5,337 5.5% With an ambulatory difficulty 8,120 8.2% 7,382 7.7% With a self-care difficulty 2,880 2.9% 2,443 2.5% 2025 Analysis of Impediments to Fair Housing Background Data 140 With an independent living difficulty 5,412 5.5% 3,991 4.1% Population 65 years and over 13,607 35.3% 13,859 32.2% With a hearing difficulty 5,671 14.7% 5,775 13.4% With a vision difficulty 2,424 6.3% 2,964 6.9% With a cognitive difficulty 3,331 8.6% 2,991 7.0% With an ambulatory difficulty 8,699 22.6% 8,482 19.7% With a self-care difficulty 2,995 7.8% 2,773 6.4% With an independent living difficulty 5,550 14.4% 5,148 12.0% Sex Male 17,620 13.7% 17,302 13.1% Female 18,834 13.7% 18,928 13.7% Race or Ethnicity White alone 29,116 13.8% 28,473 14.3% Black or African American alone 5,458 15.9% 4,580 13.3% American Indian and Alaska Native alone 347 30.8% 89 10.8% Asian alone 250 4.3% 237 3.4% Native Hawaiian and Other Pacific Islander alone 3 1.1% 15 8.5% Some other race alone 435 7.6% 720 9.3% Two or more races 845 10.1% 2,116 10.5% White alone, not Hispanic or Latino 27,981 14.3% 27,646 14.5% Hispanic or Latino (of any race) 1,767 7.9% 2,300 8.9% Source: 2013-2017 and 2018-2022 American Community Survey table S1810 Disabled Population – City of South Bend The following table includes the 2013-2017 and 2018-2022 American Community Survey estimates for the number of disabled individuals in South Bend City. The total population of disabled persons in South Bend is estimated to be 14,647 persons, 14.4% of the City’s population. The two most common disability types are ambulatory difficulties and cognitive difficulties. Disabled Persons in South Bend City Disability Status of the Civilian Non- Institutional Population 2013-2017 ACS 2018-2022 ACS # % # % Total Civilian Population 100,394 - 101,598 - Total Population with a disability 15,438 15.4% 14,647 14.4% Population under 5 years 97 1.3% 38 0.5% 2025 Analysis of Impediments to Fair Housing Background Data 141 With a hearing difficulty 58 0.8% 38 0.5% With a vision difficulty 59 0.8% 0 0.0% Population 5 to 17 years 1,675 8.6% 1,966 9.7% With a hearing difficulty 177 0.9% 241 1.2% With a vision difficulty 208 1.1% 293 1.4% With a cognitive difficulty 1,399 7.2% 1,555 7.7% With an ambulatory difficulty 198 1.0% 267 1.3% With a self-care difficulty 289 1.5% 237 1.2% Population 18 to 34 years 2,037 7.9% 2,425 9.4% With a hearing difficulty 249 1.0% 187 0.7% With a vision difficulty 265 1.0% 477 1.9% With a cognitive difficulty 1,461 5.7% 1,581 6.1% With an ambulatory difficulty 372 1.4% 481 1.9% With a self-care difficulty 246 1.0% 251 1.0% With an independent living difficulty 963 3.7% 1,167 4.5% Population 35 to 64 years 6,727 19.2% 5,420 15.6% With a hearing difficulty 1,407 4.0% 826 2.4% With a vision difficulty 1,289 3.7% 1,127 3.2% With a cognitive difficulty 3,010 8.6% 2,473 7.1% With an ambulatory difficulty 4,037 11.5% 3,212 9.3% With a self-care difficulty 1,344 3.8% 1,123 3.2% With an independent living difficulty 2,649 7.5% 1,748 5.0% Population 65 years and over 4,902 39.8% 4,798 35.5% With a hearing difficulty 1,879 15.3% 1,479 10.9% With a vision difficulty 1,102 9.0% 875 6.5% With a cognitive difficulty 1,176 9.6% 1,197 8.9% With an ambulatory difficulty 3,179 25.8% 3,252 24.0% With a self-care difficulty 1,117 9.1% 1,105 8.2% With an independent living difficulty 2,261 18.4% 1,986 14.7% Sex Male 7,031 14.6% 6,535 13.6% Female 8,407 16.1% 8,112 15.1% Race or Ethnicity White alone 9,840 15.6% 9,132 16.1% Black or African American alone 4,702 17.7% 3,705 14.4% American Indian and Alaska Native alone 155 32.9% 31 6.5% Asian alone 38 2.6% 36 1.7% 2025 Analysis of Impediments to Fair Housing Background Data 142 Native Hawaiian and Other Pacific Islander alone 0 0.0% 9 15.0% Some other race alone 335 7.9% 576 9.7% Two or more races 368 8.6% 1,158 10.9% White alone, not Hispanic or Latino 9,163 17.0% 8,612 16.6% Hispanic or Latino (of any race) 1,090 7.5% 1,610 9.6% Source: 2013-2017 and 2018-2022 American Community Survey table S1810 Disabled Population – City of Mishawaka The following table includes the 2013-2017 and 2018-2022 American Community Survey estimates for the number of disabled individuals in Mishawaka City. The total population of disabled persons in Mishawaka is estimated to be 8,295 persons, 16.4% of the City’s population. The two most common disability types are ambulatory difficulties and cognitive difficulties. Disabled Persons in Mishawaka City Disability Status of the Civilian Non- Institutional Population 2013-2017 ACS 2018-2022 ACS # % # % Total Civilian Population 48,301 - 50,538 - Total Population with a disability 7,257 15.0% 8,295 16.4% Population under 5 years 72 2.1% 0 0.0% With a hearing difficulty 72 2.1% 0 0.0% With a vision difficulty 0 0.0% 0 0.0% Population 5 to 17 years 398 5.3% 472 6.6% With a hearing difficulty 56 0.7% 8 0.1% With a vision difficulty 44 0.6% 52 0.7% With a cognitive difficulty 318 4.2% 320 4.5% With an ambulatory difficulty 22 0.3% 70 1.0% With a self-care difficulty 49 0.7% 91 1.3% Population 18 to 34 years 828 6.4% 1,620 11.1% With a hearing difficulty 99 0.8% 202 1.4% With a vision difficulty 116 0.9% 349 2.4% With a cognitive difficulty 623 4.8% 781 5.4% With an ambulatory difficulty 139 1.1% 498 3.4% With a self-care difficulty 114 0.9% 207 1.4% With an independent living difficulty 390 3.0% 519 3.6% Population 35 to 64 years 2,922 17.1% 2,960 17.1% With a hearing difficulty 695 4.1% 725 4.2% 2025 Analysis of Impediments to Fair Housing Background Data 143 With a vision difficulty 502 2.9% 437 2.5% With a cognitive difficulty 989 5.8% 1,087 6.3% With an ambulatory difficulty 1,671 9.8% 1,742 10.1% With a self-care difficulty 515 3.0% 446 2.6% With an independent living difficulty 910 5.3% 767 4.4% Population 65 years and over 3,037 41.2% 3,243 39.5% With a hearing difficulty 1,296 17.6% 1,604 19.5% With a vision difficulty 537 7.3% 784 9.5% With a cognitive difficulty 788 10.7% 803 9.8% With an ambulatory difficulty 2,093 28.4% 1,857 22.6% With a self-care difficulty 658 8.9% 637 7.8% With an independent living difficulty 1,138 15.5% 1,069 13.0% Sex Male 3,334 14.5% 4,002 15.6% Female 3,923 15.5% 4,293 17.2% Race or Ethnicity White alone 6,548 16.0% 7,523 18.7% Black or African American alone 273 7.8% 329 7.6% American Indian and Alaska Native alone 46 12.5% 21 23.3% Asian alone 59 6.2% 69 5.4% Native Hawaiian and Other Pacific Islander alone 3 4.6% 0 0.0% Some other race alone 71 13.7% 34 4.2% Two or more races 257 13.5% 319 8.5% White alone, not Hispanic or Latino 6,396 16.4% 7,384 19.0% Hispanic or Latino (of any race) 236 7.7% 238 7.6% Source: 2013-2017 and 2018-2022 American Community Survey table S1810 St. Joseph County and the Cities of South Bend and Mishawaka recognize the need for accessible and visitable housing units. The County and the Cities ensure that multi-family housing developments which are rehabilitated or constructed using Federal funds, must comply with ADA requirements, and encourage visitable units beyond minimum requirements. Another issue is a lack of affordable housing that is accessible. Public housing often has higher proportions of disabled residents and with most public housing consisting of 1-bedroom units, it is difficult for families and larger households with disabled members to find housing that is both accessible and affordable. The Housing Authority of South Bend and the 2025 Analysis of Impediments to Fair Housing Background Data 144 Housing Authority of Mishawaka both respond to requests for reasonable accommodations and modifications in a timely manner. While single-family housing is generally not accessible, the Fair Housing Act requires that multifamily properties built after 1991 meet Federal accessibility standards; therefore, multifamily housing units built after 1991 are in compliance with Federal Law and meet the minimum level of accessibility. However, as 74.7% of housing units in St. Joseph County were built prior to 1990, many of these units are more likely to have narrow halls, stairs, narrow doors, and little room for ramps to entrance doors. The City of South Bend funds a variety of home repair and rehabilitation programs for both renter- and owner-occupied housing. These programs can be used to make accessibility improvements on the existing housing stock. Government and Housing Authority Facilities: St. Joseph County does not discriminate on the basis of disability for access to nor operations of its programs, services, or activities. If a resident of St. Joseph County requires additional assistance to gain access to County facilities, he or she may contact the City of South Bend’s designated ADA Coordinator, Jessica McLain. The Coordinator can be contacted at:  City of South Bend Legal Department, 227 W. Jefferson Boulevard, Suite 1200S, South Bend, IN 46601  574-235-9241  legaldept@southbendin.gov The ADA Coordinator for the City of South Bend has jurisdiction throughout all of St. Joseph County in partnership with the South Bend Human Rights Commission. The Housing Authority of South Bend and the Mishawaka Housing Authority provide reasonable modifications upon request. When a tenant requests an accommodation, the Housing Authorities may verify the disability only to the extent necessary to ensure the applicants are entitled to the preference. However, the Housing Authority will not ask what the disability is. The process a tenant may go through to request modifications includes the contacting of a Building Manager or Tenant Selection Supervisor and providing any required documentation supporting the request. Once modifications are deemed reasonable, the work will be coordinated with the tenant; if the modifications are tantamount to those required for a fully 2025 Analysis of Impediments to Fair Housing Background Data 145 accessible unit, the tenant/applicant will be placed on an Authority transfer/waiting list for the next available unit with the features requested, if so desired. Public Infrastructure: The City of South Bend and the City of Mishawaka each administer funds through the Federal Community Development Block Grant (CDBG) program to benefit low- and moderate-income areas. The City of South Bend has preferred to fund accessibility improvement projects through its housing activities. The City of Mishawaka has preferred to use funds for ADA curb cuts, sidewalks, and street improvements. South Bend has also used matching grant funds through the State of Indiana to address safe, ADA accessible infrastructure near and around schools. Schools: The Indiana Department of Education partners with IN*SOURCE to provide information and training to assist in the implementation of 504 plans in area schools. School districts are responsible for the provision of special education and related services for every student with a disability under the Individuals with Disabilities Education Act (IDEA) and Section 504 of the Rehabilitation Act of 1973. 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 146 III. Review/Update to Original Plan In FY 2020, the Cities of South Bend and Mishawaka, IN, completed a joint Analysis of Impediments to Fair Housing Choice (AI) to evaluate the housing conditions in St. Joseph County. The analysis was intended to focus on both Cities and the outlying areas of the County to serve as a basis for fair housing planning for the St. Joseph County Housing Consortium. The following paragraphs restate the identified impediments from the 2020 Analysis of Impediments to Fair Housing Choice and summarize the progress made on each for the time period of 2020 through 2024. A. Summary of 2020 Impediments  Impediment 1: Fair Housing Education and Outreach There is a need to educate persons about their rights under the Fair Housing Act and to raise community awareness to affirmatively further fair housing choice, especially for low-income residents, minorities, and the disabled population. Goal: Improve the public’s, realtors’, landlords’, and local officials’ knowledge and awareness of the Fair Housing Act, related laws, regulations, and requirements to affirmatively further fair housing throughout St. Joseph County. Strategies: To meet this goal, the following activities and strategies may be undertaken by the Cities of South Bend and Mishawaka, and St. Joseph County:  1-A: Continue to promote Fair Housing awareness through media, seminars, and training to provide educational opportunities for all persons to learn about their rights under the Fair Housing Act and Americans with Disabilities Act.  1-B: Continue to prepare and distribute literature and informational material concerning fair housing issues, an individual’s housing rights, and a landlord’s responsibilities to comply with the Fair Housing Act by making reasonable accommodations. 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 147  1-C: Educate residents that they have the right to live outside concentrated areas of poverty.  1-D: Work with the local Board of Realtors to educate and promote fair housing.  1-E: Strive for better intergovernmental cooperation between state and local partners, as well as community groups, to effectively identify and address potential barriers to affordable housing choice.  1-F: Publish forms, informational material, etc. in both English and Spanish. Accomplishments: The St. Joseph County Housing Consortium has taken the following actions to reach this goal: - The Consortium and Cities of South Bend and Mishawaka assist in the South Bend Human Rights Commission in its outreach to the community to educate landlords and tenants of Fair Housing Laws and Rights. - All advertisements announcing the availability of Draft or Proposed Plans, Notices of Public Hearings and Notices of Funding Opportunities include the Equal Housing Opportunity Log or slogan. - Include in each contract the Consortium’s Affirmative Marketing Procedures which relates to each project undertaken with Federal Funds.  Impediment 2: Quality of Rental Housing vs. Affordability St. Joseph County has a limited supply of rental housing that is decent, safe, sound and affordable and 41.8% of all households are cost burdened and they spend 30% or more of their net monthly income on housing. Goal: Increase the supply of affordable rental housing through new construction and rehabilitation activities. Strategies: To meet this goal, the following activities and strategies may be undertaken by the Cities of South Bend and Mishawaka, and St. Joseph County: 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 148  2-A: Continue to support and encourage community organizations to rehabilitate rental housing.  2-B: Continue to enforce local codes and ordinances, and develop a Rental Registry Program in the City of Mishawaka and St. Joseph County.  2-C: Promote and encourage the public housing authorities to offer Section 8 Housing Choice Voucher holders the option to convert to homeownership.  2-D: Continue to fund the Community Homebuyers Corporation’s downpayment assistance program for qualifying individuals, including tenants that wish to buy homes.  2-E: Continue to fund rental assistance to lower housing costs for the very low income, mentally disabled, special needs populations, and homeless. Accomplishments: The Cities of South Bend and Mishawaka have taken the following actions to reach this goal: - Between 2022 and 2024, the City of South Bend and St. Joseph Housing Consortium using CDBG and HOME funds allocated funds for the development and/or rehab of 66 rental units. Projects that address the construction or rehabilitation of rental housing is a high priority in selecting projects to fund each year. - South Bend’s implementation of its Rental Safety Verification Program (RSVP) ordinance, which was updated in 2023, defines minimum property standards for rental units in South Bend. - South Bend continues to provide CDBG resources to Community Homebuyers Corporation. - The City of South Bend has a HUD Certified Housing Counselor on staff who participates on the Housing Authority of South Bend’s Family Self-Sufficiency program committee. - South Bend continues to support the development of LIHTC projects in the city by collaborating with developers, providing land (when available), and providing financial support. - South Bend has provided construction gap subsidy funds to support the development of new housing (rental and owner-occupied) in its urban neighborhoods. 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 149 - South Bend supports PSH efforts and provides resources for the administration of Coordinated Entry for those experiencing housing loss.  Impediment 3: Lack of Quality Affordable Homeowner Housing There is a lack of resources for low- and moderate-income households to purchase a home. Many houses that are available for purchase are in need of substantial rehabilitation work. Goal: Increase the supply of various types of affordable housing by new construction and rehabilitation activities. Strategies: To meet this goal, the following activities and strategies may be undertaken by the Cities of South Bend and Mishawaka, and St. Joseph County:  3-A: Support financially, the purchase of small starter homes at affordable prices for low- and moderate-income residents throughout St. Joseph County.  3-B: Support and promote the development of affordable infill housing on vacant land.  3-C: Continue to fund the Community Homebuyers Corporation’s downpayment assistance program for low- and moderate-income homebuyers.  3-D: Support and promote the rehabilitation of owner-occupied homes under the South Bend/UEA Pilot Home Repair Program.  3-E: Provide financial and development incentives to private developers and non-profits to construct and/or rehabilitate affordable housing.  3-F: Encourage and promote the development, construction, and/or rehabilitation of mixed-income housing in areas that are not low- moderate income. Accomplishments: The St. Joseph County Housing Consortium has taken the following actions to reach this goal: 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 150 - The Community Homebuyers Corporation has housed 30 first-time homebuyers since 2020 by offering a forgivable second mortgage and downpayment assistance. - Between 2022 and 2024, CDBG and HOME funds were allocated for development of 17 houses. Projects that address the construction or rehabilitation of housing for sale is a high priority in selecting projects to fund each year. - Between 2022 and 2024, CDBG and HOME funds were allocated for 68 Owner-Occupied Rehabs. - South Bend has provided construction gap subsidy funds to support the development of new mixed-income housing (rental and owner- occupied) in its urban neighborhoods. - The City of South Bend continues to offer the Home Repair Program, completing repairs to homes of low-mod income households. - South Bend supports new construction through the transfer of city owner property to developers at no or low cost.  Impediment 4: Continuing Need for Accessible Housing Units As an older built-up environment, there is a lack of accessible housing units in St. Joseph County. Since 53.2% of the County’s housing units were built over 60 years ago and do not have accessibility features, while 13.7% of the County’s population is classified as disabled. Goal: Increase the number of accessible units for the physically disabled and developmentally delayed through new construction and rehabilitation of existing housing. Strategies: To meet this goal, the following activities and strategies may be undertaken by the Cities of South Bend and Mishawaka, and St. Joseph County:  4-A: Promote programs to increase the amount of accessible housing through rehabilitation of existing housing stock for homeowners and renters.  4-B: Encourage the development of new construction of accessible and visitable housing through financial or development incentives. 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 151  4-C: Continue to enforce ADA and Fair Housing requirements for landlords to make “reasonable accommodations” for tenants who are disabled.  4-D: Continue to promote programs to assist elderly homeowners with accessibility improvements to their properties so they may remain in their own homes. Accomplishments: The St. Joseph County Housing Consortium has taken the following actions to reach this goal:  The St. Joseph County Housing Consortium partners with a variety of housing providers that perform housing rehabilitation. - The City of South Bend supports the development of LIHTC projects which include visit ability requirement for new units.  Impediment 5: Economic Issues Affecting Housing Choice There is a lack of economic opportunities in the County which prevents low- income households from increasing their income and limits the choice to live outside areas of concentrated poverty. Goal: The local economy will provide new job opportunities, which will increase household income, and will promote fair housing choice. Strategies: To meet this goal, the following activities and strategies may be undertaken by the Cities of South Bend and Mishawaka, and St. Joseph County:  5-A: Strengthen partnerships that enhance local businesses, expand the tax base, and create a more sustainable economy for residents and businesses.  5-B: Support and enhance workforce development and skills training that results in increased job opportunities and a living wage.  5-C: Continue to support programming that enhances entrepreneurship and small business development, expansion, and retention within low- and moderate-income, and minority neighborhoods. 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 152  5-D: Continue to promote and encourage economic development with local commercial and industrial firms to expand their operations and increase employment opportunities. Accomplishments: The St. Joseph County Housing Consortium has taken the following actions to reach this goal: - The St. Joseph County Housing Consortium supports the Hurry Home startup, which is designing a program to assist low-income persons in obtaining a mortgage for starter homes. - The St. Joseph County Housing Consortium partners with a variety of housing providers that are utilizing vacant infill lots to develop affordable rental and owner-occupied housing. - The Community Homebuyers Corporation has housed 30 first-time homebuyers since 2020 by offering a forgivable second mortgage and downpayment assistance. - South Bend supports workforce development through the provision of UpSkill South Bend and the Pathways Program. - Talk to Erik re: RLF loans, Opportunity Fund - County / City economic development efforts – Large employers developing in county, near SB’s western border.  Impediment 6: Impacted Areas of Concentration There are specific areas throughout the County where the concentration of low-income persons and minorities exceeds 70% of the area’s population. Goal: Promote the de-concentration of minorities outside the Northwestern and Southeastern sections of the City of South Bend to reduce minority concentration. Strategies: To meet this goal, the following activities and strategies may be undertaken by the Cities of South Bend and Mishawaka, and St. Joseph County:  6-A: Support, promote, and plan for affordable housing developments outside areas of minority concentration.  6-B: Market and promote housing opportunities for minorities outside areas of minority concentration. 