HUD will no longer charge cases over untrained assistance animals — Michigan law is unchanged
HUD will no longer charge cases over untrained assistance animals — Michigan law is unchanged
2026-09-12 · Michigan · Regulation
What happened. HUD's Office of Fair Housing and Equal Opportunity issued a memorandum on 22 May 2026, effective immediately, narrowing when it will pursue animal-related reasonable-accommodation complaints. From Craig W. Trainor, Assistant Secretary for Fair Housing and Equal Opportunity, to FHEO headquarters, enforcement and regional staff.1
The operative sentence: “Effective immediately, for complaints related to animal-related reasonable accommodations, FHEO will find reasonable cause and recommend charges only for those cases involving animals trained to provide disability-related assistance.”
What it cancels
The memo permanently cancels FHEO Notice 2013-01 and FHEO Notice 2020-01 — the January 2020 Assistance Animals Notice, which HUD had already withdrawn on 17 September 2025. It grounds the shift in Executive Order 14219, 90 Fed. Reg. 10583 (19 February 2025), directing agencies to de-prioritise enforcement not based on the best reading of a statute.
Animals other than dogs still qualify if individually trained.
What Michigan boards have been doing for six years
Administering FHEO 2020-01's framework: no pet fees for emotional support animals, substantial deference to a treating professional's letter, and near-automatic accommodation for untrained support animals. That framework no longer describes how HUD will charge a case.
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