Discriminatory enforcement of CC&Rs by an HOA can support a claim for discrimination in housing under 12 USC 3604.  But here, all that the HOA did was write plaintiffs a letter threatening enforcement action.  It never took the threatened action and took no other step to enforce the CC&Rs against plaintiffs, and plaintiffs did not alter their conduct to avoid enforcement.  Absent adverse action, the 3604 claim failed.  However, the threat of enforcement was sufficient to support plaintiffs’ claim under 2 USC 3617 which prohibits threatening or intimidating anyone in the exercise of fair housing rights.  The decision holds that a plaintiff may state a claim under 12 USC 3605(b) based on a hostile housing environment.  However, the HOA could not be held liable, under a hostile housing environment theory, for hostile conduct by other homeowners against plaintiffs.  The HOA had no control over how homeowners acted toward one another.  Under 12 USC 3604(c), a party can be liable for a statement regarding sale or lease of a house that indicates a preference for or a bias against protected status.  For this purpose, statements are judged by an objective ordinary reader test.  Here, the letter threatening CC&R enforcement didn’t disclose any preference for non-religious persons.