Pta

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]

Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:
Form Title:
Component:

FEMA Form (FF) 000-0-0
IHP Occupancy & Ownership Verification
Federal Emergency
Office:
Office of Response and
Management Agency
Recovery (ORR)
(FEMA)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Disaster Assistance Registration
August 31, 2024
OMB Control
1660-0002
OMB Expiration
Number:
Date:
Click here to enter a
Collection status:
Revision
Date of last PTA (if
date.
applicable):
Name:
Office:
Phone:
Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Brian Thompson
ORR
Title:
Unit Chief
540-686-3602
Email:
[email protected]
s.gov

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Brian Thompson
ORR
Title:
Unit Chief
540-686-3602
Email:
[email protected]
s.gov

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
The purpose of this PTA is to expand on the types of additional documents that will be
requested and accepted from FEMA applicants when verifying ownership or occupancy
during the application process for FEMA Individuals and Households Program
assistance.

On January 20, 2021, President Biden issued Executive Order 13985, Advancing Racial
Equity and Support for Underserved Communities Through the Federal Government,
designed to pursue a comprehensive approach to advancing equity for all, including
people of color and others who have been historically underserved, marginalized, and
adversely affected by persistent poverty and inequality. Pursuant to this Executive Order
and other related presidential memoranda, FEMA posted a Request for Information (RFI)
in the Federal Register, requesting information on the extent to which existing agency
programs, regulations, and policies perpetuate systematic barriers to opportunities and
benefits for people of color and other underserved groups; bolster resilience to the
impacts of climate change; and address the disproportionately high and adverse climaterelated impacts on disadvantaged communities.
Based on the feedback received via this RFI and an internal analysis of our statutory and
regulatory authorities and current policy and program guidance, FEMA noted areas
where additional flexibilities could be provided to ensure access to assistance is
equitably provided to all applicants; when FEMA applicants are unable to provide the
requested occupancy or ownership verification documents, FEMA will accept a selfdeclarative statement of occupancy or ownership when the damaged dwelling was that
of a mobile home, travel trailer, or island/tribal.

The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), Public
Law 93-288, as amended, is the legal basis for the Federal Emergency Management
Agency (FEMA) to provide financial assistance and services to individuals applying for
disaster assistance benefits in the event of a federally-declared disaster. Regulations in
44 CFR, § 206.110 - Federal Assistance to Individuals and Households implements the
policy and procedures set forth in Section 408 of the Stafford Act, 42 U.S.C. 5174, as
amended. This program provides financial assistance and, if necessary, direct assistance

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

to eligible individuals and households who, as a direct result of a major disaster or
emergency, have uninsured or under-insured, necessary expenses and serious needs,
and are unable to meet such expenses or needs through other means.

Individuals and households applying for assistance must provide information detailing
their losses and needs through this information collection. The Other Needs Assistance
(ONA) provision of the Individuals and Households Program (IHP) provides financial
assistance to address disaster-related medical, dental, funeral, child care, personal
property, transportation, and other necessary expenses or serious needs resulting from a
major disaster.

FEMA is required to provide meaningful access to its programs and activities for people
with disabilities under Section 504 of the Rehabilitation Act of 1973 and Section 308 of
the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), PL 93288, as amended. FEMA regulations at 44 CFR Part 16, Enforcement of Nondiscrimination
on the Basis of Handicap in Programs or Activities Conducted by the Federal Emergency
Management Agency implement Section 504 of the Rehabilitation Act of 1973, as amended,
and the disability-related nondiscrimination provisions set forth in Sections 308 and 309
of the Stafford Act. In addition, Department of Homeland Security (DHS) Directive
Number 065-01, Nondiscrimination for Individuals with Disabilities in DHS-Conducted
Programs and Activities (Non-employment), issued 9/25/2013, requires DHS components
to provide equal opportunity for qualified individuals with disabilities served or
encountered in DHS-conducted programs and activities, including providing any
necessary modifications to afford a qualified individual with a disability full enjoyment of
the program or activity unless modifications of policies, practices, and procedures would
fundamentally alter the nature of the program, service, or activity, or result in undue
financial or administrative burdens to DHS.
Applicants (both owners and renters) must be able to prove they occupied the disasterdamaged primary residence before receiving Housing Assistance (HA) and some types of
Other Needs Assistance (ONA), e.g. Personal Property Assistance, Moving and Storage
Assistance, and Critical Needs Assistance. The following types of ONA DO NOT require
verification of occupancy of the primary residence: Transportation Assistance, Funeral
Assistance, Medical Assistance, Dental Assistance, and Child Care Assistance. NOTE: The
Code of Federal Regulations (CFR) defines occupant as a resident of a housing unit.
Occupancy-dependent eligible expenses include costs associated with: Home Repair
Assistance, Home Replacement Assistance, or Permanent Housing Construction;
Temporary Housing Assistance, e.g. Rental Assistance, Lodging Expense Reimbursement,
or Direct Housing Assistance; Critical Needs Assistance; Personal Property Assistance
(Exception: A verification of occupancy is NOT a requirement for stored personal
property); Miscellaneous/Other Items; and Moving and Storage.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

