U S. DEPARTMENT OF HOUSING

AND URBAN DEVELOPMENT
DISCRIMINATION


IN METROPOLITAN HOUSING MARKETS 

Phase 3 

Prepared for: 

Office of Policy Development and Research 

U.S. Department of Housing and Urban Development

Prepared by: 

Margery Austin Turner 

Stephen L. Ross 

With: 

Julie Adams 

Beata Bednarz 

Carla Herbig 

Seon Joo Lee 

Kimberlee Ross 

The Urban Institute 

Washington, DC 

September 2003 
ACKNOWLEDGEMENTS 

The analysis and results presented in this report could not have been produced 

without the commitment and hard work of the field implementation team, including 

testers, testing coordinators, and local testing organizations. In particular, the authors 

extend our admiration and thanks to Carla Herbig, the field implementation director, and 

Kimberlee Ross and Rani Bush, who supervised the work of local testing organizations. 

We also thank Julie Adams, David D’Orio, Fred Freiberg, Laura Gorman, Seon Joo Lee, 

Shawnise Thompson, and Diane Hendricks, all of whom made major contributions to this 

research effort. 

In addition, Todd Richardson, of the Department of Housing and Urban 

Development’s Office of Policy Development and Research, provided guidance and 

oversight throughout the project’s design and implementation. 

Despite the generous contributions from these individuals and organizations, any 

errors and omissions that may remain in this report are, of course, our own. 

The contents of this report are the views of the contractor and do not necessarily reflect the views 

or policies of the U.S. Department of Housing and Urban Development or the U.S. Government. 
FOREWORD 

Ending illegal housing discrimination is one of the highest priorities I have as Secretary of 

Housing and Urban Development. That is why I am pleased to release the third in a series of reports 

on the level of housing discrimination in the United States: Discrimination in Metropolitan Housing 

Markets: Phase 3 – Native Americans. This multi-stage study was designed to determine the extent of 

housing discrimination based on race or color that Americans may face today. By any measure, it is 

the most ambitious analysis of housing discrimination ever produced. The first two phases of this 

study reported on the level of discrimination faced by African Americans, Hispanics, and Asians and 

Pacific Islanders. 

This report, the result of comprehensive testing and sophisticated analysis, provides estimate of 

discrimination encountered by Native Americans searching for housing to rent in Montana and 

Minnesota, and rent or purchase in New Mexico. The results are based on a sample of 397 paired tests 

conducted in 2002 in the eight metropolitan areas of the three states. 

The research found that the level of discrimination faced by Native Americans in the rental 

markets of the three states is greater than the national levels of housing discrimination experienced by 

African American, Hispanic, and Asian and Pacific Islander renters. Discrimination is most 

observable on measures of availability. That is, white testers were significantly more often told an 

advertised unit was available, told about similar units, and told about more units than similarly 

qualified Native American testers inquiring about the same advertised unit. 

As the Department works to eliminate housing discrimination, this report offers invaluable 

assistance by documenting where and how discriminatory practices take place. HUD continues to 

expand efforts to learn more about discrimination, and will continue this report series with one more 

report: discrimination against persons with disabilities. 

The findings will enable HUD to devote more attention, including enforcement that penalizes 

illegal discrimination, to communities with significant Native American populations. Housing 

discrimination isn’t just unfair, it’s against the law. 

 Mel Martinez

 Secretary 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY i 

Background on HDS2000 i 

The HDS2000 Methodology ii 

Summary of Findings iii 

Measurement Issues iv 

Strengths and Limitations of This Research vi 

1. BACKGROUND AND INTRODUCTION 1-1 

Paired Testing Methodology 1-1 

HDS2000 Study Scope 1-2 

Organization of the Report 1-3 

2. PHASE III DESIGN AND METHODOLOGY 2-1 

Sampling 2-1 

Field Implementation and Paired Testing Protocols 2-9 

Using Paired Tests to Measure Discrimination 2-13 

3. STATE ESTIMATES OF DISCRIMINATION AGAINST AMERICAN INDIANS 3-1 

Montana Rental Testing Results 3-1 

Minnesota Rental Testing Results 3-4 

New Mexico Rental Testing Results 3-7 

New Mexico Sales Testing Results 3-10 

4. CONCLUSIONS AND IMPLICATIONS 4-1 

Summary of Findings 4-1 

Implications for Future Research Testing 4-3 

REFERENCES 

ANNEX 1: TEST ASSIGNMENT FORMS, REPORTING FORMS, AND INSTRUCTIONS 

ANNEX 2: TESTS OF STATISTICAL SIGNIFICANCE 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

EXECUTIVE SUMMARY 

This report presents results from the third phase of the latest national Housing 

Discrimination Study (HDS2000), sponsored by the Department of Housing and Urban 

Development (HUD) and conducted by the Urban Institute. It is one of five related reports that 

will ultimately be produced from this major research effort: 

• Discrimination in Metropolitan Housing Markets: Phase I 

• Discrimination in Metropolitan Housing Markets: Phase I — Supplement 

• Discrimination in Metropolitan Housing Markets: Phase II — Asians and Pacific 

Islanders 

• Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

• Discrimination in Metropolitan Housing Markets: Phase IV — Persons with 

Disabilities 

All of these reports present findings based upon rigorous paired tests, in which two individuals— 

one minority and the other white—pose as otherwise identical homeseekers and visit real estate 

or rental agents to inquire about the availability of advertised housing units. This methodology 

provides direct evidence of differences in the treatment minorities and whites experience when 

they search for housing. 

Background on HDS2000 

Paired testing originated as a tool for fair housing enforcement, detecting and 

documenting individual instances of discrimination. Since the late 1970s, this methodology has 

also been used to rigorously measure the prevalence of discrimination across the housing 

market as a whole. When a large number of consistent and comparable tests are conducted for 

a representative sample of real estate and rental agents, the results control for differences 

between white and minority homeseekers, and directly measure patterns of adverse treatment 

based on a homeseeker’s race or ethnicity. 

HDS2000 is the third national paired-testing study sponsored by HUD to measure 

patterns of racial and ethnic discrimination in urban housing markets. Its predecessors, the 

1977 Housing Market Practices Study (HMPS) and the 1989 Housing Discrimination Study 

(HDS) found significant levels of racial and ethnic discrimination in both rental and sales 

markets of urban areas nationwide. Enforcement tests conducted over the intervening decade 

have also uncovered countless instances of illegal discrimination against minority homeseekers. 

Housing discrimination raises the costs of housing search, creates barriers to homeownership 

and housing choice, and contributes to the perpetuation of racial and ethnic segregation. 

i 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

HDS2000 will ultimately involve four phases of paired testing. HUD’s goals for the study 

include rigorous measures of change in adverse treatment against blacks and Hispanics 

nationwide, site-specific estimates of adverse treatment for major metropolitan areas and 

selected states, and new measures of adverse treatment against Asians and Pacific Islanders, 

American Indians, and persons with disabilities. Phase I provided national estimates of adverse 

treatment against blacks and Hispanics and reported on changes in the incidence of differential 

treatment since 1989. Phase II focused on two major new goals. It produced the first national 

estimates of discrimination against Asians and Pacific Islanders, and an initial set of state 

estimates of discrimination against blacks and Hispanics that include small and medium-sized 

metropolitan areas as well as larger areas. Phase III extends the paired testing methodology to 

provide the first rigorous estimates of the incidence and forms of discrimination American 

Indians face when they search for housing in metropolitan areas. 

The HDS2000 Methodology 

This study builds upon the basic testing protocols that have been implemented in 

previous national studies and in Phases I and II of HDS2000. Random samples of advertised 

housing units were drawn from multiple advertising sources in each site on a weekly basis, and 

testers visited the sampled offices to inquire about the availability of these advertised units. 

Both minority and white partners were assigned income, assets, and debt levels to make them 

equally qualified to buy or rent the advertised housing unit. Test partners were also assigned 

comparable family circumstances, job characteristics, education levels, and housing 

preferences. They visited sales or rental agents and systematically recorded the information 

and assistance they received about the advertised unit and/or other similar units, including 

location, quality and condition, rent or sales price, and other terms and conditions. Test 

partners did not compare their experiences with one another or record any conclusions about 

differences in treatment; each simply reported the details of the treatment he or she 

experienced as an individual homeseeker.1 

The results presented here measure the incidence of discrimination in metropolitan 

housing markets of three states where substantial numbers of American Indians live in 

metropolitan areas—Minnesota, Montana, and New Mexico. Because the American Indian 

population is relatively small and highly concentrated in only a few states, state estimates of 

discrimination are more useful for policy purposes than a single set of national estimates. 

1 This phase of HDS2000 is designed to measure the extent to which minority homeseekers experience 

adverse treatment when they look for housing in the states of Minnesota, Montana, and New Mexico. The tests 

conducted for this study were not designed to assemble evidence of discrimination in individual cases. The question 

of when differential treatment warrants prosecution and the related question of whether sufficient evidence is 

available to prevail in court can only be resolved on a case-by-case basis, which might also consider other indicators 

of treatment than those reported here. 

ii 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Indian tribes are tremendously diverse, with different languages, cultural traditions, and physical 

attributes. In the metropolitan areas where HDS testing was conducted, the predominant tribes 

include Navajo and Pueblo (in New Mexico), Crow, Blackfeet, and Sioux (in Montana), and 

Chippewa and Sioux (in Minnesota). Testers were recruited to represent the predominant tribes 

in their states, and included members of all these tribes.2

 Although rental testing was conducted 

in all three states, sales testing was conducted only in New Mexico. 

Summary of Findings 

In the metropolitan housing markets of Minnesota, Montana, and New Mexico, American 

Indian renters face significant levels of discrimination, primarily due to denial of information 

about the availability of housing units. 

The example on this page is consistent 

with the pattern that whites are more 

often told about available housing than 

are equally qualified American Indians. 

Generally, the discrimination 

encountered is not outright "door 

slamming," but a pattern of treatment that 

favors whites and ultimately limits the 

housing choices and increases the cost 

of housing search for American Indians. 

Discrimination against American Indian 

renters ranges from 25.7 percent in New 

Mexico to 33.3 percent in Minnesota, 

averaging 28.5 percent across all three 

states. These levels of discrimination are 

high compared to national estimates for 

African Americans, Hispanics, and 

Asians and Pacific Islanders. In all three states, American Indian renters were significantly 

more likely to be denied information about available housing units than comparable whites. 

Other forms of adverse treatment were generally not statistically significant. 

2-bedroom unit advertised for rent at $590 in 

Billings, MT.

A 37-year old Native American woman, with 

back on Monday if she wanted to see an 

A 43-year old white female tester inquired about a 

 The agent informed the tester that 

the unit was available, gave the tester an 

application form, a brochure, and a business card. 

The agent then took the tester to inspect two 

model units that were similar to the advertised unit. 

equivalent economic characteristics to the white 

tester, inquired about the same 2-bedroom unit the 

next day. The agent responded that she was too 

busy to talk, gave the tester an application form, 

brochure, and business card, and told her to come 

apartment. The agent did not indicate whether or 

not the advertised apartment was still available. 

American Indian homebuyers in New Mexico experience significant levels of geographic 

steering—with more whites shown homes in neighborhoods that were more predominantly 

white. However, other forms of adverse treatment were not statistically significant. The overall 

incidence of discrimination is 16.9 percent. These results should be viewed as preliminary; it 

2

 Most of the American Indian testers who participated in this study spent some part of their lives on Tribal 

Lands, or have friends and relatives there and maintain a connection to tribal institutions and activities. 

iii 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

would be a mistake to draw conclusions about the overall experience of American Indian 

homebuyers based upon evidence from a single state. 

These findings clearly indicate that discrimination is a serious problem for American 

Indians searching for housing in metropolitan rental markets, and that rigorous paired testing 

can and should be expanded for both research and enforcement purposes. However, few local 

fair housing organizations have strong ties to American Indian communities or experience 

working with American Indians as testers or test coordinators. Therefore, the recruitment and 

retention of American Indians as testers present significant challenges. Future testing efforts 

should consider pairing experienced testing organizations with organizations that have strong 

ties to American Indian communities, building the capacity of American Indians to coordinate 

and conduct rigorous paired testing. 

Measurement Issues 

A paired test can result in any one of three basic outcomes for any measure of 

treatment: 1) the white tester is favored over the minority; 2) the minority tester is favored over 

the white; or 3) both testers receive the same treatment (which may be either favorable or 

unfavorable). The simplest measure of adverse treatment is the share of all tests in which the 

white tester is favored over the minority. Because there are also tests in which minority testers 

receive better treatment than their white partners, we report both the incidence of white-favored 

treatment and the incidence of minority-favored treatment. 

Gross and Net Measures. Although these simple gross measures of white-favored and 

minority-favored treatment are straightforward and easily understandable, they almost certainly 

overstate the frequency of systematic discrimination.3

 Specifically, differential treatment may 

occur during a test not only because of differences in race or ethnicity, but also because of 

random differences in the circumstances of their visits to the real estate agency. For example, 

in the time between two testers’ visits, an apartment might have been rented, or the agent may 

have been distracted by personal matters and forgotten about an available unit. Gross 

measures of white-favored and minority-favored treatment include both random and systematic 

elements, and therefore provide upper-bound estimates of systematic discrimination.4 

3

 We use the term “systematic discrimination” to mean differences in treatment that are attributable to a 

customer’s race or ethnicity, rather than to any other differences in tester characteristics or test circumstances. This 

term is not the same as “intentional” discrimination, nor is it intended to mean that these differences would 

necessarily be ruled as violations of federal fair housing law. 

4

 Note that it is conceivable that random factors might reduce the observed incidence of white-favored or 

minority-favored treatment, so that the gross-incidence measure is technically not an absolute upper-bound for 

systematic discrimination. 

iv 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

One strategy for estimating systematic discrimination, that is, to remove the cases where 

non-discriminatory random events are responsible for differences in treatment, is to subtract the 

incidence of minority-favored treatment from the incidence of white-favored treatment to 

produce a net measure. This approach essentially assumes that all cases of minority-favored 

treatment are attributable to random factors—that systematic discrimination never favors 

minorities—and that random white-favored treatment occurs just as frequently as random 

minority-favored treatment. Based on these assumptions, the net measure subtracts 

differences due to random factors from the total incidence of white-favored treatment. However, 

it seems possible that sometimes minorities may be systematically favored on the basis of their 

race or ethnicity. If so, the net measure subtracts not only random differences but some 

systematic differences, and may therefore understate the frequency of systematic 

discrimination.5 

It is possible to adapt the basic paired testing methodology to directly observe how often 

random differences in treatment occur. Specifically, in two metropolitan areas, Phase II of 

HDS2000 conducted three-part tests. In these tests, a white tester was followed by two 

minorities or a minority tester was followed by two whites, all following the same protocols. 

Comparing the treatment of the two same-race testers provides a direct estimate of random 

(non race-based) differential treatment. This exploratory triad testing effort suggests that most, 

if not all, minority-favored treatment is random; it provides no convincing evidence that minorityfavored treatment systematically exceeds differences in the treatment of same-race testers. 

However, because these results are based on a relatively small number of tests in only two 

metropolitan areas, they should be viewed as preliminary and require further confirmation. 

The body of this report presents both gross and net measures, because in combination, 

they indicate not only how often whites are favored over comparable minority homeseekers, but 

the extent to which white-favored treatment systematically exceeds minority-favored treatment. 

These two measures provide upper- and lower-bound estimates of systematic discrimination 

against minority homeseekers. 

Summary Measures. A visit with a rental or sales agent is a complex transaction and 

may include many forms of favorable or unfavorable treatment. This report presents results for 

a series of fourteen individual rental treatment indicators and fifteen sales treatment indicators, 

but also combines these individual indicators to create composite measures for categories of 

treatment (such as housing availability or housing costs) as well as for the transaction as a 

whole. For rental tests, treatment measures include the availability of advertised and similar 

5

 Even when no statistical pattern of race-based differential treatment is observed, individual cases of 

discrimination may occur. Specifically, even if the net measure is not significantly different zero, there may in fact be 

instances of race-based discrimination, although the overall pattern does not systematically favor one group over the 

other. 

v 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

units, opportunities to inspect units, housing costs, and the encouragement and assistance from 

rental agents. For sales tests, measures include the availability of advertised and similar 

homes, opportunities to inspect homes, the neighborhood characteristics of recommended and 

inspected homes, assistance with mortgage financing, and encouragement and assistance from 

the sales agent. 

Two types of composite measures have been constructed. Consistency measures 

reflect the extent to which the different forms of treatment that occur in a visit consistently favor 

one tester over the other. Specifically, tests are classified as white-favored if the white tester 

received favorable treatment on one or more individual items, while his or her partner received 

no favorable treatment. Tests were classified as “neutral” if one tester was favored on some 

individual treatment items and his or her partner was favored on even one item. Consistency 

measures were used in 1989 to summarize testing results across individual treatment 

indicators. In HDS2000, however, we also developed hierarchical measures by considering the 

relative importance of individual treatment measures to determine whether one tester was 

favored over the other. For each category of treatment measures and for the full set of 

measures, a hierarchy of importance was established independently of the testing results to 

provide an objective set of decision rules for comparing treatment across indicators.6 

The body of this report presents both consistency measures and hierarchical measures. 

These alternative measures (including both lower-bound and upper-bound estimates of 

systematic discrimination) generally tell a consistent story about the existence of discrimination 

at the state level. 

Strengths and Limitations of This Research 

Paired testing is a powerful tool for directly observing differences in the treatment that 

minority and white homeseekers experience when they inquire about the availability of 

advertised housing units. Despite the strengths of this methodology, HDS2000, like previous 

paired testing studies, is limited in its coverage of metropolitan housing markets and the 

experience of minority homeseekers. The sample of real estate and rental agents to be tested 

was drawn from publicly available advertisements, and the economic characteristics of tester 

teams were matched to the characteristics of the advertised units. However, not all housing 

units for sale or rent are advertised, not all real estate and rental agents use advertising to 

attract customers, and not all homeseekers rely upon published advertisements in their housing 

search. Therefore, results presented here do not necessarily reflect the experience of the 

6

 Again, it is important to emphasize the difference between methods used for the statistical analysis of 

paired testing results and methods used to assemble or assess evidence of unlawful conduct in an individual case. 

No pre-determined set of decision criteria can substitute for case-by-case judgements about test results. 

vi 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

typical American Indian homeseeker, but rather of homeseekers qualified to rent or buy the 

average housing unit advertised in a readily available information source. 

