Chaplaincy Engages & Housing & Urban Development

Statement: Chaplain Engagement with HUD, Housing Justice, and Community Safety

Credentialed chaplains, including those licensed through the International Association of Licensed and Commissioned Chaplains (IALCC), work in collaboration with HUD and local housing authorities to address the systemic challenges that arise from historical redlining, housing inequities, and neighborhood criminality.

This is the principal HUD regulation that authorizes faith‑based organizations to participate in HUD programs on the same basis as secular organizations:

• Faith‑based organizations are eligible, on the same basis as any other organization, to participate in any HUD program or activity for which they are otherwise eligible. 
• HUD, and any recipient of HUD funds, shall not discriminate for or against an organization based on its religious character, motives, affiliation, or lack thereof. 
• A faith‑based organization “retains its autonomy, right of expression, religious character, authority over its governance, and independence” while participating in HUD programs. 
• The regulation protects organizations from being disqualified from HUD participation simply because of their religious identity or mission. 

This regulation ensures that religious entities can work with HUD and receive program support or contracts without facing discrimination based on their faith identity.

This section applies HUD’s equal participation policy (from § 5.109) specifically to the Emergency Solutions Grants (ESG) program:

• Faith‑based organizations may participate in ESG activities consistent with the general HUD equal‑participation policy. 

Based on these regulations and policies:

• A faith‑based chaplaincy organization may apply for, participate in, or partner with HUD programs and activities when they meet program eligibility requirements — just like any secular nonprofit. 
• HUD cannot exclude or disadvantage the organization because it is religious. 
• The organization retains its governance independence and religious identity, even while partnering with HUD. 
• This does not require the organization to abandon its beliefs — only that the federally supported activities provided under HUD programs adhere to applicable requirements (for example, they may not use direct HUD funds for explicitly religious exercises). 

HUD’s equal‑participation rule (§ 5.109) is based on these executive orders:

• Executive Order 13279, “Equal Protection of the Laws for Faith‑Based and Community Organizations,” directs federal agencies to treat faith‑based organizations on an equal footing with other organizations in federal programs. 
• Executive Order 13559, “Fundamental Principles and Policymaking Criteria for Partnerships With Faith‑Based and Other Neighborhood Organizations,” reinforces that federal programs must allow faith‑based partners to compete and participate without discrimination. 

These Orders are part of the legal foundation for HUD’s rule allowing chaplaincy and similar entities to participate in federal community programs.

HUD created an internal office to facilitate these partnerships:

• Established to assist faith‑based entities (“FBOs”) and houses of worship in strengthening community service efforts.
• It facilitates communication between faith communities and HUD, provides training, education, and connections to help organizations engage with HUD and pursue grants or partnerships. 

While this is not a standalone statute, it is an official HUD structure grounded in the policy that HUD should engage with faith‑based partners. 

• The Fair Housing Act (42 U.S.C. § 3601 et seq.) and related framework require HUD to advance fair housing. Chaplains engaged in community advocacy or housing justice work can support local fair housing efforts aligned with these goals. 

• HUD regulations explicitly require that organizations receiving federal funds not discriminate against beneficiaries on the basis of religion, belief, or other protected characteristics. 

HUD equal participation rule: 24 C.F.R. § 5.109 — faith‑based organizations can participate in HUD programs on equal footing. 

Program‑specific application: 24 C.F.R. § 576.406 (ESG inclusion) applies faith‑based participation rules. 

Executive Orders: E.O. 13279 & 13559 support equal treatment and partnership criteria. 

HUD outreach structure: HUD Center for Faith facilitates engagement.