C.F.R. » Title 24 » CHAPTER I—OFFICE OF ASSISTANT SECRETARY FOR EQUAL OPPORTUNITY, DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT › PART 100—DISCRIMINATORY CONDUCT UNDER THE FAIR HOUSING ACT › Subpart H— Quid Pro Quo and Hostile Environment Harassment

24 C.F.R. § 100.600

Quid pro quo and hostile environment harassment

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(a) General. Quid pro quo and hostile environment harassment because of race, color, religion, sex, familial status, national origin or handicap may violate sections 804, 805, 806 or 818 of the Act, depending on the conduct. The same conduct may violate one or more of these provisions.

(1) Quid pro quo harassment. Quid pro quo harassment refers to an unwelcome request or demand to engage in conduct where submission to the request or demand, either explicitly or implicitly, is made a condition related to: The sale, rental or availability of a dwelling; the terms, conditions, or privileges of the sale or rental, or the provision of services or facilities in connection therewith; or the availability, terms, or conditions of a residential real estate-related transaction. An unwelcome request or demand may constitute quid pro quo harassment even if a person acquiesces in the unwelcome request or demand.

(2) Hostile environment harassment. Hostile environment harassment refers to unwelcome conduct that is sufficiently severe or pervasive as to interfere with: The availability, sale, rental, or use or enjoyment of a dwelling; the terms, conditions, or privileges of the sale or rental, or the provision or enjoyment of services or facilities in connection therewith; or the availability, terms, or conditions of a residential real estate-related transaction. Hostile environment harassment does not require a change in the economic benefits, terms, or conditions of the dwelling or housing-related services or facilities, or of the residential real-estate transaction.

(i) Totality of the circumstances. Whether hostile environment harassment exists depends upon the totality of the circumstances.

(A) Factors to be considered to determine whether hostile environment harassment exists include, but are not limited to, the nature of the conduct, the context in which the incident(s) occurred, the severity, scope, frequency, duration, and location of the conduct, and the relationships of the persons involved.

(B) Neither psychological nor physical harm must be demonstrated to prove that a hostile environment exists. Evidence of psychological or physical harm may, however, be relevant in determining whether a hostile environment existed and, if so, the amount of damages to which an aggrieved person may be entitled.

(C) Whether unwelcome conduct is sufficiently severe or pervasive as to create a hostile environment is evaluated from the perspective of a reasonable person in the aggrieved person's position.

(ii) Title VII affirmative defense. The affirmative defense to an employer's vicarious liability for hostile environment harassment by a supervisor under Title VII of the Civil Rights Act of 1964 does not apply to cases brought pursuant to the Fair Housing Act.

(b) Type of conduct. Harassment can be written, verbal, or other conduct, and does not require physical contact.

(c) Number of incidents. A single incident of harassment because of race, color, religion, sex, familial status, national origin, or handicap may constitute a discriminatory housing practice, where the incident is sufficiently severe to create a hostile environment, or evidences a quid pro quo.

Notes of Decisions
Cited in 32 cases (20 in the last 5 years), 2017–2026 · leading case: Liana Revock v. Cowpet Bay West Condo. As, 853 F.3d 96 (3rd Cir. 2017).
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Hernandez (N.D. Ill. 2026). · cites it 4× “§ 3604 (c) and 24 C.F.R. § 100.600 (a), respectively, as well as bringing several state law claims.”
Baker (W.D. Wash. 2025). · cites it 3× “Quid pro quo and hostile environment harassment, 24 C.F.R. § 100.600 4 To state a claim for quid pro quo harassment, Mr.”
Stern v. Highland Lake Homeowners Ass'n (S.D.N.Y. 2025). “” 24 C.F.R. § 100.600 (a)(2)(i). As such, the Court views the HOA amendments in conjunction with the alleged actions of Individual Defendants.”
Baker (W.D. Wash. 2025). “400 ; (iv) quid pro quo and hostile environment 10 harassment, 24 C.F.R. § 100.600 ; and (2) discrimination in the sale or rental of housing 11 under the FHA, 42 U.”
Metro. Fair Hous. Council of Oklahoma, Inc v. Feiock (E.D. Okla. 2024). · cites it 2× “]”); see also 24 C.F.R. §100.600 (defining hostile environment harassment in housing, including harassment based on handicap).”
Dickerson v. BPP PCV Owners LLC (S.D.N.Y. 2024). “’” (quoting 24 C.F.R. § 100.600 (a)(2)(i)(A)). A plaintiff must demonstrate “either that a single incident was extraordinarily severe, or that a series of incidents were sufficiently continuous and concerted to have altered the conditions of her living environment.”
Charlier v. 21 Astor Place Condo. (S.D.N.Y. 2024). “’” (quoting 24 C.F.R. § 100.600 (a)(2)(i)(A))). Plaintiff has plausibly pleaded that Mr.”
Evelyn Rivera v. Jimmy Ducharme et al., 2023 DNH 102 (D.N.H. 2023). · cites it 2× “” 24 C.F.R. § 100.600 (a)(2). “A single incident of harassment because of [protected status] may constitute a discriminatory housing practice, where the incident is sufficiently severe to create a hostile environment.”
Kalashnikov v. Myfield Lane Homeowners' Ass'n, Inc. (D. Conn. 2023). · cites it 2× “FHA Quid pro quo and hostile environment harassment claims In Count 6, the Plaintiffs allege both "quid pro quo" and "hostile environment harassment" claims on the basis of their national origin under section 3617 of the FHA and 24 C.F.R. § 100.600 , a HUD regulation. 24 C.”
Rivera v. Ducharme (D.N.H. 2023). · cites it 2× “” 24 C.F.R. § 100.600 (a)(2). “A single incident of harassment because of [protected status] may constitute a discriminatory housing practice, where the incident is sufficiently severe to create a hostile environment.”
Wissman v. Pgm Real Est. LLC, Prop. Mgmt. (E.D. Pa. 2023). “474, 485 (1998)); see also 24 C.F.R. § 100.600 . A claim under § 3617 does not depend upon a substantive violation of the FHA.”
Glagola v. Macfann (W.D. Pa. 2023). “3d at 1290 (quoting 24 C.F.R. § 100.600 ) (emphasis in original).”
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