NAHRO Submits Comment Letters on Mixed-Immigration-Status rule and FMR Methodology

Mixed Immigration Status Proposed Rule

On July 5, NAHRO submitted comments on HUD’s proposed immigration rule. The proposed rule, if implemented, would terminate federal housing assistance for families with mixed-immigration-statuses.

The National Association of Housing and Redevelopment Officials believes that the current verification of eligible status system should be left in place. The changes in the proposed rule would unnecessarily hurt families and children, including U.S. citizens, and add additional administrative burden, all without the commensurate benefits suggested in the proposal. The current subsidy proration policy decouples the size of the family from the federal benefit received. This policy has been in place for over two decades and providers of assisted housing, particularly those most impacted by this proposal that serve many mixed-status families, have not vocalized any hardships or desire to change the policy.

In its comment letter to HUD, NAHRO offers the following recommendations:

  1. Make no changes to the current eligible status verification regulations;
  2. If unwilling to follow the first recommendation, then restrict application of the new rule to new applicants of covered programs; and
  3. If unwilling to follow either of the first two recommendations, then take the steps and adopt the recommended language in NAHRO’s comment letter before implementing the proposed rule.

The Department will still be accepting comments until end of the day, July 9th. We encourage all of our members to submit comments in opposition to this rule. We also urge members to use their own language in writing comments, so that they are not automatically screened out before being read. Comments may be submitted here.

The National Association of Housing and Redevelopment Official’s full comment letter can be found here.

FMR Methodology Changes

On July 5, NAHRO submitted comments on HUD’s proposed changes in how it calculates FMRs. The National Association of Housing and Redevelopment Official’s comment letter can be found here.

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