Comments Cite Privacy Act and Statutory Concerns over HUD’s Implementation of the Report
PHADA joined the National Association of Housing and Redevelopment Officials (NAHRO), the National Leased Housing Association (NLHA), the Council of Large Public Housing Authorities (CLPHA), and the Housing and Development Law Institute (HDLI) in submitting comments on HUD’s proposed Privacy Act System of Records Notice (SORN) for the Enterprise Income Verification (EIV)–Systematic Alien Verification for Entitlements (SAVE) Tenant Matching Report.
The comments note that HUD began requiring Public Housing Authorities (HAs) to use the EIV-SAVE Tenant Matching Report months before publishing the required SORN, and before completing the Privacy Act’s notice-and-comment process, raising concerns about the order of operations HUD followed in rolling out the requirement.
The coalition also argues that HUD exceeded its statutory authority by requiring SAVE verification for certain categories of individuals not authorized under the amended Section 214 of the Housing and Community Development Act of 1980.
Given these deep concerns, the industry groups ask HUD to:
- Suspend use of the EIV-SAVE Tenant Matching Report and the related attestation requirement;
- Withdraw the current SORN; and
- Resolve the procedural and statutory issues identified before proceeding with implementation.
PHADA will continue working with its industry partners and HUD on this issue and will keep members informed of developments, including HUD’s response to the coalition’s comments.