I spoke to NJ Civil Rights Department and they felt that was extremely suspicious. 

I'm a civil engineering graduate from Cleveland, Ohio.

@Pavel Ushakov  Not really Minneapolis I suppose but if I' ve got everything straight right now in seattle you CAN look at: Credit report Credit scorePrior rental historyCivil history (evictions or other housing related judgements)Employer reference (unless income is from a non-employer legal source, e.g. social security,  alimony)Income to rent ratio (must subtract any voucher income from rent when calculating it)History of commiting a sex crime as an adult (must have "business justification" if using this to deny)You CANNOT look at any criminal history except aboveYou CANNOT consider any credit or civil history more than 7 years oldYou cannot consider source of income  (any legal, verifiable source must be accepted, including short term vouchers)You CANNOT require up front payment of security deposit and last month's rent  (must offer six month payment plan if applicant requests it unless total of fees is less than 25% of one months rent)The "First in time" ordinance that Seattle passed was struck down by a judge,  and is currently on appeal to the state supreme court.  

There isn't much you can do to avoid litigation but make sure your attorney knows what he's talking about.Charge off and release are two different concepts.

You really need to be having this discussion with a civil attorney whose practice includes a focus on estate planning.

You'd be suprised how many beginners engage in illegal civil issues with tenants.

and you dont see alot about him becasue he does refunds .. unlike these other companies were once your money is gone unless you have the money to truly litigate your not getting it back

I am graduate of the University of California, Berkeley with a bachelors of science in Civil Engineering.

Yes you are smart for finding a solution that works, just make sure you do not cross any discrimination or fair housing laws while doing that and make sure that is written down in your policy and procedure manual or it can come back on you at some point in the form of litigation.

Over the years I've obtained a degree in Civil Engineering, have a General Contractors license, enjoyed 15 years building a hospitality business, then started an App Design company.