3-9 Disclosure of Social Security Numbers

All applicant and tenant household members must disclose and provide verification of the complete and accurate SSN assigned to them except for those individuals who do not contend eligible immigration status or tenants who were age 62 or older as of January 31, 2010, and whose initial determination of eligibility was begun before January 31, 2010. This paragraph explains the requirements and responsibilities of applicants or tenants to supply owners with this information, the responsibility of owners to obtain this information, and the consequences for failure to provide the information.

• A. Key Requirements

  1. *Applicants and tenants must disclose and provide verification of the complete and accurate SSN assigned to each household member. Failure to disclose and provide documentation and verification of SSNs will result in an applicant not being admitted or a tenant household’s tenancy being terminated.

  2. Exceptions to disclosure of SSN:

     • a. Individuals who do not contend eligible immigration status.

       • (1) Mixed Families: For projects where the restriction on assistance to noncitizens applies and where individuals are required to declare their citizenship status, proration of assistance or screening for mixed families must continue to be followed. In these instances, the owner will have the tenant’s Citizenship Declaration on file whereby the individual did not contend eligible immigration status to support the individual not being subject to the requirements to disclose and provide verification of a SSN.

HUD Occupancy Handbook Chapter 3: Eligibility for Assistance and Occupancy

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• (2) For Section 221(d)(3) BMIR, Section 202 PAC, Section 202 PRAC and Section 811 PRAC properties, the restriction on providing assistance to noncitizens does not apply. At these properties, individuals who do not contend eligible immigration status must sign a certification, containing the penalty of perjury clause, certifying to that effect. The certification will support the individual not being subject to the requirements to disclose or provide verification of a SSN. The certification must be retained in the tenant file.

(See Paragraphs 3-12.N, O and P for more information on mixed families and proration of assistance)

• b. Individuals age 62 or older as of January 31, 2010, whose initial determination of eligibility was begun before January 31, 2010.

  • (1) The exception status for these individuals is retained even if there is a break in his or her participation in a HUD assisted program.

  • (2) When determining the eligibility of an individual who meets the exception requirements for SSN disclosure and verification, documentation must be obtained that verifies the applicant’s exemption status. A certification from the tenant is not acceptable verification of the exemption status. This documentation must be retained in the tenant file.*

HUD Occupancy Handbook Chapter 3: Eligibility for Assistance and Occupancy

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Section 1: Program Eligibility

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*Example:

• Mary Smith does not have a SSN. Mary does not have to disclose or provide verification of a SSN because she was 73 years old as of January 31, 2010, and her initial eligibility for HUD’s rental assistance program was determined when she moved into Hillside Apartments on February 1, 2009 (initial eligibility was determined prior to January 31, 2010).

• Mary moved out of Hillside Apartments on April 10, 2010 and moved in with her daughter who was not receiving HUD’s rental assistance.

• Mary then applied at Jones Village, another HUD subsidized apartment complex, on November 5, 2010. Because Mary’s initial eligibility to receive HUD’s rental assistance was begun prior to January 31, 2010 (February 1, 2009), Mary is not required to meet the SSN disclosure and verification requirements as long as the owner can verify Mary’s initial eligibility date at Hillside Apartments was begun prior to January 31, 2010.*