Moreover, the results presented here do not encompass all phases of the housing 

market transaction. HDS2000, like most paired testing studies, focuses on the initial encounter 

between a homeseeker and a rental or sales agent. Additional incidents of adverse treatment 

may occur later in the housing transaction, when a renter submits an application or negotiates 

lease terms, or when a homebuyer makes an offer on a particular unit or applies for mortgage 

financing. In spite of these important limitations, Phase III of HDS2000 provides compelling 

evidence that American Indians face high levels of discrimination in metropolitan housing 

markets, particularly when they search for rental housing. 

vii 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

1. BACKGROUND AND INTRODUCTION 

This report presents findings from the third phase of the latest national Housing 

Discrimination Study (HDS2000), sponsored by the Department of Housing and Urban 

Development (HUD) and conducted by the Urban Institute. HDS2000 is the third national 

paired-testing study sponsored by HUD to measure patterns of racial and ethnic discrimination 

in U.S. housing markets. The first phase of HDS2000 rigorously measured current levels of 

adverse treatment against African Americans and Hispanics for large metropolitan areas 

nationwide and tracked significant changes in these levels since 1989. It concluded that 

discrimination still persists in both rental and sales markets of large metropolitan areas 

nationwide, but that its incidence has generally declined since 1989.1 Phase II produced the 

first national estimates of discrimination against Asians and Pacific Islanders, finding that they 

also face significant levels of housing discrimination, particularly in the homeownership market.2 

Phase III of HDS2000 provides the first rigorous estimates of the incidence of 

discrimination experienced by American Indians when they search for housing in metropolitan 

areas outside of Native Lands. These estimates focus on three states—Minnesota, Montana, 

and New Mexico—each of which has a substantial population of American Indians living in 

metropolitan areas. Testing focused on discrimination in metropolitan rental markets for all 

three states, with additional testing for metropolitan sales markets in New Mexico. 

Paired Testing Methodology 

In a paired test, two individuals—one minority and the other white—pose as otherwise 

identical homeseekers, with comparable housing needs and resources. Both testers visit a real 

estate or rental agent to inquire about the availability of housing, making the same requests and 

providing the same information about themselves. Each tester systematically records the 

information and assistance he or she receives from the agent. If the minority and white are 

treated differently in important ways, the test provides direct and powerful evidence of 

differences in the treatment minorities and whites experience when they search for housing. 

1

 See M.A. Turner, S. Ross, G. Galster, J. Yinger (2002) Discrimination in Metropolitan Housing Markets: 

National Results from Phase I of HDS2000. Washington, D.C.: U.S. Department of Housing and Urban 

Development. 

2

 See M.A. Turner and S. Ross (2003) Discrimination Against Asians and Pacific Islanders in Metropolitan 

Housing Markets. Washington, D.C.: U.S. Department of Housing and Urban Development. In addition, Phase II 

produced four sets of state-wide estimates of discrimination against African Americans and Hispanics, and expanded 

the sample of metropolitan areas in the national estimates. See M.A. Turner and S. Ross (2003) Discrimination 

Against African Americans and Hispanics: Supplemental Results from Phase II of HDS2000. Washington, D.C.: U.S. 

Department of Housing and Urban Development. 

1-1 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Paired testing originated as a tool for fair housing enforcement, detecting and 

documenting individual instances of discrimination. Since the late 1970s, this methodology has 

also been used to rigorously measure the prevalence of discrimination across the housing 

market as a whole. When a large number of consistent and comparable tests are conducted for 

a representative sample of real estate and rental agents, the results directly measure patterns of 

adverse treatment based on a homeseeker’s race or ethnicity. 

For the results presented here, basic testing protocols replicated those implemented in 

Phase II of HDS2000. Samples of available housing units were drawn from multiple advertising 

sources, including major metropolitan newspapers, community newspapers, homeseeker 

guides, and the internet. Testers visited the sampled offices to inquire about the availability of 

these units. Both minority and white partners were assigned income, assets, and debt levels to 

make them equally qualified to buy or rent the advertised housing unit. Test partners were also 

assigned comparable family circumstances, job characteristics, education levels, and housing 

preferences. They took turns visiting sales or rental agents and systematically recorded the 

information and assistance they received about the advertised unit and/or other similar units, 

including location, quality and condition, rent or sales price, and other terms and conditions. 

Test partners did not compare their experiences with one another or record any conclusions 

about differences in treatment; each simply reported the details of the treatment he or she 

experienced as an individual homeseeker.3 

HDS2000 Study Scope 

HDS2000 will ultimately involve four phases of paired testing. HUD’s goals for the study 

include rigorous measures of change in adverse treatment against blacks and Hispanics 

nationwide, site-specific estimates of adverse treatment for major metropolitan areas, statewide 

estimates of adverse treatment that encompass smaller metropolitan areas, and new measures 

of adverse treatment against Asians and Pacific Islanders, American Indians, and persons with 

disabilities. 

Phase III of HDS2000 was designed to yield three sets of state estimates of 

discrimination against American Indians, based on testing in eight metro areas with substantial 

concentrations of American Indian population. Specifically, estimates of discrimination against 

American Indian renters were produced for Minnesota (based on testing in Minneapolis-St.Paul 

and Duluth), Montana (based on testing in Billings, Great Falls, and Missoula), and New Mexico 

3

 HDS2000 is designed to measure the extent to which minority homeseekers experience adverse treatment 

when they look for housing in metropolitan areas. The tests conducted for this study were not designed to assemble 

evidence of discrimination in individual cases. The question of when differential treatment warrants prosecution and 

the related question of whether sufficient evidence is available to prevail in court can only be resolved on a case-bycase basis. 

1-2 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

(based on testing in Albuquerque, Santa Fe, and Las Cruces). Estimates of discrimination 

against American Indian homebuyers were produced only for New Mexico (based on testing in 

Albuquerque, Santa Fe, and Las Cruces). Each set of statewide estimates is representative of 

the levels of discrimination faced by American Indians searching for housing in metropolitan 

areas throughout the state. 

HDS2000, like previous national paired testing studies, is limited in its coverage of 

metropolitan housing markets and the experience of minority homeseekers. The sample of real 

estate and rental agents to be tested was drawn from published advertisements, and the 

economic characteristics of tester teams were matched to the characteristics of the advertised 

units. However, not all housing units for sale or rent are advertised, not all real estate and rental 

agents use advertising to attract customers, and not all homeseekers rely upon advertisements 

in their housing search. Therefore, results presented here do not necessarily reflect the 

experience of the typical American Indian homeseeker, but rather of homeseekers qualified to 

rent or buy the average housing unit advertised in a publicly available information source. 

Moreover, the results presented here do not encompass all phases of the housing 

market transaction. HDS2000, like most paired testing studies, focuses on the initial encounter 

between a homeseeker and a rental or sales agent. Additional incidents of adverse treatment 

may occur later in the housing transaction, when a renter submits an application or negotiates 

lease terms, or when a homebuyer makes an offer on a particular unit or applies for mortgage 

financing. Despite these limitations, Phase III of HDS2000 constitutes the first effort to 

systematically measure housing discrimination against American Indians, and provides the most 

rigorous estimates of the level and forms of discrimination that American Indians face when they 

search for housing in metropolitan markets. 

Organization of the Report 

The remainder of this report consists of three chapters. Chapter 2 presents the 

methodology implemented in Phase III of HDS2000, including the samples of metropolitan 

areas in which tests were conducted, the procedures used to draw samples of available housing 

units in each of these metropolitan areas, the testing protocols implemented for both rental and 

sales housing, and the statistical procedures used to estimate the incidence of adverse 

treatment. Chapter 3 presents state-level estimates of adverse treatment against American 

Indians, incorporating both large and smaller metropolitan areas. Chapter 4 discusses the 

implications of this pilot effort for further research testing focusing on discrimination against 

American Indians. 

1-3 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

2. PHASE III DESIGN AND METHODOLOGY 

Although the paired testing methodology originated as a tool for fair housing 

enforcement, it has been successfully adapted for research purposes. In order to yield reliable 

measures of differential treatment in housing market transactions, paired testing must be 

applied to a representative sample of housing providers or available housing units in selected 

markets, and must adhere to highly standardized protocols. Phase III of HDS2000 built upon 

the experience of two previous phases to produce the first statistically rigorous measures of 

levels and forms of adverse treatment against American Indians searching for housing in 

metropolitan areas. This chapter describes the sampling procedures, testing protocols, and 

analysis techniques implemented in Phase III of HDS2000. 

Sampling 

The population of American Indians living in metropolitan areas is quite highly 

concentrated in a few states. Therefore, national estimates of housing discrimination against 

American Indians might not be as meaningful or useful for policy purposes as state estimates.1 

Moreover, exploratory work conducted during Phase I of HDS2000 indicated that testing for 

discrimination against American Indians could be particularly challenging, primarily because few 

local fair housing organizations have experience working with American Indians. Therefore, 

Phase III focused the available testing resources in three states with significant American Indian 

populations, producing representative estimates for the metropolitan markets within each state. 

More specifically, for each state, sampling was based on an integrated two-stage design. In the 

first stage, metropolitan areas were selected with certainty to provide maximum coverage of the 

American Indian population within a state’s metropolitan areas. In the second stage, 

advertisements for rental and sales housing were selected with probability sampling from 

multiple advertising sources covering the sampled metropolitan markets during the testing 

period. 

State Samples of Metropolitan Populations. Phase III of HDS2000 features an initial 

set of state-level estimates for differential treatment of American Indians in metropolitan housing 

markets where American Indians represent a significant proportion of the population. First, we 

used 2000 Census Data to identify states in which the American Indian population exceeds 

50,000 and accounts for more than 1 percent of total population. These states include Alaska, 

New Mexico, South Dakota, Oklahoma, Montana, Arizona, Washington, North Carolina, 

Minnesota, and California. Then, in consultation with HUD, we selected three of these states— 

1

 It is also important to note that the characteristics and housing circumstances of American Indians vary 

tremendously across states, metropolitan areas, and between Tribal Lands and non-tribal communities. See 

Kingsley, Mikelsons, and Herbig (1996). 

2-1 
-- 

-- 

-- 

Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Minnesota, Montana, and New Mexico—taking into consideration the capacity of local fair 

housing or other organizations to conduct large numbers of standardized paired tests. In each 

state, we then selected either two or three metropolitan areas that account for at least 90 

percent of the state’s metropolitan American Indian population. For Montana and New Mexico, 

testing was conducted in three metro areas, while only two metro areas were required to 

produce representative estimates for Minnesota. Exhibit 2-1 summarizes the final site selection 

with the resulting coverage of each state’s total metropolitan American Indian population. 

Exhibit 2-1: States and Metropolitan Areas Selected for American Indian Testing 

STATE/MSA AMERICAN INDIAN 

POP. (2000 CENSUS) 

% AMERICAN INDIAN 

POP. IN ALL MSAs 

MINNESOTA 

DULUTH 4,860 15.5 

MINNEAPOLIS-ST. PAUL* 21,326 81.3 

SAMPLED MSA POPULATION* 26,508 96.8% 

MONTANA 

BILLINGS 3,950 41.4 

GREAT FALLS 3,394 35.6 

MISSOULA 2,193 23.0 

SAMPLED MSA POPULATION 9,537 100.0% 

NEW MEXICO 

ALBUQUERQUE 39,992 85.7 

LAS CRUCES 2,580 5.5 

SANTA FE 4,089 8.8 

SAMPLED MSA POPULATION 46,661 100.0% 

* When MSA boundaries include portions of two or more states, only the state specific portion 

of that MSA had testing conducted in it. For instance, Minneapolis-St.Paul MN-WI MSA had 

testing conducted only in the MN portion of the MSA for Phase III. 

We conducted both rental and sales tests in New Mexico, but only rental tests in the 

other two states. Sales testing is very challenging for inexperienced groups and inexperienced 

testers to conduct successfully, and given the resources available for Phase III of HDS2000, 

conducting sufficient numbers of sales tests in all three states would have been prohibitively 

expensive. Moreover, in most states, homeownership rates are very low among American 

2-2 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Indians (in metropolitan areas), raising the potential for detection of testers. Therefore, we 

concluded that the most effective use of the available resources would be to produce estimates 

of discrimination against American Indian renters in three states, while estimates of 

discrimination against American Indian homebuyers would be produced for only one state. New 

Mexico was selected for sales testing because it has the largest numbers (and concentrations) 

of American Indians living in metropolitan areas, as well as the highest homeownership rates 

among American Indians in metropolitan areas (58.8 percent, compared to 33.9 percent in 

Montana and 41.5 percent in Minnesota). Thus, we anticipated that the risk of detection would 

be lowest and the availability of testers with homeownership experience would be greatest in 

New Mexico. 

In order to produce statistically valid estimates, we initially planned to conduct 100 tests 

per tenure per state, for a total of 400 tests overall. Testing targets were allocated across the 

sampled metropolitan areas in proportion to the size of their American Indian population. 

However, the local testing organization in Minnesota encountered difficulties in conducting the 

necessary number of tests on schedule. As a result, only 50 rental tests were conducted for 

Minnesota, but the number of rental tests for Montana and New Mexico was increased. Exhibit 

2-2 presents the final samples sizes by site for each state. Based upon these sample sizes, we 

can generally expect to detect net differences in treatment at the state level that exceed 5 to 7 

percentage points at a 95 percent confidence level, although the statistical power of individual 

estimates will vary. 

Exhibit 2-2: Final Sample Sizes by Metropolitan Area 

MSA / PMSA # Rental Tests # Sales Tests 

Minnesota 51 0 

Minneapolis-St.Paul 42 

Duluth 9 

Montana 121 0 

Billings 50 

Great Falls 38 

Missoula 33 

New Mexico 125 100 

Albuquerque 105 85 

Santa Fe 14 9 

Las Cruces 6 6 

Total 297 100 

2-3 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

In the metropolitan areas where HDS testing was conducted, the predominant tribes 

include Navajo and Pueblo (in New Mexico), Crow, Blackfeet, and Sioux (in Montana), and 

Chippewa and Sioux (in Minnesota). Testers were recruited to be as representative as possible 

of the predominant tribes in their areas. Exhibit 2-3 reports the distribution of completed tests 

by tribe. Because many testers report membership in more than one tribe, the percentages 

total to more than 100 percent. 

 Exhibit 2-3: Distribution of Completed Tests by Tribe 

New Mexico Rentals New Mexico Sales Montana Rentals Minnesota Rentals 

Tribal Affiliations Total Tests Percent Tribal Affiliations Total Tests Percent Tribal Affiliations Total Tests Percent Tribal Affiliations Total Tests Percent 

Navajo 84 67.7% Navajo 72 72.0% Blackfeet 25 20.7% Mississippi Choctaw 9 17.6% 

Pueblo 47 37.9% Pueblo 17 17.0% Paiute 7 5.8% Minnesota Chippewa 47 92.2% 

Zuni 6 4.8% Zuni 5 5.0% Crow 74 61.2% Shakopee Sioux 4 7.8% 

Apache 5 4.0% Apache 4 4.0% Winnebago 34 28.1% Blackfeet 4 7.8% 

Cheyenne-Arapaho 6 4.8% Cheyenne-Arapaho 0 0.0% Other 12 23.5% 

Cherokee 3 2.4% Cherokee 0 0.0% 

Other/Unknown 6 4.8% Other/Unknown 4 4.0% 

Sample of Advertised Housing Units. The basic objective of a paired testing study is 

to observe the relative treatment that housing agents provide to white and minority 

homeseekers in the private market. Because we are measuring agent behavior, we would 

ideally draw a representative sample of rental and sales agents, where an agent’s probability of 

selection reflects his or her share of available housing units. In addition, our sampling 

methodology needs to provide information about the housing being offered by each agent. This 

information allows both members of a testing team to be assigned characteristics (such as 

household size and income) and preferences (such as housing type and location) that 

correspond to housing that an agent actually has to offer.2 

The national paired testing studies conducted in prior to HDS2000 relied upon classified 

advertisements in major metropolitan newspapers to generate samples of rental and sales 

agents. The Housing Market Practices Study (HMPS, conducted in the late 1970s) drew a 

single sample of advertisements from the Sunday classified section of each metropolitan area’s 

primary newspaper (Wienk et al., 1979). Tester teams were assigned characteristics and 

preferences consistent with the sampled housing units, and visited the corresponding agents 

inquiring generally about available housing. In the 1989 Housing Discrimination Study (HDS), 

this methodology was refined to involve weekly samples of available housing units, again drawn 

from the classified advertising sections of each metropolitan area’s major newspaper (Turner, 

Struyk, and Yinger, 1989). This refinement allowed testers to begin each visit by inquiring about 

a particular housing unit, making the tests more credible and allowing both white and minority 

2

 For a more detailed discussion of sampling principles, see chapter 2 of The Urban Institute (2000) 

Research Design and Analysis Plan for Housing Discrimination Study 2000. 

2-4 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

testers to send agents the same implicit signals about housing preferences. Phase I of 

HDS2000 replicated this approach, drawing weekly samples of advertisements from the Sunday 

classified section of each metropolitan area’s major newspaper. However, relying upon 

metropolitan newspapers to represent the housing market as a whole has significant 

weaknesses. Therefore, Phase II of HDS2000 developed procedures for drawing upon multiple 

advertising sources, in order to more fully reflect the universe of housing units available for rent 

or sale in the sampled metropolitan areas. These procedures were applied again in Phase III. 

The weekly ad-sampling methodology offers several important benefits. It yields a 

representative sample of housing agents who advertise available units, where an agent’s 

probability of selection is proportionate to his or her share of all units advertised. Because the 

advertising sources selected for sampling are readily available, regardless of race, ethnicity, or 

other characteristics, this sampling frame includes agents who can realistically be accessed by 

any homeseeker. In addition, the weekly sampling methodology provides a consistent and 

credible starting point for each test, tying the characteristics and preferences of testers to 

housing actually available from the sampled agent, and sending consistent signals from both 

members of a tester team. Finally, this methodology addresses one of the major ethical 

concerns about paired testing—that it imposes an unreasonable cost burden on housing agents 

who have to spend time responding to testers’ inquiries and potentially violates their 

expectations of privacy regarding these inquiries (Fix and Struyk, 1992). By advertising in a 

widely available outlet, a housing agent is explicitly inviting inquiries from the general public. 

Four basic steps were required to produce samples for each Phase III site: 

• Select a set of advertising sources that provides reasonably complete coverage for 

the metropolitan housing market. 

• Develop a schedule for rotating across sources on a weekly basis. 

• Establish an efficient sampling protocol for each advertising source. 

• Draw weekly ad samples. 

Select advertising sources. For each metropolitan area selected for Phase III testing, we 

assembled an inventory of potential advertising sources. Drawing from media directories, the 

internet, and local informants, we prepared a list of newspapers, internet sites, and guides that 

local housing agents use to advertise rental and sales units. Excluded from this inventory were 

foreign language sources, sources with very small circulation or ad volumes, sources produced 

by a single real estate or rental company, sources that require the user to specify housing 

preferences in order to obtain listings, and sources that are not readily available to the general 

public. Based upon this inventory, we selected a set of sources that provided reasonably 

complete coverage of rental and/or sales advertisements for the metropolitan housing market as 

a whole, including rural portions of the market. A different set of sources was typically selected 

for rental advertising than for sales advertising. One or more major metropolitan dailies were 

2-5 
-- 

-- -- 

-- 

-- -- 

-- -- 

-- -- 

Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

always included among the selected sources. City and suburban community papers were 

included if they provided a reasonable volume of advertisements for specific geographic subareas. Because local experts in the Phase III sites indicated that relatively few homeseekers 

use the internet, we used the internet version of a source only for logistical convenience and if it 

provided the same information as the print version. Finally, we included free apartment-seekers 

and/or homeseekers guides and advertising circulars if they were available locally. Exhibit 2-4 

identifies the actual sources selected for each metro area. 