2025 Analysis of Impediments to Fair Housing Review/Update to Original Plan 153  6-C: Provide assistance to minority households to locate their residences outside areas of high minority concentration. Accomplishments: The St. Joseph County Housing Consortium has taken the following actions to reach this goal: - The City of South Bend and St. Joseph County Housing Consortium partners with a variety of housing providers that are utilizing vacant infill lots to develop affordable rental and owner-occupied housing, including in areas of opportunity. - The Community Homebuyers Corporation has housed 30 first-time homebuyers since 2020 by offering a forgivable second mortgage and downpayment assistance. Homebuyers are able to purchase a home located anywhere in the city of South Bend. 2025 Analysis of Impediments to Fair Housing Impediments to Fair Housing 2025 154 IV. Impediments to Fair Housing 2025 This AI was prepared jointly by the City of South Bend, IN and the City of Mishawaka, IN, as the St. Joseph County Housing Consortium AI. Housing barriers affecting residents of St. Joseph County were identified through a robust citizen participation process, which included a series of two (2) public meetings, twenty (20) small interview sessions (with City and County Departments, Housing Authority Staff, housing residents, and local housing groups), 3 phone interviews, and 195 completed resident surveys. A. Fair Housing Complaints 1. South Bend Office of Diversity & Inclusion – Human Rights Commission South Bend’s Office of Diversity & Inclusion is an Office within the South Bend Mayor’s Office. It provides access to the tools and resources that foster inclusive workplaces, diverse workforces, communities, and the city’s procurement opportunities. The South Bend Human Rights Commission was formed in 1956. Its mission is: To provide service to the citizens of South Bend through impartial, unbiased decisions regarding discrimination charges filed with the South Bend Human Rights Commission under the ordinance in areas of employment, housing, public accommodation and education, based on race, religion, color, sex, national origin or ancestry, sexual orientation or gender identity, disability and in housing familial status. To stimulate community awareness of equal protection of the law in protected areas through education, collaboration, and coordination with other community agencies. The Human Rights Commission has the duty of enforcing fair housing, equal employment, public accommodations, and education. Its goal is to South Bend Department of Diversity & Inclusion – Human Rights Commission 319 N. Niles Avenue South Bend, Indiana 46617 574-235-9355 humanrights@southbendin.gov 2025 Analysis of Impediments to Fair Housing 155 ensure equal employment opportunity for all individuals, and to provide legal recourse in the areas of discrimination. The Cities of South Bend and Mishawaka fund the South Bend Human Rights Commission with CDBG funds to undertake Fair Housing activites. The Human Rights Commission provides consultation to developers and city staff to ensure that rental and for sale units are marketed in accordance with the affirmative marketing rules of the U.S. Department of Housing and Urban Development. The Human Rights Commission ensures that all housing programs and services provided by St. Joseph County, its municipalities, and the Human Rights Commission itself, are administered in a way that promotes fair housing without regard to race, national origin, religion, gender, disability, and familial status. 2. Indiana Civil Rights Commission The Indiana Civil Rights Commission (ICRC) is tasked to enforce state laws that prohibit discrimination under the Indiana Civil Rights Laws & Regulations. Indiana enacted a public accommodations law in 1885. In 1945, the Indiana General Assembly created a Fair Employment and Labor Act to “remove discrimination with respect to employment because of race, creed, color, national origin, or ancestry.” The Indiana School Desegregation Law was passed in 1949. The Indiana Civil Rights Commission as currently constituted was created with enforcement powers in 1963. In 1965, the Indiana Civil Rights Law was amended to prohibit discrimination in both rental and for sale housing, which preceded the Fair Housing Act by three years. The ICRC has its main office in Indianapolis. It investigates employment and housing discrimination complaints on behalf of the U.S. Equal Employment Opportunity Commission (EEOC) and the U.S. Department of Housing and Urban Development (HUD), respectively. The ICRC offers online reporting forms and hotlines to report bias and hate crimes, as well as an on-line way of Indiana Civil Rights Commission Indiana Government Center North 100 North Senate Avenue Room N300 Indianapolis, Indiana 46204 1-800-457-8283 (Voice) 1-855-463-5292 (Text) Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 156 filing a complaint regarding discrimination; the current law protects citizens in matters of employment, education, public accommodations, housing, and commercial property. The ICRC publishes an annual summary of docketed cases filed during the State’s fiscal year (July 1st – June 30th). ICRC Filed Complaints in the State of Indiana, 2019-2023 Category 2019 2020 2021 2022 2023 Total Employment 612 258 282 582 735 2,469 Housing 121 116 154 128 148 667 Public Accommodations 72 47 58 53 65 295 Education 17 0 13 28 32 89 Credit 0 13 0 0 3 16 Total 822 444 507 791 980 3,544 Source: Indiana Civil Rights Commission Annual Reports, 2019-2023 ICRC Complaints by Protected Class, 2019-2023 Category 2019 2020 2021 2022 2023 Total Disability 209 144 143 257 307 1,060 Race 278 142 159 246 319 1,144 Sex 84 52 54 134 136 460 Age 54 31 23 41 76 225 Retaliation 58 30 34 17 52 191 National Origin / Ancestry 27 22 30 43 58 180 Religion 10 8 36 38 26 118 Familial Status 5 12 26 8 3 54 Color 5 2 2 7 3 19 Veteran / Military Status 0 0 0 0 0 0 Total 822 444 507 791 980 3,544 Source: Indiana Civil Rights Commission Annual Reports, 2019-2023 The ICRC operates a phone number for fair housing complaints (1-800-628- 2909) to act as an alternative for online intake for those immediately experiencing housing discrimination. The toll-free hotline has helped ensure Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 157 faster processing of housing complaints and faster relief to discrimination victims. The ICRC includes general information on the Fair Housing Act, as well as the complaint process, on its website. The State of Indiana's five cultural commissions serve under the umbrella of the Indiana Civil Rights Commission to provide education, resources and initiatives for Indiana's minority, underrepresented and ethnically diverse communities. These commissions include the Indiana Commission on the Social Status of Black Males, the Indiana Commission for Women, the Indiana Commission on Hispanic and Latino Affairs, the Indiana Native American and Indian Affairs Commission and the Dr. Martin Luther King, Jr. Indiana Holiday Commission. 3. Fair Housing & Equal Opportunity (FHEO-HUD) The U.S. Department of Housing and Urban Development’s (HUD’s) Office of Fair Housing & Equal Opportunity (FHEO) receives complaints regarding alleged violations of the Federal Fair Housing Act. From January 1, 2014 to September 3, 2024, 255 fair housing complaints originated within St. Joseph County. Attached is a listing for all the FHEO Complaints received and the status or resolution of the complaint. The fair housing complaints in St. Joseph County that were filed with HUD are disaggregated in the following table to illustrate the most common basis of complaints. In St. Joseph County, disability (48.2%) was the most common basis for a complaint filed between January 1, 2014 and September 3, 2024, with race (44.3%) and sex (19.6%) as the second and third most common causes for complaint, respectively. It is important to note that 114 complaints identified multiple bases in St. Joseph County. The following table compares the frequency of each basis of complaint for the City of South Bend, the City of Mishawaka, and all other areas of St. Joseph County. Complaints based on disability were the most common, comprising 48.3% of complaints in the City of South Bend, 60.6% of complaints in the City of Mishawaka, and 40.9% of complaints in St. Joseph County, respectively. Unsurprisingly, fair housing complaints were most common in the City of South Bend, which is the largest municipality in the County. 201 complaints were filed in South Bend, 33 were filed in Mishawaka, and 21 were filed in other jurisdictions within St. Joseph County. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 158 The following table summarizes all of the complaints filed with the HUD Office of Fair Housing & Equal Opportunity between January 1, 2014 and September 3, 2024 in St. Joseph County. Basis for Housing Complaints Between 01/01/2014 and 09/03/2024 for St. Joseph County, IN Basis St. Joseph County (not South Bend or Mishawaka) City of South Bend City of Mishawaka Count* % of County Complaints Count* % of County Complaints Count* % of County Complaints Race 8 38.1% 96 47.8% 12 36.4% Disability 9 42.9% 97 48.3% 20 60.6% Familial Status 4 19.0% 23 11.4% 4 12.1% National Origin 2 9.5% 10 5.0% 0 0.0% Retaliation 0 0.0% 21 10.4% 5 15.2% Sex 3 14.3% 43 21.3% 6 18.2% Color 2 9.5% 2 1.0% 0 0.0% Religion 0 0.0% 3 1.5% 0 0.0% Source: U.S. Department of HUD-FHEO, Chicago Regional Office *Note: Complaints may include multiple bases, so the counts may not equal the total number of complaints. Based on the previous table, disability was the most common basis for a fair housing complaint, narrowly exceeding race as a basis for complaint. This aligns with the national trend where disability has overtaken race as the most common basis for a complaint. Disability discrimination complaints make up 48.2% of all complaints filed in the entirety of St. Joseph County, with Race (44.3%) as the second-most stated basis. Sex (19.6%), Familial Status (11.8%) and Retaliation (10.2%) were the third-, fourth-, and fifth- most common basis for all complaints in the County. There were 255 complaints filed in St. Joseph County from January 1, 2014 through September 3, 2024. However, there are 361 complaint bases due to come complaints having multiple bases. Of the 255 total complaints, 144 complaints were closed because of “no cause”, eight (8) were closed due to lack of complainant cooperation, and four (4) were withdrawn by the complainant before the complaint was resolved. In other words, almost two- thirds (61.2%) of all complaints either lacked evidence or were closed without action. 62 complaints (24.3%) were resolved with HUD’s help but Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 159 without a formal charge, and only 26 complaints (10.2%) were charged or FHAP caused. The following table illustrates how complaints were closed. Complaint Closure in St. Joseph County, IN Basis No Cause Charged or FHAP Caused Conciliation / Settlement Complainant failed to cooperate Complaint Withdrawn without Resolution Complaint Withdrawn after Resolution Open Race 68 11 20 3 2 4 5 Familial Status 19 5 4 0 0 0 1 Disability 62 12 32 5 3 6 3 National Origin 9 2 0 0 0 0 1 Retaliation 15 3 5 0 0 1 1 Color 1 0 1 1 0 0 1 Sex 31 1 8 3 1 2 3 Religion 1 0 2 0 0 0 0 Total* 144 26 53 8 4 9 10 Source: U.S. Department of HUD-FHEO, Chicago Regional Office *Note: Complaints may include multiple bases, so the counts may not equal the total number of complaints. The following table illustrates the dates complaints were filed in St. Joseph County. The largest yearly number of complaints filed with HUD was in 2019, followed by 2014 and 2016. HUD Date Filed of Complaints – St. Joseph County, IN Count % of County Complaints 2014 28 10.98% 2015 25 9.80% 2016 28 10.98% 2017 15 5.88% 2018 26 10.20% 2019 31 12.16% 2020 24 9.41% 2021 26 10.20% 2022 16 6.27% 2023 24 9.41% 2024 12 4.71% TOTAL 255 100% Source: U.S. Department of HUD-FHEO, Chicago Regional Office Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 160 The following table entitled “HUD-FHEO Complaints” summarizes all of the complaints filed with the HUD Office of Fair Housing & Equal Opportunity between January 1, 2014 and September 3, 2024 in St. Joseph County. If not from South Bend or Mishawaka, the Violation City is noted as “County”. Any complaints without a closure reason remain open. HUD-FHEO Complaints for St. Joseph County, IN Violation City Filing Date Bases Issues Closure Reason South Bend 04/28/14 Familial Status Discriminatory refusal to rent; Discriminatory advertising, statements and notices; Discriminatory terms, conditions, privileges, or services and facilities Charged or FHAP Caused South Bend 01/31/14 Religion Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 02/10/14 Religion, Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) Conciliation/ Settlement South Bend 02/10/14 Race Discrimination in terms/conditions/privileges relating to rental No Cause Mishawaka 03/26/14 Disability Failure to make reasonable accommodation No Cause South Bend 04/03/14 Disability Discriminatory refusal to rent and negotiate for rental; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 04/16/14 Race, Familial Status Discriminatory refusal to negotiate for rental; Discrimination in terms/conditions/privileges relating to rental No Cause County 04/15/14 Race Discriminatory refusal to sell and negotiate for sale No Cause Mishawaka 04/28/14 Disability Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable; Failure to make reasonable accommodation Withdrawn after Resolution South Bend 05/01/14 Disability Discriminatory terms, conditions, privileges, or services and facilities Charged or FHAP Caused South Bend 05/13/14 Religion Discriminatory refusal to rent and negotiate for rental; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 07/09/14 Race, Sex Discriminatory refusal to rent and negotiate for rental Complainant failed to cooperate South Bend 06/11/14 Race, Retaliation Discrimination in terms/conditions/privileges relating to sale; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 06/10/14 Disability Failure to make reasonable accommodation Conciliation/ Settlement South Bend 06/10/14 Sex, Retaliation Discrimination in terms/conditions/privileges relating to rental No Cause Mishawaka 09/11/14 Sex Discriminatory refusal to rent; Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 161 Mishawaka 07/14/14 Race, Disability Otherwise deny or make housing unavailable No Cause South Bend 07/18/14 National Origin, Disability, Familial Status Discriminatory refusal to rent and negotiate for rental; False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental; Steering No Cause South Bend 08/04/14 Sex, Familial Status Discrimination in terms/conditions/privileges relating to rental No Cause Mishawaka 08/04/14 Race Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 08/25/14 Disability Discriminatory refusal to negotiate for rental; Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.); Failure to make reasonable accommodation Conciliation/ Settlement County 11/13/14 Disability, Familial Status Discriminatory terms, conditions, privileges, or services and facilities No Cause South Bend 10/14/14 Sex Discrimination in the terms/conditions for making loans No Cause South Bend 10/14/14 Sex Discrimination in the terms/conditions for making loans No Cause South Bend 10/23/14 Race Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 10/31/14 Race Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable Conciliation/ Settlement South Bend 11/18/14 Race Discriminatory refusal to negotiate for rental; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 11/18/14 Race, Sex Discrimination in terms/conditions/privileges relating to sale Complainant failed to cooperate 2014 TOTAL 28 South Bend 01/06/15 Race Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 03/11/15 Disability Discriminatory refusal to rent; Discriminatory advertising, statements and notices; Discriminatory terms, conditions, privileges, or services and facilities; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 01/15/15 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 02/09/15 National Origin, Familial Status, Retaliation Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable Charged or FHAP Caused South Bend 04/22/15 Race Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 04/22/15 Race Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 05/26/15 National Origin, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 05/29/15 Race, Familial Status Discriminatory terms, conditions, privileges, or services and facilities; Discriminatory acts under Section 818 (coercion, Etc.) No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 162 South Bend 06/01/15 Familial Status Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 05/29/15 Disability Steering Conciliation/ Settlement South Bend 06/22/15 Disability Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 06/12/15 Sex Discrimination in terms and conditions of membership; Discriminatory terms, conditions, privileges, or services and facilities No Cause County 07/13/15 Disability Failure to make reasonable accommodation Charged or FHAP Caused South Bend 07/07/15 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 07/31/15 Race, Sex Discriminatory financing (includes real estate transactions); Discrimination in the terms/conditions for making loans Conciliation/ Settlement South Bend 08/03/15 Race Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 08/13/15 Race Discriminatory acts under Section 818 (coercion, Etc.); Discriminatory acts under Section 901 (criminal) Charged or FHAP Caused South Bend 08/13/15 Race Discriminatory acts under Section 818 (coercion, Etc.); Discriminatory acts under Section 901 (criminal) Charged or FHAP Caused South Bend 08/19/15 Race Discriminatory acts under Section 818 (coercion, Etc.) Charged or FHAP Caused Mishawaka 10/19/15 Disability Failure to make reasonable accommodation Charged or FHAP Caused South Bend 09/15/15 Race Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 10/12/15 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause County 10/23/15 Disability Failure to make reasonable accommodation No Cause South Bend 10/29/15 Disability, Retaliation Discriminatory terms, conditions, privileges, or services and facilities No Cause South Bend 12/22/15 Familial Status Discriminatory refusal to rent and negotiate for rental; False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental No Cause 2015 TOTAL 25 South Bend 05/09/16 Race Discrimination in the terms/conditions for making loans No Cause South Bend 01/07/16 Disability Failure to make reasonable accommodation Conciliation/ Settlement South Bend 01/07/16 Disability Failure to make reasonable accommodation Conciliation/ Settlement South Bend 01/11/16 National Origin, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 02/01/16 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 02/18/16 Race, Disability, Retaliation Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 163 South Bend 07/21/16 Disability Discriminatory advertising, statements and notices; Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable; Discriminatory acts under Section 818 (coercion, Etc.) No Cause Mishawaka 03/15/16 Disability Failure to make reasonable accommodation Conciliation/ Settlement South Bend 03/24/16 Race Discriminatory refusal to sell; Discrimination in terms/conditions/privileges relating to sale; Steering; Otherwise deny or make housing unavailable No Cause South Bend 03/31/16 Race Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 04/20/16 Race Discriminatory refusal to negotiate for rental; False denial or representation of availability; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 04/27/16 National Origin Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 05/16/16 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 05/17/16 Disability Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) Conciliation/ Settlement South Bend 05/25/16 Race Otherwise deny or make housing unavailable No Cause South Bend 05/26/16 Retaliation Otherwise deny or make housing unavailable; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 06/16/16 Race Discrimination in the selling of residential real property; Steering No Cause Mishawaka 06/21/16 Sex Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 07/21/16 Race Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 07/21/16 Race, Disability Discriminatory refusal to negotiate for rental; False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 07/22/16 Race, Familial Status Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 08/09/16 Disability Failure to comply with advertising guidelines; Discrimination in terms/conditions/privileges relating to rental; Restriction of choices relative to a rental Charged or FHAP Caused County 12/02/16 Disability Discriminatory refusal to rent; Discriminatory terms, conditions, privileges, or services and facilities Complainant failed to cooperate South Bend 09/06/16 Race, Familial Status False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental; Steering Charged or FHAP Caused South Bend 09/21/16 Race, Disability Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 09/16/16 Race Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 09/19/16 Familial Status Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 10/13/16 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement 2016 TOTAL 28 South Bend 02/21/17 Race, Familial Status False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental; Steering Charged or FHAP Caused Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 164 South Bend 04/05/17 Race Discrimination in terms/conditions/privileges relating to rental; Other discriminatory acts Conciliation/ Settlement South Bend 04/24/17 Race Discrimination in terms/conditions/privileges relating to rental Charged or FHAP Caused South Bend 04/26/17 Sex Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 04/27/17 Race, Disability Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement Mishawaka 05/03/17 Race, Sex Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 09/28/17 Disability Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable; Failure to make reasonable accommodation No Cause South Bend 07/24/17 Race Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 08/18/17 Race Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 09/18/17 Race, Familial Status Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 09/22/17 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to provide reinforced walls for grab bars; Failure to provide usable kitchens and bathrooms No Cause Mishawaka 11/22/17 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Charged or FHAP Caused County 11/27/17 Sex, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 11/29/17 Disability Discriminatory acts under Section 818 (coercion, Etc.); Discriminatory acts under Section 901 (criminal) No Cause South Bend 12/05/17 Sex, Retaliation Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) No Cause 2017 TOTAL 15 Mishawaka 01/04/18 Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable; Failure to make reasonable accommodation No Cause South Bend 01/25/18 National Origin Discriminatory refusal to sell and negotiate for sale; Discrimination in terms/conditions/privileges relating to sale No Cause Mishawaka 01/25/18 Race, Familial Status Otherwise deny or make housing unavailable No Cause County 03/30/18 Familial Status Discriminatory refusal to rent; Discriminatory advertising, statements and notices; Discriminatory terms, conditions, privileges, or services and facilities Conciliation/ Settlement South Bend 02/09/18 Disability Failure to make reasonable accommodation Charged or FHAP Caused County 04/04/18 Familial Status Discriminatory refusal to rent and negotiate for rental; Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 04/27/18 Disability Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 04/30/18 Race, Sex Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 06/19/18 Disability Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 07/16/18 Disability Discriminatory terms, conditions, privileges, or services and facilities; Failure to make reasonable accommodation Withdrawn after Resolution Mishawaka 06/05/18 Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.); Failure to make reasonable accommodation No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 