Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56 Page 57 Page 58 Page 59 Page 60 Page 61 Page 62 Page 63 Page 64WWW.AGRM.ORG JULY/AUGUST 2016 17 Scott and Stephen are attorneys and shareholders in the law firm of Gammon & Grange, P.C. in McLean, Virginia. Scott leads the firm’s Religious Liberty practice group and Litigation practice group. Steve serves as the firm’s Managing Shareholder and co-leads its Exempt Organizations practice group. Visit www.gg-law.com for more information. “equal access” rule, which applies to shelters receiving a range of HUD-related funds and that prohibits assigning persons on the basis of actual or perceived sexual orientation or gender identity. If triggered, the new HUD rule requires deference to the individual’s stated gender iden- tity and makes it difficult (and risky) to apply security, safety, and privacy considerations in making assignments. 4. Strengthen Your Mission’s Religious Identity by Reviewing All Government Contracts, Grants, Sub-grants, and Other Possible Sources of Government Funds The HUD equal access rule is just one reason that it is critical to review your mission’s contracts, grants, and other sources of govern- ment funds (directly or as a sub-recipient). Receipt of certain HUD-administered funds could trigger the HUD “equal access” rule. Similarly, entering into a contract with the government—or into a subcontract with a gov- ernment contractor—could trigger the SOGI non-discrimination requirements that President Obama’s 2015 Executive Order 13672 made applicable to all federal government contractors. If so, your mission needs to determine whether a longstanding religious exemption (which mirrors the Section 702 exemption) provides protection. All such government contracts should also be reviewed to ensure that they do not undermine your mission’s legal rights as a religious organiza- tion. Provisions waiving such rights sometimes lurk hidden in a government contract or in the (often extensive) attachments. By taking these steps and others comprised in a religious identity audit, your mission can safeguard its legal rights, better achieve its God-given purposes, and avoid creating its own “identity crisis.” Ĩ