A “Refresher” on SSN Disclosure Requirements per the Final Rule

(effective 1/31/2010)
First, there are only two (2) exceptions to the requirement for providing a valid SSN:

1. The exemption for senior participants which is based on a two prong test-
   1. the participant must be 62 years of age or older on January 31, 2010; and
   2. the person’s initial determination of eligibility must have begun before that date.

   A participant who satisfies both prongs is exempt from the SSN requirements for all future income examinations, even if the senior moves to a new HUD-assisted property.

   A participant who fails either prong is subject to the SSN disclosure requirements.

2. The exemption for individuals who do not contend legal immigration status, and are therefore ineligible for HUD housing assistance.  In these cases, subsidy is pro-rated so that only the eligible household members receive the subsidy.

SSN Disclosure Requirements: (with above 2 noted exceptions)

1. New Move-ins and Initial Certifications:  ALL household members MUST provide valid SSNs, regardless of age.  Without a valid SSN for each member, housing assistance must be denied.
2. Existing households: When adding a household member to an existing household:
   1. If the member is age 6 or over, the SSN MUST be provided by the time the recertification is processed adding the member. The OA must not add the new member until the SSN is provided.
   2. If the member is under age 6, and they do not have a SSN, the SSN must be obtained within 90 calendar days of the child being added to the household.  An additional 90-day period may be granted for unforeseen circumstances.

Remember, the SSN disclosure requirements are an essential component to the full and successful implementation of EIV.  Subject to the exceptions allowed, an entire household may lose its tenancy if one member of the household does not comply with the SSN disclosure requirements.