165 South Bend 07/11/18 Race Discriminatory terms, conditions, privileges, or services and facilities No Cause South Bend 06/12/18 Race Discriminatory advertising, statements and notices; Discriminatory advertisement - rental Charged or FHAP Caused South Bend 06/22/18 Race Discriminatory advertising, statements and notices Charged or FHAP Caused Mishawaka 07/09/18 Retaliation Otherwise deny or make housing unavailable; Other discriminatory acts Conciliation/ Settlement Mishawaka 07/23/18 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 08/01/18 Race, Disability Discrimination in the terms/conditions for making loans No Cause South Bend 08/01/18 Race, Disability Discriminatory refusal to rent Complainant failed to cooperate South Bend 08/24/18 Race Discrimination in terms/conditions/privileges relating to rental No Cause Mishawaka 09/13/18 Race, Disability Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 09/13/18 Race, Sex Discrimination in terms/conditions/privileges relating to sale; Discrimination in services and facilities relating to sale Conciliation/ Settlement South Bend 09/14/18 Disability Discrimination in terms/conditions/privileges relating to rental Complaint withdrawn by complainant without resolution South Bend 11/14/18 Race, Disability Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Complaint withdrawn by complainant without resolution South Bend 12/20/18 Race, Sex Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in services and facilities relating to rental Complaint withdrawn by complainant without resolution South Bend 11/06/18 Retaliation Discriminatory terms, conditions, privileges, or services and facilities; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 11/08/18 National Origin, Sex Discriminatory terms, conditions, privileges, or services and facilities No Cause 2018 TOTAL 26 Mishawaka 03/06/19 Disability Discriminatory terms, conditions, privileges, or services and facilities Conciliation/ Settlement South Bend 02/06/19 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable Conciliation/ Settlement Mishawaka 02/12/19 Disability Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 02/22/19 Disability Discrimination in terms/conditions/privileges relating to rental; Non-compliance with design and construction requirements (handicap); Failure to provide an accessible building entrance; Failure to permit reasonable modification; Failure to make reasonable accommodation No Cause County 04/22/19 Race Discriminatory refusal to rent; Discriminatory terms, conditions, privileges, or services and facilities No Cause County 03/27/19 Race, Sex, Familial Status Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 04/01/19 National Origin Blockbusting; Other discriminatory acts No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 166 South Bend 04/10/19 Race, Sex, Familial Status Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 04/18/19 Disability Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 05/13/19 Sex Discriminatory terms, conditions, privileges, or services and facilities No Cause Mishawaka 05/14/19 Disability Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 06/17/19 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable; Failure to make reasonable accommodation No Cause South Bend 06/20/19 Race, Familial Status False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental; Steering No Cause South Bend 06/24/19 Disability Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 06/25/19 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 06/26/19 Disability Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.); Failure to make reasonable accommodation Conciliation/ Settlement South Bend 07/09/19 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 07/17/19 Disability Discriminatory refusal to rent No Cause South Bend 07/18/19 Race, Familial Status Discriminatory refusal to negotiate for rental Conciliation/ Settlement Mishawaka 09/17/19 Sex, Retaliation Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 08/07/19 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Charged or FHAP Caused South Bend 08/09/19 Race Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 09/05/19 Disability Discriminatory refusal to rent and negotiate for rental; Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Withdrawn after Resolution South Bend 09/09/19 Race, Sex, Disability Discriminatory terms, conditions, privileges, or services and facilities No Cause South Bend 09/17/19 Race, Disability Discriminatory terms, conditions, privileges, or services and facilities No Cause Mishawaka 09/23/19 Race, Disability Discriminatory terms, conditions, privileges, or services and facilities; Failure to make reasonable accommodation No Cause County 10/30/19 Race Discriminatory acts under Section 818 (coercion, Etc.) No Cause County 10/30/19 Race Discriminatory acts under Section 818 (coercion, Etc.) No Cause Mishawaka 10/31/19 Familial Status Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 12/12/19 Disability Failure to make reasonable accommodation Withdrawn after Resolution South Bend 12/17/19 Race Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental No Cause 2019 TOTAL 31 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 167 South Bend 01/08/20 Race Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental No Cause South Bend 01/13/20 Disability Discriminatory refusal to rent and negotiate for rental; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 04/15/20 Disability Discriminatory acts under Section 818 (coercion, Etc.); Failure to permit reasonable modification; Failure to make reasonable accommodation No Cause Mishawaka 04/06/20 Disability Discriminatory refusal to rent; Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental Complainant failed to cooperate Mishawaka 02/10/20 Race, Familial Status Discriminatory terms, conditions, privileges, or services and facilities No Cause South Bend 04/29/20 Disability Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 04/28/20 Race, Sex Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 05/07/20 Sex Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement County 06/01/20 Color Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.) Complainant failed to cooperate South Bend 10/06/20 Race, Disability Discriminatory terms, conditions, privileges, or services and facilities; Discriminatory acts under Section 818 (coercion, Etc.); Failure to make reasonable accommodation Withdrawn after Resolution South Bend 07/01/20 Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 07/07/20 Retaliation Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 08/18/20 Race, Sex Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 08/21/20 Disability Failure to make reasonable accommodation No Cause South Bend 08/21/20 Sex Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 09/02/20 Sex Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 09/03/20 Sex, Disability Failure to provide reinforced walls for grab bars; Failure to permit reasonable modification; Failure to make reasonable accommodation Complainant failed to cooperate South Bend 09/24/20 Sex Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable; Other discriminatory acts No Cause County 11/24/20 Race Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable No Cause Mishawaka 11/18/20 Race, Sex Discriminatory refusal to rent; Discriminatory terms, conditions, privileges, or services and facilities Conciliation/ Settlement South Bend 11/23/20 Race Discriminatory refusal to rent; Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 11/25/20 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 11/30/20 Disability, Retaliation Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental; Discriminatory acts under Section 818 (coercion, Etc.); Failure to make reasonable accommodation Conciliation/ Settlement South Bend 12/29/20 Disability Discrimination in terms/conditions/privileges relating to rental No Cause 2020 TOTAL 24 Mishawaka 03/13/21 Race Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable Charged or FHAP Caused Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 168 South Bend 03/01/21 Race Discriminatory refusal to rent; Discriminatory refusal to rent and negotiate for rental Withdrawn after Resolution South Bend 03/01/21 Race, Sex Discriminatory refusal to rent; Discriminatory refusal to rent and negotiate for rental Conciliation/ Settlement South Bend 03/03/21 Disability Discrimination in terms/conditions/privileges relating to sale; Discrimination in services and facilities relating to sale No Cause South Bend 03/02/21 Disability Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 05/21/21 Race Discriminatory refusal to rent and negotiate for rental; Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable No Cause South Bend 07/29/21 Sex, Familial Status Discriminatory financing (includes real estate transactions); Discrimination in the selling of residential real property; Discrimination in the brokering of residential real property No Cause South Bend 04/27/21 Race Discrimination in terms/conditions/privileges relating to rental; Other discriminatory acts Conciliation/ Settlement South Bend 07/26/21 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Withdrawn after Resolution Mishawaka 07/08/21 Familial Status Discriminatory refusal to rent; Otherwise deny or make housing unavailable Charged or FHAP Caused South Bend 07/28/21 Race Discriminatory refusal to rent; Discriminatory refusal to negotiate for rental; Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable Conciliation/ Settlement Mishawaka 07/29/21 Sex, Disability Failure to make reasonable accommodation No Cause South Bend 08/11/21 Sex Discrimination in terms/conditions/privileges relating to rental; Other discriminatory acts; Refusing to provide municipal services or property; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 09/08/21 Disability Otherwise deny or make housing unavailable; Failure to make reasonable accommodation No Cause South Bend 08/13/21 Race, Disability Discrimination in the making of loans; Discrimination in the terms/conditions for making loans; Steering; Failure to make reasonable accommodation Charged or FHAP Caused County 09/03/21 Race, Disability Discriminatory refusal to rent and negotiate for rental; Failure to provide usable kitchens and bathrooms No Cause South Bend 09/09/21 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 09/22/21 Sex, Familial Status Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement County 12/10/21 Race Discrimination in the appraising of residential real property South Bend 11/09/21 Sex Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable; Other discriminatory acts No Cause South Bend 11/10/21 Race, Sex Discrimination in terms/conditions/privileges relating to rental Withdrawn after Resolution South Bend 12/21/21 Disability Failure to make reasonable accommodation Complainant failed to cooperate South Bend 12/23/21 Race, Disability Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 12/23/21 Race, Disability Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 169 South Bend 12/27/21 Race, Sex, Retaliation Discrimination in services and facilities relating to rental Withdrawn after Resolution South Bend 12/29/21 Race Discrimination in terms/conditions/privileges relating to rental No Cause 2021 TOTAL 26 South Bend 03/08/22 Disability Discrimination in services and facilities relating to rental; Failure to make reasonable accommodation No Cause South Bend 01/03/22 Race Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental No Cause South Bend 01/14/22 Race, Retaliation Discrimination in terms/conditions/privileges relating to rental; Other discriminatory acts No Cause Mishawaka 02/11/22 Retaliation Discriminatory refusal to rent; Discriminatory acts under Section 818 (coercion, Etc.) Charged or FHAP Caused South Bend 03/30/22 Race, National Origin Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable; Discriminatory acts under Section 818 (coercion, Etc.) No Cause South Bend 04/27/22 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause County 07/28/22 National Origin Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 07/01/22 Race, Sex Discriminatory refusal to negotiate for rental; Discrimination in terms/conditions/privileges relating to rental No Cause County 07/29/22 Disability Discriminatory refusal to rent No Cause South Bend 07/07/22 Disability Failure to make reasonable accommodation No Cause South Bend 07/15/22 Race, Disability Discrimination in terms/conditions/privileges relating to rental No Cause South Bend 07/20/22 Disability Failure to provide an accessible building entrance; Failure to make reasonable accommodation No Cause South Bend 07/26/22 Race Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 07/27/22 Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental; Other discriminatory acts; Discriminatory acts under Section 818 (coercion, Etc.); Discriminatory acts under Section 901 (criminal) No Cause South Bend 11/21/22 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Charged or FHAP Caused South Bend 10/21/22 Sex Discriminatory terms, conditions, privileges, or services and facilities; Otherwise deny or make housing unavailable No Cause 2022 TOTAL 16 South Bend 04/20/23 Sex, Disability, Retaliation Discrimination in terms and conditions of membership; Discriminatory terms, conditions, privileges, or services and facilities; Failure to make reasonable accommodation Mishawaka 01/13/23 Disability Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement County 01/27/23 Disability Discriminatory terms, conditions, privileges, or services and facilities; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 02/01/23 Sex, Familial Status, Retaliation Discrimination in terms/conditions/privileges relating to rental Dismissed for lack of jurisdiction Mishawaka 02/06/23 Race, Disability Discriminatory refusal to rent; Discriminatory refusal to negotiate for rental; Discriminatory refusal to rent and negotiate for rental No Cause South Bend 02/09/23 Sex, Familial Status Discriminatory refusal to rent and negotiate for rental; Steering No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 170 County 03/27/23 Disability Discriminatory refusal to rent; False denial or representation of availability - rental; Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation South Bend 04/21/23 Sex Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 05/05/23 National Origin, Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Charged or FHAP Caused South Bend 06/05/23 Sex, Disability, Retaliation Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in services and facilities relating to rental; Otherwise deny or make housing unavailable; Failure to make reasonable accommodation Charged or FHAP Caused South Bend 09/12/23 Race Discriminatory terms, conditions, privileges, or services and facilities; Other discriminatory acts No Cause South Bend 07/14/23 Disability Failure to make reasonable accommodation No Cause South Bend 07/14/23 Race, Sex, Disability Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable Conciliation/ Settlement South Bend 07/26/23 Race, Color, Disability Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental No Cause South Bend 07/26/23 Familial Status Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental No Cause South Bend 08/21/23 Disability Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 08/23/23 Race Discriminatory advertising, statements and notices No Cause South Bend 09/08/23 Disability Discriminatory terms, conditions, privileges, or services and facilities; Failure to make reasonable accommodation South Bend 09/15/23 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 09/15/23 Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental Conciliation/ Settlement South Bend 09/15/23 Sex Discrimination in terms/conditions/privileges relating to rental South Bend 11/17/23 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Charged or FHAP Caused South Bend 11/17/23 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement South Bend 12/19/23 Disability, Retaliation Discrimination in terms/conditions/privileges relating to rental; Discrimination in services and facilities relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement 2023 TOTAL 24 South Bend 07/30/24 Race Discriminatory terms, conditions, privileges, or services and facilities South Bend 08/28/24 Familial Status Discrimination in terms/conditions/privileges relating to rental; Otherwise deny or make housing unavailable South Bend 09/17/24 Race Discriminatory terms, conditions, privileges, or services and facilities; Discrimination in terms/conditions/privileges relating to rental South Bend 02/19/24 Race, Disability Discriminatory advertising, statements and notices; Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation No Cause South Bend 04/16/24 Sex, Disability, Retaliation Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental No Cause Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 171 County 05/06/24 Race, Color, National Origin, Sex Discriminatory refusal to rent; Discrimination in terms/conditions/privileges relating to rental Mishawaka 05/03/24 Race Discrimination in terms/conditions/privileges relating to rental Charged or FHAP Caused County 07/11/24 Disability Failure to make reasonable accommodation Complaint withdrawn by complainant without resolution South Bend 07/11/24 Race, Color Discriminatory terms, conditions, privileges, or services and facilities Conciliation/ Settlement South Bend 07/12/24 Disability Discrimination in terms/conditions/privileges relating to rental; Failure to make reasonable accommodation Conciliation/ Settlement Mishawaka 08/13/24 Disability Failure to make reasonable accommodation No Cause South Bend 09/11/24 Race Discrimination in the selling of residential real property; Discrimination in the brokering of residential real property; Discriminatory brokerage service 2024 YEAR TO DATE 12 TOTAL 255 Source: U.S. Department of HUD-FHEO, Chicago Regional Office Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 172 National Trends The U.S. Department of Housing and Urban Development (HUD) funds the Office of Fair Housing and Equal Opportunity (FHEO), whose mission is to eliminate discrimination, promote economic opportunity, and achieve diversity. FHEO leads the nation in the enforcement, administration, development, and public understanding of Federal fair housing policies and laws. FHEO enforces laws that protect people from discrimination on the basis of race, color, religion, sex, national origin, disability, and familial status. FHEO releases annual reports to Congress, which provide information regarding complaints received during the particular year. The following table highlights the frequency of such housing complaints for the years of 2019 through 2023 organized by basis of complaint, using HUD- supplied data compiled by the National Fair Housing Association (NFHA). HUD, FHAP, NFHA Member and DOJ Housing Complaints Nationwide Basis FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 # % # % # % # % # % Race 4,757 16.5% 4,821 16.8% 5,922 19.0% 5,819 17.6% 5,820 17.0% Disability 17,010 58.9% 15,664 54.6% 16,758 53.7% 17,580 53.3% 17,968 52.6% Familial Status 2,228 7.7% 2,276 7.9% 2,261 7.2% 2,147 6.5% 2,139 6.3% Sex 1,948 6.7% 2,094 7.3% 2,309 7.4% 2,490 7.5% 2,588 7.6% National Origin 1,730 6.0% 1,636 5.7% 1,774 5.7% 1,635 5.0% 1,693 5.0% Color 646 2.2% 811 2.8% 734 2.4% 609 1.8% 824 2.4% Religion 328 1.1% 333 1.2% 382 1.2% 353 1.1% 337 1.0% Other 3,117 10.7% 3,744 13.0% 4,276 13.7% 5,622 17.0% 5,794 17.0% Total Filed Complaints 28,880 28,712 31,216 33,007 34,150 Source: NFHA 2020-2024 Fair Housing Trends Reports Note: Complaints often allege more than one (1) basis of discrimination, and each base is counted as a complaint. The majority of the HUD complaints filed nationwide in 2023 were on the basis of disability, making up 52.6% of all complaints received. Race was next, making up 17.0% of all complaints, followed by sex at 7.6% and familial status at 6.3%. The “other” category makes up 17.0% of all complaints and includes the following factors which are only protected Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 173 classes under state and local law: Source of Income; Age/Student Status; Sexual Orientation; Gender Identity/Expression; Marital Status; Criminal Background; Victims of Domestic Violence; Arbitrary (California only); Military Status; Retaliation; Immigration Status/Citizenship; and Zoning. As of February 11, 2021, FHEO issued a memorandum stating that, in light of the Supreme Court’s decision in Bostock v Clayton County, 590 U.S., 140 S. Ct. 1731 (2020), HUD interprets the Fair Housing Act to bar discrimination on the basis of sexual orientation and gender identity and directs Fair Housing Assistance Programs and Fair Housing Initiative Programs to enforce the Act accordingly. In addition, Retaliation is not one of the protected classes of the Fair Housing Act but is a basis for complaint. As illustrated in the next charts, disability is by far the most common basis of complaint. Five Year National Trends in Number of Complaints by Basis Source: NFHA 2020-2024 Fair Housing Trends Reports Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 174 Five Year National Trends in Percent of Complaints by Basis Source: NFHA 2020-2024 Fair Housing Trends Reports The HUD housing complaints filed in St. Joseph County were primarily based on disability and race, which are consistently the two most common causes for complaints across the nation as illustrated in the previous chart. Note: the percentages for each year do not equal 100% and the number of complaints each year do not equal the total complaints across all areas. This is because there is often more than one basis for the filing of a fair housing complaint. 4. Notre Dame Eviction Clinic The Notre Dame Law School offers seven clinical programs for students seeking their juris doctor degrees to provide civil legal aid to nonprofit organizations, low-income residents of the South Bend Region, and global causes. In particular, the Notre Dame Eviction Clinic represents clients facing eviction or eviction-related proceedings in St. Joseph County, Indiana courts. Law students working under the direction of David Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 175 Pruitt, the director of the Clinical Law Center, assist renters in both public and private rental housing with eviction defense, monetary damages claims, and proceedings to terminate voucher assistance. The Eviction Clinic also partners with organizations seeking to improve Indiana law and policy affecting Indiana renters, particularly with respect to the eviction process. In 2023, at the request of the Indiana Justice Project, the Clinic published a report entitled “Eviction Protections for Renters: Does Indiana Make the Grade?”. The Clinic continues to provide follow-on legal research and analysis for IJP and other partners. The Notre Dame Eviction Clinic is the successor to the Notre Dame Economic Justice Clinic, which provided free legal representation in non- criminal matters such as eviction from housing, discrimination, family law, and consumer protection issues. Other Notre Dame Law School clinics that focus on providing civil legal services to low-income St. Joseph County residents include the Exoneration Justice Clinic, the Applied Mediation Clinic, and the Special Education Clinic. In addition, the Community Development Clinic provides free non-litigation legal services to nonprofits and small businesses. 