Update on HUDs LIHTC TenantLevel Data Collection Mike

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

Overview 1. 2. 3. Review of HUD’s Mandate and Outreach Addressing Comments Received Timeline

HUD’s Mandate n 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.

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

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

Addressing Comments n 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).

Addressing Comments n Disability questions. ¨ OMB will not require use of questions included on major Federal household surveys. ¨ HUD will use more focused questions: Possibilities include: 1. Is anyone in family: Mobility Impaired? Hearing Impaired? Visually Impaired? 2. Does any member of this household have serious difficulty walking or climbing stairs? Difficulty bathing? Does the unit contain accessibility features? n

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

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

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

HUD’s Implementation Plan n Timeline: ¨ Define Data Collection Standards: Publish Proposed Rule n Publish Final Rule n ¨ Complete July 2009 Nov 2009 Data Repository System Q 1 2010 ¨ Begin Collecting Data from States Q 2 2010 ¨ Release Public-Use Dataset and Report to Congress