Use cases

Rental inquiries and showings

How a renter's agent and a landlord's agent could handle availability, showings and pre-screening, and how fair-housing and human-rights rules bear on it.

A renter’s first contact with a listing is a handful of questions (is it still available, what does it cost, are cats allowed, when can I see it) followed by a showing. A renter’s agent and a property manager’s agent can handle those in seconds and book the showing directly. Screening is different. Once an agent starts deciding who gets a showing or an application, fair-housing and human-rights law applies to what it does, and some decisions belong with people.

How it works today

Listings flow from property managers and MLSs to listing sites. For MLS data, RESO sets the standards: the Data Dictionary (version 2.0 ratified) defines the fields, and the RESO Web API Core 2.0.0, built on OData and OAuth, moves the data. Renters inquire by form, phone or text, and a leasing agent replies, answers the same questions many times a day, and books showings. Some buildings offer self-guided tours.

An application usually triggers a consumer report. Under FCRA section 1681m, a landlord who takes adverse action based on a report must tell the applicant, name the reporting agency, say the agency did not make the decision, give any credit score used with its key factors, and explain the right to a free report within 60 days and to dispute it. The FTC’s landlord guidance restates these duties.

United States: fair housing. Section 3604 of the Fair Housing Act makes it unlawful to refuse to rent or negotiate, or otherwise make a dwelling unavailable, because of race, color, religion, sex, familial status or national origin (with disability covered in 3604(f)). Two parts bear directly on an agent that answers inquiries: 3604(c) covers any statement indicating a preference or limitation, and 3604(d) makes it unlawful to tell someone a unit is not available for inspection when it is.

HUD issued guidance on tenant screening and on advertising through digital platforms on 29 April 2024. HUD withdrew the advertising guidance in a memo dated 17 September 2025, published in the Federal Register on 6 April 2026. The screening guidance was not named in that notice or in HUD’s July 2026 notice withdrawing other guidance, but it is no longer on HUD’s live site and survives only in HUD’s archive. The statute applies either way.

Canada: human rights codes. Housing is provincial. Two examples:

  • Ontario. The Human Rights Code (s. 2) guarantees equal treatment in occupying accommodation, on grounds that include family status, disability and receipt of public assistance. Under section 21(3) and Ontario Regulation 290/98, landlords may ask for credit references, rental history and consent to a credit check, and may ask for income information only together with those and must weigh it with them. The Ontario Human Rights Commission’s policy on rental housing treats rent-to-income cut-offs, such as a 30% rule, as discriminatory except in rent-geared-to-income housing, and says a lack of rental or credit history should not count against an applicant.
  • British Columbia. The Human Rights Code (s. 10) bars denying a tenancy on listed grounds, including lawful source of income.

The agent-to-agent version

Illustrative. A renter’s agent asks a property manager’s agent about a listed unit:

{
  "jsonrpc": "2.0",
  "id": 6,
  "method": "SendMessage",
  "params": {
    "message": {
      "role": "ROLE_USER",
      "messageId": "msg-rn-3301",
      "parts": [
        {"text": "Is unit 4B still available? My principal would like to see it this week."},
        {
          "data": {
            "listingId": "LST-88213",
            "moveIn": "2026-11-01",
            "pets": [{"type": "cat", "count": 1}],
            "questions": ["monthlyRent", "utilitiesIncluded", "parking", "petPolicy"],
            "showingWindows": [
              {"start": "2026-09-29T22:00:00Z", "end": "2026-09-30T01:00:00Z"},
              {"start": "2026-10-01T15:00:00Z", "end": "2026-10-01T19:00:00Z"}
            ]
          },
          "mediaType": "application/json"
        }
      ]
    }
  }
}
  1. The property manager’s agent answers from the listing record: rent, utilities, parking, a pet policy that allows one cat.
  2. It offers every open showing slot in the requested windows, the same slots it offers any other inquirer.
  3. The renter’s agent books one. For a self-guided tour, the building’s own check of the person arriving still applies.
  4. The application, the consent to a credit check and any accommodation request go to the people on both sides.

