Comments to HUD on Housing Assistance Restrictions for Immigrant Families
The Department of Housing and Urban Development (HUD) recently proposed a rule that would deny housing assistance to some immigrant households. We submitted comments focusing on serious flaws in HUD’s analysis of the rule’s impacts.
Under federal law, certain categories of noncitizens are ineligible for public housing or rental assistance. Regulations in place since the 1990s, however, allow “mixed status” households—in which some members are eligible for aid and others are not—to receive prorated assistance. HUD’s proposed rule would end this practice, forcing an estimated 25,000 mixed-status families to either separate or give up their home or rental subsidy.
In estimating the costs and benefits of this policy change, HUD fails to paint an accurate picture of mixed-status families’ likely responses to the new rule, unreasonably rejecting the possibility that families will separate in order to retain housing assistance for eligible members. As a result, the Department ignores the costs of such separations. HUD also underestimates moving, eviction, homelessness, and administrative costs that will result from the rule and provides no evidence or explanation to support its claims regarding the rule’s benefits.