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Ethics & Fraudmedium18% of exam

An applicant believes they were discriminated against on 9 February 2026 and asks how long they have to complain to HUD. What are the ordinary HUD complaint and private civil-action filing periods, subject to applicable tolling rules?

Correct Answer

D) One year to file with HUD, and 2 years to bring a civil action

D. The ordinary periods are one year for HUD and two years for a private civil action. These are different procedures with different filing periods. For repeated or continuing discrimination, the HUD rule measures from the last incident; do not automatically start the clock at the first event. Scope and exceptions: The question expressly reserves applicable tolling. This is not a calculation of a person’s final filing date; continuing conduct and procedural history require separate review. Source: 24 CFR 103.35 — https://www.ecfr.gov/current/title-24/subtitle-B/chapter-I/part-103/subpart-B/section-103.35 HUD/DOJ Joint Statement, question 19 — https://www.justice.gov/crt/us-department-housing-and-urban-development

Answer Options
A
No deadline applies, since a discrimination claim never expires
B
Three years to file with HUD, matching the general limitation
C
Six months to file with HUD, and 1 year to bring a civil action
D
One year to file with HUD, and 2 years to bring a civil action

Why This Is the Correct Answer

D. The ordinary periods are one year for HUD and two years for a private civil action. These are different procedures with different filing periods. For repeated or continuing discrimination, the HUD rule measures from the last incident; do not automatically start the clock at the first event. Scope and exceptions: The question expressly reserves applicable tolling. This is not a calculation of a person’s final filing date; continuing conduct and procedural history require separate review.

Why the Other Options Are Wrong

Option A: No deadline applies, since a discrimination claim never expires

The existence of a discrimination claim does not remove filing limits.

Option B: Three years to file with HUD, matching the general limitation

Three years is not the ordinary HUD period.

Option C: Six months to file with HUD, and 1 year to bring a civil action

These periods understate both ordinary limits.

Exam Tip

Distinguish the HUD complaint route from private litigation.

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