5. Housing and Human Services Agencies The City of South Bend and the City of Mishawaka interviewed agencies offering housing and human services within St. Joseph County to obtain their input and gain insight into potential impediments to fair housing. The following agencies participated in the information gathering through roundtable discussions, individual meetings, phone interviews, or through surveys: ARC of Indiana Brightpoint St. Joseph County Area Planning Commission 1st Source Bank Northwest Bank Communitywide Credit Union Notre Dame Law School Eviction Clinic David Pruitt, JD, Director 1111 Eck Hall of Law Notre Dame, IN 46556 574-631-6704 574-631-6725 (FAX) ndlaw@nd.edu Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 176 Northern Indiana Minority Business Association St. Joseph County Continuum of Care United Way of St. Joseph County St. Joseph County Department of Health Housing Authority of the City of South Bend Housing Authority of the City of Mishawaka Habitat for Humanity of St. Joseph County City of South Bend Fire Department City of South Bend Police Department City of Mishawaka Code Enforcement Intend Indiana Indiana Health Centers South Bend Heritage Foundation Hurry Home Health Plus Indiana Veterans’ Administration Northern Indiana Healthcare System Youth Service Bureau St. Margaret’s House Salvation Army Kroc Center Center for the Homeless Cultivate El Campito Food Bank for Northern Indiana Portage County Trustee The Clubhouse Our Lady of the Road Monroe Park Neighborhood Association Near Northwest Neighborhood, Inc Goodwill Bridges Out of Poverty Dismas House Transpo Mishawaka Homeless Coalition YWCA North Central Indiana Each of these agencies provided feedback on their experience with housing-related issues in St. Joseph County. Complete summaries of Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 177 meeting comments can be found in Appendix A. Below is a list of key points from each of the meetings. Housing Issues There appears to be a lack of affordable housing that is decent in St. Joseph County. There appears to be a lack of accessible housing in St. Joseph County. Due to seasonal tourism, a large number of rental options remain vacant during the “off season.” There are multiple landlords and companies who are not local to the area and are difficult to reach by tenants. There are “starter homes” available in stable neighborhoods that require moderate amounts of funds for rehabilitation, but the funding is not available for the purchase or rehabilitation of these homes. There is a need for housing options for all levels of income. The local housing stock is older, and the cost of rehabilitation is higher than the value of the housing, even after the rehabilitation work is completed. There are high costs for sewer and water tap-in fees for infill and new housing options. The Comprehensive Housing Affordability Strategy (CHAS) data through HUD shows that 42.2% of all renters are cost overburdened in the County. Certain classes of people, such as ex-offenders, are unable to find housing and will rent from predatory landlords. There is a need to create accessible units to allow elderly and disabled persons to age in place. Social Services There are numerous social service programs provided in the County. More social service programs are needed to assist the mentally ill, including people with addictions in the County. There is a need to provide additional sources of funding to social services to meet the changes in federal funding the Cities receive as part of their entitlement programs. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 178 Due to an increase in homeless populations, more permanent supportive housing is required for all homeless populations and subpopulations. There is a gap in housing for people with disabilities who cannot make the move to independent housing. Fair housing complaints are occurring with the disabled population which need to be addressed. There is a need for more accommodations for victims of domestic violence. There is a need for affordable childcare services for working families. Additional services are needed for youth who are coming out of foster care placement. Additional support services are needed for persons coming out of institutions including: hospitalization, correctional facilities, and mental healthcare. Public Policies Local zoning ordinances are consistently being revised and assistance is available to bring them into compliance with ADA and the Fair Housing Act. There is a continuing need for education and training on tenant’s rights and landlord’s responsibilities under the Fair Housing Act. Municipalities in St. Joseph County are still allowed to annex land, although the City of South Bend has not done so in 30 years. Source of income is not a protected class in the State of Indiana. Affordable housing needs to be located throughout the County and not just within the urban core. There is a need to provide incentives to developers and businesses to create and develop affordable housing. Transportation Transpo serves the Cities of South Bend and Mishawaka. There is a need for Sunday bus service, but funding is lacking. Many bus stops and shelters in the City of Mishawaka do not meet current accessibility standards. There is a need to hire and increase the amount of bus drivers. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 179 Economic Development Economic opportunities are needed in the County. There are plans for an Amazon data center and EV-battery plants to be constructed in St. Joseph County. Graduates of University of Notre Dame are likely to leave the area for higher paying professional work. There is a need to attract talent to remain in the area. There is a need to foster greater public transportation connection between St. Joseph County and surrounding metro areas. There is a need to increase and support retail stores in the downtown area of South Bend. Many of the low-income areas of the City of South Bend and St. Joseph County are also food deserts and there is a need for fresh food in the area. There has been an increase in small businesses requesting loans for working capital, as high interest rates have deterred firms from borrowing and the demand for fixed assets has decreased. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 180 B. Public Sector Part of the Analysis of Impediments is to examine the public policies of the jurisdiction and the impact on fair housing choice. Local governments control land use and development through their comprehensive plans, zoning ordinances, subdivision regulations, and other laws and ordinances passed by the local governing body. These regulations and ordinances govern the types of housing that may be constructed, the density of housing, and various residential uses in a community. Local officials determine the community’s commitment to housing goals and objectives. The local policies therefore determine if fair housing is to be promoted or passively tolerated. This section of the Analysis of Impediments evaluates the Cities’ and County’s policies to determine if there is a commitment to affirmatively further fair housing. 1. CDBG Program The City of South Bend The City of South Bend annually receives from HUD approximately $2,320,384 in CDBG funds. The City allocates its funds to housing construction, housing rehabilitation, operations for homeless shelters, public facilities, administration, and public services. In particular, the City proposed to allocate FY 2025 CDBG funds as outlined in the following table to affirmatively further fair housing. FY 2025 CDBG Allocation for the City of South Bend, IN Community Development Block Grant Program (CDBG) CDBG Administration $ 259,972 Housing Construction $ 880,000 Housing Rehabilitation $ 560,000 Operations for Homeless Shelters $ 360,000 Public Facilities $ 0.00 Public Services $ 273,412 Total: $ 2,333,384 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 181 The City of Mishawaka The City of Mishawaka annually receives from HUD approximately $473,296 in CDBG funds. The City allocates its funds to public facility improvements, housing rehabilitation, slums and blight removal, administration, and public services. In particular, the City proposed to allocate FY 2025 CDBG funds as outlined in the following table to affirmatively further fair housing. The City of Mishawaka anticipates a reduction in the annual CDBG allocation in the coming years as a result of further cuts in the Federal budget. FY 2025 CDBG Allocation for the City of Mishawaka, IN Community Development Block Grant Program (CDBG) CDBG Administration $ 94,659.20 Public Facilities Improvements $ 307,642.40 Housing Rehabilitation $ 0.00 Public Services $ 70,994.40 Total: $ 473,296.00 Five Year Jurisdictional Goals In its FY 2025-2029 Five Year Consolidated Plan, the Cities of South Bend and Mishawaka in partnership with the St. Joseph Housing Consortium have identified several goals to address housing needs and to develop annual funding priorities during this five-year period, as outlined in the following table: St. Joseph Housing Consortium - Five Year Objectives Housing Priority – HS St. Joseph County, including the Cities of South Bend and Mishawaka, has been experiencing a growth in population. This has created demand for housing and has strained the existing housing stock. This has resulted in an increase in the sale price of homes and rental costs in the County. Low- and moderate-income households have been severely impacted and are unable to find decent, safe, sanitary, and affordable housing because they can no longer pay the increase in housing costs. This has been identified as the top priority for St. Joseph Housing Consortium. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 182 Objective HS-1 Housing Development – Increase the number of decent safe, sanitary, accessible, and affordable housing units in the County, both for owner-occupied and rental-occupied housing through the use of federal funds, including the Section 108 Loan Guarantee Program. HS-2 Homeownership – Increase the opportunities for homeownership for low- and moderate-income households through downpayment/closing cost assistance, and housing counseling services. HS-3 Housing Rehabilitation – Promote and assist in the preservation of existing owner-occupied and renter-occupied housing in the County. HS-4 Lead-Based Paint – Promote and educate property owners on the dangers of lead-based paint and safe work practices to abate lead-based paint in their residences. HS-5 Housing Assistance - Promote and provide housing stability through rental assistance, deposits, and utility payments for low- and moderate-income households who are at risk of homelessness. HS-6 Fair Housing – Affirmatively further fair housing by promoting and informing households on their rights, and by educating landlords, realtors, mortgage brokers, financial institutions, and sellers on fair housing practices which will reduce discrimination in the sale and rental of housing. HS-7 Housing Supportive Services – Promote and assist low- and moderate- income households in the purchase, maintenance and upkeep of their homes through housing and financial counseling to avoid eviction proceedings. Homeless Priority – HO There has been an increase in the number of persons who are unhoused in St. Joseph County. Homelessness is concentrated in the Cities of South Bend and Mishawaka. Due to the high cost of housing, there is a great risk of persons becoming homeless. Objective HO-1 Housing Opportunities – Increase the housing opportunities and living conditions of persons and families who are homeless or who are at risk of homelessness. HO-2 Support and Management Services – Promote and assist supportive and management services for public and non-profit agencies and organizations which assist persons who are homeless or who are at risk of homelessness. HO-3 Homeless Prevention – Promote and assist in eviction reduction efforts and educate and discourage unfair housing practices which may contribute to homelessness. HO-4 Permanent Supportive Housing – Promote and assist in the development of new permanent supportive housing opportunities for persons Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 183 and families who are experiencing homelessness and who are exiting out of shelters and transitional housing programs. HO-5 Shelter Housing – Support and assist in the development and/or continuation of shelters supportive training and educational programs for sheltered residents. Other Special Needs Priority – SN St. Joseph County and the Cities of South Bend and Mishawaka are experiencing an increase in the number of persons who are elderly, persons with physical disabilities, developmentally delayed persons, persons with mental illnesses, persons battling substance abuse, and persons exiting from institutional settings. Objective SN-1 Housing – Increase the number of decent, safe, sound, sanitary, accessible and affordable units that is available and accessible to all sectors of special needs populations. SN-2 Accessibility – Promote and assist in making accessibility improvements to existing housing units, including making reasonable accommodations for the physically disabled so they can remain in their housing accommodations. SN-3 Public Services – Improve and increase public service programs for the youth, the elderly, disabled, and target low-income population, including feeding programs and social/welfare programs throughout the City. SN-4 Removal of Architectural Barriers – Remove architectural barriers which restrict the mobility and access to public facilities and services for persons with physical disabilities. SN-5 Transportation – Improve and expand the access to transportation services for the elderly, persons with disabilities, and persons with other special needs. Community Development Priority – CD The infrastructure, community facilities, building conditions, and public services are being strained by the County’s population growth, increase demand for services and the age of the infrastructure, buildings, and facilities. There is a need to improve, preserve, and develop public facilities and infrastructure to support the population growth in the County. Objective CD-1 Infrastructure - Improve and upgrade the City’s infrastructure through rehabilitation, reconstruction, and new construction of streets, curbs, walks, ADA ramps, retaining walls, sewer lines, service lines, bridges, flood control, storm water management and sustainability. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 184 CD-2 Community Facilities – Improve, upgrade, and expand the City's public and community facilities including parks, playgrounds, recreational facilities, libraries, public buildings, etc. to meet the needs of the growing population. CD-3 Public Services – Improve, expand, and create public service programs including social, welfare, health and nutrition programs to meet the needs of the low- and moderate-income persons in the City. CD-4 Clearance and Demolition – Remove slum and blighting conditions through the demolition and clearance of vacant buildings that are economically infeasible for rehabilitation, and sites that pose a threat to the health, safety, and welfare of the public. CD-5 Public Safety – Improve and expand fire protection, emergency health and management services, crime prevention, etc. to better serve and protect the residents of the Cities. CD-6 Public Transportation – Improve and expand public transportation with additional bus routes, improved bus shelters, increased time schedules, etc. to assist low- and moderate-income persons to access employment medical treatment, and essential services. CD-7 Neighborhood Revitalization – Improve and stabilize neighborhoods in the City by developing capacity and encouraging the formation and expansion of neighborhood based organizations and consider planning/development under the Neighborhood Revitalization Strategy Area (NRSA) Program. CD-8 Section 504 – Implement the City Section 504 Plans and bring the public and community facilities into compliance with the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990. Economic Development Priority – ED The local economy in the County has been expanding with new development occurring in the Western Portion. However, this growth requires a skilled and trained workforce. This has created a need for job training, workforce development, and services to meet the employment needs of these new companies. Objective ED-1 Employment – Encourage and support new job opportunities through job creation, job retention, job training, workforce development, and educational programs to address the need for a well-trained labor force. ED-2 Financial Assistance – Support new development of business and industry through expansion, new development, capital equipment purchases, etc., to be funded with Federal programs. ED-3 Incentives – Support local, state, and Federal tax breaks, tax credits, land development bonuses, and planning initiatives to promote new development and expansion of business and industry. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 185 Administration & Planning – AP There is a continuing need to provide administration, management, and sound planning to executive grants and loan programs by the City. Objective AP-1 General Administration – Continue to provide experienced management and oversight to maintain efficient and effective administration of local, state, and federal grant and loan programs. AP-2 Planning – Provide sound planning for special studies, environmental review records, preparing grant applications, designing programs, planning project activities, etc. AP-3 Affirmatively Furthering Fair Housing – Promote and support policies and activities to Affirmatively Further Fair Housing (AFFH) throughout St. Joseph County, including the preparation of an Analysis of Impediments to Fair Housing Choice. The following attached maps illustrate the locations of historically funded CDBG funded activities in St. Joseph County: CDBG Activities Funding CDBG Acquisition Activities CDBG Economic Development Activities CDBG Housing Activities CDBG Public Improvement Activities CDBG Public Service Activities All CDBG Activities Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 186 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 187 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 188 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 189 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 190 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 191 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 192 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 193 2. HOME Investment Partnership (HOME) Program The St. Joseph County Housing Consortium The St. Joseph County Housing Consortium is composed of the City of South Bend, the City of Mishawaka, and St. Joseph County. The Housing Consortium undertakes activities in both Cities, as well as other unincorporated areas of the County. The City of South Bend is the Participating Jurisdiction for the Housing Consortium and annually receives from HUD approximately $893,696.89 in HOME funds. The Housing Consortium allocates its funds to new construction, housing rehabilitation, homebuyer assistance, and tenant-based rental assistance. In particular, the Housing Consortium proposed to allocate FY 2025 HOME funds as outlined in the following table to affirmatively further fair housing. The St. Joseph County Housing Consortium anticipates a reduction in the annual HOME allocation in the coming years as a result of further cuts in the Federal budget. However, due to the reallocation of funds from prior years, the Consortium was able to allocate a total of $1,205,025. FY 2025 HOME Allocation for the St. Joseph County Housing Consortium, IN HOME Investment Partnership (HOME) Program HOME Administration $ 16,025 New Construction – Affordable Housing $ 1,049,000 Tenant-Based Rental Assistance $ 140,000 Total: $ 1,205,025 The following attached map illustrate the locations of HOME-funded activities in St. Joseph County: Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 194 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 195 3. Emergency Solutions Grant (ESG) Program The City of South Bend receives approximately $203,698 in an Emergency Solutions Grant (ESG) annually for Countywide programs. ESG funds are used in conjunction with the Continuum of Care (CoC) funding to provide services to homeless individuals and families in the St. Joseph County region. The uses of the FY 2020 ESG allocation are outlined below: FY 2025 ESG Allocation for the City of South Bend, IN Emergency Solutions Grant (ESG) Program Shelter Operations $ 122,000 Rapid Rehousing $ 79,000 ESG Administration $ 2,698 Total: $ 203,698 4. Continuum of Care (CoC) The City of South Bend is part of the IN Balance of State Continuum of Care, which includes 91 of the 92 Counties in the State. The Balance of State is split into sixteen (16) individual regions, which are overseen by regional planning councils and chairpersons that lead them. Regional CoCs hold regular meetings to develop and implement strategies for homeless alleviation and prevention. The City of South Bend is located in Region 2A, which includes only St. Joseph County. 5. Housing Authority of South Bend – The Housing Authority of South Bend is the primary provider of affordable housing in St. Joseph County. It runs programs for both public housing and Section 8 Housing Choice Vouchers. It aims to address the needs of the extremely low-income, very low-income, and low-income residents of the City of South Bend and St. Joseph County. All properties owned by HASB are public housing properties, and there are no project-based developments. Housing Authority of South Bend 501 Alonzo Watson Dr. South Bend, IN 46601 (574) 235-9346 https://hasbonline.com Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 196 The Housing Authority of South Bend’s mission is to provide safe and affordable housing assistance to individuals and families in a manner that is respectful, professional, and service oriented. The HASB is committed to maximize its existing resources and work in partnership with the community to assist residents in reaching individual and family goals, including self- sufficiency, through education, increasing employment and homeownership opportunities. The Housing Authority of South Bend is recognized as a public body corporate and a “Public Housing Authority” of the U.S. Department of Housing and Urban Development and the State of Indiana. HUD provides funding to the Housing Authority of South Bend through its Housing Choice Voucher Program. The Housing Authority is governed by a five (5) member Board of Commissioners and everyday operations are handled by an Executive Director. All HASB staff are required to attend one fair housing training seminar per year. The most recent seminar was the Induce My Purpose workshop for housing participants centered around credit and banking, held on June 1, 2024. The Housing Authority of South Bend is rated as a “troubled” agency by HUD, according to the HUD PHA list dated April 26, 2024. The City is working closely with the Housing Authority of South Bend to shed its troubled status. 1. The City is providing $1 million to the Housing Authority of South Bend (HASB) to make repairs to its vacant scattered-site units. This will help to house more families, reduce vacancy loss, and bring the HASB out of troubled status. The MOU for the funds has been executed and a scope of the project and needed repairs is currently being developed. 2. The City contracted with an outside consulting firm to provide an asset repositioning plan for HASB. The consultant has completed site visits of all vacant units and has completed the analysis and made initial recommendations. 3. The City is partnering with HASB on a transformation plan for the redevelopment of two former public housing sites which are currently vacant. The plan is to combine these sites into a mixed income community. The City and Community Foundation have applied for $20 million in grant funds for the project. HASB has published a RFQ for a developer partner. The City has also committed funding to the project. