The three limits the memo states about itself

This is where a board can go wrong, and the document is explicit about its own boundaries.

It is enforcement policy, not law. It directs what HUD staff will charge. It does not amend the Fair Housing Act, and the rulemaking it announces has not happened.

It does not reach other federal statutes. The memo states it “does not address how the Department will process complaints against housing providers under Section 504… or the Americans with Disabilities Act.”²

It does not touch private lawsuits. “Nothing in this enforcement guidance affects the rights of parties to seek redress through a private action in court” — with the Fair Housing Act's two-year limitation period intact.²

Connecticut's own statute is the bigger exposure

Connecticut prohibits housing discrimination under its own law, and the CHRO enforces it through its Housing Discrimination Unit with a 300-day filing deadline. The state definition of disability at § 46a-51(20) and the accommodation provision at § 46a-64c(a)(6) are Connecticut law, and a federal enforcement memo does not narrow them.³

What has narrowed the Connecticut position — and this is the change with actual effect on a board — came from the Connecticut Supreme Court. In March 2026 it held that a person only “regarded as” having a mental disability is not entitled to an accommodation, requiring an actual disability or a record of one.⁴

That decision also vacated the Appellate Court's reasoning on when an additional animal is “necessary,” leaving Connecticut with no binding appellate standard on that question. A board denying a second animal on the strength of the March 2025 Appellate opinion is relying on vacated reasoning.

Where a Connecticut board actually stands

Do not adopt a trained-animals-only policy. It matches HUD's charging posture and matches neither Connecticut law nor the exposure to a private federal action. It is the single most likely way to convert a manageable request into a complaint.

Keep assessing requests individually. The withdrawn guidance described a process; the process was not the source of the obligation. The underlying duty to consider a request from a person with a disability, and to grant it where reasonable, comes from the statutes, which are unchanged.

Focus on the elements that Connecticut law makes relevant. After the Supreme Court's decision, the disability element carries real weight: an actual disability or a record of one. That is a legitimate question. What a requester's medical records say is a much riskier one.

Separate the animal question from the enforcement question. Fining an owner while an accommodation request is pending is where associations generate their worst facts.

Why this reaches Connecticut associations specifically

The federal memo cites, among decisions that deferred to the withdrawn notices, the Connecticut Appellate Court's decision in the CHRO case that the Connecticut Supreme Court later reviewed. Connecticut law is part of the record HUD relied on in narrowing its own posture — while CHRO, a named recipient of the withdrawal notice, continues to enforce the state statute.

Connecticut introduced no bill on assistance animals in associations in either the 2025 or 2026 session.

What to watch next

The announced rulemaking is the thing to track. Notice-and-comment rulemaking would convert an internal enforcement posture into something with legal force, and it would be open to challenge in a way a staff memo is not.

The second is what fills the vacated space in Connecticut on multi-animal necessity. The next Connecticut case to raise it will be argued on the statutory text and persuasive authority — including an Eleventh Circuit decision that arose in a condominium.