1. OHCS is of the opinion that applicants that cannot disclose the SSN should be able to remain on the waiting list for 90 days with one 90-day extension. They should not be able to remain indefinitely on the waiting list.
2. Under Section A.5. OHCS thinks that the owner should not have the ability to determine when a newly assigned SSN must be disclosed. We would like to have the statement "or at such earlier time specified by the processing entity" removed.
3. Section 5.218 (c)(3) states, "Failure of the participant to disclose a SSN by the deadline specified in paragraph (c)(2) of this section will result in termination of the assistance or tenancy, or both, of the participant." Please clarify if the entire household would lose their tenancy if one member of the household (ie. a child under six years of age) does not comply with the SSN disclosure.
Comment Submitted by Rhonda Crawford
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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