Exhibit 2-4: Phase III Sampling Ad Sources for American Indian Testing Sites 

Major Metro 

Newspapers 

Community 

Papers 

Rental/Sales

Guides 

Advertising 

Circulars 

MINNESOTA 

MinneapolisSt.Paul 

Minneapolis Star 

Tribune 

St. Paul Pioneer 

Anoka Shopper 

Elk River Star News 

Shoreview Press 

Apartments for Rent 

Twincities Apt Living 

Guide 

Press Stillwater Gazette 

City Pages 

Hastings Star 

Gazette 

Waconia Patriot 

Wright County 

Journal Press 

Duluth Duluth News-Tribune The Hibbing Daily 

Tribune 

The Mesabi Daily 

News 

MONTANA 

Billings Billings Gazette Laurel Outlook Thrifty Nickel Want 

Ads 

Yellowstone 

Shopper 

Great Falls Great Falls Tribune Consumer Press 

Missoula Missoulian Missoula 

Independent 

NEW MEXICO 

Albuquerque Albuquerque Journal The News-Bulletin 

The Rio Rancho 

Observer 

Apartments for Rent 

Apartment Guide 

Albuquerque Homes 

Illustrated 

Quick Quarter Thrifty 

Nickel 

Real Estate Book 

Santa Fe Santa Fe New 

Mexican 

Los Alamos Monitor Apartment Guide 

Santa Fe Homes 

Thrifty Nickel Ads 

Santa Fe Real 

Estate Guide 

Las Cruces Las Cruces Sun- Las Cruces 

News Apartment Guide 

Real Estate Press 

2-6 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Develop a rotational schedule. Once a reasonable set of advertising sources was 

selected for a metropolitan area, we developed a schedule for rotating across sources on a 

weekly basis. Our goals in developing this schedule were to minimize the overlap between 

sources that might be used in the same week, to sample on the most appropriate day of the 

week for each source, and to ensure an adequate number of advertisements per week. Thus, a 

source that covered all or most of a metro area (such as a major metro newspaper or a metrowide internet site) would be the only source utilized in a given week. In contrast, several 

sources that targeted different geographic sub-areas might be combined in the same week. 

Finally, sources that were published monthly rather than daily or weekly were generally utilized 

during the weeks when they were first released. 

Establish sampling protocols. For each advertising source to be utilized, we used 

randomly generated numbers to select a starting point, and then sampled every “nth ” ad to yield 

the target sample size. Not all advertised housing units are eligible for inclusion in our sample. 

Some types of ads are not suitable for our paired testing protocols. For example, subsidized 

rental housing units must be excluded because they impose specialized income and other 

eligibility criteria for tenants, and homes for sale by owner are excluded because they do not 

contribute to the sample of housing agents active in the local housing market. Phase III 

adopted the same eligibility criteria as were implemented in Phase II of HDS2000.3 

Draw weekly samples. Once a Phase III site was ready to begin testing, we drew ad 

samples on a weekly basis, applying the site-specific rotational schedule and sampling 

protocols outlined above. The weekly samples were two to three times larger than the target 

number of tests to be conducted in a given week, because some advertisements that appear to 

be eligible for inclusion in the sample turn out to be ineligible when further information is 

gathered on site, some advertised housing units are no longer available by the time testers call 

to schedule a visit, and some providers (particularly owners of small rental properties) were very 

difficult to reach. Each week we drew roughly equal numbers of ads for a given site. To the 

greatest extent possible, we combined ad sources so that the ad volume of the frame sets was 

roughly equal from week to week, making the sampling rates approximately the same. Within a 

given week, all ad sources had the same sampling rate applied to generate the ads for testing. 

This means that a proportionate stratified sample was drawn across frame sources in a given 

week, with each frame source representing a different stratum. Each testing site received one 

rental sample set and (if applicable) one sales sample set each week, though not always on the 

same day each week. If a sample proved to be too small for a particular site in a given week, 

additional sample units were drawn (from the same advertising source if possible) at the request 

of the testing organization. 

2-7 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Analytic Weights. Analytic weights were generated to produce state estimates for the 

population of inference, which in HDS2000 comprises the collection of housing agents who 

interact with American Indian households seeking to purchase or rent a home and who use 

housing advertisements as their entryway into the housing market. More specifically, we 

developed a model-based weighting approach that balances the sample by stratum using 

Census 2000 data. The weights are model based in that they rely on a plausible “model” that 

posits the distribution of housing agents being distributed like population. Specifically, the 

model assumes that the percentage distribution of minority population across sampling strata 

reflects the percentage distribution of agents who serve minority homeseekers across those 

strata. 

The methodology for calculating the analytic weights is relatively straightforward. It 

involves the creation of a two-factor weight: 

AWT = SWT x POP_ADJ (1) 

Where AWT denotes the analytic weight, SWT represents the first stage sampling weight, and 

POP_ADJ represents a population adjustment using Census 2000 data (calculated separately 

for each tenure). The stage-one sampling weight is simply the reciprocal of a site’s selection 

probability: 

SWT(i) = 1 (2) 

since all sites were chosen with certainty. The population adjustments, POP_ADJ, represent 

enhancements to the sampling weights that align the sample to known Census 2000 population 

distributions across our sampling strata. Again, since all sites are chosen with certainty, each 

site forms a stratum. The adjustments simply comprise the ratio of the site’s American Indian 

population relative to the total American Indian population of all metropolitan areas in the state. 

Given the nature of the population of inference, we chose not to incorporate differential 

weighting associated with weekly fluctuations of tester productivity and ad volume. Similarly, we 

did not consider the source of the advertisement when developing weights because no 

information is available concerning the population of available housing stock that is directly and 

indirectly represented by these sources. Finally, our pooled three-state results are weighted to 

reflect the relative size of each state's American Indian population. 

3

 For a full description of the eligibility criteria, see chapter 2 of M.A. Turner and S. Ross (2003) 

Discrimination in Metropolitan Housing Markets: Phase II — Asians and Pacific Islanders; or Discrimination in 

Metropolitan Housing Markets: Phase I — Supplement. 

2-8 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Field Implementation and Paired Testing Protocols 

Phase III of HDS2000 largely adopted the testing procedures and protocols that were 

implemented in Phases I and II, making only modest changes to clarify the wording of questions 

that created confusion in earlier phases. During Phase III, we continued to use the paperless, 

web-based system developed and deployed in Phase II to enter, transmit, and manage all 

testing data. This system—known as CODE—did not change the testing protocols or field 

procedures, but did significantly enhance the speed and reliability of data collection and 

exchange. In Phase III, we made technical improvements to CODE, expanding it to include all 

of the forms and enhancing reporting functions. 

Phase III field implementation was managed by Regional Coordinators under the 

supervision of the Urban Institute’s Director of Field Operations. The Urban Institute 

subcontracted with a local fair housing organization in each state to conduct the testing. Staffs 

of these local testing organizations, designated as Test Coordinators, were responsible for the 

day-to-day testing activities, directing testers and ensuring that tests were completed according 

to established procedures and protocols. This section describes the field guidelines and 

procedures implemented in Phase III, including procedures involved in 1) preparing to test, 2) 

conducting the test, and 3) following the test. 

Preparing to Test. For each advertised housing unit selected for testing, the Urban 

Institute’s sampling staff prepared a Test Authorization Form (TAF), which was transmitted to 

the local testing organization via the CODE system. Each test was identified by a unique 

control number, and the TAF specified the parameters of the test structure: 

• Transaction Type – the test tenure, whether rental or sales; 

• Required Sequence – the randomly assigned order (minority/non-minority) in which 

the testers should make their test visits; 

• Sales and Rental Information – the type of housing (single-family or condo for sales, 

furnished or unfurnished for rental) of the advertised unit; and 

• Ad Information – the information from the advertisement (the type, edition, and name 

of the ad source, the date of publication, and location of the ad), including texts of the 

ad. 

Local testing organizations were required to use the TAFs they received each week in 

order, and to begin by making advance calls both to confirm the eligibility of the advertised units 

and to obtain information needed to make credible test assignments. Advance calls were made 

for all rental tests. For sales tests, advance calls were only made when the ad did not state a 

location of the home, a price for the home, or the number of bedrooms in the home. Advance 

callers were instructed to obtain specific pieces of information about every advertised unit, such 

as the exact date of availability (for rentals); the housing price; the number of bedrooms; and the 

2-9 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

address of the apartment or home. In the case of a rental test, if the advertised unit was no 

longer available, the advance caller inquired about other units that might be coming available. 

In order to facilitate the test visits, the advance caller also asked about office hours and whether 

or not an appointment was needed to view the housing or speak with a housing provider.4 

Personal, household and financial characteristics, along with a detailed set of 

instructions, were provided to each tester prior to conducting a test.5

 Responsibility for 

developing tester characteristics was shared by the Urban Institute and the Test Coordinators. 

Test Coordinators developed the tester’s personal information, such as current employer, 

names of household members, and names of creditors, sometimes using the tester’s real 

characteristics, if appropriate. Extensive training was provided to Test Coordinators on how to 

assign personal characteristics to testers (e.g., employers and occupations to avoid). Other test 

characteristics, such as number of bedrooms to request and type of approach, were determined 

by the Test Coordinators using information obtained during the advance phone call. Financial 

characteristics assigned to testers and housing requests to be made by testers were 

automatically assigned by the CODE system, based on the characteristics of the advertised 

housing unit to be tested, such as: 

• minimum number of bedrooms acceptable for the household; 

• area or geographic preference; 

• monthly and annual income for the tester and everyone in the tester’s household; 

• total household income; 

• length of time on the job; 

• household assets and debts; 

• credit standing; and 

• length of time at current residence. 

Test Coordinators were required to meet with each tester, individually and in person, 

prior to a test being conducted. During this initial briefing, Test Coordinators were responsible 

for: reviewing the test assignment form with the tester and answering any questions about 

assigned characteristics, instructions, and/or testing procedures; providing the tester with the 

appropriate test forms and materials; helping the tester develop a “cheat sheet” for sales tests 

listing detailed financial information from the Test Assignment form; and reviewing procedures 

4

 Advance callers were required to make at least five attempts to reach a housing provider (calling at 

different times of the day on different days) before a TAF could be deemed ineligible. 

5

 Each tester was provided with only one test assignment at a time and was required to complete that test 

before receiving another test assignment. 

2-10 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

for conducting the test and completing the test report forms. In addition, testers were provided 

with a detailed set of instructions for every test assignment. These instructions detailed the 

standard set of tasks testers were expected to accomplish during their test, including how to 

approach the test site, what questions to ask, and how to end the visit. Annex 1 provides 

examples of Test Assignment Forms and the detailed instructions provided to both rental and 

sales testers. 

Conducting the Test. HDS2000 required testers to make appointment calls for all 

sales tests and some rental tests. On sales tests, testers were not to mention the advertised 

home during this call and were also to refrain from providing their personal and financial 

information. Testers were also instructed not to commit to bring certain documents, such as tax 

returns or pay stubs, nor to agree to meet in advance with a lender to be pre-qualified for 

mortgage financing. If an agent was reluctant to make an appointment with the tester, perhaps 

stating that there were regular office hours, the tester could specify with the agent what time he 

or she planned to arrive during those hours in lieu of an actual appointment. While the standard 

approach for most rental tests was for the tester to “drop in” rather than making an appointment, 

appointment calls were required when the sampled advertisement did not provide the location of 

the available housing, when the advertisement indicated that an appointment was required, or 

when the advance call indicated that an appointment was required. 

Several procedures were implemented to ensure that real estate and rental agents could 

recognize the ethnicity of the American Indian testers. They all had identifiable American Indian 

surnames, and were trained to introduce themselves at the start of the test visit. In addition, 

they had physical characteristics that made them identifiable as American Indians, and were 

instructed to wear identifiable American Indian dress, jewelry, and hairstyles. In some 

communities, non-Hispanic whites may have difficulty differentiating between American Indians 

and Hispanics. However, local test coordinators and Urban Institute supervisors confirmed that 

all of the American Indian testers selected to participate in HDS were unambiguously 

identifiable. 

During their test visits, testers were trained to inquire about the availability of the 

advertised housing unit that prompted their visit, similar units (units with the same number of 

bedrooms and within the same price range) that might be available, and other units that might 

meet their housing needs. On rental tests, testers asked to view all units that they were told 

would meet their needs and recorded information about all available units whether or not they 

were able to inspect them. On sales tests, they were required to spend a minimum of three 

hours viewing units with the agent and to record information about all units that were 

recommended to them. In response to questions from the real estate or rental agent, testers 

provided information about their (assigned) household composition, financial characteristics, 

employment, and housing needs. They were trained to express no preferences for particular 

amenities or geographic locations, and they did not submit formal applications, agree to credit 

2-11 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

checks, or make offers to rent or buy available units. In conjunction with these basic testing 

protocols, testers were also trained to be convincing in the role of an ordinary homeseeker, 

obtain as much information as possible from the housing provider about available housing, and 

take notes in order to remember key information about what occurred during the test and what 

information was provided by the housing provider. 

Following the Test. Following every test visit, each tester was required to complete a 

set of standardized reporting forms on the CODE system (provided in Annex 1).6 Test partners 

did not compare their experiences with one another or record any conclusions about differences 

in treatment; each simply recorded the details of the treatment he or she experienced as an 

individual homeseeker. The site visit report forms record observations made by the tester and 

information provided by the housing provider. In addition to a site visit report form, each tester 

completed Available Rental Unit Forms for rental tests and Recommended Home Forms for 

sales tests. In addition, for a randomly selected sub-set of tests (approximately 50 percent), 

testers were required to compose test narratives. The test narrative provided a detailed, 

chronological accounting of the test experience. Testers did not know prior to their conducting a 

test if a narrative would be required. This served both to ensure that testers were conducting all 

tests with equal attention to established protocols and procedures, including taking notes, and to 

ensure against fabrication of tests. 

After completing each test, testers were instructed to contact their Test Coordinators in 

order to arrange for an in-person debriefing. At the debriefing, Test Coordinators were 

responsible for collecting all of the completed test forms, as well as any notes or other materials 

obtained by the tester; reviewing the forms to make sure they were filled out completely; and 

discussing any concerns the tester may have had about the test or any deviations they may 

have made from the test assignment or instructions. Many visits to real estate or rental 

agencies result in follow-up contact, and these contacts were systematically monitored and 

recorded. All follow-up contacts (including mail as well as telephone calls) were recorded on 

Follow-Up Contact Form, which documented when the follow-up was received, who initiated it, 

and the nature of the follow-up. 

Challenges in American Indian Testing. Conducting rigorous research testing with 

American Indians posed significant challenges, primarily because few local testing organizations 

have much experience working with American Indians, and experienced American Indian 

testers are scarce. In Phase III of HDS2000, recruiting and retaining testers were difficult 

because many fair housing groups have not forged strong relationships with American Indian 

organizations or within American Indian communities. Without such relationships, 

6

 Among the advantages of web-based data entry, the CODE system performed basic checks for data 

completeness and consistency as the data were entered, and made test reports immediately available for quality 

control reviews by local Test Coordinators and the Urban Institute’s Regional Coordinators. 

2-12 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

communication and trust between the testers and the testing organization can become strained. 

We found that the most successful testing organizations were those that already had longstanding relationships with several American Indian groups and had already established pools 

of American Indian testers. 

Even with established relationships, however, challenges remain. Because of the short 

time frame for research testing projects, they offer only part-time work for testers. 

Consequently, the tester pool is often made up of people who already have full-time jobs and 

people who are unemployed. Those with full-time jobs may be unreliable because of other work 

commitments; those who are unemployed may have other problems that lead to unreliability, 

such as lack of transportation and a telephone, as well as having to search for full-time 

employment during the testing period. In addition, the testing organizations with whom we 

contracted for this effort had particular difficulty recruiting and retaining American Indian testers 

who could credibly portray homeseekers of higher priced housing. And individuals with no 

experience as homebuyers or homeowners sometimes find it daunting to conduct sales tests. 

Traditional culture must also be taken into consideration in understanding some of the 

challenges involved in testing for discrimination against American Indians. In one Phase III 

metro area, for example, Test Coordinators noted a marked variation between testers from 

different tribes. They observed that members of some tribes appeared to be shyer, less 

assertive, and less likely to have had interaction with non-Native people in metropolitan areas; 

other tribes seemed to be more integrated into the larger, non-Native community. Finally, some 

American Indian testers who experienced inappropriate behavior or heard discriminatory 

remarks from housing providers during a test were so distressed by this experience that they 

dropped out of the testing altogether. Sometimes Test Coordinators were told about these 

experiences immediately; other times they found out only well after the testing had been 

completed. 

Using Paired Tests to Measure Discrimination 

Data from a sample of standardized and consistent paired tests can be combined and 

analyzed to measure the incidence and forms of discrimination in urban housing markets. The 

remainder of this chapter describes the statistical techniques used to analyze data from Phase 

III of HDS2000 at the state level. Specifically, we discuss basic measures of adverse treatment, 

the challenge of distinguishing systematic discrimination from random differences in treatment, 

rental and sales treatment indicators, summary indicators, and tests of statistical significance. 

Gross and Net Measures. A paired test can result in any one of three basic outcomes 

for each measure of treatment: 1) the white tester is favored over the minority; 2) the minority 

tester is favored over the white; or 3) both testers receive the same treatment (which may be 

either favorable or unfavorable). The simplest measure of adverse treatment is the share of all 

tests in which the white tester is favored over the minority. This gross incidence approach 

2-13 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

provides very simple and understandable indicators of how often whites are treated more 

favorably than equally qualified minorities. However, there are instances in which minority 

testers receive better treatment than their white partners. Therefore, we report both the gross 

incidence of white-favored treatment and the gross incidence of minority-favored treatment. 

Although these simple gross measures of white-favored and minority-favored treatment 

are straightforward and easily understandable, they may overstate the frequency of systematic 

discrimination.7

 Specifically, adverse treatment may occur during a test not only because of 

differences in race or ethnicity, but also because of random differences between the 

circumstances of their visits to the real estate agency. For example, in the time between two 

testers’ visits, an apartment might have been rented, or the agent may have been distracted by 

personal matters and forgotten about an available unit. Or one member of a tester pair might 

meet with an agent who is unaware of some available units. Gross measures of white-favored 

and minority-favored treatment include some random factors, and therefore provide upperbound estimates of systematic discrimination.8 

One strategy for estimating systematic discrimination, that is, to remove the cases where 

non-discriminatory random events are responsible for differences in treatment, is to subtract the 

incidence of minority-favored treatment from the incidence of white-favored treatment to 

produce a net measure. This approach essentially assumes that all cases of minority-favored 

treatment are attributable to random factors—that systematic discrimination never favors 

minorities—and that random white-favored treatment occurs just as frequently as random 

minority-favored treatment. Based on these assumptions, the net measure subtracts 

differences due to random factors from the total incidence of white-favored treatment. 

