Q&A: Social Security Number Requirements

Question: I have an applicant that delivered a child three days before she moved in. When she came to sign her documents and receive the keys to her new unit, I told her she had 90 days to provide me with verification of her new daughter’s social security number. Did I handle that correctly?

Answer:
Revised answer effective April 7, 2016, due to Federal Register, Streamlining Administrative Regulations for Public Housing, Housing Choice Voucher, Multifamily Housing, and Community Planning and Development Programs.

Yes. Since the baby is under the age of 6 and was added to the household within the last six months, the household has 90 days to provide the SSN.
If the household is still unable to provide the SSN at the end of the 90 day period, one additional 90 day extension will be granted to provide the SSN.

Answer originally published December 29, 2009.
Unfortunately, no. This is a common misinterpretation of the regulations related to the disclosure of social security numbers that have been in effect since January 31, 2010. Applicants must disclose and provide verification of the complete and accurate SSN assigned to each household member, prior to being admitted to the property. There are two exceptions to this rule: 1) those claiming ineligible, non-citizen status and 2) individuals age 62 or older as of January 31, 2010 and whose initial determination of eligibility began before January 31, 2010.

The 90-day extension only applies to new members, under the age of 6 without an assigned SSN, being added to an existing household (an in-place tenant household).

In your scenario, if the applicant had moved in and then delivered her child after move-in, the extension could be granted.

See Section 3-9 of HUD Handbook 4350.3 REV-1 CHG-4 for a full description of the SSN disclosure requirements for applicants versus tenants.