A primary residence is the home where the applicant normally lives during the majority
of the calendar year (more than six months), or the home required because of proximity
to employment, including agriculture activities that provide 50% of the household’s
income. Primary occupancy for household members may also include individuals NOT
present at the time of the disaster, e.g. infants, spouse, or students, but who are expected
to return during the assistance period. If an applicant was NOT occupying the disasterdamaged residence at the time of the disaster, they may still be eligible if they can prove
their intent to occupy the home as their primary residence.

When FEMA is unable to verify an applicant’s occupancy of their disaster-damaged
primary residence, FEMA informs the applicant via letter that additional information is
required to verify occupancy. The applicant may provide FEMA with any of the
documents outlined below for occupancy verification. The documents may be provided
in person at a FEMA facility such as DRC and/or via mail, fax, or uploaded by the
applicant to their electronic FEMA registration. Previously, occupancy documents had to
be dated within three months prior to the disaster.

To provide additional flexibility to disaster survivors who may experience difficulty in
gathering specific documents, FEMA has expanded the types of documents we will accept
from applicants to verify IHP eligibility criteria and the extended acceptable date range
for documents to include pre and post disaster where appropriate. For the purpose of
the following list of documents, one year prior to the disaster means within one year
prior to the start of the incident period for the declared disaster. Documents provided to
FEMA with a date within the registration period must show pre-disaster usage, such as a
phone or utility bill, or clearly show that the applicant or co-applicant resided at the
damaged dwelling at the time of the disaster.

When FEMA is unable to verify an applicant’s ownership of their primary residence,
FEMA informs the applicant via letter that additional information is required to verify
ownership. The applicant may provide FEMA with any of the documents outlined below
to prove ownership. The documents may be provided in person at a FEMA facility such as
DRC and/or via mail, fax, or uploaded by the applicant to their electronic FEMA
registration. For documents provided to FEMA with a date in the registration period, the
document must demonstrate the applicant owned the damaged dwelling at the time of
the disaster. If the applicant is a minor child, documentation must be in the
parent/guardian co-applicant’s name.
The documentation or verification needed to verify occupancy include one of the
following: Utility Bills, Other Bills, Employer’s Documents, Lease/Housing Agreement,
Landlord (LL) Statement, Rent Receipts, Bank Statements with image of the cancelled
rent check, Public Official’s Documents, Social Service Organization Documents, Federal
or State Benefit Documents, Local School Documents, Motor Vehicle Registration,
Driver’s License, State-issued Identification (ID) card, Voter’s Registration Card, Mobile

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Home Park Documents, and Affidavits of Residency or other Court Documents. Please
reference the enclosed appendix for more information and examples of these types of
documents.

If the listed documentation is unavailable, FEMA may accept a written self-declaration of
occupancy as a last resort from applicants whose pre-disaster residence was a mobile
home or travel trailer. FEMA may also accept a written self-declaration from applicants
living in any type of housing located in insular areas, e.g. Guam, the Commonwealth of
the Northern Mariana Islands, American Samoa, the U.S. Virgin Islands, Puerto Rico, or
otherwise remote areas such as the interior of Alaska, tribal lands, and islands. Written
self-declarations must include the address of the disaster-damaged residence, the length
of time they lived in the disaster damaged residence prior to the Presidential disaster
declaration, an explanation of the circumstances that prevent standard occupancy
verification, an under penalty of perjury statement, and the applicant’s name and
signature.
Applicants must be able to prove they owned and occupied the damaged dwelling (DD),
pre-disaster, as their primary residence before receiving Home Repair Assistance; Home
Replacement Assistance; or Permanent Housing Construction under the Housing
Assistance (HA) provision of the IHP.

