Fair Housing Notice

1. Our commitment

MIA's Place, a DBA of TCS Rental Properties, LLC, is committed to compliance with:

• The federal Fair Housing Act (Title VIII of the Civil Rights Act of 1968, as amended)
• The Fair Housing Amendments Act of 1988
• The Pennsylvania Human Relations Act
• All applicable state and local fair housing laws in any state into which MIA's Place expands

We commit to non-discrimination in the operation of our platform, in our communications with members, in any agent-representation services that members opt into through TCS Group's affiliated brokerage, and in any in-person events we host.

2. The two halves of a roommate platform — the controlling split

The controlling case for a roommate platform like MIA's Place is:

Fair Housing Council of San Fernando Valley v. Roommates.com LLC, 521 F.3d 1157 (9th Cir. 2008) (en banc).

The Ninth Circuit's en banc decision split a roommate platform's behavior into two halves and resolved them oppositely:

• Profile-preferences half — PERMITTED.The Fair Housing Act does not reach roommate selection. Choosing who shares your bedroom, kitchen, and bathroom is intimate association, outside the FHA's ambit. A roommate platform may allow users to disclose their own protected-class characteristics on profiles and to express protected-class preferences for prospective roommates. CDA §230 immunity is preserved on this half.
• Listing-creation / advertising half — NOT PERMITTED. When the same platform asked listing-creation questions soliciting protected-class preferences from people advertising housing, and then sorted listings on those preferences, the platform “materially contributed” to housing discrimination as a co-developer of the content and lost §230 immunity. The FHA reaches advertising of housing accommodations regardless of who shares the unit afterward.

MIA's Place adopts that split as the architectural rule of the platform:

• On profiles (roommate context) — sex / gender, age, familial status, sexual orientation, and gender identity are optionally disclosable and filterable. Race, color, national origin, religion, disability, and source of income remain forbidden in our pilot state of Pennsylvania, pending state-by-state legal review.
• On apartment listings (housing-accommodation context) — every protected class is forbidden, freeform text is moderated for §3604(c) discriminatory-advertising language, and our marketplace and listing surfaces have no protected-class filter dimensions.
• On both halves — we do not run a sorting, ranking, or recommendation algorithm. Search returns hard-filter results in recency order. We log search-filter use, match-request actions, marketplace filter use, and event door-check decisions to an internal bias audit log so we can monitor for patterns suggesting discriminatory use and demonstrate compliance.

This is in addition to the non-discrimination obligations TCS Group's licensed brokerage assumes when MIA's Place groups opt into agent representation under §12 of the Privacy Policy. The §14.4 profile-side carve-out does not extend to the brokerage; once the brokerage's role in finding a housing accommodation begins, every protected class returns to its full statutory protection.

3. Protected classes

Under the federal Fair Housing Act, the Pennsylvania Human Relations Act, and applicable state and local law, we recognize the following protected classes:

• Race
• Color
• National origin / ancestry
• Religion or creed
• Sex (including gender identity and sexual orientation)
• Familial status (including families with children under 18, pregnant individuals, and those securing legal custody of minor children)
• Disability (physical or mental)
• Age (under PA Human Relations Act and many state laws)
• Source of income (under PA HRA, NY Exec Law §296(5), NJ LAD, NYC HRL, and other state and local statutes)

Where state or local protections exceed federal law, we follow the broader standard. Pennsylvania's Human Relations Act and Philadelphia's Fair Practices Ordinance extend protection in our pilot footprint.

3.1 How these classes appear on the platform — the two-tier structure

Under the §2 architectural split, our handling of protected classes depends on whether you are looking at a profile (roommate context) or a listing (housing-accommodation context).

3.2 Profile-side optional disclosures (Pennsylvania pilot only)

On profiles, the following may be optionally disclosed and filtered on, under the §2 Roommates.com carve-out:

• Sex / gender
• Age (presented as a 5-year band derived from your verified date of birth, with optional finer-grain self-disclosure)
• Familial status
• Sexual orientation
• Gender identity

Each disclosure is OPTIONAL with a “Prefer not to say” default. We never require disclosure as a condition of using the platform. A user who does not disclose is not surfaced under another user's filter on that field — the filter operates as a positive match against disclosed values, not as an exclusion against undisclosed users.

3.3 Forbidden on profiles (Pennsylvania pilot)

The following protected classes are not disclosable or filterable on profiles in our pilot state. Each requires state-specific legal review before any expansion state surfaces it:

• Race
• Color
• National origin / ancestry
• Religion or creed
• Disability or medical condition (separate accommodation pathway — see §6)
• Source of income

3.4 Forbidden on listings — every protected class

On apartment listings (whether posted by a member, surfaced from a third-party site, saved to the marketplace, or supplied by a partner landlord), every protected class is forbiddenas a field, filter, or freeform-text expression. Listing freeform text is moderated for §3604(c) discriminatory-advertising language. A tenant's roommate preferences belong on their profile under §3.2; an apartment listing advertising a housing accommodation is subject to the full FHA.

