MHP comment on HUD proposed “mixed status” rule

July 9 was the last day to submit comments to oppose a proposed HUD rule that would put 25,000 mixed-status families, including 55,000 children, at risk of homelessness. Read our comment letter below. Learn more about the proposed rule.


Office of General Council, Rules Docket Clerk Department of Housing and Urban Development 451 7th Street SW, Room 10276, Washington, DC 20410-0500

Re: HUD Docket No FR-6124-P-01, RIN 2501-AD89 Comments in Response to Proposed Rulemaking: Housing and Community Development Act of 1980: Verification of Eligible Status 

To whom it may concern:

On behalf of the Minnesota Housing Partnership, thank you for the opportunity to provide comments in response to the Department of Housing and Urban Development’s (HUD) proposed rule  regarding “verification of eligible status,” published in the Federal Register on May 10, 2019 (RIN 2501- D89: HUD Docket No FR-6124-P-01). We express our strong opposition to this proposed rule, urge that it be withdrawn in its entirety, and that HUD’s long-standing regulations remain in place.

Minnesota Housing Partnership (MHP)

MHP convenes, guides and mobilizes diverse partners working to improve conditions of home and community, from private developers and tribal leaders to elected officials. Crossing boundaries to forge broad coalitions, we amplify a common vision: Building strong, equitable communities that provide opportunity for everyone, especially those with lower incomes. We provide capacity building and technical assistance in rural areas and Native nations, produce original research, and advocate for policies that advance affordable housing and strengthen communities.

MHP strongly opposes HUD’s proposed rule that could cause more than 100,000 people to be evicted from their homes, including more than 55,000 children who are U.S. citizens or have legal status. HUD’s own  analysis shows that the proposed rule will result in fewer families receiving federal housing benefits.

In Minnesota, HUD’s proposed rule will not create solutions and savings, but will increase costs, disrupt and destabilize families and children through the violent process of eviction, and produce distrust and fear – especially in immigrant families – of accessing government benefits for which they are qualified.

MHP prides itself on non-partisan, data driven solutions. It engages bipartisan lawmakers in developing smart policies and program design that increases supply of and access to affordable homes. This proposed rule is not a data driven solution to any articulable problem; rather, HUD’s own data indicates that the proposed rule will cost taxpayers a significant amount in fiscal and social outcome costs; it is clear there is no “problem” to be solved.

Minnesota impacts include:

  • There are 3,290 Minnesotans receiving housing assistance today who are elderly (over age 62) immigrants; elders are less likely to have the documents needed to verify their status, putting almost 3,300 elderly Minnesotans at risk of losing their homes under this rule
  • Minnesota families that face eviction, particularly immigrant families, will face certainly face homelessness. Potentially thousands of households in Minnesota may not have the new” required documentation of eligible status under the proposed rule, and thus face eviction and homelessness. Minnesota families are already facing a crisis in homelessness due to lack of affordable homes. While at least 90 households are “mixed status” in Minnesota, forcing an impossible choice between family and housing safety, potentially thousands may be impacted due to a lack of access to documentary proof of citizenship of nationality. A Minnesota homelessness study by Wilder research, found at, shows a 10% increase in homelessness since 2015. These results are in violation ofthe Minnesota goal to end homelessness.
  • Minnesota public housing systems are already insufficient to meet needs of Minnesota families; HUD’s proposed rule, which HUD’s own analysis shows may lead to a decrease in assisted families, will reduce the number of Minnesota families with safe housing at a time we need it most. As one indication of need, over 45,000 families recently signed up for a chance to wait for federal housing assistance (Section 8) in the Twin Cities metro area, with only 7,500 available waiting spots to be awarded.

We all share the concern that millions of U.S. households struggle to find affordable housing in the ongoing nationwide housing crisis, but blaming struggling immigrant families will not fix this problem. The real issue is the lack of funding to ensure that every family, including mixed-income immigrant families, has access to one of the most basic of human rights-a safe place to call home.

The Trump Administration should immediately withdraw this cruel and counterproductive proposed rule.


Elizabeth Glidden

Director of Strategic Initiatives and Policy