Documentation or Verification Needed for ownership verification (at least one): Deed or
Official Record, Mortgage Documents, Real Property (RP) Insurance document, bill, or
payment record, Property Tax Receipts or Bill, Manufactured Home Certificate of Title,
Real Estate Provision, Contract for Deed, Land Installment Contract, Quitclaim Deed, Bill
of Sale or Bond for Title, Death Certificate accompanied by a Will; Affidavit of Heirship
(only when consistent with state, territorial, or tribal government law); Receipts for
Major Repairs or Improvements, Letter or Written Statement from a Mobile Home Park
owner or manager, Court Documents, or a letter or other written statement from a Public
Official’s verifying the applicant owned the disaster-damaged residence at the time of the
disaster. Please reference the enclosed appendix for more information and examples of
these types of documents

Regardless of the ownership verification method (NEMIS public records verification,
visual verification during housing inspection process, or submitted documents), an
applicant who is responsible for maintenance and/or taxes will be considered an owner.
Ownership documents must reflect: the name of the applicant or co-applicant registering
for assistance. If a minor child is registering for assistance, the document must be in the
adult co-applicant’s name; the address of the damaged pre-disaster residence; and a date
prior to the disaster incident period.
Document exceptions: if the listed documentation is unavailable, FEMA may accept a
written self-declarative statement of ownership from applicants living in a mobile home

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

or travel trailer. FEMA will also accept a written self-declarative statement as a last
resort from applicants living in insular areas, e.g. Guam, the Commonwealth of the
Northern Mariana Islands, American Samoa, the U.S. Virgin Islands, Puerto Rico, or
otherwise remote areas such as the interior of Alaska; tribal lands, and islands.

Self-declarative statements must be provided to FEMA in writing to be maintained in the
applicant’s file, not solely viewed by an inspector. The statement must include:
• the address of the disaster-damaged residence;
• length of time the applicant lived in the disaster-damaged primary residence
prior to the Presidential disaster declaration;
• the major elements of the following statement and additional explanation, “I have
made a good faith effort, in coordination with FEMA, to obtain and provide a copy
of acceptable ownership documentation. I do meet FEMA’s definition of an owneroccupant because I am (A) the legal owner of the home, (B) pay no rent, but am
responsible for the payment of taxes or maintenance for the residence, or (C) hold
lifetime occupancy rights. I was unable to obtain this documentation because
[provide an explanation of the circumstances that prevent standard ownership
verification of the appropriate owner-occupant category]. I hereby declare under
penalty of perjury that the foregoing is true and correct.”; and
• the applicant’s name and signature.
FEMA may also accept a written self-declarative statement as a last resort from
applicants whose pre-disaster residence was passed down via heirship (Heirship is the
legal right to receive real and personal property under state law upon the death of an
ancestor or next of kin). Self-declarative statements must be provided to FEMA in
writing to be maintained in the applicant’s file, not solely viewed by an inspector. The
statement must include:
• the address of the disaster-damaged residence;
• length of time the applicant lived in the disaster-damaged primary residence
prior to the Presidential disaster declaration;
• the major elements of the following statement and additional explanation, “I have
made a good faith effort, in coordination with FEMA, to obtain and provide a copy
of acceptable ownership documentation. I was unable to obtain this
documentation because [provide an explanation of the circumstances that
prevent standard ownership verification].”;
• the major elements of the following statement, “As the nearest relative of the
deceased in the line of succession, my ownership includes all the rights and
obligations of the deceased. The decedent’s name is __________, who died on
____________. I hereby declare under penalty of perjury that the foregoing is true
and correct.”; and
• the applicant’s name and signature.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Applicants who pay rent to another party to live in the home DO NOT qualify as owners.
There may be an exception if the applicant is legally responsible for major repairs and/or
taxes on the damaged residence through lease-to-own or land installment agreements.
Additional exceptions are made in the circumstance of adverse possession, hereditary
family lands, and cultural traditions in islands or insular areas. For Intent to Own, there
may be instances when an applicant was in the process of purchasing the damaged
dwelling and was unable to complete the purchase before the disaster occurred. If the
applicant has provided documentation showing Intent to Own within the incident period,
a request for clarification of documents is submitted to IHP Program Specialists for
review.
b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
The Robert T. Stafford Disaster Relief and Emergency Act, Pub. L. 93-288 provides the
legal authority for FEMA’s collection of information for disaster assistance benefits. 44
CFR §206.110 implements the policy and procedures set forth in section 408 of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5174, as amended.
44 CFR Part 16, Enforcement of Nondiscrimination on the Basis of [Disability] in
Programs or Activities Conducted by the Federal Emergency Management Agency,
implements Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 794,
and the disability-related non-discrimination provisions set forth in §§ 308 and 309 of
the Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended, 42
U.S.C. §§ 5151 and 5152.
DHS Directive Number 065-01, Nondiscrimination for Individuals with Disabilities in
DHS-Conducted Programs and Activities (Non-employment) issued 9/25/2013 requires
DHS Components to provide equal opportunity for qualified individuals with
disabilities served or encountered in DHS-conducted programs and activities, including
providing any necessary modifications to afford a qualified individual with a disability
full enjoyment of the program or activity unless modifications of policies, practices,
and procedures would fundamentally alter the nature of the program, service, or
activity, or result in undue financial or administrative burdens to DHS. These laws,
regulations, and policies require FEMA to provide meaningful access to individuals
with disabilities.
The Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended, 42
U.S.C. §§ 5121-5207; 6 U.S.C. 776-77; The Homeland Security Act of 2002, 6 U.S.C. §§ 311321j; Reorganization Plan No. 3 of 1978; 4 U.S.C. §§ 2904 and 2906; 44 CFR §
206.2(a)(27); The Personal Responsibility and Work Opportunity Reconciliation Act of
1996 (Pub. L. 104-193); the Government Performance and Results Act, Pub. L. 103,62, as
amended; Executive Order 12862, Setting Customer Service Standards, dated September

