Policy & ComplianceAnalysis
OurPetPolicy's operations team describes how online ESA letters are flagged, why provider contact checks matter, and how one resident forged three letters and a doctor's email.
So what: Apply one documented review to every ESA request and verify providers through independent contact details. HUD's pullback does not override state law or private suits.
Most property managers see an emotional support animal letter at one moment: when it lands in an application file. On a recent episode of the Beyond the Lease podcast, two members of OurPetPolicy's operations team described what happens after that moment. Their account is useful less for any single red flag than for the case it makes about process. The letters that cause trouble are rarely hard to spot. The hard part is handling every request the same way, every time, without turning a paperwork review into a fight with a resident.
A note on the source: Beyond the Lease is produced by Landlord Tech, which operates OurPetPolicy, a paid ESA verification service. The guests are company staff, and the episode is partly a showcase for the company's work. The practices they describe are worth examining on their own terms, but readers should weigh the commercial context.
Host Marven Shook spoke with Victoria, who onboards property management clients, and Noelle, who oversees the operations team, according to the episode transcript. The episode was published October 16, 2025.
Victoria said the operators she onboards differ by property type. Multifamily communities tend to apply strict, uniform animal rules across a building, while single family operators are more likely to vary rules by unit, allowing more animals in a house with a yard than in a studio. Across both, she said, the common complaint is time. Managers "can't be hounding their tenants" for animal documentation and want to hand the work to someone who knows the rules.
Shook set up a scenario: an applicant sees a Facebook ad, pays about $75, completes a short online survey, and submits the resulting ESA letter. Noelle said the team compares incoming letters against what she called "a massive database" of letters purchased from online ESA websites. Victoria described the patterns that tend to give those letters away:
When a letter matches a known online template, Noelle said, the team does not call the listed clinician first. It contacts the resident, explains why the document appears unreliable, and invites clarification. If the resident says the evaluation was a genuine, thorough session, the team then contacts the provider to verify, as it would with any other letter.
The verification step that matters most, in the guests' telling, is confirming who is on the other end of the phone or inbox. Noelle said clinicians tied to online letter mills often have no verifiable contact information. A search on the email address or phone number returns nothing, which would be odd for a licensed practice. By contrast, she said, providers behind letters that were not bought online are usually simple to reach.
Victoria's example shows why that check matters. A resident with three animals submitted unreliable documentation, then a changing story about which animal belonged to whom, then new letters with a scribbled signature. Verification forms came back from a Gmail address in the doctor's name. When the team called the practice directly, staff said the doctor had been on vacation and had not written the letters. The resident had forged three letters and three verification forms and created the email account to pose as the doctor. The resident was in fact a patient of that provider, which Victoria noted means they likely could have obtained a legitimate letter by asking.
Without an independent call to a verified number, she said, the forged package "could have been approved," because many managers simply approve whatever arrives to avoid the headache.
Both guests said residents are often upset when told their letter will not work, especially after paying for it. Their team's approach is to listen, present the findings plainly, and lay out next steps while holding to the client's rules. Noelle stressed that the door stays open: residents can submit better documentation at any time.
She also framed consistency as a fair housing safeguard, not just an efficiency gain. Every request gets the same steps and the same depth of review, with no one allowed to "cut the line," because the subject matter involves disability and health information where uneven treatment can look like discrimination.
On motive, the guests declined to generalize. Some residents are clearly trying to avoid pet fees or breed restrictions, which is what many online ESA ads promise. Others found the sites while searching for legitimate help and did not realize the documents were unreliable. Noelle observed that residents who openly name the website are often the ones who did not know it was a problem.
The guests repeatedly referred to "HUD criteria" for unreliable documentation. That language traces to HUD's January 2020 notice, FHEO-2020-01, which said documentation from websites that sell certificates after a questionnaire or short interview "is not, by itself, sufficient" to establish a disability related need, while recognizing that licensed clinicians can serve patients remotely.
HUD withdrew that notice on September 17, 2025, about a month before the episode was published, according to HUD's own May 22, 2026 enforcement memo. That memo, signed by Assistant Secretary Craig Trainor, permanently rescinded the 2020 notice and directed HUD's fair housing office to find reasonable cause in pet policy waiver cases only where the animal is individually trained to perform disability related work or tasks. It states that requests to waive pet policies for untrained ESAs are not presumptively reasonable.
That is a shift in how HUD handles its own complaints, not a repeal of tenant protections. The memo does not change the text of the Fair Housing Act or eliminate private lawsuits, as the South Carolina Human Affairs Commission noted when it confirmed its state law protections are unaffected. California's Civil Rights Department issued a legal alert stating that state law still requires housing providers to accommodate untrained ESAs. HUD has also said it intends to pursue formal rulemaking, and no final rule exists yet, according to LeadingAge.
For operators, the practical lesson from this episode survives the federal change. The specific red flags the guests describe, from meaningless registration numbers to unverifiable provider contacts, still help separate purchased documents from real clinical relationships. What has changed is the legal backdrop, which now varies more by state. A portfolio that applies one documented, consistent review to every request, verifies providers through independent contact information, and keeps a respectful channel open for residents is better positioned under any version of the rules than one that approves everything to avoid conflict or denies broadly on the strength of a federal memo.
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