However, it seems unlikely that all minority-favored treatment is the result of random 

factors; sometimes minorities may be systematically favored on the basis of their race or 

ethnicity. For example, a minority landlord might prefer to rent to families of his or her own race 

or a real estate agent might think that minority customers need extra assistance. Other 

instances of minority-favored treatment might reflect a form of race-based steering, in which 

white customers are discouraged from considering units in minority neighborhoods or 

developments. The net measure subtracts not only random differences but also some 

systematic differences, and therefore probably understates the frequency of systematic 

7

 We use the term “systematic discrimination” to mean differences in treatment that are attributable to a 

customer’s race or ethnicity, rather than to any other differences in tester characteristics or test circumstances. This 

term is not the same as “intentional” discrimination, nor is it intended to mean that these differences would 

necessarily be ruled as violations of federal fair housing law. 

8

 Note that it is conceivable that random factors might reduce the observed incidence of white-favored or 

minority-favored treatment, so that the gross-incidence measure is technically not an absolute upper-bound for 

systematic discrimination. 

2-14 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

discrimination. Thus, net measures provide lower-bound estimates of systematic 

discrimination,9

 and they reflect the extent to which the differential treatment that occurs (some 

systematically and some randomly) is more likely to favor whites than minorities. 

Rental and Sales Treatment Indicators. A visit with a rental or sales agent is a 

complex transaction, and may include many forms of favorable or unfavorable treatment. This 

report presents results for a series of individual treatment indicators that reflect important 

aspects of the housing transaction. Many, but not all, of these indicators are common to both 

rental and sales tests. In selecting indicators for analysis, we have focused on forms of 

treatment that can be unambiguously measured, and appear to have real potential to affect the 

outcomes of housing search. Ultimately, other analysts may choose to focus on additional or 

alternative treatment indicators. But the indicators presented here provide a comprehensive 

overview of the treatment testers received during their visits to real estate and rental agents’ 

offices.10 

Indicators of adverse treatment in rental housing transactions address four critical 

aspects of the interaction between a renter and a landlord or rental agent. The first group of 

indicators focuses on the extent to which minority and white partners received comparable 

information in response to their inquiries about the availability of the advertised housing unit and 

other similar units that would meet their needs: 

• Was the advertised housing unit available? 

• Were similar units available? 

• How many units were available? 

Testers not only inquired about the availability of housing units, but they also attempted to 

inspect units that were available for rent. Therefore, the next group of treatment indicators 

focuses on whether minority and white partners were able to inspect the advertised housing unit 

and/or other available units: 

• Was the advertised unit inspected (if available)? 

• Were similar units inspected (if available)? 

9

 Even when no statistically significant pattern of race-based differential treatment is observed, individual 

cases of discrimination may occur. Specifically, even if the net measure is not significantly different zero, there may 

in fact be instances of race-based discrimination, although the overall pattern does not systematically favor one group 

over the other. See Annex 2 for a discussion on tests of statistical significance. 

10 Note that the results presented here do not include differences in treatment that testers may have 

experienced during their appointment calls. Although discrimination may occur at this stage, we are not confident 

that agents are aware of a tester’s race or ethnicity at the time of a telephone call, and therefore have decided to limit 

our analysis to the in-person visit. 

2-15 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

• How many units were inspected? 

The third group of treatment indicators explores potential differences in the costs quoted to 

minority and white testers for comparable housing:11 

• How much was the rent for the advertised unit (if available)? 

• Were rental incentives offered? 

• How large a security deposit was required? 

• Was an application fee required?12 

Finally, the last group of treatment measures for rental tests assesses the extent to which 

agents encouraged or helped minority and white testers to complete the rental transaction: 

• Did the agent make follow-up contact? 

• Was the tester asked to complete an application? 

• Was the tester told that a credit check was required?13 

• Were arrangements made for future contact? 

Indicators of adverse treatment in sales housing transactions address five critical 

aspects of the interaction between a homebuyer and a real estate agent. The first group of 

indicators focuses on the extent to which minority and white partners received comparable 

information in response to their inquiries about the availability of the advertised home and other 

similar homes that would meet their needs: 

• Was the advertised housing unit available? 

• Were similar units available? 

• How many units were available? 

Testers not only inquired about the availability of homes, but they also attempted to inspect 

homes that were available. Therefore, the next group of treatment indicators focuses on 

whether minority and white partners were able to inspect the advertised home and/or other 

available homes: 

11 For both rent and security deposit, we performed a manual match of addresses to confirm that the units 

identified as the “advertised unit” to the white and minority partners were the same. Any difference in dollar amounts 

between the white and minority tester was counted as a difference in treatment. 

12 Requiring an application fee from one tester but not from the other is viewed as unfavorable treatment 

because it raises the cost of housing search. 

13 This indicator was not included in Phase I because the information needed to construct it was not 

available for HDS 1989. 

2-16 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

• Was the advertised unit inspected (if available)? 

• Were similar units inspected (if available)? 

• How many units were inspected? 

The third group of treatment indicators explores potential differences in the neighborhoods 

where homes were made available for minority and white homebuyers:14 

• Average percent white for neighborhoods where recommended homes were located. 

• Average percent white for neighborhoods where inspected homes were located. 

Real estate agents can play an important role in helping homebuyers learn about mortgage 

financing options. Therefore, the fourth group of sales treatment indicators assesses the 

financing assistance agents provided to minority and white homebuyers: 

• Was help with financing offered? 

• Did the agent “pre-qualify” the tester for mortgage financing? 

• Were specific lenders recommended? 

Finally, the last group of treatment measures for sales tests assesses the extent to which 

agents encouraged or helped minority and white testers to complete the sales transaction: 

• Did the agent make follow-up contact? 

• Was the tester told that he or she must be pre-qualified before seeing an agent? 

• Was the tester told he or she was qualified to buy a home? 

• Were arrangements made for future contacts? 

Summary Indicators. In addition to presenting results for all of the individual treatment 

indicators discussed above, this report combines these individual indicators to create composite 

measures for categories of treatment (such as housing availability or housing costs) as well as 

for the transaction as a whole.15 The first type of composite classifies tests as white-favored if 

the white tester received favorable treatment on one or more individual items, while his or her 

minority partner received no favorable treatment. Tests are classified as “neutral” if one tester 

was favored on some individual treatment items and his or her partner was favored on even one 

item. This approach has the advantage that it identifies tests where one partner was 

14 A difference in the average racial composition of neighborhoods for white and minority testers was 

counted as a difference in treatment only if it exceeded 5 percentage points. 

15 Again, it is important to emphasize the difference between methods used for the statistical analysis of 

paired testing results and methods used to assemble or assess evidence of unlawful conduct in an individual case. 

No pre-determined set of decision criteria can substitute for case-by-case judgments about test results. 

2-17 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

unambiguously favored over the other. But it may incorrectly classify tests as neutral when one 

tester received favorable treatment on several items, while his or her partner was favored on 

only one. This approach also classifies tests as neutral if one tester was favored on the most 

important item while his or her partner was favored on items of lesser significance. Therefore, it 

may understate the overall incidence of differential treatment across indicators, but nonetheless 

provides a very useful measure of the consistency of adverse treatment. 

In addition to the consistency approach, hierarchical composites were constructed by 

considering the relative importance of individual treatment measures to determine whether one 

tester was favored over the other. For each category of treatment measures (and for the overall 

test experience), a hierarchy of importance was established independent of analysis of the 

testing results. For example, in the availability category, if the white tester was told that the 

advertised home was available, while the minority was told it was no longer available, then the 

white tester was deemed to be favored overall, even if the minority was favored on less 

important items. Exhibit 2-5 presents the decision rules used to create composite measures of 

differential treatment for both rental and sales tests. The hierarchical composites offer the 

advantage of reflecting important differences in the treatment of minorities and whites. But 

because random differences on a single treatment indicator may cause a test to be classified as 

white-favored or minority-favored, the gross hierarchical composite measures may overstate the 

incidence of systematic discrimination. Therefore, we present both consistency composites and 

hierarchical composites for the overall testing experience. 

2-18 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 2-5: Construction of Hierarchical Composites 

Rental Availability 

Advertised Unit Available? 1 

Similar Units Available? 2 

Number of Units Available 3 

Rental Inspection 

Advertised Unit Inspected? 1 

Similar Units Inspected? 2 

Number of Units Inspected 3 

Rental Cost 

Rent for Advertised Unit 1 

Rental Incentives Offered? 2 

Amount of Security Deposit 3 

Application Fee Required? 4 

Rental Encouragement 

Follow-up Contact from Agent? 1 

Asked to Complete Application? 2 

Credit Check Required? 3 

Arrangements for Future? 4 

Overall Rental Treatment 

Advertised Unit Available? 1 

Advertised Unit Inspected? 2 

Rent for Advertised Unit 3 

Similar Units Available? 4 

Similar Units Inspected? 5 

Number of Units Available 6 

Number of Units Inspected 7 

Rental Incentives Offered? 8 

Amount of Security Deposit 9 

Application Fee Required? 10 

Follow-up Contact from Agent? 11 

Asked to Complete Application? 12 

Credit Check Required? 13 

Arrangements for Future? 14 

Sales Availability 

Advertised Unit Available? 1 

Similar Units Available? 2 

Number of Units Available 3 

Sales Inspection 

Advertised Unit Inspected? 1 

Similar Units Inspected? 2 

Number of Units Inspected 3 

Geographic Steering 

Steering – Homes Recommended -

Steering – Homes Inspected -

Financing Assistance 

Help with Financing Offered? 1 

Agent Pre-Qualified Tester? 2 

Lenders Recommended? 3 

Sales Encouragement 

Follow-up Contact from Agent? 1 

Pre-Qualification Required? 2 

Told Qualified to Buy? 3 

Arrangements for Future? 4 

Overall Sales Treatment 

Advertised Unit Available? 1 

Advertised Unit Inspected? 2 

Similar Units Available 3 

Similar Units Inspected? 4 

Steering – Homes Recommended 5 

Number of Units Available 6 

Steering – Homes Inspected 7 

Number of Units Inspected 8 

Help with Financing Offered? 9 

Agent Pre-Qualified Tester? 10 

Lenders Recommended? 11 

Follow-up Contact from Agent? 12 

Pre-Qualification Required? 13 

Told Qualified to Buy? 14 

Arrangements for Future? 15 

2-19 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

3. STATE ESTIMATES OF DISCRIMINATION AGAINST AMERICAN INDIANS 

No previous testing studies have focused on systematically measuring the incidence and 

forms of discrimination against American Indian homeseekers. As discussed in chapters 1 and 

2, Phase III of HDS2000 produced state-level estimates of discrimination against American 

Indian renters in Minnesota, Montana, and New Mexico, as well as estimates of discrimination 

against American Indian homebuyers in New Mexico. 

Montana Rental Testing Results 

During the fall of 2002 (and early 2003), 121 American Indian/white rental tests were 

conducted in three Montana metropolitan areas: Billings, Great Falls and Missoula. These 

metropolitan areas account for 100 percent of Montana’s metropolitan American Indian 

population. 

Housing Availability. In 

Montana, American Indians inquiring 

about recently advertised rental 

housing experience significant adverse 

treatment with respect to availability 

(see Exhibit 3-1). In 10.0 percent of 

tests, only the white tester was told 

about the availability of units similar to 

the advertised unit (compared to only 

4.0 percent of tests in which American 

Indians were favored). And whites 

were told about more available units 

than their Indian counterparts in 17.3 

percent of tests (compared to only 5.6 percent Indian-favored). Overall, whites were favored 

with respect to housing availability in 18.2 percent of tests (compared to only 8.7 percent Indianfavored). The lower-bound (net) measures of systematic discrimination are statistically 

significant for the availability of similar units (6.0 percent), the number of available units (11.6 

percent), and the overall availability composite (9.5 percent). 

A 43-year old American Indian woman 

herself. 

The building manager 

any alternatives. 

She 

le, 

visited an apartment building in Billings, asking 

about a one-bedroom apartment to live in by 

She was looking to pay between $250 

and $300 per month in rent. 

told her that the advertised unit was no longer 

available, and did not tell her about or show her 

A few hours later, a 55-year old 

white woman met with the same building manager, 

and asked about the same type of apartment. 

was told that the advertised unit was still availab

and she was able to walk through it that afternoon. 

3-1 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-1: Differential Treatment for Housing Availability, 

American Indian/White Rental Tests, Montana 

HOUSING AVAILABILITY 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit available? 

Similar units available? 

Number units available 

Overall availability 

7.3% 3.1% 4.3% 

10.0% 4.0% 6.0% * 

17.3% 5.6% 11.6% ** 

18.2% 8.7% 9.5% ** 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Housing Inspections. We find no statistically significant evidence of systematic 

adverse treatment with respect to housing inspections for American Indian renters in Montana’s 

metropolitan areas. As shown in Exhibit 3-2, none of the lower-bound (net) estimates of 

discrimination are statistically significant. 

Exhibit 3-2: Differential Treatment for Housing Inspections, 

American Indian/White Rental Tests, Montana 

HOUSING INSPECTION 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit inspected? 

Similar units inspected? 

Number units inspected 

Overall inspection 

7.1% 4.8% 2.2% 

2.4% 0.9% 1.4% 

8.7% 6.9% 1.8% 

8.7% 9.4% -0.7% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Housing Costs. We also find no statistically significant evidence of systematic adverse 

treatment with respect to housing costs in Montana’s metropolitan rental markets. As shown in 

Exhibit 3-3, none of the lower-bound (net) estimates of discrimination are statistically significant. 

3-2 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-3: Differential Treatment for Housing Costs, 

American Indian/White Rental Tests, Montana 

HOUSING COST 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Rent for advertised unit 

Rental incentives offered? 

Amount of security deposit 

Application fee required? 

Overall cost 

5.2% 5.3% -0.1% 

2.4% 2.0% 0.4% 

7.0% 7.5% -0.5% 

4.1% 1.0% 3.1% 

11.6% 9.4% 2.2% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Agent Encouragement. We find no statistically significant evidence of systematic 

adverse treatment with respect to agent encouragement for American Indian renters in 

Montana’s metropolitan areas. As shown in Exhibit 3-4, none of the lower-bound (net) 

estimates of discrimination are statistically significant. 

Exhibit 3-4: Differential Treatment for Agent Encouragement, 

American Indian/White Rental Tests, Montana 

AGENT ENCOURAGEMENT 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Follow-up contact from agent? 

Asked to complete application? 

Credit check required? 

Arrangements for future? 

Overall encouragement 

1.7% 0.0% 1.7% 

18.9% 11.2% 7.7% 

5.6% 9.6% -4.0% 

12.6% 13.0% -0.4% 

31.2% 22.0% 9.2% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Summary Indicators. In Montana, the statistically significant evidence of discrimination 

in rental housing availability does not yield significant lower-bound estimates for the overall 

composite indicators (see Exhibit 3-5). However, white renters in Montana’s metropolitan 

housing markets were consistently favored over the American Indian counterparts in 28.6 

percent of tests. 

3-3 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-5: Summary Indicators of Differential Treatment, 

American Indian/White Rental Tests, Montana 

SUMMARY MEASURES 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Hierarchical 

Consistency 

39.7% 32.0% 7.7% 

28.6% 24.1% 4.5% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Minnesota Rental Testing Results 

During the fall of 2002, 51 American Indian/white rental tests were conducted in two 

Minnesota metropolitan areas: Minneapolis-St. Paul and Duluth.1

 These metropolitan areas 

account for 97 percent of Minnesota’s metropolitan American Indian population. Despite the 

small sample size, these tests provide some statistically reliable information about patterns of 

discrimination against American Indians searching for rental housing in Minnesota’s 

metropolitan area. 

Housing Availability. In 

Minnesota, American Indians 

inquiring about recently advertised 

rental housing experience 

significant adverse treatment with 

respect to availability (see Exhibit 

3-6). The lower-bound (net) 

measures of systematic 

discrimination are not statistically 

significant for any of the individual 

treatment measures. But the 

overall estimate of adverse 

treatment on housing availability 

indicates that whites are favored 

over comparable American Indians 

in 31.1 percent of tests, compared 

had seen. 

$2,285 per month. 

two other apartments in the property that she might want 

to consider. 

property later in the day and made a comparable request 

In Minneapolis, an American Indian woman visited 

a rental property to inquire about an advertisement she 

She and her husband were looking for a twobedroom apartment, and could afford to pay as much as 

The rental agent told her that although 

the advertised unit was no longer available, there were 

 She was able to inspect one of them. 

However, when her white partner visited the same 

of the same rental agent, she was told that the advertised 

unit was available, along with two other apartments, and 

she was able to inspect all three of the available units. 

1

 As discussed in Chapter 2, the local testing organization in Minnesota had difficulty completing the target 

number of tests in the time available. However, because some of the differences in treatment were large (yielding net 

measures over 12 percentage points), they provide statistically reliable evidence of discrimination. 

3-4 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

to only 15.5 percent Indian-favored treatment. The lower-bound (net) estimate of systematic 

discrimination for this composite indicator is statistically significant at 15.7 percent. 

Exhibit 3-6: Differential Treatment for Housing Availability, 

American Indian/White Rental Tests, Minnesota 

HOUSING AVAILABILITY 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit available? 

Similar units available? 

Number units available 

Overall availability 

7.8% 3.9% 3.9% 

13.7% 7.8% 5.9% 

25.5% 17.5% 8.0% 

31.3% 15.5% 15.7% * 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Housing Inspections. We find no statistically significant evidence of systematic 

adverse treatment with respect to housing inspections for American Indian renters in 

Minnesota’s metropolitan areas. As shown in Exhibit 3-7, none of the lower-bound (net) 

estimates of discrimination are statistically significant. 

Exhibit 3-7: Differential Treatment for Housing Inspections, 

American Indian/White Rental Tests, Minnesota 

HOUSING INSPECTION 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit inspected? 

Similar units inspected? 

Number units inspected 

Overall inspection 

15.5% 9.8% 5.7% 

15.7% 5.8% 9.9% 

23.4% 13.6% 9.8% 

29.3% 17.6% 11.7% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Housing Costs. We also find no statistically significant evidence of systematic adverse 

treatment with respect to housing costs in Minnesota’s metropolitan rental markets. As shown 

in Exhibit 3-8, none of the lower-bound (net) estimates of discrimination are statistically 

significant. 

3-5 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-8: Differential Treatment for Housing Costs, 

American Indian/White Rental Tests, Minnesota 

HOUSING COST 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Rent for advertised unit 

Rental incentives offered? 

Amount of security deposit 

Application fee required? 

Overall cost 

0.0% 7.4% -7.4% 

8.4% 2.1% 6.3% 

3.7% 2.6% 1.1% 

2.0% 0.0% 2.0% 

11.8% 7.9% 3.9% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Agent Encouragement. We find no statistically significant evidence of systematic 

adverse treatment with respect to agent encouragement for American Indian renters in 

Minnesota’s metropolitan areas. As shown in Exhibit 3-9, none of the lower-bound (net) 

estimates of discrimination are statistically significant. 

Exhibit 3-9: Differential Treatment for Agent Encouragement, 

American Indian/White Rental Tests, Minnesota 

AGENT ENCOURAGEMENT 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Follow-up contact from agent? 

Asked to complete application? 

Credit check required? 

Arrangements for future? 