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 197 It is expected that once the vacant units are occupied, HASB will be able to shed its troubled status. Public Housing Communities – The Housing Authority of South Bend owns and professionally manages family communities and elderly/disabled rental apartments. HASB has four (4) Asset Management Projects (AMP) that encompass nine (9) developments. HASB lists 814 housing units in these nine (9) developments, but 231 of these units in the Monroe Circle and Rabbi Shulman properties are unavailable. The Monroe Circle property has been demolished in partnership with the City of South Bend, and the Rabbi Shulman development is under redevelopment. Housing Authority of South Bend – Public Housing Communities Address Owner/Manager Units Monroe Circle – Monroe Circle, South Bend, IN 46601 Housing Authority of South Bend N/A Rabbi Albert M. Shulman Complex – 628 Western Avenue, South Bend, IN 46601 Housing Authority of South Bend N/A Laurel Place – Laurel Court, South Bend, IN 46601 Housing Authority of South Bend 42 South Bend Avenue – South Bend Avenue, South Bend, IN 46617 Housing Authority of South Bend 20 Westcott Apartments and The Quads – 501 Alonzo Watson Drive, South Bend, IN 46601 Housing Authority of South Bend 179 LaSalle Landing – Oak Park Court, South Bend, IN 46613 Housing Authority of South Bend 24 Harber Homes – Boston Drive, South Bend, IN 46619 Housing Authority of South Bend 54 Edison Gardens and Twyckenham Apartments – 3602 Edison Road & Twyckenham Drive, South Bend, IN 46615 Housing Authority of South Bend 38 Scattered Sites, South Bend, IN Housing Authority of South Bend 243 Total Units 598 Source: Housing Authority of South Bend, September 2024 board minutes The waiting list for public housing is currently closed. There are 858 households on the waiting list as of September 2024. With public housing Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 198 occupancy at 94%, there is a greater demand than supply. However, public housing residents have been converting to Section 8, and the demand for public housing has decreased among households who qualify for Section 8. The Housing Authority of South Bend does not have any active resident councils. They have attempted to start resident councils multiple times, however the councils do not sustain themselves. Section 8 – The Housing Authority of South Bend oversees the Section 8 Housing Choice Voucher Program. Eligible participants who receive vouchers may search on their own for privately owned housing. The Housing Authority encourages voucher holders to locate in areas of high opportunity and outside R/ECAPs. Because the City’s inventory of Section 8 Housing does not meet the demand for housing, many Section 8 Voucher holders attempt to “port out” of South Bend. The Housing Authority of South Bend grants extensions to Voucher Holders to assist them in finding a house in South Bend. HASB administers 2,343 Section 8 Housing Choice Vouchers as of September 2024. A total of 2,193 of these vouchers are living in Section 8 Housing. Demand for a quality Section 8 Housing rental exceeds the supply of decent, affordable rental units. Section 8 Housing is currently at 94% occupancy. There were 1,489 families or individuals on the Housing Choice Voucher waiting list as of March 16, 2023 (the most recent waiting list available). The waiting list is currently closed and is expected to reopen in late 2024 or early 2025. Homebuyer and Family Self-Sufficiency Programs – The Housing Authority of South Bend has two homebuyer programs: one for Public Housing residents and one for Section 8 Residents. HASB allows potential homebuyers to hold money in an escrow account toward the purchase of a home. Family Self-Sufficiency (FSS) programs are provided to Section 8 Housing Choice Voucher holders and public housing tenants to transition from welfare to work or better paying jobs. The Head of Household works with the FSS staff to create a five-year plan, which lists steps they will take to Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 199 pursue economic stability for their family. The plan includes goals to seek and maintain employment and become free of any welfare (cash) assistance received. Throughout the program, FSS staff helps families access government and community programs and services for financial aid, career training, job search, childcare, transportation, counseling, budgeting, credit repair, and even homeownership. As the family progresses in their program, any rent increases caused by increases in salary, better jobs, or wages are deposited in an FSS savings account. At the end of five years, when the Head of Household completes their FSS goals and "graduates," they are eligible to receive money collected in this account. Past participants in FSS have returned to school, obtained living wage jobs, improved credit and finances, purchased vehicles, started businesses, and bought homes of their choice. Their futures become more secure as they build assets. As of September 2024, there are 59 participants in the FSS program. 6. Housing Authority of the City of Mishawaka – The Housing Authority of the City of Mishawaka also operates programs for both public housing and Section 8 Housing Choice Vouchers in the City of Mishawaka. It is the second largest provider of public housing in St. Joseph County, Indiana. The Mishawaka Housing Authority is recognized as a public body corporate and a “Small Housing Authority” of the U.S. Department of Housing and Urban Development and the State of Indiana. The Housing Authority has seven board members, all of whom are appointed by the Mayor with the consent of City Council. The Housing Authority is considered a “high performer” by HUD. The Housing Authority of the City of Mishawaka assists in meeting the public housing needs of the City of Mishawaka. The Housing Authority has three (3) properties with 324 units. The Mishawaka Housing Authority is eligible for 350 Section 8 Housing Choice Vouchers and is currently using 322. The Housing Authority of the City of Mishawaka has resident involvement in its two senior living facilities. Both councils are active. The Mishawaka Housing Authority 601 E 11th Street Mishawaka, IN 46544 (574) 258-1656 https://affordablehousing mishawaka.com/ Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 200 Mishawaka Housing Authority does not have a Family Self-Sufficiency program. The Mishawaka Housing Authority makes accommodations on request after the receipt of a doctor’s note that certifies the need for accommodation. The Mishawaka Housing Authority currently has 41 accessible units, all of which are in the Riverview Towers elderly housing. The Mishawaka Housing Authority owns and professionally manages one family community and two elderly/disabled rental apartments. Of the elderly/disabled rental apartments, one is a tax credit property. Mishawaka Housing Authority staff receive yearly trainings in Fair Housing. Public Housing – The Mishawaka Housing Authority aims to address the needs of the extremely low-income, very low-income, and low-income residents of the City of Mishawaka and St. Joseph County. HUD provides funding to the Mishawaka Housing Authority through its Public Housing and Housing Choice Voucher Programs. The Mishawaka Housing Authority owns and manages 324 apartments of subsidized and affordable housing. 41 of these apartments are accessible for elderly/disabled residents at River View Towers. Mishawaka Housing Authority – Public Housing Address Owner/Manager Units River View – 500 Lincolnway East, Mishawaka, IN 46544 Mishawaka Housing Authority 151 Barbee Creek Village – 400 10th Street, Mishawaka, IN 46544 Mishawaka Housing Authority 148 Mary Phillips School – Mishawaka, IN 46545 Mishawaka Housing Authority 25 Source: The Housing Authority of the City of Mishawaka Section 8 – The Mishawaka Housing Authority oversees the Section 8 Housing Choice Voucher Program in the City of Mishawaka. Eligible participants who receive vouchers may search for their own privately owned housing. The Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 201 Housing Authority encourages voucher holders to locate in areas of high opportunity and outside R/ECAPs. Housing Choice Voucher holders from the City of South Bend will port into the City of Mishawaka. The Mishawaka Housing Authority has a baseline of 350 Section 8 Housing Choice Vouchers, with 322 vouchers currently in use as of November, 2024. 7. St. Joseph County Housing Authority – The St. Joseph County Housing Authority is recognized as a public body corporate and a “Small Housing Authority” of the U.S. Department of Housing and Urban Development and the State of Indiana. The St. Joseph County Housing Authority assists in meeting the public housing needs of St. Joseph County. The St. Joseph Housing Authority only administers Section 8 Housing Choice Vouchers in the areas of St. Joseph County outside of the Cities of South Bend and Mishawaka. Section 8 – Eligible participants who receive vouchers may search on their own for privately owned housing. The Housing Authority encourages voucher holders to locate in areas of high opportunity and outside R/ECAPs. The following map illustrates all HUD multifamily properties in and around St. Joseph County. St. Joseph County Housing Authority 2410 Grape Road, Suite 2 Mishawaka, IN 46545 (574) 233-9305 https://sjcha-in.com Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 202 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 203 8. Low Income Housing Tax Credit – The Low-Income Housing Tax Credit (LIHTC) Program was created under the Tax Reform Act of 1986 and is intended to attract private investment to develop affordable rental housing for low- and moderate-income households. This program provides a dollar-for-dollar tax credit to reduce the developer’s Federal income tax. The City of South Bend, the City of Mishawaka, and St. Joseph County promote the use of Low Income Housing Tax Credits. The following table shows LIHTC projects completed in St. Joseph County. Only one of the LIHTC projects completed in St. Joseph County were outside the City of South Bend or the City of Mishawaka (Dogwood Estates in Walkerton, IN). St. Joseph County, IN LIHTC Projects HUD ID Number Project Name Project Address / City Project ZIP Code Total Number of Units Total Low- Income Units INA00000027 Dogwood Estates (Walkerton: West York Redevelopment) 611 Lincoln Dr, Walkerton 46574 40 40 INA00000047 Historic Rushton Apartments 501 W Washington St, South Bend 46601 23 INA00000068 Mishawaka River Center Apartments 402 Lincolnway W, Mishawaka 46544 37 32 INA00000081 Parkview Terrace Apartments 1110 Dodge Ave, Mishawaka 46544 112 112 INA00000083 Prairie Apartments Phase II 2630 Prairie Ave, South Bend 46614 96 96 INA19920022 1349 E Dubail Ave 1349 E Dubail Ave, South Bend 46613 1 1 INA19920105 Historic Dunbar Corner 118 N Walnut St, South Bend 46628 15 15 INA20010001 Arbors at Ironwood Apartments II 1310 Blossom Dr, Mishawaka 46544 40 40 INA19970120 The Robertson’s Building 211 S Michigan St, South Bend 46601 92 80 INA19980042 Dunedin Apartments Phase II 53880 Generations Dr, South Bend 46635 84 84 INA19989119 Emerald Pointe Apartments (formerly Dunedin I and II) 53880 Generations Dr, South Bend 46635 168 168 INA20010082 Arbors at Ironwood Apartments I 1310 Blossom Dr, Mishawaka 46544 88 88 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 204 INA20119175 Washington Dunbar Homes 118 N Walnut St, South Bend 46628 80 80 INA20030125 St. Joseph County YWCA Residence 1102 Fellows St, South Bend 46601 30 26 INA20060088 Hope Transitional Housing 432 S Lafayette Blvd, South Bend 46601 22 22 INA20070005 Arbors at Belleville Park III 23291 Belleville Cir, South Bend 46619 40 38 INA20080090 Prairie Apartments Phase I 2630 Prairie Ave, South Bend 46614 108 108 INA20080115 The Preserve at Fir Road 2705 Spicer Ln, Mishawaka 46545 144 122 INA20120085 Heritage Place at LaSalle Square 3224 Ardmore Trail, South Bend 46628 72 72 INA20120110 New Heritage Homes Southeast 501 Pennsylvania Ave, South Bend 46601 54 54 INA20160007 Hoffman Hotel Apartments 120 W Lasalle Ave, South Bend 46601 48 48 INA20160019 South Bend Mutual Homes Scattered Site, South Bend 46616 24 24 INA20175179 South Bend Permanent Supportive Housing (D.B.A. Oliver Apartments) 924 W Indiana St, South Bend 46613 32 32 INA20190018 Silver Birch of Mishawaka 3630 Hickory Rd, Mishawaka 46545 114 119 INA20190019 Silver Birch of Mishawaka 3630 Hickory Rd, Mishawaka 46545 119 119 INA20193173 Ironwood Village Apartments 1310 Blossom Dr, Mishawaka 46544 128 128 INA20202173 Hellenic Senior Living of Mishawaka 1540 S Logan St, Mishawaka 46544 136 136 INA20210002 Cedar Glen Apartments 425 S 25th St, South Bend 46615 179 179 Source: https://lihtc.huduser.org/ The following table provides the number of residents in publicly supported housing units, with the percentage identified as white, black, Hispanic, or Asian/Pacific Islander. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 205 Publicly Supported Housing, St. Joseph County White Black / African American Hispanic Asian or Pacific Islander Public Housing 327 32.47% 638 63.36% 26 2.58% 9 0.89% Project-Based Section 8 871 52.92% 707 42.95% 51 3.10% 6 0.36% Other Multifamily 155 72.43% 57 26.64% 2 0.93% 0 0.00% Housing Choice Voucher 478 18.76% 2,004 78.65% 47 1.84% 10 0.39% Total Households 76,709 78.99% 12,166 12.53% 4,779 4.92% 1,855 1.91% Source: HUD AFFH Tool The following map illustrates all HUD properties in St. Joseph County and the surrounding area overlaid by race. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 206 Source: HUD AFFH Tool Map 5 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 207 Per the HUD AFFH Tool, the racial makeup of all public housing is available on both the County and regional level. The four types of public housing are: Public Housing Section 8 Project-Based Rental Assistance (PBRA) Housing Choice Voucher (HCV) Program Other Assisted Housing The Black racial group makes up the majority of Publicly Supported Households at 3,406, as well as being the largest cohort of tenants in Public Housing (63.36%) and most users of Housing Choice Vouchers (78.65%). Meanwhile, the White racial group makes up the largest cohort of tenants in Section 8 Project Based Housing (52.92%) and Other Multifamily Housing (72.43%), with 1,831 households using Publicly Supported Housing programs. There are 126 Hispanic households and 25 Asian or Pacific Islander households using Publicly Supported Housing. When comparing these rates to the overall population makeup of St. Joseph County, it can be determined which racial cohorts are over- or under- represented in public housing. The Black/African-American population comprises 12.53% of the County’s population, but occupies 63.36% of public housing, 42.95% of Section 8 Housing, and 78.65% of HCV. Overall, 28.00% of the County’s Black households are publicly supported. Only 2.39% of the County’s White households are publicly supported, along with 2.64% of Hispanic households and 1.35% of Asian or Pacific Islander households. The tables below detail the racial and ethnic demographics of residents at individual housing complexes in St. Joseph County. Public Housing – St. Joseph County Development Name Housing Authority Units White Black Hispanic Asian Households w/Children NORTHWEST PLAZA Housing Authority of South Bend 145 8.33% 87.88% 3.79% N/A 63.64% PLAZA APTS & MONROE CIR Housing Authority of South Bend 311 21.22% 76.26% 1.08% 1.08% N/A PLAZA APTS & MONROE CIR Housing Authority of South Bend 188 11.98% 86.23% 1.2% N/A 86.23% NORTHWEST PLAZA Housing Authority of South Bend 165 16.2% 78.87% 3.52% N/A 75.35% Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 208 RIVER VIEW 500 Housing Authority of the City of Mishawaka 151 84.03% 13.19% 1.39% N/A N/A BARBEE CREEK VILLAGE Housing Authority of the City of Mishawaka 148 64.58% 24.31% 6.25% 4.17% 56.94% Source: HUD AFFH Tool Table 8 Project-Based Section 8 Housing – St. Joseph County Development Name Units White Black Hispanic Asian Households w/Children FAIRINGTON SOUTH BEND 201 90.5% 6% 3% N/A N/A LASALLE PARK HOMES 149 11.03% 79.41% 8.82% 0.74% 47.79% BEACON HEIGHTS APARTMENTS 174 18.42% 78.95% 1.32% 0.66% 74.34% KARL KING RIVERBEND TOWER 219 60.59% 36.45% 1.97% N/A N/A ST. JOSEPH'S TOWER 84 30.49% 63.41% 4.88% 1.22% 1.22% CORBY APARTMENTS 150 33.8% 61.97% 2.82% 0.7% 52.11% LAUREL WOODS APARTMENTS 100 18.81% 78.22% 1.98% N/A 58.42% THE ADDISON ON MAIN 48 42.55% 53.19% 4.26% N/A 46.81% CARRIAGE HOUSE MISHAWAKA II 48 60.42% 33.33% 2.08% 2.08% 43.75% MIAMI HILLS APARTMENTS 150 31.96% 62.89% 5.15% N/A 71.13% PARKVIEW TERRACE 107 36.11% 60.19% 3.7% N/A 63.89% 100 CENTER HI-RISE LLC 104 91% 6% 2% 1% 1% CHICAGO TRAIL VILLAGE 102 100% N/A 0% N/A N/A EASTGATE COMMUNITY 38 100% N/A 0% N/A 7.69% LAKESIDE APARTMENTS 48 90.7% 2.33% 4.65% N/A 67.44% Source: HUD AFFH Tool Table 8 Other Multifamily Assisted Housing – St. Joseph County Development Name Units White Black Hispanic Asian Households w/Children MADISON GROUP HOME 8 N/A N/A N/A N/A N/A LASALLE PARK HOMES II 42 2.56% 94.87% 2.56% N/A N/A Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 209 UHRIG APARTMENTS 20 75% 25% 0% N/A N/A RIVER COURT 14 85.71% 14.29% 0% N/A N/A LINDEN HOUSE OF MISHAWAKA 49 97.87% 2.13% 0% N/A N/A PENELOPE 60 APARTMENTS 50 97.78% 2.22% 0% N/A N/A AHEPA 100 APARTMENTS 49 75.51% 22.45% 2.04% N/A N/A Source: HUD AFFH Tool Table 8 With some exceptions, the housing developments in the City of South Bend have a much higher proportion of Black residents than White; the opposite tends to be true in the City of Mishawaka. St. Joseph County and SJHA compared the demographics of residents of each program category of publicly supported housing to the population in general to determine if there is a higher or lower proportion of groups based on protected class. Publicly Supported Housing and Income – St. Joseph County Race / Ethnicity St. Joseph County 0-30% AMI 0-50% AMI 0-80% AMI % Publicly Supported Households # % # % # % # % # % White 76,709 78.99% 7,185 57.80% 15,823 63.69% 29,877 69.16% 1,831 2.39% Black / African American 12,166 12.53% 3,874 31.16% 6,223 25.05% 8,866 20.52% 3,406 28.00% Hispanic 4,779 4.92% 784 6.31% 1,724 6.94% 2,827 6.54% 126 2.64% Asian or Pacific Islander 1,855 1.91% 287 2.31% 420 1.69% 698 1.62% 25 1.35% Source: HUD AFFH Tool Table 6 Data from the previous table provides information for further analysis of publicly supported housing in the MSA. While the White population makes up 78.99% of the population, it makes up 69.16% of the income-eligible population. The Black/African-American population comprises 12.53% of the South Bend-Mishawaka MSA’s population, but 20.52% of the income- eligible population. Comparing the publicly supported housing population with the income-eligible population provides a more accurate assessment. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 210 9. HUD Assisted Housing – HUD previously funded the Section 202 and Section 811 Supportive Housing programs to encourage and support the development of assisted housing in cities and counties across the country. The Section 202 Supportive Housing for the Elderly Program provided financial support for the construction, rehabilitation, or acquisition of supportive housing for the elderly. Similarly, the Section 811 Supportive Housing for the Disabled provided financial assistance for nonprofit organizations seeking to develop affordable, supportive housing for low-income adults with disabilities. The City of South Bend, the City of Mishawka, and St. Joseph County are supportive of the use of Section 202 and Section 811 Supporting Housing Programs, as well as the use of Low Income Housing Tax Credits (LIHTC). 10. Social Service Agencies – The following table lists the organizations for the at-risk, homeless, or disabled populations in St. Joseph County. Supportive Service Programs in St. Joseph County Agency Name Description Health Plus Indiana Health Plus Indiana helps support and enhance the lives of people infected with and affected by HIV and AIDS. They provide outreach and care services, as well as housing. Boys & Girls Club of St. Joseph County The Boys & Girls Club of St. Joseph County serves children throughout St. Joseph County with programming and a safe space for all children in the region. Center for the Homeless The Center for the Homeless is the lead entity for the St. Joseph County Continuum of Care. They provide emergency shelter, transitional housing, and housing for veterans. They also provide programs for adult self-sufficiency, children’s support and development services, and mental health counseling. Dismas House Dismas House provides housing for the homeless with an emphasis on providing homes for ex-offenders. They encourage students to reside in Dismas House also offer warm meals to their residents. Goodwill Bridges Out of Poverty The Goodwill Bridges Out of Poverty program provides workforce and employment training, as well as financial management to individuals without jobs or with low-paying jobs. Habitat for Humanity of St. Joseph County Habitat for Humanity has a variety of programs to assist in providing quality housing for low- and moderate-income families, including Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 211 homeownership programs, aging in place programs, and housing for victims of domestic violence. HOPE Ministries HOPE Ministries assists homeless individuals in St. Joseph County with housing, meals, and on-site healthcare. IN*Source IN*Source assists parents in St. Joseph County with the tools and training to work with children with a variety of disabilities, while also assisting the children with its programming. La Casa de Amistad La Casa de Amistad is a community center that works to provide bilingual and bicultural youths and adults with programming in St. Joseph County, with an emphasis on Hispanic/Latino culture. Logan Center The Logan Center supports people with intellectual and developmental disabilities in St. Joseph County. A wide variety of programs are run by the center for adults and children. Mishawaka Food Pantry The Mishawaka Food Pantry provides food for individuals in the City of Mishawaka and clothing for individuals throughout St. Joseph County that are experiencing homelessness. Near Northwest Neighborhood, Inc. Near Northwest Neighborhood is a neighborhood organization in South Bend with a housing component. Near Northwest Neighborhood will undertake housing rehabilitations in the neighborhood to preserve housing for residents. Notre Dame Economic Justice Clinic The Notre Dame Economic Justice Clinic is a pro bono legal clinic run out of the Notre Dame University Law School. Among other types of legal complaints, the Clinic will handle fair housing cases in St. Joseph County. Our Lady of the Road/Motels for Now Our Lady of the Road provides social services to those experiencing homelessness and operates Motel for Now which provides overnight shelter for chronically homeless individuals. REAL Services REAL Services provides social services to seniors in the region, including meal delivery. REAL Services also acts as an advocate for the disabled elderly in the region. South Bend Heritage Foundation South Bend Heritage Foundation creates affordable housing developments in the City of South Bend. St. Joseph County Public Library The St. Joseph County Public Library provides educational programming that serves youth, adults, and jobseekers in the County, while acting as a welcoming public space. St. Margaret’s House St. Margaret’s House is a day center that welcomes women and children who live in economic poverty. They also provide educational and emotional support programs for women at the facility. Upper Room Recovery Upper Room Recovery provides addiction services and a safe space for recovering addicts. They also provide a women’s home for recovering addicts who are women. Youth Services Bureau Youth Services Bureau provides safety, shelter, and the opportunity to succeed for all youth with a variety of services, including emergency youth shelters, counseling programs, and a Drop In Center. