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GN 03314.105: Disclosure Without Consent to Public Housing Authorities

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  • Effective Dates: 01/17/2017 - Present
  • Effective Dates: 06/06/2018 - Present
  • TN 2 (01-17)
  • GN 03314.105 Disclosure Without Consent to Public Housing Authorities
  • A. Disclosure of information to the Federal Department of Housing and Urban Development (HUD)
  • Public housing agencies (PHA) administer certain federally funded housing programs sponsored by HUD and the Farmers’ Home Administration (FmHA). To administer the housing programs effectively, PHAs access the Enterprise Income Verification (EIV) system maintained by the HUD Real Estate Assessment Center (REAC). We electronically provide HUD with benefit verification on all current participants and household members who disclosed a valid Social Security Number (SSN) to HUD. HUD, in turn, makes this information available to administrators of public housing programs through the EIV system. EIV supports HUD’s Housing Choice Voucher and Public Housing programs (Section 8), both of which assist low income families, the elderly, and the disabled afford decent, safe, and sanitary housing in the private market.
  • Prior to the use of EIV, HUD maintained the Tenant Assessment Subsystem (TASS) through which PHAs received the data they needed for administering the public housing programs. EIV is a secure web-based system that contains sensitive financial and rental housing information. Persons must register for a system identification credential to gain access to the EIV system. EIV data is current and allows HUD’s program administrators to access our Title II and Supplemental Security Income benefit history information through an Internet portal.
  • B. Disclosure policy
  • Federal housing programs are income-maintenance programs. We may disclose certain non-tax return information to PHAs to administer the subsidized housing programs sponsored by HUD and FmHA.
  • NOTE: HUD recognizes private landlords participating in Title VIII housing programs as agents of HUD. We may disclose information to HUD Title VIII landlords without the tenant’s written consent. However, consistent with the guidance in GN 03314.105A in this section, private landlords should utilize the EIV system. Unlike landlords participating in Title VIII housing programs, landlords participating in FmHA housing programs must secure the tenant’s written consent when requesting SSA data. This is because FmHA has not recognized private landlords participating in FmHA housing programs as its agents.
  • REMINDER: Loans for home improvement, mortgages, or other purposes do not meet our criteria for an income maintenance program. For the definition of an income maintenance program, see GN 03314.001A.4. Do not disclose personal information without consent when the disclosure request does not meet our income maintenance criteria. Refer requests for information in connection with loan programs to the regional office Data Exchange Coordinator (DEC) or Privacy Act Coordinator (PAC).
  • We may disclose certain non-tax return information, including verification of SSNs, to PHAs for administration of the subsidized housing programs sponsored by HUD and the FmHA. Disclosure is permissible under the health maintenance and income maintenance routine use cited in a number of our systems of records, including but not limited to the following:
  • * 60-0058—Master Files of SSN Holders and SSN Applications System;
  • * 60-0089—Claims Folders System;
  • * 60-0090—Master Beneficiary Record;
  • * 60-0103—Supplemental Security Income Record and Special Veterans Benefits System; and
  • * 60-0320—Electronic Disability Claims File.
  • For information concerning the verification of SSNs, see GN 03325.003.
  • For information concerning the verification of SSNs, see GN 03325.002.
  • For information on the disclosure of tax return information to HUD, see GN 03320.015C.2.
  • C. Procedure for handling requests
  • We provide benefit verifications that PHAs need to administer public housing programs to HUD’s EIV system, as stated in GN 03314.105A in this section. SSA and HUD developed a centralized electronic data exchange, replacing the need for us to respond to most income verification requests from HUD Program Administrators of rental assistance programs. Refer requests received from PHAs and private landlords participating in Title VIII housing programs to HUD’s EIV system. Process requests received from private landlords participating in FmHA housing programs in the FO, with the written consent of the tenant. Consult with the regional office DEC or PAC for resolutions of questions regarding PHAs administration of public housing programs. For more information regarding the handling of requests from State and local agencies, see GN 03314.001E.
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