4. What we do as a platform

To uphold our commitment, MIA's Place:

• Treats profiles and listings as different surfaces with different rules. The §2 architectural split is enforced at every layer — schema (separate tables, separate columns), application (separate intake forms, separate filter allowlists), audit (separate event types), and policy (this Notice and our Terms of Use). Roommate preferences live on profiles only; apartment listings are FHA-strict regardless of who posts them.
• Limits profile-side protected-class disclosure to the §3.2 set. In our Pennsylvania pilot, the only protected classes optionally disclosable on profiles are sex / gender, age, familial status, sexual orientation, and gender identity — the classes most squarely within the Roommates.com intimate- association carve-out. The full inventory is governed by our internal FHA-Safe Matching Inputs document. Expansion states require state-specific legal review before any §3.2 disclosure becomes available there.
• Keeps listings FHA-strict. Our listing schema (`unit_listings`, `profile_candidates`, marketplace) carries no protected-class columns. The marketplace and listing search bar have no protected-class filters. Listing freeform text is moderated for §3604(c) discriminatory-advertising language.
• Does not run a matching algorithm. On either side, search returns members or listings matching your hard filters, sorted by recency. We do not rank, score, or recommend.
• Logs filter use and match requests to a bias audit log — including §3.2 protected-class filter use. Every search-filter application, every match-request action, every marketplace filter use, and every event door-check decision writes a row to an internal audit log. Searches that include any §3.2 disclosed-preference dimension are recorded under a distinct event type so the quarterly audit can probe specifically for whether §3.2-permitted filtering produces match-rate disparity at the intersectional level. The bias audit log is governed by our internal Bias Audit Log Specification.
• Verifies identity uniformly. Every member completes the same Stripe Identity verification before they can send a match request, message another member, or form a group with another member. Verification status is not a protected class and is applied to every member equally.
• Treats every member by the same Terms of Use. Our prohibited-uses section (Privacy Policy & Terms of Use §19) prohibits discriminatory listing-side advertising and harassment-or-refusal-to-engage based on §3.2 disclosure on profile-side. Violations result in account suspension or termination.
• Maintains records. Account records, bias audit log entries, and moderation events are retained per the Privacy Policy §23 retention schedule.

5. Member conduct

We expect every member to engage with other members in good faith and within the §2 architectural split. Member-conduct rules track that split.

5.1 On apartment listings (housing-accommodation context)

You agree, when you post an apartment listing on the platform — a room replacement, a lease takeover, a sublet, or any other listing that advertises a housing accommodation — that:

• You will not include in the listing any statement that indicates a preference, limitation, or discrimination based on race, color, religion, sex (including gender identity and sexual orientation), familial status, national origin, disability, source of income, or any other class protected under federal, state, or local law. Listing freeform text is moderated for FHA §3604(c) discriminatory-advertising language and offending listings will be removed.
• You understand that your roommate preferences belong on your profile under §3.2 (where they are permitted under Roommates.com), not in the listing description (where the FHA reaches them).
• If TCS Group's licensed brokerage represents you in showing or leasing the unit, the brokerage assumes its own FHA, PHRA, and state-law obligations independent of any §3.2 carve-out.

5.2 On profiles, browse, and messages (roommate context)

You agree that:

• You may optionally disclose any of the §3.2 fields (sex / gender, age, familial status, sexual orientation, gender identity) in our pilot state of Pennsylvania, and you may filter for roommates on those preferences. You may use the platform's search and filter tools to find roommates whose disclosed preferences align with your own.
• You will not use the platform to discriminate against any person on the basis of any protected class beyond the §3.2 set — race, color, national origin, religion, disability, source of income, and any other protected class outside §3.2 are off-limits as a basis for differential engagement.
• You will not harass, threaten, or refuse to communicate with another member based on any §3.2 disclosure they have made on their profile. The §3.2 carve-out permits filtering at the search stage; it does not permit harassment or hostile conduct toward members who appear in your search results or who reach out to you.
• You will not include in your profile or messages any expression of preference, limitation, or discrimination based on a protected class outside the §3.2 set. (For example, “only renting to [racial group]” is forbidden in any field.)

If you receive a message from another member that you believe expresses unlawful discrimination, or you encounter a listing that contains discriminatory advertising language, you can report it through the in-platform reporting tools. Reports route to MIA's Place staff for review.

6. Reasonable accommodations on the platform

MIA's Place is committed to accessibility. We will:

• Make reasonable accommodations to our platform to afford a person with a disability equal opportunity to use the platform — including alternate forms of communication, plain-language guidance for any non-obvious flow, and assistance navigating the verification process.
• Engage in a good-faith interactive process with any member or applicant who requests an accommodation, and respond promptly.

You are not required to disclose the nature of a disability to request an accommodation — only that the requested accommodation is needed because of a disability.

To request a reasonable accommodation, contact us using the information in §9 below. Please note that physical accommodations to a specific apartment (modifications, assistance animals, accessible parking, etc.) are governed by the Fair Housing Act obligations of the apartment's landlord — not MIA's Place. If you encounter a landlord-side accommodations issue while searching with us, contact us and we will help you navigate the request to the appropriate party (and, if applicable, your TCS Group agent under Privacy Policy §12).

7. When TCS Group provides agent representation

MIA's Place groups can opt into agent representation under §12 of the Privacy Policy. If your group opts in, a TCS Group licensed real estate agent assumes its own Fair Housing Act and state-law obligations as a licensed broker. This includes:

• Showing the same available units to qualified prospective tenants without steering based on a protected class.
• Quoting the same rental rates, deposits, fees, and lease terms to every applicant for the same unit.
• Applying the same screening criteria — including credit history, rental history, income verification, and background checks — uniformly to every applicant.
• Using inclusive advertising language and the Equal Housing Opportunity logo or statement.

If you believe an agent affiliated with TCS Group has engaged in discriminatory conduct, contact us using the information in §9 below or use one of the external complaint channels in §8.

8. Reporting discrimination

If you believe you have experienced housing discrimination on the platform, by another member, or by a TCS Group affiliated agent, contact us directly using the information in §9 below. We will investigate promptly.

You also have the right to file a complaint with:

If you reside or were searching in another state, you may also file a complaint with that state's fair-housing or anti-discrimination agency. Contact us at the email below for assistance identifying the right agency.

9. Contact us

For questions about this Fair Housing Notice, to request a reasonable accommodation, or to report a concern: