NAHRO Submits Comments on Form HUD-9886-A

On August 21, NAHRO submitted comments on HUD’s proposed revisions to Form HUD-9886-A, the Authorization for the Release of Information/Privacy Act. While NAHRO supports modernizing HUD forms and strengthening income-verification processes, it raised concerns about changes to the form’s authorization language.

Most notably, the proposed form includes a new, standalone authorization allowing the Social Security Administration (SSA) to verify applicants’ identities and disclose information about Social Security benefits and payment amounts. NAHRO asked HUD to clarify whether this language simply reflects existing computer-matching practices or would expand the information applicants are authorizing SSA to disclose.

NAHRO also urged HUD to confirm that SSA information obtained under the revised authorization will be used only for income and identity verification for HUD-assisted housing programs – not for immigration verification or other purposes. Finally, NAHRO questioned HUD’s characterization of the proposal as an extension of an existing information collection, arguing that changes to the legal consent language may constitute a substantive revision under the Paperwork Reduction Act.

NAHRO asked HUD to provide greater clarity on the scope, legal effect, and permitted uses of the revised authorization before implementing the new form.