Update on HUD’s
LIHTC Tenant-Level
Data Collection
Mike Hollar
HUD
June 16, 2009
Overview
1. Review of HUD’s Mandate and Outreach
2. Addressing Comments Received
3. Timeline
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.
Data Collection Forms

Tenant Form:
 Based

Project Form:
 Use

on NCSHA Best Practices TIC.
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.
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.
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).
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:
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?

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 recertification.

Disability status can change, but race & ethnicity
does not need to be re-collected from tenant.
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.
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.
HUD’s Implementation Plan

Timeline:
 Define
Data Collection Standards:
Publish Proposed Rule
 Publish Final Rule

 Complete
July 2009
Nov 2009
Data Repository System Q1 2010
 Begin Collecting Data from States Q2 2010
 Release Public-Use Dataset and Report to
Congress