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 212 466 Works 466 Works is a non-profit development corporation designed to develop affordable housing and provide resources for rehabilitation for residents of the Southeast Neighborhood of South Bend. 11. Planning, Zoning, and Building Codes St. Joseph County – St. Joseph County Zoning addresses the zoning ordinances for the Town of Lakeville, the Town of New Carlisle, the Town of North Liberty, the Town of Osceola, and the Town of Roseland, as well as the unincorporated areas of St. Joseph County. However, the City of Walkerton addresses its own zoning ordinances. Reasonable accommodations in St. Joseph County must receive zoning approvals. Annexations are permitted in the State of Indiana provided they are contiguous and 100% of the residents of the annexed land approve of the annexation. The County follows the 2020 Indiana Residential Code, as amended. South Bend City – The City of South Bend’s Zoning Ordinance received a comprehensive update was adopted in 2019, and effective January 1, 2020 at the same time as the City retook responsibility of zoning administration within its corporate boundaries from the County. Zoning Districts for the City of South Bend Standard Districts District Type Single- Unit Ancillary Dwelling Shared Housing Duplex Multi- Unit Commercial Industrial S1 Suburban Neighborhood 1 A C X SE X X X S2 Suburban Neighborhood 2 A A X A A X X U1 Urban Neighborhood 1 A C X SE X X X U2 Urban Neighborhood 2 A C X A A X X U3 Urban Neighborhood 3 A A SE A A X X UF Urban Neighborhood Flex A A SE A A A/SE X Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 213 NC Neighborhood Center C A SE C A A X DT Downtown C A A C A A X Special Districts OS Open Space X A X X X SE X U University X C X X A A C C Commercial X A X X X A C I Industrial X A X X X A A Overlay Districts HP Historic Preservation Overlay Established to preserve buildings, other structures, and sites of historic, architectural, engineering, and cultural significance in South Bend. NNZO Northeast Neighborhood Overlay Codified recommendations of the Northeast Neighborhood Design Guidelines which are most relevant and applicable to new development in the NNZO. Source: City of South Bend Zoning Ordinance Note: A – Allowed, C – Allowed subject to conditions, SE – Special Exception, X – Not Permitted Much of the housing in the region is single-family housing, and the City has created two Suburban Neighborhood types to guard that housing type. In the S1 district, duplexes require special exceptions, while the S2 district allows single-family detached residences as well as carriage houses, cottage courts, duplexes, townhouses, apartment houses and stacked flats. There are also six types of Urban Neighborhoods which allow varying density of homes from single-family detached to multi-family apartment buildings: U1, U2, U3, UF (Urban Flex), NC (Neighborhood Center), and DT (Downtown). Variances must be requested for setbacks for housing. Large, older single-family houses near the University of Notre Dame in the City of South Bend are frequently divided into households by bedroom. The definition of family in the City of South Bend has been intentionally kept narrow to prevent overcrowded and deficient student housing and to encourage construction of dedicated student housing. The City has also created a Shared Housing use to allow for such housing in designated zones. However, group homes for residential care are permitted in all residential zones by State law. In the City of South Bend, code enforcement issues are common, particularly in rental housing, and the City is actively pursuing methods of resolving these issues. Inspectors spend the majority of time in the field ensuring code compliance, including conducting windshield inspections and Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 214 interior/exterior inspections of rental units. Code enforcement frequently cites absentee landlords for code deficient structures. To combat the code issues with rental apartments in the region, the City of South Bend adopted RSVP, which requires rental units to meet minimum property standards. Following passing the RSVP inspection, units are certified by the City. Mishawaka City – The City of Mishawaka’s Zoning Ordinance is designed to maintain a single- family housing, primarily residential character. The Zoning Ordinance allows for housing in some commercial zones as long as it follows the relevant district zoning regulations. There is a special zoning district for mobile homes. Unlike South Bend, Mishawaka does not allow for ancillary housing units such as carriage houses, but it does allow agricultural uses in nearly every district. Zoning Districts for the City of Mishawaka Standard Districts District Type Single- Unit Mobile Homes Duplex Multi- Unit Commercial Industrial Civic R-1 Single-Family Residential P X X X X X P R-2 Two-Family Residential P X P X X X P R-3 Multiple-Family Residential X X P P L X P R-4 Manufactured Home Residential X P X X X X P C-1 General Commercial X X X X P X P C-2 Shopping Center Commercial X X X X P X P C-3 City Center Commercial P X P P P X P C-4 Automobile- Oriented X X X X P X P C-5 Neighborhood Commercial P P P X P X P C-6 Linear Office Commercial P X P X P X L Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 215 C-7 Automobile- Oriented Restaurant Commercial X X X X P X P C-8 High-Density Suburban Commercial X X X X P X P C-9 Automobile- Oriented Sales X X X X P X P C-10 Filling Stations X X X X P X P I-1 Light Industrial X X X X X P X I-2 Heavy Industrial X X X X X P X Special Districts S-1 Extensive Open Space and Public Use This district is designed to help preserve large tracts of land for land extensive uses which are necessary and desirable for the long term health, use, and enjoyment of the community L X P S-2 Planned Unit Development Planned Unit Development zoning will provide for: a variety of housing and building types; useful patterns of open space and accessory commercial development; the preservation of natural and scenic resources; more efficient land use and utilities; and, a development pattern in harmony with the Mishawaka Comprehensive Plan objectives for land use density, transportation facilities, and community facilities. Overlay Districts H Historic Overlay District The City’s zoning ordinance does not appear to define a Historic Overlay District or set any regulations regarding its use. Source: City of Mishawaka Zoning Ordinance Note: P – Permitted, C – Conditional, L – Limited Types, X – Not Permitted The Mishawaka Zoning Ordinance defines family broadly, as either one or more persons living in the same housekeeping accommodations, or one or more individuals occupying premises as a single household with single kitchen accommodations. This is in contrast to South Bend’s restrictive definition, and it is unknown whether Mishawaka has difficulty enforcing student housing restrictions as a result. Mishawaka does not have a distance separation requirement for group homes. However, inspections of group homes are required on the part of police and fire departments, which could be considered discriminatory since it is not required for other multi-family developments. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 216 U.S. Department of Housing and Urban Development (HUD) HUD encourages its grantees to incorporate “visitability” principles into their designs. Housing that is “visitable” has the most basic level of accessibility that enables persons with disabilities to visit the home of a friend, family member, or neighbor. “Visitable” homes have at least one accessible means of egress/ingress for each unit, and all interior and bathroom doorways have 32-inch clear openings. At a minimum, HUD grantees are required to abide by all Federal laws governing accessibility for disabled persons. Federal Requirements Federal laws governing accessibility requirements include Section 504 of the Rehabilitation Act, the Americans with Disabilities Act, and the Fair Housing Act. Section 504 of the Rehabilitation Act (24 CFR Part 8), known as “Section 504” prohibits discrimination against persons with disabilities in any program receiving Federal funds. Specifically, Section 504 concerns the design and construction of housing to ensure that a portion of all housing developed with Federal funds is accessible to those with mobility, visual, and/or hearing impairments. The Americans with Disabilities Act (42 U.S.C. 12131; 47 U.S.C. 155, 201, 218, and 225) (ADA) prohibits discrimination against persons with disabilities in all programs and activities sponsored by state and local governments. Specifically, ADA gives HUD jurisdiction over housing discrimination against persons with disabilities. The Fair Housing Act was amended in 1988 to include persons with disabilities as a protected class, as well as to include design and construction requirements for housing developed with private or public funds. Specifically, this law requires property owners to make reasonable accommodations to units and/or public areas in order to allow the disabled tenant to make full use of the unit. Additionally, property owners are required to make reasonable accommodations to rules or procedures to afford a disabled tenant full use of the unit. As it relates to local zoning ordinances, the Fair Housing Act prohibits local government from making zoning or land use decisions, or implementing land use policies, that exclude or discriminate against persons of a protected class. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 217 12. Taxes Real estate property taxes may also impact housing affordability. This may not be an impediment to fair housing choice, but it does impact the affordability of housing. The following table shows the millage rates (1/1000 of each dollar of assessed property value) for jurisdictions within St. Joseph County. St. Joseph County Property Tax Rate per Taxing District, 2023-2024 Taxing District Rate Taxing District Rate 001 Centre Township 2.7697 022 Mishawaka – PHM School 3.8675 002 South Bend – Centre 5.3227 023 Mishawaka – Penn 4.3748 003 Clay Township 2.5281 025 Portage Township 2.8018 004 South Bend – Clay 5.3384 026 South Bend – Portage 5.3548 005 Mishawaka – Clay 4.3566 027 Union Township 2.2698 006 Indian Village 2.5281 028 Lakeville 3.2273 007 Roseland 3.1207 029 Warren Township 2.7780 008 German Township 2.5112 030 Osceola 2.3066 009 South Bend – German 5.3215 031 Penn Township 2.0523 010 Greene Township 2.5271 032 Penn Twp-Mishawaka Schools 2.5596 011 Harris Township 2.0153 033 South Bend – Penn 4.8493 014 Lincoln Township 2.2872 034 Liberty Township 2.3168 015 Walkerton 3.8732 035 North Liberty 3.6223 016 Madison Township 1.7113 036 Mishawaka – Harris 3.8438 017 Olive Township 2.6822 037 South Bend Warren 5.3430 018 New Carlisle 3.8971 Source: St. Joseph County Office of Assessment The Residential Tax Abatement program that may be available to potential homeowners for consideration when thinking about building a new home. This allows homebuyers to phase in costs and lessen the immediate financial burden. There is also a legislative property tax cap for the State of Indiana, where the maximum tax paid after deductions is capped through a “circuit breaker” tax. 13. Transportation Transportation plays an important aspect in determining where residents choose to live. Some families choose to live in an area that is more private Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 218 than physically connected, while others place more emphasis on proximity to main arteries and highways for commuting to work. Major Highways St. Joseph County is traversed by the Indiana Toll Road (Interstate 80/90), an east-west tolled superhighway near the northern edge of the county. It serves as a major artery between the eastern and midwestern United States for both commercial and personal vehicles. Most residents would use this route to access northwest Indiana, Chicago, and points west. Other major highways include US 20 (the St. Joseph Valley Parkway) passing south and west of Mishawaka and South Bend, Business US 20 parallelling the St. Joseph River via downtown South Bend to South Bend International Airport, US 31 which passes Lakeville on its way north to the Michigan border, and Business US 31 which begins at the US 31/St. Joseph Parkway interchange and passes through downtown South Bend on its way past the University of Notre Dame. State Route 933 (the Lincolnway) connects downtown Mishawaka and South Bend before turning north toward Niles, MI, and State Route 23 travels northeast-southwest from Granger through South Bend to Walkerton. Transpo Transpo serves the City of South Bend, the City of Mishawaka, and the outlying areas of St. Joseph County, IN with 20 fixed routes (plus an additional “Game Day Express” bus for University of Notre Dame home football games) and paratransit in the Cities of South Bend and Mishawaka. It also serves as the de facto school bus provider for School City of Mishawaka. There is no bus service on Sundays or major holidays. Over the last five years, Transpo’s ridership went from a high of 1,594,252 in 2019 to a low of 937,474 in 2020 (as a result of the COVID pandemic) and has steadily risen to a 2023 total of 1,255,253 riders. The system’s operating subsidy ratio is 89%; $5,263,404 of its annual funding is from local assistance, $2,080,062 from state assistance, $2,849,749 from Federal assistance, and $1,282,495 from fare revenue. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 219 Below is the Transpo service map: Source: Transpo System Map, https://www.sbtranspo.com/plan-your-trip/system-map/ Transpo has 50 fixed route buses and 21 paratransit vehicles. All Transpo vehicles are equipped with handicap lifts, and all Transpo fixed-route buses are additionally equipped with bike racks. Transpo began a total fleet renewal program in 2014 and completed it in 2023; its entire fixed-route fleet is now fueled by compressed natural gas. Passenger Rail The Northern Indiana Commuter Transportation District (NICTD) operates the South Shore Line between South Bend International Airport and downtown Chicago, IL, serving Michigan City, Gary, and intermediate stops. The service offers six trains to and from Chicago on weekdays, with five on weekends. At present South Bend Airport is the only stop within St. Joseph County, but NICTD is considering reopening a stop in New Carlisle and rerouting the line to terminate in downtown South Bend. Ridership to/from South Bend was 142,652 passengers between May 2023 and April 2024. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 220 South Bend has two Amtrak trains daily in each direction, connecting it to Chicago and to Boston, New York, and Washington, DC. Westbound trains are scheduled to arrive at 7:45am and 9:20am but are often delayed; eastbound trains depart at 1:45am and 5:40am, prior to the first daily Transpo bus. It had 19,481 passenger arrivals and departures in FY 2023. Air Travel South Bend International Airport (SBN) is a regional airport served by Allegiant Air, American Airlines, Delta Airlines, and United Airlines. As of October 2024, about 30 flights arrive and depart from the airport daily. The shortest distance flights are to Chicago O’Hare International Airport and Detroit-Wayne County Airport; other destinations include Atlanta, Charlotte, Dallas-Ft. Worth, Minneapolis-St. Paul, Orlando, and Punta Gorda, FL. There are also FedEx and UPS air freight facilities at the airport, as well as private/charter aircraft service. During 2023, there were 411,562 enplanements at South Bend International Airport. 14. Jobs and Workforce Development Access to good employment affects housing choice. However, there can be disparities in access to good jobs. The City of South Bend has acknowledged these disparities and created the Office of Diversity and Inclusion to address the disparities in wealth resulting from the historic discrimination of certain protected classes. Stakeholders in the region have largely identified that racial and ethnic minorities and women are more likely to be disadvantaged financially, and therefore have limited housing choices. Organizations and programs that are in place to develop the County’s workforce, with an emphasis on diversity, include: The City of South Bend’s Office of Diversity and Inclusion has a Diversity and Inclusion Plan with 3-5 specific goals in the areas of internal workforce, external workforce, and the makeup of the community. The Office performed a disparity study to create accountability and enforce the City’s MWBE (minority/women-owned business enterprise) ordinance for the first time since it was enacted in 1983. The Office has been working to create Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 221 race- and gender-neutral measures to increase business development and support businesses at all levels from aspiration to scaling. Upskill SB provides funding for City residents to work toward a certificate in high-demand job fields. These include clean energy, cybersecurity, data management, and project management. The South Bend Technology Resource Center (TRC) was built in 2022 in Ignition Park to democratize technology in the Northern Indiana region. It is intended for residents to learn about technology and data, gain skills, and co-build an inclusive tech future for South Bend. The center is managed by the nonprofit enFocus and has regular seminars, workshops and events. The Indiana Small Business Development Center focuses on entrepreneurship. They serve small businesses and recruit small businesses. Small businesses may have trouble recruiting employees because they cannot fund the transportation and healthcare services that their employees often need. The Women’s Entrepreneurship Initiative is an accelerator that is designed to assist women entrepreneurs in growing their businesses. This organization, based at Saint Mary’s College and funded by the US Small Business Association, is designed to assist women in polishing a business plan and can gain access to high growth industries in the region. 15. Education Education is often an important factor influencing the opportunities for where people choose to live. There are six (6) school districts in or partially in St. Joseph County, as well as charter schools and private schools. The six (6) districts are: John Glenn School Corporation, New Prairie United School Corporation, Penn-Harris-Madison Schools, School City of Mishawaka, South Bend Community School Corporation, and Union-North United School Corporation. To ensure Indiana schools are performing, the State uses the Indiana Department of Education’s Graduates Prepared to Succeed (GPS) platform, which is an online platform that provides a building level academic score to all schools. Additionally, the Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 222 GPS Dashboard informs the public of the academic performance measures of each school and provides local teachers, administrators, and parents an opportunity to compare the performance of local schools. For the 2022-2023 and 2023-2024 school years, the Indiana Department of Education no longer issues letter grades to indicate school and district performance. Instead, it now issues school and district “report cards” with multiple Headline Indicators. There are seven Benchmarked Headline Indicators, of which five are currently published: Kindergarten Readiness: Percentage of students demonstrating the skills necessary to be considered ready to start kindergarten. Coming soon. PreK-Grade 2 Literacy: Percentage of PreK-Grade 2 students demonstrating progress in essential early reading skills from one year to the next. Coming soon. 3rd Grade Literacy: Percentage of grade 3 students showing proficiency on IREAD-3. Goal: 95% by 2027. 6th Grade Math Growth: Percentage of grade 6 students meeting their individual growth targets on the math ILEARN. Goal: 45.8% by 2030. Graduation Pathways Completion: Percentage of grade 12 students who complete graduation requirements. Goal: 95% by 2030. College & Career Credentials: Percentage of grade 12 students earning high quality college and career credentials. Goal: 60% by 2030. Employment & Enrollment: Percentage of grade 12 students employed or enrolled, within Indiana, one year after their expected graduation year. Goal TBD. The following data table is provided through the Indiana DOE GPS dashboard and shows the goal progress percentage of each student body. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 223 2023-2024 School Year Performance Grades St. Joseph County, IN 3rd Grade Literacy 6th Grade Math Growth Graduation Pathways Completion College & Career Credentials Employment & Enrollment John Glenn School Corp 94.3% 44.7% 100% No Data 88.2% New Prairie United School Corp 95.6% 46.9% 97.6% No Data 87.8% Penn-Harris-Madison School Corp 87.7% 34.0% 98.1% 11.3% 84.6% School City of Mishawaka 73.3% 34.4% 85.9% 5.2% 86.2% South Bend Community School Corp 58.0% 15.5% 84.8% 4.2% 82.3% Union-North United School Crop 88.0% 50.5% 91.9% No Data 79.8% Statewide Average 81.9% 35.1% 89.0% 5.5% 84.5% Source: Indiana Department of Education The Federal government tracks school demographics in Indiana through the Indiana Federal Report Card, which is also published by the Indiana Department of Education. Below are the enrollment numbers, racial makeup, and selected other characteristics of the student bodies of all public school districts in the County. John Glenn School Corp, Walkerton, IN 2,012 students 89.7% White, 5.7% Hispanic, 3.1% Multiracial, 1.1% Black 45.1% Economically Disadvantaged (Free/Reduced Lunch) 21.0% High Ability 16.0% Students with Disabilities New Prairie United School Corp, New Carlisle, IN 2,910 students 85.5% White, 9.3% Hispanic, 3.8% Multiracial, 1.0% Black 39.0% Economically Disadvantaged (Free/Reduced Lunch) 13.6% High Ability 16.4% Students with Disabilities Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 224 Penn-Harris-Madison School Corp, Mishawaka, IN 11,360 students 71.3% White, 8.1% Hispanic, 7.3% Black, 7.1% Multiracial, 5.7% Asian 29.2% Economically Disadvantaged (Free/Reduced Lunch) 26.0% High Ability 11.7% Students with Disabilities School City of Mishawaka, Mishawaka, IN 5,128 students 64.4% White, 13.9% Black, 11.2% Multiracial, 10.1% Hispanic 70.2% Economically Disadvantaged (Free/Reduced Lunch) 10.3% High Ability 18.7% Students with Disabilities South Bend Community School Corp, South Bend, IN 15,444 students 36.8% Black, 26.7% White, 24.8% Hispanic, 10.6% Multiracial 70.3% Economically Disadvantaged (Free/Reduced Lunch) 10.5% High Ability 18.9% Students with Disabilities Union-North United School Corp, Lakeville, IN 1,228 students 88.8% White, 6.4% Hispanic, 3.6% Multiracial 47.1% Economically Disadvantaged (Free/Reduced Lunch) 8.0% High Ability 16.8% Students with Disabilities The South Bend Community School Corp is the most diverse school district in the region, and it is the only Minority-Majority school district in St. Joseph County. The graduation rate in South Bend is lower than the graduation rate for the State of Indiana (84.8% versus 89.0%). Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 225 Higher Education St. Joseph County is home to several colleges and universities. The most well-known is the University of Notre Dame, a global leader in research, sports, and education. Other colleges include Holy Cross College and St. Mary’s College (which often function in concert with Notre Dame), Indiana University South Bend, Bethel College in Mishawaka, and Ivy Tech Community College in South Bend. 16. Section 3 HUD’s definition of Section 3 is: Section 3 is a provision of the Housing and Urban Development Act of 1968. The purpose of Section 3 to ensure that employment and other economic opportunities generated by certain HUD financial assistance shall, to the greatest extent feasible, and consistent with existing Federal, State and local laws and regulations, be directed to low- and very low income persons, particularly those who are recipients of government assistance for housing, and to business concerns which provide economic opportunities to low- and very low- income persons. The following are the guidelines that the City of South Bend’s Department of Community Investment uses to accomplish Section 3 compliance: Notifying the Housing Authority of South Bend and local job training centers of new employment, training, or contracting opportunities resulting from the expenditure of funding covered by Section 3. Entering the Section 3 Clause into all covered contracts funded with CDBG and HOME funds. Assisting and actively cooperating with HUD in ensuring contractors and subcontractors comply with Section 3. Refraining from entering into contracts with contractors that are in violation of Section 3 regulations. Documenting actions taken to comply with Section 3 and submitting Section 3 summary reports. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 226 During the preparation of this Analysis of Impediments study, no impediments or complaints were mentioned or filed based on the HUD Section 3 Requirements. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 227 C. Private Sector The private sector has traditionally been the greatest impediment to fair housing choice in regard to discrimination in the sale, rental, or advertising of dwellings, the provision of brokerage services, or in the availability of financing for real estate purchases. The Fair Housing Act and local laws prohibits such practices as the failure to give the same terms, privileges, or information; charging different fees; steering prospective buyers or renters toward a certain area or neighborhood; or using advertising that discourages prospective buyers or renters because of race, color, religion, sex, handicap, familial status, national origin, and sexual orientation. 1. Community Homebuyers Corporation The Community Homebuyers Corporation is a non-profit homeownership program in South Bend. The program is a loan pool that is operated by a consortium of seven bankers and credit unions in the region in conjunction with the City of South Bend’s Department of Community Investment. The Community Homebuyers Corporation has no minimum mortgage rate that they require to provide a homeownership loan. In recent years, given the competitive housing market, the Community Homebuyers Corporation has struggled to expend all of its available funds. This is due primarily to the lack of affordable housing as well as high interest rates (which increase costs). Loans disbursed by the Community Homebuyers Corporation traditionally have low delinquency rates and default rates. Participants are required to complete financial and budget counseling and homebuyer education with a HUD certified Housing Counseling Agency. 2. Newspaper/Magazine Advertising Under Federal Law, no advertisement with respect to the sale or rental of a dwelling unit may indicate any preference, limitation, or discrimination because of race, color, religion, sex, handicap, familial status, or national origin. Under the Fair Housing Act Amendments, descriptions are listed in regard to the use of words, photographs, symbols, or other approaches that are considered discriminatory. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 228 3. Private Financing The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (F.I.R.R.E.A.) requires any commercial institution that makes five (5) or more home mortgage loans per year, to report all home loan activity to the Federal Reserve Bank under the Home Mortgage Disclosure Act (HMDA). The annual HMDA data can be found online at www.ffiec.gov/hmda/ and is included in Part VII, Appendix C of this Analysis of Impediments. This analysis uses 2023 HMDA data in order to relate with the Five-Year Consolidated Plan. The available data indicates that there may be discriminatory lending patterns between minority and non-minority households. The following tables provide an analysis of the HMDA data in the South Bend & Mishawaka Metropolitan Statistical Area (MSA). Data for the City of South Bend & Mishawaka and St. Joseph County is highlighted where possible. This analysis uses 2023 HMDA data to identify any discriminatory lending patterns between minority and non-minority households. The following two (2) tables provide an analysis of the HMDA data in the St. Joseph & South Bend-Mishawaka Metropolitan Statistical Area (MSA). It should be noted that the HMDA data pertains to the entire South Bend- Mishawaka, IN-MI MSA, which includes both St. Joseph County, IN and Cass County, MI. While data for St. Joseph County is highlighted where possible, there are many differences between the County and the surrounding counties and municipalities that may provide some skewed outcomes. The following table compares lending in St. Joseph County to the South Bend-Mishawaka, IN-MI MSA. Lending in St. Joseph County has been extracted from the MSA data based on census tract. Conventional loans in St. Joseph County comprised 82.9% of the number of such loans in the MSA as a whole and 79.8% of the value of such loans. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 229 HMDA Data Analysis for 2023 Home Purchase Loans FHA, FSA / RHS & VA Conventional Refinancing Home Improvement Loans # $ x 1000 # $ x 1000 # $ x 1000 # $ x 1000 St. Joseph County 1,986 177,458 8,342 137,924 855 121,533 1,236 67,905 South Bend & Mishawaka MSA 2,388 201,556 9,909 157,713 1,025 241,312 1,528 68,842 % of MSA lending in St. Joseph County 83.17% 88.04% 84.19% 87.45% 83.41% 50.36% 80.89% 98.64% Source: https://www.ffiec.gov/hmda/ The following table shows the conventional loan applications in South Bend & Mishawaka MSA. 8,342 of the MSA’s 9,909 mortgage applications came from St. Joseph County, which is 84.19% of applications. Over one half (60.43%) of the loan applications in the County were originated, while nearly a fifth (19.61%) were denied. County applicants had about the same origination rate than the MSA as a whole, which had 60.32% of all loans originated, as well as 19.44% of denied applications. Disposition of Conventional Loans St. Joseph County Count % of St. Joseph County Applications % of Total MSA Applications Loans Originated 5,978 60.43% 60.32% Approved, Not Accepted 386 4.09% 3.90% Applications Denied 1,926 19.61% 19.44% Applications Withdrawn 910 8.87% 9.18% File Closed for Incompleteness 292 2.69% 2.95% Source: https://www.ffiec.gov/hmda/ The following table outlines the disposition of conventional loans in South Bend & Mishawaka MSA by income level. Loan applications from low- income households have the highest denial rates by a large margin, while above average income households have the lowest denial rates and highest origination rates. The percentage of loans originated and percentage of Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 230 applications denied are both correlated with income, whereas the higher the income level, the more likely the application will be approved and loan originated. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 231 Disposition of Conventional Loans by Income Level in the South Bend-Mishawaka, IN-MI MSA – 2023 Applications Received Loans Originated Applications Approved, Not Accepted Applications Denied Applications Withdrawn Applications Withdrawn or Closed for Incompleteness Income Level Count % of Total Count % of Total Income Level Count % of Total Income Level Count % of Total Income Level Count % of Total Income Level Count % of Total Income Level Less than 50% of MSA Median 2,250 4.4% 968 43.0% 75 3.3% 564 25.1% 228 10.1% 83 3.7% 50-79% of MSA Median 3,203 20.1% 1,689 52.7% 99 3.1% 493 15.4% 286 8.9% 95 3.0% 80-99% of MSA Median 1,387 21.3% 794 57.2% 50 3.6% 199 14.3% 115 8.3% 43 3.1% 100-119% of MSA Median 875 20.1% 632 72.2% 24 2.7% 131 15.0% 68 7.8% 20 2.3% 120% or More of MSA Median 2,806 34.1% 1,969 70.2% 190 6.8% 377 13.4% 282 10.0% 85 3.0% Total 12,297 100.0% 5,978 48.6% 386 3.1% 1,924 15.7% 910 7.4% 292 2.4% Source: https://www.ffiec.gov/hmda/ The following tables show the disposition of conventional loans where the race of the applicant was reported, disaggregated by minority status and income level for the South Bend & Mishawaka MSA. The number of applications for conventional loans submitted by White applicants outnumbers minority applicants in each income level analyzed. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 232 Conventional Loan Disposition Rates by Minority Status, Less than 50% of MSA Median Income Applications Received Applications Received % of Total Applications Loans Originated % of Received Applications by Minority Status Applications Approved but Not Accepted % of Received Applications by Minority Status Applications Denied % of Received Applications by Minority Status Applications Withdrawn % of Received Applications by Minority Status Applications Closed for Incompleteness % of Received Applications by Minority Status American Indian or Alaska Native 27 1.2% 12 44.4% 2 7.4% 3 11.1% 5 18.5% 5 18.5% Asian 24 1.1% 10 41.7% 2 8.3% 11 45.8% 1 4.2% 0 0.0% Black or African American 221 9.8% 86 38.9% 7 3.2% 86 38.9% 30 13.6% 12 5.4% Native Hawaiian or Other Pacific Islander 5 0.2% 2 40.0% 0 0.0% 2 40.0% 1 10.0% 0 0.0% White 1,641 72.9% 858 52.3% 64 3.9% 462 28.2% 191 11.6% 66 4.0% Hispanic or Latino 233 10.4% 120 51.5% 6 2.6% 72 30.0% 31 13.3% 4 1.7% Not Hispanic or Latino 1,700 75.6% 856 50.4% 67 3.9% 495 29.1% 206 12.1% 76 4.5% Total 2,250 100.0% 968 43.0% 75 3.3% 564 25.1% 228 10.1% 83 3.7% Source: https://www.ffiec.gov/hmda/ White applicants have the highest origination rate 50% below median income. In this income category, Black and Hispanic applicants have a higher denial rate than their application rate, as do American Indian or Alaska Native applicants. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 233 Conventional Loan Disposition Rates by Minority Status, 50-79% of MSA Median Income Applications Received Applications Received % of Total Applications Loans Originated % of Received Applications by Minority Status Applications Approved but Not Accepted % of Received Applications by Minority Status Applications Denied % of Received Applications by Minority Status Applications Withdrawn % of Received Applications by Minority Status Applications Closed for Incompleteness % of Received Applications by Minority Status American Indian or Alaska Native 24 1.2% 13 54.2% 0 0.0% 8 33.3% 0 0.0% 3 12.5% Asian 51 1.0% 28 54.9% 0 0.0% 9 17.6% 9 17.6% 5 9.8% Black or African American 295 10.1% 124 42.0% 7 2.4% 68 23.1% 34 11.5% 6 2.0% Native Hawaiian or Other Pacific Islander 7 0.2% 5 71.4% 0 0.0% 1 14.3% 2 28.6% 0 0.0% White 2,340 63.7% 1519 64.9% 92 3.9% 407 17.4% 241 10.3% 81 3.5% Hispanic or Latino 289 11.1% 173 59.9% 14 4.8% 57 19.7% 36 12.5% 9 3.1% Not Hispanic or Latino 2,440 66.3% 1,542 63.2% 102 4.2% 452 18.5% 250 10.2% 94 3.9% Total 3,203 100.0% 1,689 52.7% 99 3.1% 493 15.4% 286 8.9% 95 3.0% Source: https://www.ffiec.gov/hmda/ In this income category, Black, Asian, and Hispanic applicants have a higher denial rate than their application rate, as do American Indian or Alaska Native and Native Hawaiian or Other Pacific Islander applicants. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 234 Conventional Loan Disposition Rates by Minority Status, 80-99% of MSA Median Income Applications Received Applications Received % of Total Applications Loans Originated % of Received Applications by Minority Status Applications Approved but Not Accepted % of Received Applications by Minority Status Applications Denied % of Received Applications by Minority Status Applications Withdrawn % of Received Applications by Minority Status Applications Closed for Incompleteness % of Received Applications by Minority Status American Indian or Alaska Native 17 1.2% 8 47.1% 1 5.9% 6 35.3% 2 11.8% 0 0.0% Asian 31 2.2% 21 67.7% 1 3.2% 4 12.9% 2 6.5% 2 6.5% Black or African American 91 6.6% 64 50.8% 4 3.2% 32 25.4% 14 11.1% 10 7.9% Native Hawaiian or Other Pacific Islander 2 0.1% 0 0.0% 0 0.0% 2 100.0% 0 0.0% 0 0.0% White 1,028 74.1% 701 68.2% 44 4.3% 155 15.1% 97 9.4% 31 3.0% Hispanic or Latino 92 6.6% 60 65.2% 2 2.2% 20 21.7% 7 7.6% 3 3.3% Not Hispanic or Latino 1,079 77.8% 699 64.8% 55 5.1% 180 16.7% 113 10.5% 32 3.0% Total 1,387 100.0% 794 57.2% 50 3.6% 199 14.3% 115 8.3% 43 3.1% Source: https://www.ffiec.gov/hmda/ In this income category, Black, Asian, and Hispanic applicants have a higher denial rate than the overall population, as do Native Hawaiian or Other Pacific Islander applicants. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 235 Conventional Loan Disposition Rates by Minority Status, 100-119% of MSA Median Income Applications Received Applications Received % of Total Applications Loans Originated % of Received Applications by Minority Status Applications Approved but Not Accepted % of Received Applications by Minority Status Applications Denied % of Received Applications by Minority Status Applications Withdrawn % of Received Applications by Minority Status Applications Closed for Incompleteness % of Received Applications by Minority Status American Indian or Alaska Native 0 0.0% 0 0.0% 0 0.0% 0 0.0% 0 0.0% 0 0.0% Asian 12 1.4% 6 50.0% 2 16.7% 2 16.7% 1 8.3% 1 8.3% Black or African American 54 6.2% 29 53.7% 0 0.0% 14 25.9% 6 11.1% 5 9.3% Native Hawaiian or Other Pacific Islander 0 0.0% 0 0.0% 0 0.0% 0 0.0% 0 5.0% 0 0.0% White 809 92.5% 597 73.8% 22 2.7% 115 14.2% 61 7.5% 14 1.7% Hispanic or Latino 57 6.5% 35 61.4% 1 1.8% 16 28.1% 4 7.0% 1 1.8% Not Hispanic or Latino 829 94.7% 605 73.0% 26 3.1% 118 14.2% 64 7.7% 16 1.9% Total 875 100.0% 632 72.2% 24 2.7% 131 15.0% 68 7.8% 20 2.3% Source: https://www.ffiec.gov/hmda/ In this income category, Black and Hispanic applicants have a higher denial rate than the overall population, as do American Indian or Alaska Native and Native Hawaiian or Other Pacific Islander applicants. In the table below, the number of White, non-Hispanic upper-income applicants significantly outnumbers the number of minority applicants. Of the racial/ethnic groups with more than 20 applicants in this income category, Black or African American, Asian applicants and Hispanic applicants have a lower origination rate and a higher denial rate to white applicants. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 236 Conventional Loan Disposition Rates by Minority Status, 120% or More of MSA Median Income Applications Received Applications Received % of Total Applications Loans Originated % of Received Applications by Minority Status Applications Approved but Not Accepted % of Received Applications by Minority Status Applications Denied % of Received Applications by Minority Status Applications Withdrawn % of Received Applications by Minority Status Applications Closed for Incompleteness % of Received Applications by Minority Status American Indian or Alaska Native 15 0.5% 12 80.0% 0 0.0% 3 20.0% 0 0.0% 0 0.0% Asian 114 4.1% 71 62.3% 2 1.8% 17 14.9% 17 14.9% 7 6.1% Black or African American 142 5.1% 86 60.6% 4 2.8% 29 20.4% 16 11.3% 7 4.9% Native Hawaiian or Other Pacific Islander 4 0.1% 1 25.0% 0 0.0% 2 50.0% 0 0.0% 1 25.0% White 2,531 90.2% 1,799 71.1% 87 3.4% 326 12.9% 249 9.8% 70 2.8% Hispanic or Latino 120 4.3% 69 57.5% 5 4.2% 27 22.5% 12 10.0% 7 5.8% Not Hispanic or Latino 2,693 96.0% 1,894 70.3% 92 3.4% 343 12.7% 286 10.6% 78 2.9% Total 2,806 100.0% 1,969 70.2% 190 6.8% 377 13.4% 282 10.0% 85 3.0% Source: https://www.ffiec.gov/hmda/ Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 237 In the table below, the largest share of loan denials overall was cited as credit history, 602 denials or 31.1% followed by debt-to-income ratio, 513 denials or 26.7%. These reasons were the most common across all income levels. Conventional Loan Denial Rates by Denial Reason and Income Level Less than 50% Low 50-79% Middle 80-99% Upper- Middle 100-119% Upper 120% or More High Total Denials Count % of Income Level Count % of Income Level Count % of Income Level Count % of Income Level Count % of Income Level Count % of Total Debt- to-Income Ratio 30 23.44% 78 20.05% 77 19.85% 72 22.02% 256 36.99% 513 26.7% Employment History 2 1.56% 3 0.77% 12 3.09% 3 0.92% 4 0.58% 24 1.2% Credit History 50 39.06% 138 35.48% 124 31.96% 113 34.56% 177 25.58% 602 31.3% Collateral 16 12.50% 64 16.45% 66 17.01% 57 17.43% 76 10.98% 279 14.5% Insufficient Cash 1 0.78% 4 1.03% 2 0.52% 2 0.01% 6 0.87% 15 .8% Unverifiable Information 19 14.84% 43 10.05% 32 8.25% 34 10.40% 81 11.71% 209 10.9% Credit Application Incomplete 5 3.91% 34 8.84% 39 10.05% 33 10.09% 59 8.53% 170 8.8% Mortgage Insurance Denied 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.00% 0 0.0% Other 5 3.91% 25 6.43% 36 9.28% 13 3.98% 33 4.77% 112 5.8% Total Denials and % of Total 128 6.65% 389 20.22% 388 20.17% 327 17.00% 692 35.97% 1,924 100.00% Source: https://www.ffiec.gov/hmda/ Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 238 In summary, the HMDA data shows that nearly half (48.6%) of loan applications in the South Bend & Mishawaka MSA were originated, and slightly less than one-sixth (15.7%) were denied. In the South Bend & Mishawaka MSA, the number of White applicants exceeds the number of minority applicants. Additionally, the origination rates are higher and denial rates lower for White applicants than for Black or African American applicants in every income category. As incomes decrease, denial rates increase, often due to these applicants being first-time homebuyers with little to no collateral, poor credit history, and debt. While denial rates decrease as income increases, minorities still have higher denial rates even within the same income groups. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 239 D. Citizen Participation The South Bend Department of Community Investment and the Mishawaka Department of Community Development undertook a broad participation strategy for this Analysis of Impediments to Fair Housing Choice to engage as many individuals, organizations, and agencies as possible. Stakeholders: The City of South Bend and the City of Mishawaka developed a list of stakeholders with direct knowledge of, and experience in, the housing market and issues affecting fair housing. Identified stakeholders were divided into the following categories: Planning and Zoning Agencies Continuum of Care Education Organizations Housing Authorities Faith Based Organizations Social Services Agencies and Organizations Economic Development Agencies and Organizations Fair Housing Organizations Banks, Credit Unions, and Lenders Housing Developers Public Safety Agencies Neighborhood Organizations Transportation Agencies Healthcare Providers Advocacy Groups Housing Agencies Elected Leaders Agency/Organization/Stakeholder Meetings: The City of South Bend and the City of Mishawaka contacted all identified organizations and agencies to set up smaller meetings consisting of similar organizations to hold more in-depth conversations. These meetings were held via teleconference. Planning Organizations – August 12, 2024 Housing Authorities – August 13, 2024 Continuum of Care – August 13, 2024 Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 240 Faith-Based Organizations – August 14, 2024 Social Services – August 14, 2024 & August 15, 2024 Workforce and Economic Development Agencies – August 15, 2024 & August 21, 2024 Fair Housing Organizations – August 15, 2024 Banks/Mortgage Companies – August 16, 2024 Neighborhood Organizations – August 19, 2024 & August 20, 2024 Housing Providers – August 19, 2024 Public Transit – August 20, 2024 Health Services – August 21, 2024 Advocacy Organizations – August 22, 2024 Any identified stakeholders that were not available to attend the meeting, as well as some of the aforementioned stakeholders, were then called to either (1) follow-up if they partook in either of the Community Meetings or (2) discuss fair housing issues with agencies/individuals who were unable to attend one of the Public Meetings. Public Meetings: The City of South Bend and the City of Mishawaka also held two (2) Public Meetings to engage the public and local organizations/agencies and help identify issues impacting Fair Housing Choice. The First Public Meeting was held on Wednesday, August 7, 2024 at the South Bend Tech Resource Center and the Second Public Meeting was held on Thursday, August 8, 2024 at the Mishawaka City Hall. There were no other resident attendees at the meeting held in the City of South Bend and two (2) resident attendees at the meeting held in the City of Mishawaka. Additionally, the twenty-one (21) scheduled meetings with various government staff, social service organizations, housing agencies, realtors, and banks were well-attended. Public Meetings were advertised in the “South Bend Tribune,” the largest English-language newspaper in circulation in the area, and “El Puente” (Spanish) newspapers. The City of South Bend and the City of Mishawaka emailed Public Meeting and Stakeholder Meeting invitations to: o Advocacy Agencies o Banking Institutions o Workforce and Economic Development Organizations o Fair Housing Agencies o Housing Agencies o Housing Authorities Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 241 o Planning Agencies o Social Service Agencies o Educational Institutions o Transportation Agencies Additional Outreach: The City of South Bend and the City of Mishawaka also employed the following to encourage extensive engagement and participation: Invitations to the stakeholder meetings were sent out by the Cities prior to the meetings (August 12th through August 22nd). The City of South Bend and the City of Mishawaka also sent Agency Surveys for any representatives who could not attend over video call. The Cities received three (3) surveys from organizations who were unable to attend the public hearings or individual group meetings. The City of South Bend and the City of Mishawaka conducted follow-up meetings via Zoom with three (3) additional organizations who were unable to attend the public hearings or individuals group meetings. Outreach to Persons with Disabilities: The City of South Bend and the City of Mishawaka conducted stakeholder interviews using the Zoom teleconference software allowing individuals who could not attend in person to contribute. Resident Surveys: The survey was available online in both English and Spanish and physical copies were placed on public display to encourage resident input. Links to the survey were also posted on the Cities’ websites and sent to stakeholder agencies. The online survey produced 195 responses. Actions to spread knowledge of the surveys included posting the survey on sending the survey to neighborhood organizations and associations for distribution, and emailing the link to interested parties. The information provided in these anonymous surveys were crucial in developing an accurate assessment of fair housing issues in the County and Cities. The following is a summary of the 195 responses received: Notable Characteristics Some of the notable characteristics of respondents included (as a percentage of those that answered each question): Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 242 The majority of respondents are female at 73.44%. The majority (61.90%) of respondents are White. Approximately 32.99% of responders were over the age of 60. The next largest age demographic was 40-49 year olds with 25.26% of all respondents. 30.37% came from two person households. 60.42% were homeowners. 