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

11, 2003; Executive Order 13411, Improving Assistance for Disaster Victims, dated
August 29, 2006; and Executive Order 9397 as amended by Executive Order 13478,
Related to Federal Agency Use of Social Security Numbers, dated November 18, 2008.

FEMA requests Social Security Numbers (SSNs) pursuant to the Debt Collection
Improvement Act of 1996, 31 U.S.C. §§ 3325(d) and 7701(c)(1), as amended.
2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

c. Who will complete and
submit this form? (Check
all that apply.)

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

☒ The record subject of the form (e.g., the
individual applicant).
☒ Legal Representative (preparer, attorney,
etc.).
☐ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☐ No
☐ Law enforcement.
☒ DHS employee or contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.

1
Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

d. How do individuals
complete the form? Check
all that apply.

Click here to enter text.

☐ Paper.
☒ Electronic. (ex: fillable PDF)
☒ Online web form. (available and submitted via
the internet)
Provide link: www.disasterassistance.gov

e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
Currently Approved Information Collected:
• Applicant and household member names
• Applicant’s Citizenship Status
• Disability-related accommodations or assistance the applicant may need:
o Sign Language Interpreter
o CART (Communication Access Real-time Translation) (in person or remote)
o Text Message to Communicate
o Assistive Listening Device
o Braille
o Wheelchair Access
o Large Print
o Face-to-Face Assistance
o Language Other Than English
• Age of household occupants
• Household occupants’ relationship to the applicant
• Dependent status of household occupants
• Damaged dwelling address
• Current mailing address
• County in which the damaged occurred
• Applicant’s current phone number
• Applicant’s alternate phone number
• Applicant’s cell phone number
• Applicant’s email address
• Birth date of the applicant, co-applicant, and household occupants
• Social Security Number (of the applicant and co-applicant only)

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

•
•
•
•
•
•
•
•

Household income of applicant, co-applicant, and adult occupants
Home insurance information
Residence type
Bank name
Bank account type
Bank account number
Amount of damage (self-assessed) to the applicant’s home or personal property
Disaster-related expenses
o Medical
o Dental
o Funeral
• Medical, Dental, and Funeral/Burial insurance information
• Household vehicle information
o Year
o Make
o Model
o Damaged by the disaster (yes or no)
o Currently Drivable (yes or no)
o Insurance Information
o Current registration status (yes or no)
• Emergency Needs (food, medication, durable medical equipment, gas, shelter,
and/or clothing)
• Applicant or household member disability-related needs, for example:
o Mobility
o Cognitive/Developmental Disabilities/Mental Health
o Hearing or Speech
o Vision
o Self-Care
o Independent Living
No new data elements are collected by FEMA as a result of this process; however, new
categories of documents are collected to verify occupancy and ownership. For a full list
of the document categories and examples see appendix.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply.
☒ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☒ Bank Account, Credit Card, or other
financial account number
☒ Other. Please list: Disability-related
information

☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
The Robert T. Stafford Disaster Relief and Emergency Act, Public Law 93-288 provides the
legal authority for FEMA’s collection of information for disaster assistance benefits. 44
CFR § 206.110 implements the policy and procedures set forth in section 408 of the
Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5174, as
amended.
The Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended, 42 U.S.C.
§§ 5121-5207; The Homeland Security Act of 2002, 6 U.S.C. §§ 311-321j; Reorganization
Plan No. 3 of 1978; 4 U.S.C. §§ 2904 and 2906; 44 CFR § 206.2(a)(27); The Personal
Responsibility and Work Opportunity Reconciliation Act of 1996 (Pub. L. 104-193);
Executive Order 12862, Setting Customer Service Standards, dated September 11, 2003;
and Executive Order 13411, Improving Assistance for Disaster Victims, dated August 29,
2006.

