HUD's EIV & SSN rules open for public comment

On October 15, HUD posted for public comment a proposed multi-family housing rule which could effectively separate the requirements for mandatory use of EIV from the other occupancy related changes contained in the earlier final rule, which had caused confusion and which amendments were not central or necessary to full implementation of EIV.

One possible outcome is the 'grandfathering' of participants 62 years of age or older from new SSN requirements, and exemption for individuals who have already disclosed a valid SSN. We are concerned that some housing providers may have existing elderly residents who do not have or cannot produce documentation of a valid SSN, yet have been receiving housing assistance and in compliance with all program requirements so far. Does the proposed rule language go far enough, or could it still leave actual residents at risk of loss of subsidy or eviction for inability to obtain or prove a valid SSN?

The rule language can be found here: http://edocket.access.gpo.gov/2009/pdf/E9-24809.pdf