Overall encouragement 

3.9% 1.9% 1.9% 

17.5% 11.8% 5.7% 

8.0% 11.7% -3.7% 

23.5% 11.9% 11.7% 

41.1% 29.4% 11.7% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Summary Indicators. Despite the fact that only the housing availability indicators 

showed evidence of systematic discrimination against American Indian renters in Minnesota, the 

overall indicators of adverse treatment are statistically significant (see Exhibit 3-10). The 

hierarchical composite shows that white renters were favored over comparable American 

Indians in 54.7 percent of tests, with a statistically significant lower-bound (net) discrimination 

estimate of 21.3 percent. Moreover, white renters in Minnesota’s metropolitan housing markets 

were consistently favored over the American Indian counterparts in 33.3 percent of tests. 

3-6 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-10: Summary Indicators of Differential Treatment, 

American Indian/White Rental Tests, Minnesota 

SUMMARY MEASURES 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Hierarchical 

Consistency 

54.7% 33.4% 21.3% * 

33.3% 13.8% 19.5% ** 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

New Mexico Rental Testing Results 

During the fall of 2002 (and early 2003), 125 American Indian/white rental tests were 

conducted in three New Mexico metropolitan areas: Albuquerque, Las Cruces, and Santa Fe. 

These metropolitan areas account for 100 percent of New Mexico’s metropolitan American 

Indian population. 

Housing Availability. In New 

Mexico, American Indians inquiring 

about recently advertised rental housing 

experience significant adverse 

treatment for every indicator of 

availability (see Exhibit 3-11). In 12.3 

percent of tests, only the white tester 

was told that the advertised housing 

unit was available, compared to 4.7 

percent of tests in which the Indian was 

favored over his or her white partner. In 

16.9 percent of tests, only the white 

tester was told about the availability of 

units similar to the advertised unit 

(compared to 4.1 percent of tests in 

which American Indians were favored). 

And whites were told about more 

available units than their Indian 

In Albuquerque, a 21-year old American 

She was looking for a 

$775. 

might consider. 

Indian woman visited an apartment complex to 

inquire about the availability of an apartment for 

herself and her husband. 

two-bedroom apartment for between $725 and 

She was told that the advertised unit was 

available, and told about another possible unit she 

However, the rental agent was not 

able to show her any apartments. Later that day, 

a 24-year old white woman visited the same 

complex, also inquiring about the availability of 

two-bedroom apartments in the same rent range. 

She met with the same agent, who told her that 

the advertised apartment was indeed available, as 

well as three other possible units, and gave her 

the opportunity to inspect one of these apartments 

to see whether she liked it. 

counterparts in 27.6 percent of tests 

(compared to only 11.0 percent Indian-favored). Overall, whites were favored with respect to 

housing availability in 31.7 percent of tests (compared to 13.5 percent Indian-favored). The 

lower-bound (net) measures of systematic discrimination are statistically significant for the 

3-7 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

availability of the advertised unit (7.6 percent), availability of similar units (12.8 percent), the 

number of available units (16.5 percent), and the overall availability composite (18.2 percent). 

Exhibit 3-11: Differential Treatment for Housing Availability, 

American Indian/White Rental Tests, New Mexico 

HOUSING AVAILABILITY 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit available? 

Similar units available? 

Number units available 

Overall availability 

12.3% 4.7% 7.6% ** 

16.9% 4.1% 12.8% ** 

27.6% 11.0% 16.5% ** 

31.7% 13.5% 18.2% ** 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Housing Inspections. We find no statistically significant evidence of systematic 

adverse treatment with respect to housing inspections for American Indian renters in New 

Mexico’s metropolitan areas. As shown in Exhibit 3-12, none of the lower-bound (net) estimates 

of discrimination are statistically significant. 

Exhibit 3-12: Differential Treatment for Housing Inspections, 

American Indian/White Rental Tests, New Mexico 

HOUSING INSPECTION 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit inspected? 

Similar units inspected? 

Number units inspected 

Overall inspection 

9.6% 8.0% 1.6% 

3.9% 4.1% -0.2% 

16.8% 13.7% 3.1% 

18.4% 14.5% 3.9% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Housing Costs. We also find no statistically significant evidence of systematic adverse 

treatment with respect to housing costs in New Mexico’s metropolitan rental markets. As shown 

in Exhibit 3-13, none of the lower-bound (net) estimates of discrimination are statistically 

significant. 

3-8 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-13: Differential Treatment for Housing Costs, 

American Indian/White Rental Tests, New Mexico 

HOUSING COST 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Rent for advertised unit 

Rental incentives offered? 

Amount of security deposit 

Application fee required? 

Overall cost 

7.0% 9.7% -2.8% 

7.3% 7.3% 0.0% 

5.9% 8.1% -2.2% 

4.5% 6.7% -2.2% 

12.5% 16.7% -4.2% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Agent Encouragement. We find no statistically significant evidence of systematic 

adverse treatment with respect to agent encouragement for American Indian renters in New 

Mexico’s metropolitan areas. As shown in Exhibit 3-14, none of the lower-bound (net) estimates 

of discrimination are statistically significant. 

Exhibit 3-14: Differential Treatment for Agent Encouragement, 

American Indian/White Rental Tests, New Mexico 

AGENT ENCOURAGEMENT 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Follow-up contact from agent? 

Asked to complete application? 

Credit check required? 

Arrangements for future? 

Overall encouragement 

3.1% 4.1% -1.0% 

18.6% 13.7% 4.9% 

19.2% 12.3% 6.9% 

20.3% 22.8% -2.5% 

37.1% 33.6% 3.4% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

Summary Indicators. In New Mexico as in Minnesota, even though only the housing 

availability indicators showed evidence of systematic discrimination against American Indian 

renters, the overall indicators of adverse treatment are statistically significant (see Exhibit 3-15). 

The hierarchical composite shows that white renters were favored over comparable American 

Indians in 54.8 percent of tests, with a statistically significant lower-bound (net) discrimination 

estimate of 19.0 percent. Moreover, white renters in Minnesota’s metropolitan housing markets 

were consistently favored over the American Indian counterparts in 25.7 percent of tests. 

3-9 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-15: Summary Indicators of Differential Treatment, 

American Indian/White Rental Tests, New Mexico 

SUMMARY MEASURES 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Hierarchical 

Consistency 

54.8% 35.8% 19.0% ** 

25.7% 17.1% 8.6% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

New Mexico Sales Testing Results 

During the fall of 2002, 100 American Indian/white sales tests were conducted in three 

New Mexico metropolitan areas: Albuquerque, Las Cruces, and Santa Fe. These metropolitan 

areas account for 100 percent of New Mexico’s metropolitan American Indian population. 

Housing Availability. Unlike New Mexico’s rental market, we find no statistically 

significant evidence of systematic adverse treatment with respect to housing availability for 

American Indian homebuyers in New Mexico’s metropolitan areas. As shown in Exhibit 3-16, 

none of the lower-bound (net) estimates of discrimination are statistically significant. 

Exhibit 3-16: Differential Treatment for Housing Availability, 

American Indian/White Sales Tests, New Mexico 

HOUSING AVAILABILITY 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit available? 

Similar units available? 

Number units available 

Overall availability 

14.1% 15.7% -1.6% 

17.0% 18.0% -0.9% 

44.0% 44.0% -0.1% 

45.2% 44.8% 0.3% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 % 

level, and ** indicates significance at the 95% level (using a two-tailed test). Gross estimates 

are by definition statistically significant. 

Housing Inspections. Similarly, there is no statistically significant evidence of 

systematic adverse treatment against American Indians with respect to housing inspections in 

New Mexico’s metropolitan sales markets. As shown in Exhibit 3-17, none of the lower-bound 

(net) estimates of discrimination are statistically significant. 

3-10 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-17: Differential Treatment for Housing Inspections, 

American Indian/White Sales Tests, New Mexico 

HOUSING INSPECTION 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit inspected? 

Similar units inspected 

Number units inspected 

Overall inspection 

14.0% 17.8% -3.7% 

13.0% 19.0% -6.0% 

41.1% 40.0% 1.1% 

41.3% 41.9% -0.6% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 % 

level, and ** indicates significance at the 95% level (using a two-tailed test). Gross estimates 

are by definition statistically significant. 

Geographic Steering. American Indian homebuyers in New Mexico’s metropolitan 

areas do appear to face significant racial steering (see Exhibit 3-18). In 24.0 percent of tests, 

whites were shown homes in more predominantly white neighborhoods than their Indian 

partners, compared to only 11.0 percent of tests in which American Indians were shown homes 

in more predominantly white neighborhoods. Differences in the racial composition of 

neighborhoods where homes were recommended to whites and Indians were not statistically 

significant. 

Exhibit 3-18: Geographic Steering, 

American Indian/White Sales Tests, New Mexico 

GEOGRAPHIC STEERING 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Steering - homes recommended 

Steering - homes inspected 

23.0% 18.0% 5.0% 

24.0% 11.0% 13.1% ** 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 % 

level, and ** indicates significance at the 95% level (using a two-tailed test). Gross estimates 

are by definition statistically significant. 

Financing Assistance. We find no statistically significant evidence of systematic 

adverse treatment with respect to financing assistance for American Indian homebuyers in New 

Mexico’s metropolitan areas. As shown in Exhibit 3-19, none of the lower-bound (net) estimates 

of discrimination are statistically significant. 

3-11 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-19: Differential Treatment for Financing Assistance, 

American Indian/White Sales Tests, New Mexico 

FINANCING ASSISTANCE 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Help with financing offered? 

Agent prequalified tester? 

Lenders recommended? 

Overall financing 

24.9% 19.0% 5.9% 

21.9% 24.1% -2.2% 

18.9% 16.1% 2.8% 

38.0% 36.1% 1.8% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 % 

level, and ** indicates significance at the 95% level (using a two-tailed test). Gross estimates 

are by definition statistically significant. 

Agent Encouragement. We also find no statistically significant evidence of systematic 

adverse treatment with respect to agent encouragement for American Indian homebuyers in 

New Mexico’s metropolitan areas. As shown in Exhibit 3-20, none of the lower-bound (net) 

estimates of discrimination are statistically significant. 

Exhibit 3-20: Differential Treatment for Agent Encouragement, 

American Indian/White Sales Tests, New Mexico 

AGENT ENCOURAGEMENT 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Follow-up contact from agent? 

Prequalification required? 

Told qualified? 

Arrangements for future? 

Overall encouragement 

16.0% 16.1% -0.1% 

8.1% 7.9% 0.1% 

1.0% 0.0% 1.0% 

7.0% 9.0% -2.0% 

26.1% 28.1% -2.0% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 % 

level, and ** indicates significance at the 95% level (using a two-tailed test). Gross estimates 

are by definition statistically significant. 

Summary Indicators. In New Mexico’s metropolitan sales markets, the statistically 

significant evidence of geographic steering does not yield significant lower-bound estimates for 

the overall composite indicators (see Exhibit 3-21). However, white homebuyers in New 

Mexico’s metropolitan housing markets were consistently favored over the American Indian 

counterparts in 16.9 percent of tests. 

3-12 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 3-21: Summary Indicators of Differential Treatment, 

American Indian/White Sales Tests, New Mexico 

SUMMARY MEASURES 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Hierarchical 

Consistency 

52.1% 46.9% 5.2% 

16.9% 16.9% 0.0% 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 % 

level, and ** indicates significance at the 95% level (using a two-tailed test). Gross estimates 

are by definition statistically significant. 

3-13 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

4. CONCLUSIONS AND IMPLICATIONS 

This phase of HDS2000 represents an initial, exploratory effort to extend rigorous 

research testing to measure the extent to which American Indians face systematic 

discrimination when they search for housing in metropolitan areas. Compared to other racial 

and ethnic minorities in the U.S., the American Indian population is small and geographically 

concentrated; so we focused on producing a limited number of state-level estimates of 

discrimination rather than a single set of nationwide results. This chapter briefly reviews these 

initial findings, and discusses the implications of this exploratory effort for future research on 

housing discrimination against American Indians. 

Summary of Findings 

In the metropolitan housing markets of Minnesota, Montana, and New Mexico, American 

Indian renters experience significant adverse treatment with respect to housing availability. 

Exhibit 4-1 presents pooled results of our rental testing across all three of these states. In 10.3 

percent of the tests, American Indians were told that the advertised unit was no longer available, 

while their white partners were told that it was available. In contrast, American Indians were 

favored over whites with respect to availability of the advertised unit in only 4.3 percent of tests. 

In 15.1 percent of tests, only the white tester was told about the availability of units similar to the 

advertised unit (compared to only 5.3 percent of tests in which American Indians were favored). 

And whites were told about more available units than their Indian counterparts in 25.7 percent of 

tests (compared to only 12.5 percent Indian-favored). Overall, whites were favored with respect 

to housing availability in 30.0 percent of tests (compared to only 13.6 percent Indian-favored). 

The lower-bound (net) measures of systematic discrimination are statistically significant for all of 

the treatment indicators in this category: availability of the advertised unit (6.1 percent), 

availability of similar units (9.8 percent), number of available units (13.2 percent), and the overall 

availability composite (16.4 percent). 

This pattern of discrimination across all indicators of rental housing availability is striking 

in comparison to results from earlier phases of HDS2000. It suggests that American Indians 

may be more likely than African Americans, Hispanics, or Asians and Pacific Islanders to be 

denied access to available rental housing in metropolitan areas. More specifically, the lowerbound (net) estimates of discrimination on housing availability at the national level were 4.6 

percent for African American renters, 12.4 percent for Hispanic renters, and not statistically 

significant for Asian and Pacific Islander renters. Although the three-state estimate of 16.4 

percent for American Indians is not directly comparable, it does stand out as a strikingly high 

level of discrimination on the most basic aspect of the rental housing transaction. 

4-1 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Exhibit 4-1: Pooled Estimates of Differential Treatment, 

American Indian/White Rental Tests, Minnesota, Montana, and New Mexico 

HOUSING AVAILABILITY 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit available? 

Similar units available? 

Number units available 

Overall availability 

10.3% 4.3% 6.1% ** 

15.1% 5.3% 9.8% ** 

25.7% 12.5% 13.2% ** 

30.0% 13.6% 16.4% ** 

HOUSING INSPECTION 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Advertised unit inspected? 

Similar units inspected? 

Number units inspected 

Overall inspection 

11.2% 8.2% 3.0% 

7.5% 4.3% 3.2% 

18.0% 12.9% 5.1% 

20.8% 14.9% 5.9% * 

HOUSING COST 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Rent for advertised unit 

Rental incentives offered? 

Amount of security deposit 

Application fee required? 

Overall cost 

4.5% 8.5% -3.9% 

7.1% 5.0% 2.1% 

5.3% 6.3% -1.0% 

3.7% 3.9% -0.2% 

12.2% 13.0% -0.9% 

AGENT ENCOURAGEMENT 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Follow-up contact from agent? 

Asked to complete application? 

Credit check required? 

Arrangements for future? 

Overall encouragement 

3.2% 2.9% 0.2% 

18.3% 12.8% 5.5% * 

14.0% 11.8% 2.2% 

20.5% 18.2% 2.3% 

37.7% 31.0% 6.7% 

SUMMARY MEASURES 

Differential Treatment in 2002 

% white 

favored 

% AI 

favored net measure 

Hierarchical 

Consistency 

53.0% 34.6% 18.4% ** 

28.5% 16.9% 11.6% ** 

Note: For net estimates and change estimates, * indicates statistical significance at the 90 

% level, and ** indicates significance at the 95% level (using a two-tailed test). Gross 

estimates are by definition statistically significant. 

The pooled rental testing results also suggest that American Indians may face 

systematic discrimination in housing inspections and at least one indicator of agent 

encouragement. Specifically, whites were favored with respect to the composite indicator for 

housing inspections in 20.8 percent of tests, compared to 14.9 percent in which American 

4-2 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Indians were favored. The lower-bound (net) measure of systematic discrimination on this 

indicator was statistically significant at 5.9 percent. In addition, only the white tester was invited 

to complete an application in 18.3 percent of tests, compared to 12.8 percent in which only the 

American Indian tester received such an invitation. For this indicator, the lower-bound (net) 

measure was statistically significant at 5.5 percent. However, neither of these treatment 

measures was statistically significant for the individual state estimates. 

Even though housing availability appears to be the primary form of adverse treatment 

experienced by American Indian renters in Minnesota, Montana, and New Mexico, the overall 

indicators of adverse treatment are also high and statistically significant. The hierarchical 

composite shows that white renters were favored over comparable American Indians in 53.0 

percent of tests, with a statistically significant lower-bound (net) discrimination estimate of 18.4 

percent. Again, this lower-bound (net) estimate of discrimination against American Indians is 

high compared to national estimates for African Americans (8.4 percent) and Hispanics (13.8 

percent). 

Results are far less conclusive for discrimination against American Indian homebuyers. 

As discussed in chapter 2, sales testing was conducted only in New Mexico. American Indian 

homebuyers in New Mexico’s metropolitan housing markets appear to face systematic 

discrimination with respect to geographic steering, but on other indicators the estimated levels 

of systematic discrimination were not statistically significant. And the overall (net) estimates of 

discrimination were not statistically significant. These results should be interpreted with caution, 

since they are based on only 100 tests in a single state. 

Implications for Future Research Testing 

Phase III of HDS2000 has established that it is feasible to conduct rigorous research 

testing for discrimination against American Indians searching for housing in metropolitan areas, 

and that serious levels of discrimination exist, at least in metropolitan rental markets. Clearly, 

the problem of discrimination against American Indian homeseekers deserves continued 

research and policy attention. However, this exploratory effort encountered substantial 

challenges, with implications for ongoing research. 

First, the population of American Indians living in metropolitan areas is relatively small 

and highly concentrated in a few states. For policy purposes, therefore, it makes more sense to 

continue to produce estimates of discrimination against American Indians at the state or 

metropolitan level, rather than attempting to design a meaningful nationwide sample of sites. 

Potentially important additional states to cover would include Arizona, Oklahoma, California, and 

Alaska, all of which have significant populations of American Indians living in metropolitan 

areas. 

4-3 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

In all of these states, it is critical to conduct testing in small metropolitan areas (like 

Billings, Montana and Las Cruces, New Mexico), as well as in larger metropolitan areas. 

However, conducting a large volume of tests in a small metropolitan market can be difficult, 

because these areas often lack experienced testing organizations and testers, the number of 

rental and sales agents may be relatively small and close-knit, and a large number of visits by 

minority homeseekers over a short time period may arouse suspicion. Distributing the testing 

activity across several metropolitan areas in a state can produce a reasonable statewide sample 

size without saturating any individual market. However, deploying testers to several different 

locations throughout a state also poses logistical challenges and increases costs. 

Moreover, as discussed in chapter 2, few local testing organizations have much 

experience working with American Indians and experienced American Indian testers are scarce. 

This makes it particularly difficult to recruit and retain a sufficient pool of testers to conduct a 

large volume of research tests over a two- to four-month period of time. One solution to this 

problem would be to form partnerships between experienced testing organizations and one or 

more local organizations that have strong ties to the American Indian community. The Indian 

organizations could assist in recruiting a wider diversity of American Indian testers and providing 

supplemental training and supports to ensure that testers do not become discouraged by the 

process. Ideally, American Indians could also be recruited and trained to serve as Test 

Coordinators as well. 

