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Author: Mark Ainely | Partner GC Realty & Development & Co-Host Straight Up Chicago Investor Podcast
A resident walks into your leasing office, or sends an email, or mentions on a phone call that they have an assistance animal. What you do in the next minute matters more than almost anything else in that conversation. Handle it right and it is a non-event. Handle it wrong and you have the opening chapter of a fair housing complaint.
Here is the good news. The process is not complicated once you know it. After leasing over 5,000 units in the last two decades across Chicagoland, I can tell you that almost every accommodation request fits into three simple steps. Let me walk you through them.
Key Takeaways
- A request can be triggered by almost any words. The tenant does not have to say the phrase "reasonable accommodation."
- If the disability and the need are obvious, you grant the request on the spot with no documentation.
- If they are not obvious, you verify the disability and the disability related need through reliable documentation.
- In Illinois that documentation has to come from a real provider relationship, and you are allowed to confirm it is authentic.
Step One: Recognize That a Request Has Been Made
This is the step most owners blow without even knowing it. They are waiting for the tenant to fill out a form or say some magic legal phrase, and that is not how it works.
A request for accommodation can be made with almost any words. It can be spoken out loud at the leasing desk. It can be a line in an email. The tenant does not need to say "I am requesting a reasonable accommodation." If someone tells you they have a service animal, or that their doctor says they need their dog, or that they have an emotional support animal, you have received a request. The clock just started.
The mistake I see again and again is the owner who hears something like that, gets annoyed, and reacts. They push back, they mention the no-pet policy, they ask why the tenant did not disclose this sooner. Do not do that. Treat the request as routine, because to you it should be. The moment you recognize a request has been made, you stop and you move to step two. Nothing in your face or your tone should telegraph that this is a problem.
One more thing on timing. A request can come before someone applies, during the lease, or years into a tenancy. It does not matter when it arrives. Once it is made, you have to consider it.
Step Two: Ask Whether the Disability and the Need Are Observable
Now you ask yourself one question. Can I see the disability and the need for this animal?
Sometimes the answer is obviously yes. A resident in a wheelchair with a dog in a harness is the classic example. The disability is observable and the need is observable. In a case like that, your inquiry is over. You grant the accommodation. You do not ask for a letter, you do not ask for proof, you do not ask what the animal does. Asking for paperwork on an obvious case is itself a way to get yourself in trouble.
This is where most service animals land. When the disability and the need are clear, you are done at step two.
If it is not fully obvious but the resident tells you it is a service animal, your questions are still very limited. You may ask two things. Is the animal needed because of a disability, and what work or task has the animal been trained to perform. That is it. You cannot demand proof of training, a certificate, or a special vest or ID. There is no such thing as an official service animal registry, and you cannot require one.
If you cannot observe the disability and the need, and it is not a service animal answering those two questions, you move to step three.
Step Three: If It Is Not Obvious, Verify the Disability and the Need
Most emotional support animal requests live here, where the disability and the need are real but not something you can see across a desk. In that case, you are allowed to ask for reliable documentation, and you are looking for two things.
Does the person have a disability, and does the person have a disability related need for the animal. That is the whole test. You are not entitled to know what the disability is. You cannot demand a specific diagnosis, you cannot ask what medication they take, and you cannot require their medical records. You are confirming that a disability and a need exist, not running an investigation into their health.
In Illinois there is an extra layer worth knowing. Under the state's Assistance Animal Integrity Act, the documentation has to come from a real therapeutic relationship with a licensed provider who actually knows the person and their need. A certificate someone bought online in three minutes from a site that never spoke to them does not meet that standard. You are allowed to confirm that the letter is authentic and that it came from a genuine provider relationship. If it does not hold up, the documentation is insufficient and you can ask for something that does.
Once you have documentation that confirms the disability and the need, and you have verified it is real, you grant the accommodation. And remember what you cannot do at that point. You cannot apply breed, size, or weight restrictions to the animal, and you cannot charge a pet deposit, pet fee, or pet rent for it. A verified assistance animal is not a pet.
Keep Your Cool and Document Everything
The single best habit you can build is to treat every accommodation request as routine, because nine times out of ten it is. The owners who get into trouble are the ones who react emotionally and let it show.
The second best habit is documentation. Write down when the request was made, what was said, what you asked for, and what you received. Consistency is your best friend if a complaint ever lands on your desk. If you handle every request the same calm, documented way, you are in a strong position no matter what.
FAQ
Does the tenant have to use the words "reasonable accommodation"? No. Any words that let you know they need an exception for an assistance animal count as a request. The phrasing does not matter.
Can I require the tenant to use my specific form? You can ask for reliable documentation, but you cannot deny an otherwise valid request just because it did not arrive on your preferred form. Focus on whether the disability and the need are confirmed, not on the format.
What if the disability and the need are obvious? Then you grant the request with no documentation at all. Asking for paperwork on an obvious case can itself be a violation.
Can I ask what the tenant's disability is? No. You can confirm that a disability and a disability related need exist. You cannot demand a specific diagnosis or details about their condition.
What if the request comes after they already moved in? A request can be made at any time. You still have to consider it the same way you would a request made before move in.
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Don't Go At This Alone!
Accommodation requests are one of those areas where a calm, consistent process is the difference between a routine Tuesday and a costly fair housing problem. At GC Realty & Development, our team runs this exact three step process across roughly 1,500 units in Chicago and the suburbs, every single day. We recognize the request, we evaluate it the right way, and we document every step so our owners stay protected and never have to guess.
My mission has always been simple. Help owners protect what they have built, lower their risk, and buy back the time they are losing to the parts of this job that drain them. Knowing how to handle a request the moment it lands is one of the small things that keeps the big things from ever going wrong.
