Peter Lohmann's Newsletter - Issue #193

HUD Narrows the Definition of "Assistance Animal"

Last Friday, The New York Times reported that HUD issued an internal memo instructing its Fair Housing office to exclude emotional support animals (ESAs) from recognized disability accommodations, effective immediately. The memo also directs staff to apply a stricter definition of "service animal" when reviewing accommodation requests.

According to the Times, the memo frames ESAs as a loophole, asserting that "an entire industry has emerged to convert pets into emotional support animals." If the policy holds, it could affect how we handle accommodation requests nationwide.

Some background on recent ESA guidance changes:

• Back in 2013, HUD's original guidance recognized ESAs as assistance animals.

• In January 2020, under Ben Carson, HUD issued an updated notice - the version most operators have been working under for the past six years, which kept ESAs protected while giving landlords clearer documentation standards.

• Then, in September 2025, HUD quietly withdrew both notices.

Online ESA mills routinely sell letters for $149–$199 with minimal-to-no clinical evaluation, and the number of registered ESAs doubled between 2015 and 2019. NAA and NMHC have been asking HUD to address ESA fraud for years.

What we know, and what we don't

As of this newsletter, no official public guidance has been released. Again, the memo is internal (for now). Jon Bradford from PetScreening (whose company touches roughly 1 in 7 rental units nationwide) put out a video over the holiday weekend confirming his team is working directly with HUD and fair housing experts to verify what this actually means in practice.

Disability rights advocates have already raised objections, and groups like DREDF are mobilizing with tenant organizers already preparing to support appeals and potential lawsuits.

All that said, the Fair Housing Act itself is untouched. This memo only changes how HUD will handle complaints going forward. State attorneys general, state human rights commissions, and private plaintiffs can all still bring claims.

My read (just speculation at this point)

If this memo holds up, it could be a meaningful shift for property managers who've been navigating the many complexities of ESA compliance for years. The fraud problem is real, and a tighter federal standard would reduce some of the harder judgment calls operators face every week.

But there's a lot of "if" in that sentence. The memo could get reversed in court. It could get watered down in the official guidance HUD eventually releases. It could create new exposure under state laws that haven't moved an inch. We're probably 6–12 months from knowing what this actually means for day-to-day PM policy.

For now, I'm not changing anything at my company.

-Peter

Keyrenter is a Highly Selective Franchise: Here’s Why

Fun fact: Keyrenter could be 2-3x its current size if they approved everyone who wanted to be a franchisee. They don't. CEO Nate Tew has 94 locations with ~14,000 doors under management, and he's deliberately keeping growth slower than the market would allow.

In this episode, we get into why most PM companies stall at ~100 doors (and what the operators who blow past it do differently), Nate's Model 300 framework, and a contrarian take I mostly agree with: most 'bad owner' stories are a YOU problem.

Also available on Apple Podcasts and Spotify

Property Management Companies For Sale This Week

• 22-home property management portfolio in Florida (asking $5.3M, includes established rental operations and recurring income)

• Established HOA/condo management firm in Hillsborough County, FL (asking $565k)

• 40-year HOA management company in Los Angeles, CA (asking $444k, ~$222k annual revenue)

• Absentee-run PM company in San Jose, CA (asking $120k, 12 properties under management)

Sponsored by AppFolio. Simply meeting resident expectations isn’t enough. New research from AppFolio shows that operators must evolve their strategies to prioritize occupancy and diversify revenue streams. Learn more in the 2026 Renter Preferences Report.

Industry News & Events

• The PM Trends 2026 Report is OUT NOW. Get your copy here [no email gate].

• Tenant Turner just announced a two-way sync with Rentvine.

• New Hampshire lawmakers have proposed a really weird new security deposit law that isn’t what you think.

• NARPM Southern States Conference is offering $100 off with coupon PETER through 5/31. I’ve heard great things about this show. Check it out.

• Professional tenant (scammer) arrested and charged in Palm Beach, FL. “Investigators say Grantlin moved from one high-end Wellington property to another, allegedly repeating the same scheme nearly 30 times over the past two decades. Court records [show] 26 eviction cases dating back to 2005.”

• The brand-new NARPM Trust Chart of Accounts has just been released, and we’re going deep with a 45-minute live webinar next week in collaboration with ProfitCoach. Register here for the event + recording.

Closing Thought

A few quick things before you go…

• Last week’s issue went to 21,358 readers (50.2% opened, 3.8% clicked)

• The most popular link was the Inside the Owner's Mind: Key Findings from the 2026 PM Trends Report webinar (163 clicks)

• Property managers: Your professional trade association is NARPM. You need to join if you’re not already a member.

• Did someone forward you this email? Subscribe here.

Software I’m using to scale my 700+ door property management company:

Note: These are affiliate links, but I’ve been recommending all these companies long before any financial arrangements came into place.

The content of this newsletter is for informational purposes only and does not constitute professional advice. I may have consulting agreements with, or financial interests in, companies mentioned in this newsletter. Additionally, some of the links included in this newsletter are affiliate links, meaning I may earn a commission if you make a purchase through these links. Always perform your own due diligence before making any financial or business decisions.