In addition, in order to recruit and retain a substantial pool of well-qualified American 

Indian testers, it might be necessary to hire testers on a full-time rather than a part-time basis. 

Supplemental funding for tester transportation, cell phones, and other work-related expenses 

would also reduce the burden on American Indian testers and provide greater incentives for 

them to focus on the quality of testing. This would be particularly important for further testing in 

the sales market, given the difficulty of conducting high-quality sales tests. 

All of the strategies outlined here would require longer time periods for further research 

testing on discrimination against American Indians. In large metropolitan areas where 

experienced testing organizations and testers exist and numerous rental and sales opportunities 

thrive, it is feasible to conduct 75 to 100 tests (per tenure) over a two- to four-month period. 

However, in general, given the challenges involved in measuring discrimination against 

American Indians, it would make more sense to extend this time period to as much as six 

months. 

4-4 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

REFERENCES 

Farley, Reynolds. 1996. “Racial Differences in the Search for Housing: Do Whites and Blacks 

Use the Same Techniques to Find Housing.” Housing Policy Debate 7(2): 367-386. 

Fix, Michael and Raymond J. Struyk. 1992. Clear and Convincing Evidence: Testing for 

Discrimination in America. Washington, D.C.: Urban Institute Press. 

Galster, George, Fred Freiberg, and Diane Houk. 1987. “Racial Differences in Real Estate 

Advertising Practices: An Exploratory Case Study.” Journal of Urban Affairs. 9: 199-215. 

Harris, David R. 2000. “What’s the Internet got to do with it? Housing discrimination in the 

twenty-first century.” Focus. 21(2): 63-64. 

Kingsley, G. Thomas, Maris Mikelsons, and Carla Herbig. 1996. Housing Problems and Needs 

of American Indians and Alaska Natives. Washington, D.C.: U.S. Department of 

Housing and Urban Development 

Newburger, Harriet. 1995 “Sources of Difference in Information Used by Black and Whtie 

Housing Seekers: An Exploratory Analysis.” Urban Studies. 32 (3): 445-470. 

Newburger, Eric C. 1999. “Computer Use in the United States.” Current Population Reports. 

P20-522. Washington, D.C.: U.S. Bureau of the Census. 

Roth, K. 2000. The 2000 National Association of Realtors Profile of Home Buyers and Sellers. 

Report of the National Association of Realtors. 

<http://www.nar.realtor.com/research/images/668prof.pdf> 

Turner, Margery, John Edwards, and Maris Mikelsons. 1991. Housing Discrimination Study: 

Analyzing Racial and Ethnic Steering. Washington, D.C.: U.S. Department of Housing 

and Urban Development. 

Turner, Margery, Raymond Struyk, and John Yinger. 1991. Housing Discrimination Study: 

Synthesis. Washington, D.C.: U.S. Department of Housing and Urban Development. 

Turner, Margery and Ron Wienk. 1993. “The Persistence of Segregation in Urban Areas: 

Contributing Causes.” In T. Kingsley and M. Turner (eds) Housing Markets and 

Residential Mobility. Washington, D.C.: Urban Institute Press. 

Wienk, Ron, Cliff Reid, John Simonson, and Fred Eggers. 1979. Measuring Racial 

Discrimination in Housing Markets: The Housing Market Practices Study. Washington, 

D.C.: U.S. Department of Housing and Urban Development. 

Wissoker, Douglas, Wendy Zimmerman, and George Galster. 1998. Testing for Discrimination 

in Home Insurance. Washington, D.C.: Urban Institute Press. 
ANNEX 1 

TESTS ASSIGNMENT FORMS, REPORTING FORMS, AND INSTRUCTIONS 
ADVANCE CALL FORM 

(COMPLETE ONE FORM FOR EACH CALL ATTEMPTED) 

Control # - - - 3 Person Making Call: 

Phone Number(s) ( ) ; ( ) 

Day of the Week: 

Date / / Time :  AM  PM 

1. Were you able to obtain housing information during this advance call?  Yes  No 

1a. If No, why not? 

 Left Message on Voice mail, Answering Machine, or Pager 

 Left Message with Person who did not have information 

 Told to Call Back Later 

 Wrong Number 

 No Answer 

 Telephone Number No Longer in Service 

 Other (Specify: ) 

(SKIP to Question 7) 

If Yes, Continue: 

2. Housing Information (enter one type of unit [i.e., bedroom size] per line): 

Address of Apartment/House # of 

Bedrooms 

Price Date Available 

/ / 

Advertised Unit? 

a.  Yes  No 

b.  Yes  No 

c.  Yes  No 

d.  Yes  No 

e.  Yes  No 

3. What are the office hours? 

4. Is it possible to drop in to speak with an agent about the available housing? 

 Yes (you may drop in)  No (you must have an appointment) 

5. Verify the address to be visited: 
6. With whom did you speak? : 

7. Is this the final advance call?  Yes  No 

7a. If Yes, based on the results of the advance call, is the housing ineligible for any reason? 

 Yes  No 

7b. If Yes, please specify the reason(s) for ineligibility: 

 Housing provider could not be reached after repeated attempts 

 Telephone Number was no longer in service 

 Telephone Number was incorrect 

 Outside of target area for MSA 

 Located on Indian Land (e.g., reservations, Tribal Jurisdictional Statistical Areas, etc.) 

 Seasonal/temporary/vacation/short-term 

 For Sale By Owner 

 Exceeds price range for MSA 

 Multi-unit structure for sale 

 Housing for older persons 

 Unimproved lot (housing is yet to be constructed) 

 New mobile home sale through dealership 

 Share situation 

 Apartment locator service 

 Sublet 

 Public/subsidized housing development 

 Other (specify): 

8. Based on the source of the advertisement, the wording of the advertisement, and/or 

information obtained from a rental agent during the advance call, please check the most 

appropriate response: 

 The rental advertisement does NOT refer to a specific rental unit but instead 

describes a “type” of rental housing that is generally made available by this housing 

provider (check all that apply): 

 The advertisement is from a monthly apartment guide or other source that 

only contains general rental housing advertisements. 

 The advertisement contains wording which clearly indicates the availability 

of a “type” of rental unit rather than a specific rental unit. 

 I was informed by an agent during my call that the advertisement does NOT 

refer to a specific rental housing unit. 

 Other: 
 The rental advertisement refers to a specific rental housing unit (check all that 

apply): 

 The advertisement contains the exact address of the available housing unit. 

 I was informed by an agent during my call that the advertisement does refer 

to a specific rental housing unit. 

 Other: 

 I am not sure whether the rental advertisement refers to a specific rental unit or 

whether it refers to a “type” of rental housing that is generally available through this 

housing provider. 

Comments: 

9. General Comments: 
Test Assignment Form (Rental) 

SITECODE Site UI Training Test Site

CONTROL 0 CONTROL # ZZ-R1-0125-2

SEQUENCE Tester sequence 1

RACEID RACEID *****

TESTERID 0 TESTER ID NUMBER ZZ329-Janelle Scott

ATSTTYPE 0 TYPE OF TEST rental

AAPPTYPE 0 TYPE OF APPROACH Drop-In

DATE OF VISIT ADATEV 7/15/01 (mm/dd/yy) 

ATIMEV Time (_ _:_ _) 10:00

A.M. P.M. for time of ATIMEVM AM visit 

header9 TEST SITE 

1 Name of Test site (if PPNAME ***** known) 

header11 Site Address 

PADDRS 2 street ***** 

PCITY 2 city ***** 

PSTATE 2 state ***** 

PZIP 2 ZIP 00000 ***** 

Head171 Telephone number(s) of test site: 

3 First Number (000)000- PPHN1 ***** 0000 

3 Second Number: PPHN2 ***** (000)000-0000 

header20 SOURCE OF INFORMATION ON TEST SITE 

4 Advertisement: Name SRCENAME Milwaukee Journal Sentinel of source 

5 Advertisement: Date of ADDATE 6/10/01 Publication (mm/dd/yy) 

6 Advertisement: text of CEDARBURG CEDAR PLAZA N142 W6212 ADTEXT 

ad Concord St. Suburban living within minutes of
Milwaukee. Near Hwy 57 and C 2 Bedroom 

Apartments Appliances, Carpeting, Ceiling 

Fan $630 includes HEAT, Security Deposit 

$400 1 year lease, no pets. 262-375-1513. 

header24 TYPE OF HOUSING TO BE REQUESTED 

PBEDS 7 Number of Bedrooms 

to be requested 2 

PMINBED 7a Minimum number of 

bedrooms for household 0 

PHMTYPS 8 Type of home (SALES 

only) -1 

PHMTYPR 9 Type of unit (RENTAL 

only) Unfurnished 

PHNEED 10 Date Housing is

Needed (mm/dd/yy) 8/1/01 

PHMPRI Home price ***** 

PHHCOMP 8 Household 

Composition Married Couple, No Children 

APRIR 

11 Price Range [Tester

may look at units for 

LESS than this range as 

well] (For RENTAL Only) 

605 to 655 

APREFER Area Preference (IMPORTANT: DO NOT CITE A NEIGHBORHOOD 

PREFERENCE) 

AAREAP 

12 If you are pressed by 

the agent, you may state 

that you are looking in 

Milwaukee and surrounding counties 

header33 Remember: You are always open to considering any areas 

recommended by the agent. 

AMOVERR 13 Reason for Moving 

(Rental Tests) 

Lvng with family member/friend; want own 

place 

AMOVERS 13 Reason for moving 

(Sales Tests) 

AHEAD55 Other places visited: Just started looking 

header36 ASSIGNED CHARACTERISTICS 

TFNAME 15 Tester Name: Janelle Scott 

header38 Tester Address 
TFADD1 16 Tester Address 2100 Pine Road 

16 Tester Address TFADD2 Milwaukee, Wisconson, 53205 (city/state/zip) 

16 Voice Mail Number 

TVPHONE Assigned to Tester (414)348-6788 

(000)000-0000 

header42 Information on Persons in Household 

ARACE1 18 Tester's race Black

TSEX 18 Tester's gender Female

AAGE1 18 Tester's age 25

TH01 Household Income Gross Monthly Income Gross Annual Income 

AINCMON1 18 Tester 1475 17450 

AINCMON2 18 Spouse 1150 14050 

AINCMONT 18 Total for Household 2625 31500 

TABH11 Other persons in household Relationship Name Sex Age 

Bill ARELATE2 18 Person 2 Spouse Male 26 Scott 

ARELATE3 18 Person 3 Female -1 

ARELATE4 18 Person 4 Female -1 

ARELATE5 18 Person 5 Female -1 

header73 Employment Information 

AOCC1 19 Tester current occupation Clerk 

Milwaukee 

Area AEMP1 19 Name of tester's current employer Technical 

College 

19 First line of tester's employer's AEAD11 State Street addres 

19 Second line of tester's employer's Milwaukee, AEAD12 

address WI 

AELNG1 19 Length of employment at current job 3 years 

AOCC2 19 Tester previous occupation 

AEMP2 Name of tester's previous employer 

19 First line of tester's previous AEAD21 

employer's address 
job 

19 Spouse's occupation at current job Sales 

Associate 

JC Penney 

Catalog 

Dept. 

19 First line of spouse's employer's

address 

Highland 

Mall 

address Mequon 

current job 4 years 

19 First line ofspouse's previous 

Household Assets 

20 Savings Account -1 

-1 

20 Other asset -1 

20 Total Assets -1 

Creditors Name account 

Balance 

21 Creditor 1 -1 -1 

21 Creditor 2 -1 -1 

21 Creditor 3 -1 -1 

21 Creditor 4 -1 -1 

21 Creditor 5 -1 -1 

AEAD22 19 Second line of tester's previous 

employer's address 

AELNG2 19 Length of employment at previous 

ASOCC1 

ASEMP1 19 Name of spouse's current employer 

ASEAD11 

ASEAD12 19 Second line of spouse's employer's 

ASELNG1 19 Spouse's length of employment at 

ASOCC2 19 Spouse's occupation at previous job 

ASEMP2 Name of spouse's previous employer 

ASEAD21 

employer's address 

ASEAD22 19 Second line of spouse's previous 

employer's address 

header94 

TH31 Financial Institution Balance 

ASAVINST 

ACHKINST 20 Checking Account 

AOTRINST 

ATOTASST 

header10 Household Debts 

TABH21 Type of Monthly 

payment owed 

ACRDNAM1 

ACRDNAM2 

ACRDNAM3 

ACRDNAM4 

ACRDNAM5 
ACRDNAM6 21 Creditor 6 -1 -1 

ACRDNAM7 21 Creditor 7 -1 -1 

ACRDMONT 21 Total monthly payments on all 

debts -1 

ACRDBALT 21 Total balance owed on all debts -1 

AHEAD21 Credit standing: Excellent, no late payments 

header13 CURRENT HOUSING SITUATION 

AHEAD31 Type of current housing: Rent 

ARENTNOW 24 Amount of Current Rent 620 

ALGNCUR 25 Years at Current Residence 2 years 

26 Type of Rental Agreement at ALEASETP Month-to-Month Current Residence 

AHEAD61 History of rent payment at current residence: Always on time 

AHEAD62 Other characteristics: Non-smoking, No pets 

Hwy 57 to C. Left on C 1 

ADSITE block, turn right into 

office. 

28 Directions to the Test Site 

RELEASE Test Released Yes
INSTRUCTIONS FOR ALL HDS SITE VISITS - RENTAL 

C If you made an appointment prior to this visit, please ask to speak with the 

person with whom you made the appointment to meet. If you are dropping in 

without an appointment on this site visit, please ask to speak with a rental 

agent. Express interest in and ask to view the rental housing that was 

advertised for rent. 

C Ask about the availability of other rental housing with the same number of 

bedrooms as the advertised housing. Express interest in and ask to view any 

rental housing which has the same number of bedrooms, provided that it is 

within your price range and available when you need it. 

C If a rental agent informs you that the advertised housing is no longer available 

and no other rental housing is available with the same number of bedrooms as 

the advertised housing, ask the agent if any other rental units are available for 

the time you requested. Express interest in and ask to view any other rental 

housing that: 1) has at least the minimum number of bedrooms for your 

household; 2) is within your price range; and 3) is available when you need it. 

C If, at any time during your site visit, a rental agent recommends other rental 

units to you, you should express interest in and ask to view any rental housing 

that is recommended by the agent provided it: 1) has at least the minimum 

number of bedrooms for your household; 2) is within your price range; and 3) is 

available when you need it. 

C Please remember to obtain information about the exact address (including 

apartment #), number of bedrooms, rent, security deposit, other fees, lease 

length, which utilities are included and the dates of availability for any homes 

or apartments suggested by the agent if this information is not provided by the 

end of your visit. 

C If you are told about any homes or apartments that meet your needs, please ask 

about the application process and find out what amount of money, if any, would 

need to accompany a completed application, whether a credit check is 

conducted and, generally, how long it takes to obtain approval on a rental 

application once it is submitted. 

C Do not ask for or complete a rental application. If the agent offers you an 

application, you should agree to take it with you. 

C If you are informed that there is a waiting list for rental housing that you 

requested, please ask how many people are on the waiting list. If the agent 

invites you to add your name to the waiting list, you should politely decline to 

add your name. 

C Lastly, if by the end of your visit the agent has not volunteered his or her name, 

please ask for it. 

May 22, 2001 
Test Assignment Form (Sales) 

SITECODE Site UI Training Test Site

CONTROL 0 CONTROL # ZZ-S1-0125-2

SEQUENCE Tester sequence 1

RACEID RACEID *****

TESTERID 0 TESTER ID NUMBER ZZ124-William Morrison

ATSTTYPE 0 TYPE OF TEST sales

AAPPTYPE 0 TYPE OF APPROACH Call for appointment

DATE OF VISIT ADATEV (mm/dd/yy) 

ATIMEV Time (_ _:_ _) 

ATIMEVM A.M. P.M. for time of visit 

header9 TEST SITE 

1 Name of Test site (if PPNAME ***** known) 

header11 Site Address 

PADDRS 2 street ***** 

PCITY 2 city ***** 

PSTATE 2 state ***** 

PZIP 2 ZIP 00000 ***** 

Head171 Telephone number(s) of test site: 

3 First Number (000)000- PPHN1 ***** 0000 

3 Second Number: PPHN2 ***** (000)000-0000 

header20 SOURCE OF INFORMATION ON TEST SITE 

4 Advertisement: Name of SRCENAME Milwaukee Journal Sentinel 

source 

5 Advertisement: Date of ADDATE 6/10/01 Publication (mm/dd/yy) 

GERMANTOWN Prime location 6 Advertisement: text of ADTEXT N102W14738 Providence Ct. 4BR, 2.5BA, 2 ad story on cul de sac, 3/4 ac landscaped lot. 
1996. 3000+ sq ft. FT, 1st floor utility, deck, 

office, large master suite, $339,900. 262-

253-0961. 

header24 TYPE OF HOUSING TO BE REQUESTED 

PBEDS 7 Number of Bedrooms to 

be requested 4 

PMINBED 7a Minimum number of 

bedrooms for household 2 

PHMTYPS 8 Type of home (SALES 

only) Single Family 

PHMTYPR 9 Type of unit (RENTAL 

only) -1 

PHNEED 10 Date Housing is

Needed (mm/dd/yy) 

PHMPRI Home price ***** 

PHHCOMP 8 Household Composition Married Couple, 2 Children (Same Gender) 

APRIR 

11 Price Range [Tester

may look at units for 

LESS than this range as 

well] (For RENTAL Only) 

APREFER Area Preference (IMPORTANT: DO NOT CITE A NEIGHBORHOOD 

PREFERENCE) 

AAREAP 

12 If you are pressed by 

the agent, you may state 

that you are looking in 

Milwaukee and surrounding suburbs 

header33 Remember: You are always open to considering any areas 

recommended by the agent. 

