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Update on HUD’s LIHTC Tenant-Level Data Collection

Update on HUD’s LIHTC Tenant-Level Data Collection. Mike Hollar HUD June 16, 2009. Overview. Review of HUD’s Mandate and Outreach Addressing Comments Received Timeline. HUD’s Mandate.

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Update on HUD’s LIHTC Tenant-Level Data Collection

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  1. Update on HUD’s LIHTC Tenant-Level Data Collection Mike Hollar HUD June 16, 2009

  2. Overview • Review of HUD’s Mandate and Outreach • Addressing Comments Received • Timeline

  3. HUD’s Mandate • The Housing and Economic Recovery Act of 2008 (HERA) requires HUD to collect and report on the following information for LIHTC tenants: • Race; • Ethnicity; • Family Composition; • Age; • Income; • Use of Section 8 (or other) Rental Assistance; • Disability Status; and • Monthly Rental Payment.

  4. Data Collection Forms • Tenant Form: • Based on NCSHA Best Practices TIC. • Project Form: • Use HUD’s LIHTC form. • Submission of both tenant and project data would use XML format and HUD’s iMAX system, similar to submission of TRACS data.

  5. Soliciting Early Comments • Presentations at TRACS quarterly meetings and NCSHA’s HFA Institute. • Working Group and Online Forum • Over 100 individuals representing state housing agencies, software vendors and non-profits. • Solicitation of Comment published in Federal Register (March 30, 2009). • Comments posted on www.regulations.gov • Proposed Notice will contain HUD’s response.

  6. Addressing Comments • Collection of SSNs • Why? To identify Section 8 tenants by matching to HUD’s TRACS database. • Several commenters requested that HUD not collect data for LIHTC Section 8 tenants, but instead use TRACS data. • Concerns over privacy protections. • Response: Need SSNs to ensure accurate match. HUD believes accurate matches could be obtained with last 4-digits only (and DOB).

  7. Addressing Comments • Disability questions. • OMB will not require use of questions included on major Federal household surveys. • HUD will use more focused questions: • Possibilities include: • Is anyone in family: Mobility Impaired? Hearing Impaired? Visually Impaired? • Does any member of this household have serious difficulty walking or climbing stairs? Difficulty bathing? Does the unit contain accessibility features?

  8. Addressing Comments • Race, Ethnicity and Disability • Comment: Allow these as an addendum to existing state TIC forms. • HUD will not require specific forms, but rather standards and definitions of data elements. • Comment: Collect only once, not each re-certification. • Disability status can change, but race & ethnicity does not need to be re-collected from tenant.

  9. Addressing Comments • Family Composition and Age • Comment: Collect these in aggregate for HH. • Can’t fully understand Family Composition if collected in aggregate. • Age would not need to be recollected from tenant if DOB provided for each member. • Rent • Comment: Collect components of rent. • Tenant form requests: Tenant Paid Rent; Rental Assistance; Utility Allowance; Other Non-Optional charges.

  10. Implementation • Initial collection will include all projects and tenants in low-income units. • Does not apply to market rate units. • Annual updates will include only: • New projects and buildings. • New and re-certified tenants; • No updates for same tenants in 100% low-income projects. • Data will be required for all properties monitored for compliance.

  11. HUD’s Implementation Plan • Timeline: • Define Data Collection Standards: • Publish Proposed Rule July 2009 • Publish Final Rule Nov 2009 • Complete Data Repository System Q1 2010 • Begin Collecting Data from States Q2 2010 • Release Public-Use Dataset and Report to Congress

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