Two statutes, two jobs
The Fair Housing Act governs dwellings and responds to requests. The ADA governs public accommodations, such as the brokerage office, and acts on its own.
Modification versus accommodation
A modification is a physical change to the premises under 42 U.S.C. 3604(f)(3)(A) and 24 CFR 100.203; the disabled person pays. A reasonable accommodation is a change to a rule, policy, practice, or service under 3604(f)(3)(B); the provider pays.
Worked example: a wheelchair user asks to widen an interior doorway and install grab bars for $2,400. That is a modification, so the tenant pays the $2,400, and the landlord may, where reasonable, require restoration of the interior at the end of the tenancy, with an interest-bearing escrow. Restoration covers interior work, not a ramp.
Assistance animals
Under HUD Notice FHEO-2020-01, an animal providing therapeutic emotional support is an assistance animal, not a pet. Waiving a no-pets policy is a reasonable accommodation, and no pet fee, pet deposit, or pet rent may be charged, though the owner stays liable for actual damage. Breed and weight limits do not apply. Limiting assistance animals to dogs imports the ADA definition, which does not govern housing.
Design and construction
Covered multifamily dwellings are buildings of four or more units with an elevator, all units covered, and the ground-floor units of four-or-more-unit buildings without one. The seven design requirements reach only buildings built for first occupancy after March 13, 1991. A six-unit walk-up first occupied in 1996 qualifies as to its ground-floor units; a three-unit walk-up or duplex is below the threshold.
ADA at the office
A brokerage office is a public accommodation under ADA Title III. In an existing building, barriers must be removed where removal is readily achievable — easily accomplishable without much difficulty or expense, per 42 U.S.C. 12181(9). That duty is proactive, not request-driven; the stricter standard applies to new construction first occupied after January 26, 1993.
Worked example: a brokerage spends $150,000 altering its office. Under 28 CFR 36.403(f), path-of-travel costs above 20% of the alteration are disproportionate: $150,000 × 0.20 = $30,000.