AMOVERR 13 Reason for Moving 

(Rental Tests) 

AMOVERS 13 Reason for moving 

(Sales Tests) Seems like a good time to buy 

AHEAD55 Other places visited: Just started looking 

header36 ASSIGNED CHARACTERISTICS 

TFNAME 15 Tester Name: Bill Morrison 

header38 Tester Address 

TFADD1 16 Tester Address 1620 Wisconsin Ave. 
16 Tester Address TFADD2 Apt. #42 (city/state/zip) 

16 Voice Mail Number 

TVPHONE Assigned to Tester (414)555-0000 

(000)000-0000 

header42 Information on Persons in Household 

ARACE1 18 Tester's race Black

TSEX 18 Tester's gender Male

AAGE1 18 Tester's age 39

TH01 Household Income Gross Monthly Income Gross Annual Income 

AINCMON1 18 Tester 6730 80750 

AINCMON2 18 Spouse 5045 60550 

AINCMONT 18 Total for Household 11775 141300 

TABH11 Other persons in household Relationship Name Sex Age 

ARELATE2 18 Person 2 Spouse Barbara Female 32 

ARELATE3 18 Person 3 Child William Male 6 

ARELATE4 18 Person 4 Child David Male 2 

ARELATE5 18 Person 5 Female -1 

header73 Employment Information 

District AOCC1 19 Tester current occupation Manager 

19 Name of tester's current Marriott AEMP1 

employer Services 

19 First line of tester's employer's AEAD11 64th Street addres 

19 Second line of tester's AEAD12 Wauwatosa employer's address 

19 Length of employment at current AELNG1 5 years job 

Sales AOCC2 19 Tester previous occupation Representative 

AEMP2 Name of tester's previous employer Holiday Inn 

19 First line of tester's previous AEAD21 3rd Street employer's address 

AEAD22 19 Second line of tester's previous South 
previous job 4 years 

19 Spouse's occupation at current

job 

Database 

Administrator 

19 Name of spouse's current Children's 

Medical Center 

19 First line of spouse's employer's

address 

Good Hope 

Rd. 

at current job 4 years 

job 

Computer 

Programmer 

Name of spouse's previous University of 

WI 

19 First line ofspouse's previous 

Household Assets 

20 Savings Account First Bank 35750 

First Bank 4850 

20 Other asset -1 

20 Total Assets 40600 

Creditors Name account 

Balance 

21 Creditor 1 GMAC 566 8690 

21 Creditor 2 Citibank 

Visa 

Credit 

Card 309 7720 

21 Creditor 3 

Citibank 

Master 

Card 

Credit 

Card 56 1740 

employer's address Milwaukee 

AELNG2 19 Length of employment at 

ASOCC1 

ASEMP1 

employer 

ASEAD11 

ASEAD12 19 Second line of spouse's 

employer's address Milwaukee 

ASELNG1 19 Spouse's length of employment 

ASOCC2 19 Spouse's occupation at previous 

ASEMP2 

employer 

ASEAD21 

employer's address Milwaukee 

ASEAD22 19 Second line of spouse's previous 

employer's address 

header94 

TH31 Financial Institution Balance 

ASAVINST 

ACHKINST 20 Checking Account 

AOTRINST 

ATOTASST 

header10 Household Debts 

TABH21 Type of Monthly 

payment owed 

ACRDNAM1 Car loan 

ACRDNAM2 

ACRDNAM3 
ACRDNAM4 21 Creditor 4 Macy's Credit 

Card 34 1160 

ACRDNAM5 21 Creditor 5 0 0 

ACRDNAM6 21 Creditor 6 0 0 

ACRDNAM7 21 Creditor 7 0 0 

ACRDMONT 21 Total monthly payments on all 

debts 965 

ACRDBALT 21 Total balance owed on all debts 19300 

AHEAD21 Credit standing: Excellent, no late payments 

header13 CURRENT HOUSING SITUATION 

AHEAD31 Type of current housing: Rent 

ARENTNOW 24 Amount of Current Rent 3000 

ALGNCUR 25 Years at Current Residence 4 years 

26 Type of Rental Agreement at ALEASETP Month-to-Month Current Residence 

AHEAD61 History of rent payment at current residence: Always on time 

AHEAD62 Other characteristics: Non-smoking, No pets 

Get directions at time of ADSITE 28 Directions to the Test Site appointment call 

RELEASE Test Released Yes
INSTRUCTIONS FOR ALL HDS SITE VISITS - SALES 

C If you made an appointment prior to this visit, please ask to speak with the person with 

whom you made the appointment to meet. If you are dropping in without an 

appointment on this site visit, please ask to speak with a sales agent. Express interest 

in and ask to view the housing that was advertised for sale. 

C Ask the agent to recommend other homes that have the same number of bedrooms as 

the advertised housing. Express interest in and ask to view any homes that are 

recommended by the agent provided that they have the same number of bedrooms as 

the advertised home or at least the minimum number of bedrooms for your household. 

C After viewing the advertised home, try to arrange to spend three hours looking at 

additional homes that are recommended by the agent. If, on the day of your initial site 

visit, the agent is unavailable or unable to show you the advertised home and/or other 

recommended homes, let the agent know that you would like to spend some time (e.g. 

a few hours, several hours, etc.) on another day viewing additional homes. 

C If, in response to your request that the agent recommend some homes to view, the 

agent presents you with a long list of homes available for sale, please ask the agent to 

select homes to show you so that you can begin to get an idea of what is available. If 

the agent refuses to pick out any homes on the list and insists that you make the 

selections, please tell the agent that you would like to take the list of homes with you 

so that you can spend some time looking it over. NEVER select the homes to view. 

C Please remember to obtain information about the exact address of each property that 

is recommended by the agent, including the number of bedrooms, current asking 

price, number of bathrooms, and other features and amenities, if this information is not 

provided by the end of your visit. 

C If the agent, someone in the agent’s office, or someone the agent calls while you are in 

the office, requests that you provide detailed personal and financial information about 

your income, debts, assets, etc. in order to help you figure out what price range of 

housing that you can afford, please provide this information exactly as it appears on 

your assignment form. Do not, UNDER ANY CIRCUMSTANCES, provide your date of 

birth, social security number, or authorize anyone to conduct a credit check. If 

anyone asks about your credit standing or requests that a credit check be conducted, 

offer to characterize your credit as it appears on your assignment form. If you are 

provided with an estimated price range or with an estimated mortgage amount for 

which you might qualify, please remember to include this information in your notes. 

C If you are provided more detailed information about financing options, be sure to write 

down the information that is offered (e.g. type of financing, interest rates, down 

payment requirements, etc.). Also, if the agent refers you to a lender or mortgage 

broker for further assistance with financing, please remember to include this 

information in your notes. 

C Lastly, if by the end of your visit the agent has not volunteered his or her name, please 

ask for it. 
APPOINTMENT CALL FORM 

(ALL CONTACTS WITH AGENT MADE PRIOR TO ANY SITE VISIT SHOULD BE RECORDED ON AN APPOINTMENT CALL 

FORM. COMPLETE ONE FORM FOR EACH CALL ATTEMPTED BY TESTER OR RECEIVED FROM AGENT.) 

Control # - - - 3 Tester ID # 

Phone Number (s) ( ) ; ( ) 

-

Day of the Week: 

Date / / Time :  AM 

Call was Initiated by:  Tester (Go to Q1)  Agent (Go to Q7 ) 

 PM 

1. Was the Appointment Call Completed? 

 Yes (check one box below) 

 Appointment / Site Visit Arrangements made (Go to Q2) 

 Appointment not made (check one box below) 

 Agent will not make an appointment 

(Why not? ) 

 No housing is available 

 Other (specify): 

 Test terminated by Test Coordinator 

 No (check one box below) 

 Left message on voice mail, pager, etc. 

 Left message with person 

 Told to call back later 

 Wrong number 

 No Answer 

 Telephone number no longer in service 

 Other (specify): 

 Test terminated by Test Coordinator 

2. When is your site visit scheduled for? 

Day of the Week 

Date / / 

Time :  AM  PM 

3. Name of person you have arranged to meet with: 

4. Location to meet: 

5. Name of person you spoke with during this contact: 

6. Comments made: 

FOR AGENT INITIATED CALL: 

7. Call was Received By:  Tester  Test Coordinator 

7a. What was the Purpose of the Agent’s Call? 

 Agent called to confirm appointment time 

 Agent called to cancel appointment and reschedule 

 Agent called to cancel appointment, but did not reschedule 

 Other (specify): 

September 15, 2003 
__________________________ __ __ __ __ __ __ __ 

HOUSING DISCRIMINATION STUDY 

SITE VISIT REPORT FORM - RENTAL 

CONTROL #: __ __ - __ __ - __ __ __ __ - 3 TESTER ID NUMBER: __ __ - __ __ __ 

1. Name of Test Site (if applicable): ______________________________________________________ 

2. Address: _______________________ _______________________________ ________________ 

(number) (street) (unit #) 

(city) (state) (zip) 

3. Type of Visit: � Drop In � Appointment 

4. Date and Time of Site Visit: 

Date (month/day/year): __ __/__ __/__ __ Day of Week: _______________________________ 

Appointment Time: __ __:__ __ AM PM 

5. Time began (office arrival):__ __:__ __ AM � PM 

Time ended (departure): __ __:__ __ AM � PM 

6. Information on persons with whom you had contact during your visit 

[check responses where appropriate]: 

Name/ Race/Ethnicity (check one box) Gender Age Group 

Primary 

Person 

Who 

Provided 

Info 

Position W=White I=American 

B=Black Indian 

H=Hispanic O=Other 

A=Asian/ DK=Don't 

Pacific Islander Know 

W B H A I O DK M F 18-

30 

31-

45 

46-

65 

65 

+ 

1. Name:___________________ 

Position: ___________________ � 

2. Name:___________________ 

Position: ___________________ � 

3. Name:___________________ 

Position: ___________________ � 

4. Name:___________________ 

Position: ___________________ � 

5. Name:___________________ 

Position: ___________________ � 

May 20, 2002 
7. Were you able to meet with an agent to discuss housing options? 

 Yes 

� No 

7a. If No, why not? __________________________________________________________________ 

(Note: If No, STOP here, do not complete the rest of the form) 

8. How many minutes did you wait to meet with someone (i.e. between the time you were 

greeted by someone when you entered and the time you met with the agent)? 

____________ minutes 

9. When you asked the agent about the availability of the rental housing that was advertised, what 

were you told [check only ONE box]? 

 The advertised rental housing is available when I need it. 

 The advertised rental housing is NOT available when I need it. 

 The agent did not know whether the advertised rental housing was available. 

 Something else (specify): ________________________________________________________ 

10. Did the agent tell you that any “similar” rental housing was available? 

[“Similar” rental housing has the same number of bedrooms as the advertised housing, is in your 

price range, and is available when you need it.] 

 Yes 

 No 

10a. If Yes, how many “similar” rental housing units did the agent tell you about? ________ units 

11. Did the agent tell you that any “other” rental housing was available? 

[“Other” rental housing has at least the minimum number of bedrooms for your household, is in your 

price range, and is available when you need it. "Other" rental housing also includes housing with a 

greater number of bedrooms than the rental housing.] 

 Yes 

 No 

11a. If Yes, how many “other” rental housing units did the agent tell you about? ________ units 

12. How many TOTAL rental housing units did the agent tell you were available? 

(Note: Add rental housing units from Questions 9 [if you answered that the advertised rental housing 

was available], 10a and 11a.) ________ units 

May 20, 2002 
___________________________________________________________________________________ 

___________________________________________________________________________________ 

13. During your visit, did the agent comment on or make reference to any of the following: Fair Housing 

 Laws, Equal Housing Opportunity, Open Housing Ordinance, or Anti-discrimination Laws? 

� Yes

� No 

13a. If Yes, what was the comment or reference? 

14. Did the agent tell you that an application form of some kind must be completed before renting a unit? 

 Yes 

 No 

14a. Did the agent ask you to complete an application during your visit or give you an application to take 

with you? 

 Yes 

� No 

14b. Did the agent tell you that a credit check was part of the application process? 

 Yes 

 No 

14c. Did the agent tell you that a criminal background check was part of the application process? 

 Yes 

 No 

15. Complete the grid below regarding any of your qualifications to rent that were requested by the 

agent. (check only one per line) 

Qualification I 

volunteered 

Agent 

Requested 

Exchanged 

in earlier 

phone call 

Agent did 

not obtain 

a. Your marital status 

b. Your family size 

c. Your income 

d. Your spouse's income 

e. Your occupation 

f. Your spouse's occupation 

g. Your length of employment 

h. Your spouse's length of employment 

i. Your credit standing 

j. Your rent history 

k. Your address/phone number 

l. Other: 

May 20, 2002 
_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

16. Did the agent make any remarks about race or ethnicity that were not associated with 

neighborhoods in which the available rental housing was located? 

 Yes 

 No 

16a. If Yes, please record what the agent said: _____________________________________________ 

17. Did the agent make any remarks about religion, persons with disabilities, or families with children? 

 Yes 

 No 

17a. If Yes, please record what the agent said: _____________________________________________ 

18. Did the agent provide you with any of the following items THAT YOU DID NOT ASK FOR? (Check 

all that apply.) 

� Business card 

� Brochure 

� Floor plan 

 Listing of available units 

 Lease/Rental Agreement 

� Gift

 Other (specify): 

19. What arrangements were made regarding future contact between you and the agent [check all that 

apply]? 

 The agent said that he/she would contact you 

 The agent invited you to call him/her 

 Future arrangements were not made 

 Other (specify): ________________________________________________________________ 

20. When was this report completed? 

Date (month/day/year): ____/____/____ Day of Week ___________________________ 

Time __ __:__ __ AM PM 

May 20, 2002 
AVAILABLE RENTAL UNIT 

Complete one form for each unit that you were told about and that met your needs 

CONTROL # - - - 3 TESTER ID# -

1. Address:

 (number) (street) (unit #) 

(city) (state) (zip) 

1a. Type of Building 

 Apartment Building - 4 or Fewer Units  Apartment Building - 5 or More Units 

 Single-Family Home  Mobile Home 

Basic Information 

2. Is this the advertised unit?  Yes  No  Not Sure 

3. What did you inspect? 

 Actual available unit 

 Model similar to the actual available unit (Do Not Answer Question 12) 

 Other unit similar to the actual available unit (e.g., manager’s unit, recently rented unit, etc.) 

(Do Not Answer Question 12) 

 Nothing (Do Not Answer Question 12) 

4. Date Available / / 

5. How much is the rent? $ / month 

5a. Did the agent inform you that the rent was in any way negotiable?  Yes  No 

5b. If Yes, please describe: 

6. Number of bedrooms 

7. Number of bathrooms 

8. How many floors in building? 

9. Unit is on what floor? 

10. Length of Lease? [check all that apply] 

 Month-to-month 

 Three month 

 Six month 

 One year 

 Two year 

 Other (specify: ) 

12. How do you rate the physical condition of the unit’s INTERIOR? 

 Clean and in excellent repair, move in condition 

 Some cleaning and minor maintenance needed; adequate 

September 15, 2003 
 Very dirty and in need of substantial maintenance; serious problems 

 Not applicable (did not view interior of actual unit or unit was a model/example) 

13. How do you rate the physical condition of the building’s EXTERIOR? 

 Clean and in excellent repair, move in condition 

 Some cleaning and minor maintenance needed; adequate 

 Very dirty and in need of substantial maintenance; serious problems 

 Not applicable (did not view exterior) 

14. Did the agent know what utilities were included in the rent? 

 Yes  No 

14a. If Yes, what utilities did the agent say were included in the rent (check all that apply)? 

 Electric 

 Gas 

 Water 

 Partial Utilities [i.e., extra for seasonal 

heating/cooling] 

 Other Utilities (specify: ) 

15. What building/complex amenities did the agent show you (check all that apply)? 

 Parking area/garage  Hiking trails 

 Laundry facility  Mail Room 

 Exercise Room/Health Club  Trash/Recycling Area 

 Storage area  Picnic/Barbeque Area 

 Sauna/Whirlpool  Basketball Court 

 Playground/Play Area  Other 

 Pool  Other 

 Tennis/Racquetball Courts  Other 

Fees 

16. Specify any fees that you were told would be required AT THE TIME OF APPLICATION. 

Name/Purpose of Fee Amount of Fee 

(e.g., Credit Check, Cleaning Fee, Application Processing fee, etc.) 

$ 

$ 

$ 

$ 

Total Amount Required with Application $ 

16a. Did the agent inform you that any of the fees listed above were in any way negotiable? 

 Yes  No If Yes, please describe: 

Security Deposit 

September 15, 2003 
17. Is a security deposit required?  Yes  No  Agent did not know 

17a. If Yes, how much is it? $ 

17b. Did the agent inform you that any part of the security deposit was negotiable?  Yes  No 

If Yes, please describe: 

Waiting List 

18. Did the agent tell you that there were any applicants who would be considered for renting 

this unit before you would be considered?  Yes  No 

If Yes, please describe what you were told: 

18a. Were you told that there was a waiting list for this unit?  Yes  No 

18b. If Yes, how many people were you told were on the list? 

18c. If Yes, did the agent offer to place your name on the list:  Yes  No 

Financial Incentives / Specials 

19. Did the agent inform you that you might be able to take advantage of any financial incentives or 

specials if you decided 

to apply for and rent 

this unit?  Yes 

 No 

19a. If Yes, record these incentives or specials and provide their approximate value: 

Type of Incentive/Special (e.g., first Value (indicate monthly or annual) 

month’s rent free, discounted or free 

parking or health club membership, 

application fee waived, etc.) 

$  Monthly (how many months? ) 

 Annual 

$  Monthly (how many months? ) 

 Annual 

$  Monthly (how many months? ) 

 Annual 

$  Monthly (how many months? ) 

 Annual 

$  Monthly (how many months? ) 

 Annual 

Total Value of Incentive / Special $ 

September 15, 2003 
Other Buildings/Complexes 

20. Did the agent suggest that you consider a different rental building or complex than the one that 

this unit is located in?  Yes 

 No 

If Yes, was that building or complex managed by the same company? 

 Yes  No  Don’t Know 

21. Did the agent make any of the following comments about the surrounding 

neighborhood? 

a. Noise b. Safety c. Schools 

 Quiet  Safe/low crime  Good 

 Noisy  Dangerous/high crime  Poor 

 No comment  No comment  No comment 

d. Maintenance/ Services 

 Good Services/Amenities 

 Poor Services/Amenities 

 No comment 

e. Race or Ethnicity?  Yes  No 

If Yes, please record what the agent said: 

September 15, 2003 
__________________________ __ __ __ __ __ __ __ 

HOUSING DISCRIMINATION STUDY 

SITE VISIT REPORT FORM - SALES 

CONTROL #: __ __ - __ __ - __ __ __ __ - 3 TESTER ID NUMBER: __ __ - __ __ __ 

1. Location of Office: 

Firm Name (if applicable): __________________________________________________________ 

Office/Room Number: _____________________________________________________________ 

Address: _______________________ ______________________________________________ 

(number) (street) 

(city) (state) (zip) 

2. Date and Time of Site Visit: 

Date (month/day/year): __ __/__ __/__ __ Day of Week: _______________________________ 

Appointment Time: __ __:__ __ AM PM 

2a. Time began (office arrival):__ __:__ __ AM � PM

 Time ended (departure): __ __:__ __ AM � PM 

3. Is this your second site visit? 

 Yes 

 No 

4. Information on persons with whom you had contact during your visit 

[check responses where appropriate]: 

Name/ 

Position 

Race/Ethnicity 

(check one box) 

Gender Age Group 

Primary 

Person 

Who 

Provided 

Info 

W=White I=American 

B=Black Indian 

H=Hispanic O=Other 

A=Asian/ DK=Don't 

Pacific Islander Know 

W B H A I O DK M F 18-

30 

31-

45 

46-

65 

65 

+ 

1. Name:___________________ 

Position: ___________________ � 

2. Name:___________________ 

Position: ___________________ � 

3. Name:___________________ 

Position: ___________________ � 

4. Name:___________________ 

Position: ___________________ � 

5. Name:___________________ 

Position: ___________________ � 

1 
5. Were you able to meet with an agent today to discuss housing options? 

 Yes 

 No 

5a. If Yes, where did you meet? 

