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SSN Requirements HUD vs LIHTC

SSN Requirements in HUD vs. LIHTC

Lately, we have had a lot of questions from our Certification Approval clients about the requirements of Social Security Number disclosure on LIHTC vs. HUD programs. The most complex part of performing Move-In File Audits on multiple funding programs is helping our clients to understand why the same family is eligible at one property and not at another.

Mixed Immigration Status and Minor Without an SSN

We worked with a customer recently whose property is a Project-Based Section 8 HUD property with 100% LIHTC. The family, we’ll call her “Ms. Jones”, has applied to live at the property. Ms. Jones is not an eligible citizen of the US and does not contend eligible immigration status, and she has an infant with legal immigration status (a baby) who has not yet been issued a Social Security number (SSN). She also has two older children who do have SSNs and are legal immigrants. This family would not be eligible due to the HUD Section 8 requirements for SSN Disclosure, but if it was just a LIHTC property, there is no requirement for SSN disclosure.

For this scenario, Ms. Jones’s citizenship status is not what is causing the household to lose their eligibility for HUD Section 8. She is not claiming eligible immigration status and there are other members of the household who are eligible citizens. However, the baby who doesn’t have an SSN is what creates a compliance issue. The lack of SSN would make the entire family ineligible for the subsidy. HUD Notice H 10-08 was issued on 4/13/2010, and this notice states that an applicant must provide management with SSNs for all non-exempt household members prior to moving in.

Households with Pregnancy at the Time of Application

If an applicant is pregnant at the time of initial application and has a baby prior to the Move-In Date; they will have 90 days to provide management with an SSN for the baby and during that time can remain at the top of the waiting list, but cannot move in until they can provide a copy of the SSN. If the family is unable to provide management with the SSN within the 90 days, they will be determined ineligible and must be removed from the waiting list.

As we often have to tell our clients – many of the rules between HUD and Tax Credit line up closely, and other times – it’s not even close.

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