What has to be true

Identity. The renter’s agent needs to know it is dealing with the real property manager for that unit, which the manager’s Agent Card on its own domain can establish. The manager’s agent needs to know which renter’s agent is asking, mostly to apply rate limits and to keep a consistent record.

Authority. A renter can safely delegate questions and booking a showing. Consenting to a credit check, disclosing income and signing anything should stay with the renter. On the landlord side, the agent’s answers are the landlord’s statements, and whatever criteria it applies are the landlord’s criteria.

Record. Consistency is the practical protection under both sets of rules: every inquirer asking the same question gets the same answer and the same slots. A log of each inquiry, what was said and which slots were offered lets a property manager show that, and lets a renter show otherwise.

Where Emissar fits

  • Front Door (open to design partners) lets a property manager answer renters’ agents in front of the listing and scheduling systems it already uses.
  • Verify (in development) tells the manager which provider runs the renter’s agent.
  • Ledger (spec in progress) would keep a signed record of each inquiry and answer, available to both sides.
  • Handoff (in development) routes applications, accommodation requests and anything outside the listing’s facts to a leasing agent with the exchange attached.

Open questions

  • Automated screening. Where is the line between answering questions and screening? An agent that tells some renters a unit is taken and others that it is open creates exactly the 3604(d) problem.
  • What renters’ agents disclose. The data sent should be what the listing questions need. Details about household members, health or sources of income are exactly what these rules protect, and an agent has no reason to volunteer them.
  • Status of HUD guidance. With the 2024 screening guidance off HUD’s live site but not formally withdrawn, operators have less federal guidance to design against than they did two years ago.
  • Provincial differences. Protected grounds differ by province, such as lawful source of income in British Columbia. A single national agent needs per-province rules.

Questions

Can a landlord's agent pre-screen applicants automatically?
The fair-housing and human-rights rules apply to the landlord whether a person or software applies the criteria. In Ontario, for example, the Human Rights Commission's policy treats rent-to-income cut-offs as discriminatory outside rent-geared-to-income housing, so an automated income ratio would run into that policy. This page describes the rules; it is not legal advice.
Is HUD's 2024 tenant-screening guidance still in force?
HUD did not name it in its 2025 and 2026 withdrawal notices, but it is no longer on HUD's live site and survives only in HUD's archive. The companion guidance on advertising through digital platforms was formally withdrawn. The Fair Housing Act itself is unchanged.

Sources

  1. 42 U.S. Code § 3604 (Fair Housing Act): Discrimination in the sale or rental of housing (accessed )
  2. HUD: Housing Discrimination Under the Fair Housing Act (accessed )
  3. HUD FHEO: Notice of the Withdrawal of FHEO Guidance Documents (17 September 2025) (accessed )
  4. Federal Register: Notification of Withdrawal of Fair Housing and Equal Opportunity Guidance Documents (6 April 2026) (accessed )
  5. Federal Register: Notice of the Withdrawal of OGC Guidance Documents (17 July 2026) (accessed )
  6. HUD archive: HUD Issues Fair Housing Act Guidance on Applications of Artificial Intelligence (May 2024) (accessed )
  7. 15 U.S. Code § 1681m (FCRA): Requirements on users of consumer reports (accessed )
  8. FTC: Using Consumer Reports: What Landlords Need to Know (accessed )
  9. Ontario Human Rights Code, R.S.O. 1990, c. H.19 (accessed )
  10. Ontario Regulation 290/98: Business Practices Permissible to Landlords in Selecting Prospective Tenants (accessed )
  11. Ontario Human Rights Commission: Policy on human rights and rental housing (accessed )
  12. British Columbia Human Rights Code, section 10 (accessed )
  13. RESO Data Dictionary (accessed )
  14. RESO Web API (accessed )