 Agent’s office 

 Somewhere else (specify): 

5b. If No, why not? (specify): 

(Note: If No, STOP here and do not complete the rest of the form) 

6. Did the agent decline to meet with you today? 

 Yes 

 No 

7. How many minutes did you wait to meet with someone (i.e. between the time you were greeted by 

someone at the firm when you entered and the time you met with the agent)? 

__________ minutes

8. When you asked the agent about the availability of the advertised home, what were you told? 

[Check only ONE box] 

 Home is available. 

 Home is available, but the agent recommended that I not consider it. 

 Home is not available. 

 The agent did not know the status of the house. 

 Something else (specify): _______________________________________________________ 

9. Did the agent recommend any other homes that had the same number of bedrooms as the 

advertised home? 

 Yes 

 No 

9a. If Yes, how many homes with the same number of bedrooms did the agent recommend? 

(Do not include advertised home) ______ Homes 

2 
___________________________________________________________________________________ 

___________________________________________________________________________________ 

10a. Did the agent recommend any other homes that had a different number of bedrooms than the 

advertised home? 

[Other homes must have at least the minimum number of bedrooms for your household and can 

 include homes with a greater number of bedrooms than the advertised home.] 

 Yes 

 No 

10a. If Yes, how many homes with a different number of bedrooms than the advertised home did the 

agent recommend? ________ Homes 

11. How many TOTAL homes did the agent recommend, including the advertised home?: ______ 

(Add units from Questions 7 [if you answered “Home is available”], 8a, and 9a). 

12. How many homes did the agent offer for your review in a listing or other format (i.e., these homes 

were NOT SPECIFICALLY RECOMMENDED)? ______ Homes 

13. During your visit, did the agent comment on or make reference to any of the following: Fair Housing 

Laws, Equal Housing Opportunity, Open Housing Ordinance, or Anti-discrimination Law? 

 Yes 

 No 

13a. If Yes, what was the comment or reference? 

14. Based on your observations and the remarks of the agent, indicate below the sources used to select 

properties for your review: [check all that apply] 

 Multiple listings book(s) 

 Home seeker guides/magazines 

 Computer 

 Internet website - (specify): _______________________________________________________ 

 Other printed sheet 

 File cards 

 Scraps of paper 

 Other (specify): ________________________________________________________________ 

 None 

15. At any time during your visit, did the agent refer you to another real estate agent for assistance in 

buying a home? 

 Yes 

 No 

15a. If Yes, did this other agent work for the same real estate agency? 

 Yes 

 No 

3 
16. Was the agent’s role described to you as being one of the following: 

 Buyer’s agent 

 Seller’s agent 

 Dual agent 

 Did not disclose 

17. Were you asked to sign any agreements or documents? 

 Yes 

 No 

17a. If Yes, please specify each below: 

Document Name Purpose Did you sign? 

1. Yes No 

2. Yes No 

3. Yes No 

4. Yes No 

18. Did the agent ask if you had already visited a lender or been pre-qualified for financing? 

 Yes 

 No 

19. Did the agent refuse to provide any of the following services unless you were pre-qualified by a 

lender (i.e., not during this site visit)? 

Agent could not tell me about the advertised home Yes No 

Agent could not recommend any homes to me Yes No 

Agent could not provide me with any listings Yes No 

Agent could not show me any homes Yes No 

Agent would show me only the advertised home, but no others Yes No 

Agent would not make a second site visit appointment with me Yes No 

4 
20. Complete the grid below regarding any of your qualifications to purchase a house that were 

requested by the agent at any point. (Check only one per line) 

Qualification I 

volunteered 

Agent 

Requested 

Obtained in 

earlier 

phone call 

Agent did 

not obtain 

a. Your marital status 

b. Your family size 

c. Your income 

d. Your spouse's income 

e. Your occupation 

f. Your spouse's occupation 

g. Your length of employment 

h. Your spouse's length of employment 

i. Your savings/assets (e.g. funds available 

for downpayment, closing costs, etc.) 

j. Your debts 

k. Credit Standing 

l. Reason for moving 

m. Geographic preference 

n. Your address/phone number 

o. Your current housing situation (rent/own) 

p. Other: 

21. Did the agent tell you that you were not qualified to be a homebuyer at this time? 

 Yes 

 No 

22. Did the agent volunteer to help you find financing? 

 Yes 

 No 

5 
_______________________________________ 

__________________________________ 

23. Did the agent suggest one or more mortgage companies, lenders, or brokers? 

 Yes 

 No 

23a. If Yes, please list them below: 

Mortgage Company/Firm Lender/Broker Name City Telephone 

1. 

2. 

3. 

4. 

24. Did the agent discuss the type of financing that might be available to you? 

 Yes 

 No 

24a. If Yes, please indicate which types of financing the agent discussed or mentioned by filling out the 

grid below: [check one per line] 

Agent 

Discussed 

Agent did 

not mention 

a. Conventional Fixed Rate Financing (non FHA) 

b. Conventional Adjustable Rate Financing (ARM) 

c. FHA or VA Financing 

d. Other government financing (state or local) 

(specify): 

e. Other (specify): 

25. During the visit, did anyone pre-qualify you or calculate for an estimated home price or loan amount 

for which you could qualify using your specific financial information (e.g., income, debts, and 

assets)? 

 Yes 

 No 

25a. If Yes, using the numbers from Question 4, enter the number of the person who provided you with 

the information on the amount of financing you could afford: [enter line #] 

25b. If Yes, was this person? 

 The agent who was providing housing information to you 

 An in-house mortgage specialist 

 A lender by telephone 

 Someone else 

6 
26. Home Price: 

Did the agent suggest a house price or price range for which you might qualify? 

 Yes 

 No 

26a. If Yes, what was the home price range? 

$ ___________________ (lowest) $ ___________________ (highest) 

27. Loan/Mortgage Amount: 

Did the agent suggest a mortgage amount ($ borrowed) or range for which you might qualify? 

 Yes 

 No 

27a. If Yes, what was the loan amount range? 

$ ___________________ (lowest) $ ___________________ (highest) 

28. Interest Rates: 

Did the agent mention interest rates for mortgage loans? 

 Yes 

 No 

28a. If Yes, what were the interest rates mentioned? 

________% (lowest) ________% (highest) 

29. Monthly Payments: 

Did the agent mention monthly payments for a mortgage loan? 

 Yes 

 No 

29a. If Yes, what were the monthly payments? 

$ ___________________ (lowest) $ ___________________ (highest) 

30. Downpayment: 

Did the agent mention the likely downpayment on a house? 

 Yes 

 No 

30a. If Yes, what was the downpayment amount or percentage? 

Downpayment Amount: $ __________ (lowest) $ __________ (highest) 

Downpayment Percent: ________% (lowest) ________% (highest) 

7 
_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

_______________________________________________________________________________ 

31. Did the agent discuss any of the following with you? [check all that apply] 

 Paying down debts 

 Debt consolidation 

 Downpayment assistance (gift, special program) 

 Co-signer 

 Seller assistance 

 Pre-qualification letter 

 None of the above were discussed 

31a. For any items discussed, please describe what you were told: 

32. Did the agent discuss or make any comments about specific neighborhoods or geographic areas that 

were not associated with any recommended homes? (If yes, fill out a Neighborhood Information 

Form.) 

 Yes 

 No 

33. Did the agent make any remarks about race or ethnicity that were not associated with any particular 

home or neighborhood? 

 Yes 

 No 

33a. If Yes, please record what the agent said: _____________________________________________ 

34. Did the agent make any remarks about religion, persons with disabilities, or families with children? 

 Yes 

 No 

34a. If Yes, please record what the agent said: _____________________________________________ 

8 
35. Did the agent provide you with any of the following items THAT YOU DID NOT ASK FOR? 

(Check all that apply) 

 Business card 

 Brochure 

 Listings 

 Homebuying Guide/Video 

 Financing Information 

 Financing Worksheet 

 Mortgage Calculator 

 Gift 

 Other (specify):_________________________________________________________________ 

36. What arrangements were made regarding future contact between you and the agent? 

(Check all that apply) 

 The agent said that he/she would contact you 

 The agent invited you to call him/her 

 Arrangements for future contact were not made 

 Other (specify): ________________________________________________________________ 

37. When was this report completed? 

Date (month/day/year): ____/____/____ Day of Week ____________________________ 

Time __ __:__ __ AM � PM 

9 
___________________________________________________________________________ 

RECOMMENDED HOME 

(Complete one form for each home recommended and/or inspected) 

CON TRO L # - - - 2 TESTER ID# -

1. Full Address of Home 

(number) (street) (unit) 

(city or town) (state) (zip code) 

2. Basic Information 

a. Is this the advertised home? 9 Yes 9 No 

b. Did you inspect the home? 9 Yes 9 No 

c. How many bedrooms were in the home? 

d. What was the current asking price? 

3. What type of building is it? 4. Is this a newly built home that has 

never been occupied? 

9 Single-family detached 9 Yes 

9 Duplex 9 No 

9 Rowhouse or Townhouse 

9 Multi-family structure 

9 Mobile home 

5. How do you rate the physical condition of the home’s INTERIOR? 

9 Clean and in excellent repair, move-in condition 

9 Some cleaning and minor maintenance needed, adequate 

9 Very dirty and in need of substantial maintenance, serious problems 

9 Not Applicable, did not view interior 

6. How do you rate the physical condition of the home’s EXTERIOR? 

9 Clean and in excellent repair, move-in condition 

9 Some cleaning and minor maintenance needed, adequate 

9 Very dirty and in need of substantial maintenance, serious problems 

9 Not Applicable, did not view exterior 

7. Did the agent make any of the following comments about the surrounding neighborhood? 

a. Noise b. Safety c. Schools 

9 Quiet 9 Safe/low crime 9 Good 

9 Noisy 9 Dangerous/high crime 9 Poor 

9 No comment 9 No comment 9 No comment 

d. Investment e. Public Services 

9 Rising values/good investment 9 Good Services/Amenities 

9 Flat values/not much appreciation 9 Poor Services/Amenities 

9 Declining values/depreciation 9 No comment 

9 No comment 

f. Race or ethnicity? 9 Yes 9 No 

If Yes, please record what the agent said: 
___________________________________________________________________________ 

NEIGHBORHOOD INFORMATION 

Complete one form for each neighborhood that the agent discussed with you other than those 

surrounding recommended and/or inspected homes. 

CONTROL #: __ __ - __ __ - __ __ __ __ - 2 TESTER ID NUMBER: __ __ - __ __ __ 

1. Name of Area: __________________________________ 

2. This area is a: 

� County 

� Town or City 

� School District 

� Neighborhood 

� Don't know 

3. Did the agent make any of the following comments about the neighborhood? 

a. Noise 

9 Quiet 

9 Noisy 

9 No comment 

b. Safety 

9 Safe/low crime 

9 Dangerous/high crime 

9 No comment 

c. Schools 

9 Good 

9 Poor 

9 No comment 

d. Investment 

� Rising values/good investment 

� Flat values/not much appreciation 

� Declining values/depreciation 

� No comment 

e. Public Services 

� good services/amenities 

� poor/unreliable services 

� no comment 

f. Race or Ethnicity? 

9 Yes 

9 No 

If Yes, please record what the agent said: _________________________________________ 

___________________________________________________________________________ 

___________________________________________________________________________ 
FOLLOW-UP CONTACT FORM

Χ COMPLETE AT LEAST ONE FORM FOR EACH TEST 

Χ DO NOT USE THIS FORM FOR APPOINTMENT CALLS 

Χ TESTER: NOTIFY TEST COORDINATOR OF ANY CONTACT AND FORWARD MATERIALS RECEIVED 

CONTROL #: __ __ - __ __ - __ __ __ __ - 3 TESTER ID NUMBER: __ __ - __ __ __ 

1. Was there any follow-up contact? 

� No 

� Yes (if yes, complete rest of form) 

2. Date and time of contact: 

Day of the Week: ________________ 

Date / / __ __ 

Time __ __ : __ __ AM PM 

3. Type of Contact 

 Telephone call to tester at home 

 Telephone message left at tester’s home 

 Voice mail message retrieved by Test Coordinator 

 Postal mail 

 E-mail 

 Other [Specify]:______________________________________________ 

4. Name of person making contact:_______________________________________ 

5. Name of agency (if given): ____________________________________________ 

6. What was the stated purpose of the contact? [check all that apply] 

 Agent wanted to see if tester is still interested in purchase/rental 

 Agent wanted to recommend a lender to the tester 

 Agent wanted to let tester know about more housing 

 Agent wanted to get more information from tester 

 Agent wanted to thank tester 

 Other [specify]:_________________________________________________ 

7. Describe any materials received:__________________________________________ 

September 15, 2003 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

ANNEX 2: TESTS OF STATISTICAL SIGNIFICANCE 

The gross measure of adverse treatment is simply an estimate of the probability that the 

white tester is favored over his or her minority partner, or the empirical mean of a variable (Z10) 

that takes on the value of one if the white tester is favored and zero otherwise. In simple 

random samples, the standard error of the gross measure estimate is square root of the 

element variance of this discrete outcome divided by the sample size; the element variance of 

the variable is simply 

σg

2

 = E[Z10

2

] - E[Z10]

2

 = Pr[Wik=1, Mik=0] ( 1.0 - Pr[Wik=1, Mik=0] ) 

where Wik is a Bernoulli variable denoting a favorable outcome for the white tester 

(1=favorable; 0=unfavorable) and Mik denotes the Bernoulli analogue for the Minority treatment 

outcome. Doubling the standard error yields a 95 percent confidence interval for the gross 

measure of adverse treatment. However, this apparently straightforward hypothesis test that 

the gross measure is greater than zero is not meaningful; the fact that any instances of white- or 

minority-favored treatment occurred in the sample of tests means (by definition) that the null 

hypothesis must be rejected (the probability of differential treatment in the total population 

cannot be equal to zero). In other words, a null hypothesis that a probability is zero is 

automatically rejected whenever at least one such event is observed. 

The (effective) sample size for these tests is quite large, and based on the central limit 

theorem the 95 percent confidence interval for the gross measure is simply the estimated 

measure plus or minus 1.96 times the estimated standard error. This assumes that the 

estimated proportion is neither close to zero or one. If percentages are extreme (say, greater 

than 0.95 or less than 0.05), nonsymmetrical confidence intervals are calculated using formulae 

in Fleiss (1981) with adjustments to variance which incorporate the design effect. Also, note 

that the standard error cannot be used to provide a statistical test that the gross measure is 

greater than or equal to zero. The gross measure is the estimate of an event probability. The 

null hypothesis that a probability equals zero is rejected upon even a single observation of the 

event because if the null is true the event cannot occur. 

The net measure of adverse treatment is the difference between the proportion of tests 

where the white is favored and the proportion where the minority is favored. For the net 

measure, the standard error of the estimate is based on a simple difference of means, and the 

variance of the net measure may be written as 

σn

2

 = Var[Wik] + Var[Mik] - 2 Cov[Wik, Mik] 

Wik and Mik are both binary variables, and calculations of their variance are straightforward. The 

element covariance can be calculated as follows: 

A2-1 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

σWM = Pr[Wik=1, Mik=1] * Pr[Wik=0, Mik=0] - Pr[Wik=1, Mik=0] * Pr[Wik=0, Mik=1] 

The null hypothesis that the net measure is positive and differs from zero (a one-sided 

test) is rejected with a 5 percent chance of a type I error or less if the net exceeds 1.65 times 

the estimated standard error. 

Results for individual states and metropolitan areas are based on small sample sizes of 

approximately 70 to 120 tests per site, tenure, and ethnic group. The statistical tests described 

earlier could be replaced by a t-test with N-1 degrees of freedom in which N is the sample size. 

This test, however, requires either an assumption that the errors are distributed normally or a 

large enough sample size to invoke the central limit theorem, which insures normality of the 

mean even when errors are non-Normal. We apply the central limit theorem for the confidence 

intervals on the gross measure of adverse treatment. Gross adverse treatment is simply a 

binary or Bernoulli variable. In practice, the frequencies arising from a Bernoulli variable are 

approximately distributed normally when each cell contains at least five entries. 

Neither the normality assumption nor the use of the central limit theorem is appropriate 

for the net measure of adverse treatment. For example, Heckman and Siegelman (1993) 

examines data from the Urban Institute employment tests and finds that the t-test for a 

difference of means is less likely to detect net adverse treatment against minority testers 

compared to more appropriate statistical tests. 

Heckman and Siegelman (1993) suggest that the one-sided test for whether net adverse 

treatment is greater than zero can be written as simply 

H0: E[Y10 | Y11=0, Y00=0] <= 0.5 

where Y11 is one if Wik=1 and Mik=1 and Y00 is one if Wik=0 and Mik=0. This test conditions on 

the occurrence of either relatively favorable white or minority treatment, and tests whether the 

conditional likelihood of white-favored treatment is 50 percent. This test, often called the sign 

test, is the uniformly most powerful statistical test for this null hypothesis. 

Under H0, the probability of observing N2 or more tests in which the white tester receives 

favorable treatment and the minority tester does not is the number of permutations under this 

restriction divided by the total number of permutations for which Nd tests can be assigned to two 

outcomes. 

Pr[N2 = k | Nd = N2 + N3] = Nd! / (2Nd (Nd - k)! k!) 

where N3 is the number of tests in which outcome 3 is observed. The critical value (NC) is 

chosen so that 

A2-2 
Discrimination in Metropolitan Housing Markets: Phase III — Native Americans 

Nd 

∑ [ Prob N 2 = j | Nd ] ≤ 0.05

j = NC

Due to the nature of permutation tests, the sum of the probabilities will not equal 5 

percent exactly. In principle, a randomization test may be conducted so that the null will be 

rejected with some probability if N2 equals NC minus one.1

 In practice, however, the probability 

of a type one error given the observed values is simply calculated by setting NC equal to N2 in 

the equation above. 

Due to the small sample sizes for the three-part tests, we also use exact, non-parametric 

tests to determine the statistical significance of the net adverse treatment measures. A simple 

sign test can be constructed by creating a sample in which the events Y6 (W is not favored, M1 

is favored, and M2 is not favored) and Y7 (W is not favored, M1 is not favored, and M2 is 

favored) each create one observation in which differential treatment occurs between testers of 

the same race and the event Y5 (W is favored, M1 is not favored, and M2 is not favored) 

creates two observations in which white favored treatment occurs (Y5=1). The resulting sign 

test is 

Prob[Y5=1 | Y1 + Y2 + Y3 + Y4 + Y8 = 0] <= 0.5 

where the observations with Y5=1 enter the sample twice.2 

1

 Heckman shows that a randomized test can be used to obtain significant tests with exactly a 5% probability 

of a type I error. The randomized test rejects the null hypothesis if the value of N2 exceeds NC, and also rejects the 

null hypothesis with probability a if the net measure equals the NC minus one where the following equation holds: a 

p2 + p1 = 0.05, p1 the probability of a type I error implied by the cut-off of NC, and p2 is the increase in the probability 

of a type I error implied by lowering the cut-off to NC minus 1. 

2

 Strictly speaking this test is no longer a permutation test because the event Y5 cannot truly occur twice 

and the two across group comparisons in the triad test are mutually exclusive. Nonetheless, the sign test does 

provide a convenient non-parametric test for whether two probabilities differ from each other. 

A2-3