Since the stated purpose of this rule is to fully implement the use of the Enterprise
Income Verification system (EIV) to promote the absolute best method of
determining correct subsidy, I must say that someone has missed the boat. I am
not sure how accuracy will be improved by requiring 3 month old children to submit
Social Security Numbers and Cards, but not "persons claiming not to have eligible
immigration status". Although they "do not receive assistance" they still benefit by
living in the federal subsidized housing. In addition the subsidy of those who
are "eligible non-citizens" or US Citizens is determined based on the income of all,
including those who are not required to provide Social Security Numbers. This
perpetuates the unjust system whereby we verify the information of US Citizens
seven ways from Sunday, while taking the word of those with no legal right to live in
our country. This also creates the unsafe situation where we have no real idea (in
the case of non-citizens) who we are really housing. Please, make this new reg
worthwhile!
I would also hope that a comprehensive list of documents that will be allowed to
verify citizenship will be included as guidance with the final reg to help us comply
with this requirement.
Lastly, I hope that the provisions allowing use of prior year's income to determine
rent will be left in the final rule. However, I believe this will require action on the
part of Congress to modify the Interim Recertification rule to allow this, and prevent
continued use of this rule to abuse the system
Comment Submitted by Kurt Aldinger, Flagstaff Housing Authority
This is comment on Proposed Rule
FR–5351–P–01 Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of Enterprise Income Verification
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