March 11, 2010
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On February 24, HUD published a Federal Register notice soliciting comments on its proposed tenant and project data forms for collecting data on Low Income Housing Tax Credit (Housing Credit) tenants and properties.  The Housing and Economic Recovery Act (HERA) of 2008 requires each state Credit allocating agency to provide HUD with information on the race, ethnicity, family composition, age, income, use of federal rental assistance, disability status, and monthly rental payments of households residing in each property receiving Housing Credits.  The proposed forms represent HUD’s efforts to comply with HERA’s mandate. 

 HUD has submitted to the federal Office of Management and Budget a request for approval of the data collection forms.  HUD is also soliciting comments from the public and affected agencies to:  evaluate whether the proposed information collection is necessary and will have practical utility; receive input on whether the agency’s information collection burden estimate is accurate and how to minimize that burden; and enhance the quality, utility, and clarity of the information to be collected. 
 
Comments on the proposed data collection forms are due to HUD on March 26.  NCSHA will submit comments to HUD on behalf of all HFAs.  Please send your comments on the data collection forms to Ellen Lurie Hoffman by March 17 for inclusion in NCSHA’s comments.
 
On March 3, HUD also published a related notice in the Federal Register, which provides a summary of the comments HUD received last year on its Housing Credit information collection plans and HUD’s response.  HUD has accommodated several of the comments NCSHA submitted at that time and has rejected others.  Though HUD is not encouraging parties which submitted comments in 2009 to resubmit their comments, NCSHA may have additional and new points to make in light of HUD’s plans.