Comment Submitted by Kurt Aldinger, Flagstaff Housing Authority

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