37.20% of respondents did not know how to report fair housing violations The following is a list of needs/issues associated with different areas of community and economic development. Values were calculated as a percentage of those that answered each question. Accessibility: 17.02% of respondents believe that there are is a need for curb and sidewalk improvements in the County. Employment: Only 66.6% of respondents indicated that there are employment issues in the County. Of the respondents, 63.85% believed a lack of transportation hinders employment opportunities. 50.77% believed there was a lack of childcare for workers. Housing: 89.2% said that there are housing issues within St. Joseph County, and 76.44% of those respondents think affordability is the biggest issue. 51.15% do not believe there is enough housing options or inventory for residents. 50.00% of residents believe there is a need for major rehabilitation of housing units across the County 17.82% of respondents believe there is a need for more accessible housing. Other housing issues, needs, and programs include vacant housing, low- quality housing, absent landlords, and lead-based paint. Fair Housing: Only 43.29% of respondents know how to report fair housing violations in Saint Joseph County. 19.51% were unsure. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 243 Reasons Fair Housing Complaints Are Not Reported: 64.43% specifically mention fear of retaliation, including eviction, legal reprisal, and poor retreatment. 69.13% point to a lack of knowledge in reporting practices as a cause. 51.68% reported that persons may distrust the process. Transportation: 66.6% of respondents stated that there are problems or issues with public transportation in St. Joseph County. 57.69% believe there are not enough service hours for transportation services. 43.85% believe public transit is currently unreliable. Other: 61.33% of respondents believe that there is a need to demolish and clear vacant dilapidated structures. Many respondents believed that social services for homeless and childcare are needed in their communities. The following table illustrates the types of situations that may result in further discriminations and/or barriers to fair housing in St. Joseph County: Resident Survey Results Yes No Unsure State or Local Laws and policies that limit Housing Choices 51.30% 16.23% 32.47% Lack of Fair Housing organizations in the City 39.47% 27.63% 32.89% Lack of Knowledge among bankers/lenders regarding fair housing 47.37% 17.76% 34.87% Lack of knowledge among landlords and property managers regarding fair housing 57.24% 14.47% 28.29% Lack of knowledge among real estate agents regarding fair housing 46.31% 22.15% 31.54% Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 244 Lack of knowledge among residents regarding fair housing 66.01% 11.11% 22.88% Lack of accessible housing for persons with disabilities 56.95% 11.92% 31.13% Lack of accessibility in neighborhoods 57.05% 16.11% 26.85% Lack of fair housing education 62.50% 13.16% 24.34% Lack of affordable housing in certain areas 79.35% 7.10% 13.55% Concentration of subsidized housing in certain neighborhoods 63.33% 10.67% 26.00% Source: Citizen Survey Additional Comments or Concerns: Typical responses included: “Rent and housing prices are too high.” “Mental health services for the poor and houseless are unavailable.” “People with criminal records have a difficult time finding housing. What housing is available is often substandard.” Public Meeting on the Draft AI Public Comments The 2025-2029 Analysis of Impediments to Fair Housing Choice was made available on the City of South Bend’s website at https://southbendin.gov/department/community-investment/neighborhood- development/, the City of Mishawaka’s website at http://mishawaka.in.gov/communitydevelopment, and a hardcopy was placed at the following locations beginning on November 27, 2024: The St. Joseph County Public Library (all branches) Mishawaka Public Library (all branches) Walkerton Public Library New Carlisle-Olive Township Public Library City of South Bend Department of Community Investment City of South Bend Office of the Clerk City of Mishawaka Department of Community Development Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 245 The document was on public display for a period of thirty (30) days. Residents were encouraged to submit written or oral feedback on the Analysis of Impediments. Based on the citizen participation process and fair housing analysis, the City of South Bend, the City of Mishawaka, and St. Joseph County staff identified the following fair housing issues: Housing Opportunities: There is a lack of affordable housing in St. Joseph County that is decent, safe, and sanitary. There is a lack of Federal and State funds for housing subsidies and the development of new affordable housing is not economically feasible for private developers. There is a lack of affordable rental units within the County. Rent has increased to the point where 46.0% of all rental households in the County are cost burdened. There is a lack of affordable housing units in areas of opportunity where low-income persons and households may move. There is a lack of financing to support the purchase of affordable starter homes. There is enough vacant land for infill housing, but a lack of financial incentives to develop affordable housing on the vacant land. Housing Choice: Housing units that are deteriorated and below code standards tend to be available at affordable rents. The special needs population in St. Joseph County, particularly in the City of South Bend, has grown. It is necessary to rehabilitate and construct housing units which are accessible to this growing population. There is a need to demolish vacant housing units which are a blighting influence on neighborhoods and prevent new housing developments. There are physical, economic, and social justice barriers that impede the development of new affordable and accessible housing in St. Joseph County. There is a lack of "mixed-income" housing being built in the County. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing 246 Cost burden: Approximately 14.2% of homeowners and 42.2% of renters in the County are cost burdened of 30% or more. Seniors, on fixed income, cannot afford to make the repairs, alterations, and accommodations to their homes to make them accessible to their needs. Disability/Accessibility: There is a lack of housing in the County that is accessible and affordable for the elderly, the disabled, and persons with special needs. The denial by landlords to make reasonable modifications and accommodations limits the amount of accessible units in the County that are for rent for persons with special needs. Fair Housing: Tenants and homebuyers do not always file housing discrimination complaints when renting or buying a home. Persons with Limited English Proficiency (LEP) do not always have a fair housing choice. There is a lack of cooperation on the part of landlords to address accessibility issues. There is a lack of awareness of tenants' rights, including what reasonable modifications and accommodations are. Access/Mobility: The lack of public transportation in the County is not convenient for work, health care, shopping, etc., which limits the choices where a low-income household can live. A lack of sidewalks in neighborhoods limits walkability for disabled and elderly residents of the County. Families and individuals have a right to live wherever they chose if affordable housing is available outside areas of concentration. The St. Joseph County Housing Consortium held two Public Hearings on the “draft” 2025-2029 Analysis of Impediments on, December 11, 2024 and December 12, 2024 in the Cities of South Bend and Mishawaka. There were no public comments. Impediments to Fair Housing 2025 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 247 V. Actions and Recommendations The following impediments to fair housing choice and recommendations are presented to assist the Cities of South Bend and Mishawaka, and St. Joseph County to affirmatively further fair housing in the Region. The previously identified impediments to fair housing choice were discussed in Section III and progress was reported for each impediment. New and carried-over impediments to Fair Housing Choice are presented on the pages that follow. Of the previously identified impediments, the lack of affordable housing for sale and for rent, the lack of accessible housing, and economic barriers are still present in St. Joseph County, despite the Cities’ and County’s best efforts. Based on national trends, these will continue to be addressed by the City of South Bend, the City of Mishawaka, and St. Joseph County. Below is a list of impediments that were developed by the City of South Bend, the City of Mishawaka, and St. Joseph County for the shared 2025 Analysis of Impediments to Fair Housing Choice. A. Impediments to Fair Housing Choice The City of South Bend, the City of Mishawaka, and St. Joseph County have identified the following impediments for the 2025 Analysis of Impediments to Fair Housing Choice and have defined specific goals and strategies to address each impediment. Impediment 1: Lack of Affordable Housing for Sale The median value and cost to purchase a single-family home in St. Joseph County that is decent, safe, and sound has increased significantly to over $165,700. For the City of South Bend it is over $113,800, and for the City of Mishawaka it is $128,200. This limits the choice of housing for lower-income households throughout the County and in both Cities. Goal: Development of for-sale, single-family homes for lower-income households will occur through new construction, infill housing, and the rehabilitation of vacant structures throughout St. Joseph County and the Cities of South Bend and Mishawaka. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 248 Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka: 1-A: Support and encourage plans from both private developers and nonprofit housing providers to develop and construct new affordable housing that is for sale for lower-income households throughout the Cities and County. 1-B: Support homebuyer education and training programs to improve homebuyer awareness and increase the opportunities for lower-income households to become homebuyers by affirmatively furthering fair housing choice. 1-C: Provide funds for down payment and closing cost assistance to lower-income households. 1-D: Promote housing counseling programs for first-time homebuyers. Impediment 2: Affordable Rental Housing The current supply of rental housing is not necessarily affordable to lower-income households. The monthly housing cost for apartments has steadily increased to the point that 46.0% of all rental households in St. Joseph County, 49.0% of all rental households in South Bend, and 44.5% of all rental households in Mishawaka are considered cost burdened by 30% or more. Goal: The development of affordable rental housing will occur throughout the County and both Cities, especially for households whose income is less than 60% AMI, through new construction, the rehabilitation of vacant buildings, and the development of mixed- income housing, to reduce the number of lower-income households who are cost burdened. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  2-A: Support and encourage both private developers and nonprofit housing providers to develop plans for the construction of new affordable and mixed-income rental housing. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 249  2-B: Support and encourage the rehabilitation of the existing housing stock and new housing which will be decent, safe, sound and affordable rental housing to lower-income households.  2-C: Support and encourage the development of independent housing and community living arrangements for the disabled in the County and both Cities.  2-D: Provide financial assistance in the form of development subsidies, so low-income households that are cost burdened, particularly households whose incomes are at or below 60% of AMI, are able to afford decent, safe, and sound housing.  2-E: Promote partnerships with the local housing authorities and private and nonprofit housing developers to construct additional Low Income Housing Tax Credit (LIHTC) multi-family rental housing in high opportunity areas of the County and Cities. Impediment 3: Continuing Need for Accessible Housing Units As an older built-up environment, there is a lack of accessible housing units in St. Joseph County and the Cities of South Bend and Mishawaka. Since 41.5% of the County’s housing units, 60.6% of South Bend’s housing units, and 31.3% of Mishawaka’s housing units were built prior to 1960, these units were not constructed with accessibility features. It is estimated that 13.4% of the County’s overall population, 14.4% of South Bend’s population, and 16.4% of Mishawaka’s population is classified as disabled. Goal: Increase the number of accessible units for the physically disabled and developmentally delayed through new construction and rehabilitation of existing housing. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  3-A: Promote programs to increase the amount of accessible housing through rehabilitation of existing housing stock for homeowners and renters. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 250  3-B: Encourage the development of new construction of accessible and visitable housing through financial or developmental incentives.  3-C: Continue to enforce ADA and Fair Housing requirements for landlords to make “reasonable accommodations” for tenants who are disabled.  3-D: Continue to promote programs and provide funds to assist elderly homeowners with accessibility improvements to their properties so they may remain in their own homes. Impediment 4: Fair Housing Education and Outreach There is a continuing need to educate persons about their rights under the Fair Housing Act and to raise community awareness to affirmatively further fair housing. Goal: All residents of St. Joseph County and the Cities of South Bend and Mishawaka will have an increased awareness and knowledge of their rights under the Fair Housing Act and the County and Cities will continue to affirmatively further fair housing, especially for low-income residents, minorities, and the disabled population. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  4-A: Continue to promote fair housing awareness through the media, seminars, and training, to provide educational opportunities for all persons to learn more about their rights under the Fair Housing Act, Americans with Disabilities Act, and visitability.  4-B: Continue to provide and distribute literature and informational material in English and Spanish concerning fair housing issues, an individual’s housing rights, and the landlords’ responsibilities to affirmatively further fair housing, including laws regarding reasonable modifications and accommodations.  4-C: Continue to support and provide funding for the South Bend Human Rights Commission to provide testing services, education, outreach, referrals, and assistance in addressing fair housing complaints that may arise in the County and Cities. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 251  4-D: Continue to work with the local Board of Realtors to educate and promote fair housing.  4-E: Strive for better intergovernmental cooperation between state and local partners, as well as community groups, to effectively identify and address potential barriers to affordable housing choice. Impediment 5: Private Lending Practices The HMDA data for St. Joseph County indicates that there may be a disparity between the approval rates of home mortgage loans originated from minorities and those originated from non-minority applicants. Goal: Approval rates for all originated home mortgage loans will be fair, unbiased and equal, regardless of race, familial status, and location. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  5-A: The Cities and County should consider using Federal and State funding to provide housing or credit counseling to potential low- and moderate-income homebuyers in impacted neighborhoods to decrease the number of denials due to poor credit, debt-to-income ratios, or incomplete applications.  5-B: The Cities and County should consider entering into an agreement with Indiana Legal Services, Inc. to perform research to determine if any patterns of discrimination are present in home mortgage lending practices for minorities and other protected classes when they wish to purchase properties located in impacted areas of the Cities or County.  5-C: The Housing Consortium should consider using Federal and State funding to provide a higher rate of public financial assistance to potential homebuyers in impacted neighborhoods to improve the loan-to-value ratio, so that private lenders will increase the number of loans made in these areas. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 252 Impediment 6: Impacted Areas of Concentration There are specific areas throughout the two Cities and the County where the concentration of low-income persons exceeds 70% of the area’s population, and areas with concentrations of minority persons. Goal: Promote the de-concentration of low-income and minority areas that may exist within the Cities of South Bend and Mishawaka to reduce concentrations of low-income households and minorities, while preserving fair housing choice for both low-income and minority residents. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  6-A: Support, promote, and plan for affordable housing developments outside areas of low-income concentration, while still supporting the improvement of housing within concentrated areas.  6-B: Market and promote housing opportunities for both minority and low-income residents outside areas of low-income concentration.  6-C: Provide financial assistance to low-income households to provide them with a choice to reside outside areas of low-income concentration. Impediment 7: Economic Issues Affecting Housing Choice There is a lack of economic opportunities in the County and both Cities which prevents low-income households from improving their income and providing an opportunity to live outside areas of low-income concentration. Goal: The local economy will provide new job opportunities, which will increase household income, and thus promote fair housing choice and mobility. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 253 Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  7-A: Strengthen partnerships that enhance local businesses, expand the tax base, and create a more sustainable economy for residents and businesses.  7-B: Support and enhance workforce development and skills training that results in increased job opportunities and a living wage.  7-C: Continue to support programming that enhances entrepreneurship and small business development, expansion, and retention within low- and moderate-income and minority neighborhoods.  7-D: Continue to promote and encourage economic development with local commercial and industrial firms to expand their operations and increase employment opportunities. Impediment 8: Public Policies That May Affect Housing Choice Public policies such as community comprehensive plans and zoning ordinances sometimes affect the location of affordable housing, special needs housing, and the development process of these types of housing. Goal: The local governing bodies will review their public policies, plans, and ordinances to affirmatively further fair housing and eliminate any barriers or obstacles to fair housing choice. Strategies: To meet this goal, the following activities and strategies may be undertaken by St. Joseph County and the Cities of South Bend and Mishawaka:  8-A: The Cities and County should consider making source of income a protected class, which would prevent landlords from rejecting tenants based on their source of income, i.e. Housing Choice Vouchers.  8-B: The Cities should consider offering vacant lots that they have acquired to private developers at no cost to promote the development of single-family affordable housing, along with 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 254 providing development subsidies and reducing development standards.  8-C: The local zoning ordinances were reviewed and should be brought into compliance with the Fair Housing Act, especially the definition of “Family” and in particular protective classes and being permitted uses in all residential zoning districts.  8-D: The municipalities will annually review their zoning and development ordinances to make sure they are in compliance with the Fair Housing Act and the Americans with Disabilities Act. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 255 B. Activities and Recommendations to Affirmatively Further Fair Housing To affirmatively further fair housing, the following actions have, and will be, implemented by the City of South Bend, the City of Mishawaka, and St. Joseph County through their Fair Housing Plan through various activities noted below: 1. The South Bend Human Rights Commission serves all of St. Joseph County in addressing Fair Housing Complaints. All municipalities within St. Joseph County will continue to support the expansion of the capabilities of the Human Rights Commission. 2. South Bend’s Human Rights Commission will continue to enforce fair housing through public education and outreach. This will include providing updated housing discrimination to organizations, testing and auditing fair housing providers, and teaching providers and residents to report housing discrimination. 3. The communities will partner with nonprofit service providers to promote fair housing and provide assistance to low- and moderate- income homeowners and renters. 4. The City will continue to provide funds to report housing discrimination complaints. 5. The Human Rights Commission will continue to educate and attempt to overcome any remaining “Not in My Back Yard” attitudes in the County through its fair housing providers. 6. The Cities will continue to make every attempt to increase geographic choice in housing by providing links on their websites for low-income households to use. 7. The Cities will utilize vacant land to construct affordable housing. 8. The Human Rights Commission will continue to promote integration of public housing. 9. The Housing Authorities will promote Section 8 Voucher landlords to rent to residents outside racially and ethnically concentrated areas of poverty. 10. The City of South Bend will continue to partner with neighborhood organizations to improve the quality of the affordable housing stock in the area for renters and homeowners. 11. The Cities will work to ensure available housing units are accessible through rehabilitation of existing units for homeowners and renters. 2025 Analysis of Impediments to Fair Housing Actions and Recommendations 256 12. The communities will continue to promote economic development programs to assist in providing quality jobs to residents that will enable them to access more housing options. 13. On an annual basis, the Cities of South Bend and Mishawaka and St. Joseph County will continue to declare April to be Fair Housing Month via proclamation, in conjunction with holding an annual fair housing workshop with partners. 14. The Human Rights Commission will continue to work with the Indiana Civil Rights Commission. 257 2025 Analysis of Impediments to Fair Housing CertificatioŶ 2025 Analysis of Impediments to Fair Housing Appendix 258 VII. Appendix A.Appendix A See the City of South Bend’s FY 2025 – FY 2029 Five-Year Consolidated Plan and appendices for demographic data and sources relied upon in the preparation of the FY 2025 Analysis of Impediments to Fair Housing Choice (AI). B.Appendix B See the City of South Bend’s FY 2025 – FY 2029 Five-Year Consolidated Plan and appendices for citizen participation documentation including notices; summaries of stakeholder interviews, meetings, and hearings; resident survey responses; stakeholder questionnaire responses; and, public comments.