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Homes and Community Renewal

2009-B-01: Resident Disclosure of Social Security Numbers, Revisions to Pet Rules Relating to Persons with Disabilities and Dependent Deduction

To: All Federally-Assisted Housing Companies
     Owners, Managing Agents and Site Managers

From: Robert Damico, Downstate Director
          Housing Management Bureau

Date: January 22, 2009

Subject: Resident Disclosure of Social Security Numbers,
             Revisions to Pet Rules Relating to Persons with Disabilities and
             Dependent Deduction


In order to keep the staff of our federally assisted housing companies informed about current and/or proposed HUD requirements, we are providing you with the following information:

Resident Disclosure of Social Security Numbers

On June 29, 2007 a Proposed Rule was published in the Federal register proposing a revision to HUD's regulations on the resident disclosure of social security numbers. This revision to the regulations requires disclosure of social security numbers by all individuals applying for, or participating in, HUD's rental assistance programs. The Final Rule will be published in the Federal Register in the near future. Once the final Rule is in effect, applicants will be required to disclose and provide verification of the social security numbers for all members of their household before they can be admitted. Current residents will be required to disclose and provide verification of social security numbers of their household, where disclosure and verification has not occurred, at the time of their next interim or annual recertification.

Owners and management agents are encouraged to begin informing applicants and residents who have not disclosed their social security number, or the social security number of a child under the age of 6, or who have certified they do not have a social security number, of this upcoming revision to the regulations and their need to begin the process of obtaining a social security number.

For more information on resident disclosure of social security numbers, please refer to HUD Handbook 4350.3 REV.1, Occupancy Requirements of Subsidized Multifamily Housing Programs, Chapter 3, paragraph 3-31. This paragraph contains the existing rule.

Revisions to Pet Rules Relating to Persons with Disabilities

The Final Rule

revising the regulations on Pet Ownership for Persons with Disabilities was published in the Federal Register on October 27, 2008. The Final Rule is effective on November 26, 2008.

The Final Rule excludes animals that assist, support or provide services to persons with disabilities from the pet ownership rules. The revisions to the regulations:

For more information on assistance animals as a reasonable accommodation, please refer to HUD Handbook 4350.3 REV.1, Occupancy Requirements of Subsidized Multifamily Housing Programs, Chapter 2, paragraph 2-44.

Dependent Deduction

When more than one family shares custody of a child and both live in assisted housing, only one family at a time can claim the dependent deduction for that child. The family with primary custody, or with custody at the time of the initial certification or annual certification, receives the deduction. If there is a dispute about which family should claim the dependent deduction, the owner should refer to available documents such as copies of court orders or an IRS return showing which family has claimed the child for income tax purposes.

For more information on dependent deductions, please refer to HUD Handbook 4350.3 REV.1, Occupancy Requirements of Subsidized Multifamily Housing Programs, Chapter 5, paragraph 5-10.

If you have any questions, please call Linda Kedzierski, housing and Community Renewal Manager, at (212) 480-2021 or email her at LKedzierski@nyshcr.org.

- Robert Damico

Last updated on 05/18/10