FEMA requests SSNs pursuant to the Debt Collection Improvement Act of 1996, 31 U.S.C. §§
3325(d) and 7701(c)(1), as amended.
Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities
Through the Federal Government.
h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
Applicants will submit occupancy or ownership verification documents via online upload
or fax. FEMA uses these verification documents to determine eligibility for Housing
Assistance. This information is not shared outside of FEMA.
The SSN is collected to verify the applicant’s identity and prevent duplication of disaster

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

benefits among FEMA, federal, state, and local disaster agencies. In accordance with the
U.S. Treasury Department, the applicant’s social security number is required to issue
funds to individuals determined eligible for assistance.

Additional SPII is collected for FEMA to deposit financial assistance through electronic
funds transfers (EFT) to applicants’ bank accounts. Medical information is collected for
the purpose of reimbursing survivors for disaster-related injuries, and to replace durable
medical equipment lost or damaged due to the disaster.
i. Are individuals
☒ Yes. Please describe how notice is provided.
provided notice at the
time of collection by
Individuals will be provided separate notices
DHS (Does the records
consistent with the purpose of the information
subject have notice of
collection. Notice is provided when the applicant
the collection or is
registers for assistance, and a copy of the disaster
form filled out by
assistance registration is mailed to the applicant
third party)?
which includes the notice.
☐ No.
3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☒ Electronic. Please describe the IT system that will

b. If electronic, how
does DHS input the
responses into the IT
system?

Privacy Threshold Analysis – IC/Form

store the data from the form.
National Emergency Management Information
System – Individual Assistance (NEMIS-IA) will
store the data
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
NEMIS-IA

☒ Manually (data elements manually entered). Please
describe.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

d. What is the records
retention
schedule(s)? Include
the records schedule
number.

e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?

FEMA manually enters data into the NEMIS-IA
electronic version of FF 009-0-1 or 009-0-2 for
registrants applying for disaster assistance
telephonically or using paper versions of the
forms.
☒ Automatically. Please describe.
Information is collected and uploaded into the
NEMIS-IA Registration Intake Modules via
business rules.

☒ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
By the applicant’s name, address, social security
number, disaster registration ID, and email
address.
☐ By a non-personal identifier. Please describe.
Click here to enter text.
Records pertaining to disaster assistance will be
placed in inactive storage two years after FEMA
receives the application and will be destroyed when
they are six years and three months old, NARA
Authority N1-311-86-1, item 4C10a. These same
records when electronically entered into NEMIS will
be stored indefinitely.
The program adheres to the disposition schedule
which provides timeframes for records destruction
and/or disposal of relevant documents associated
with the program.

2

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☒ Yes, information is shared with other DHS components or offices. Please describe.

FEMA programs administering federal disaster relief assistance adhere to
comprehensive internal management procedures to prevent, detect, deter, report,
and investigate fraud, waste, and abuse. FEMA programs and employees
proactively review FEMA’s awards of disaster assistance payments. After the
disaster assistance registration process, it may be found an applicant potentially
committed fraud and/or identity theft. FEMA may share the applicant information
with the DHS Office of the Inspector General (OIG) to assist with investigation of
potential fraud and/or identity theft.

☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Upon receipt of the information collected during the disaster assistance registration
process, FEMA may share disaster applicant information with state governments to
assist with implementation of housing programs, to ensure applicants receive
additional disaster assistance as necessary, and to prevent a duplication of benefits.

FEMA programs administering federal disaster relief assistance adhere to
comprehensive internal management procedures to prevent, detect, deter, report,
and investigate fraud, waste, and abuse. FEMA programs and employees proactively
review FEMA’s awards of disaster assistance payments. After the disaster assistance
registration process, it may be found an applicant potentially committed fraud
and/or identity theft. FEMA may share the applicant information with the Federal
Bureau of Investigations (FBI), the Department of Justice (DOJ) and/or state law
enforcement to assist with investigation of potential fraud and/or identity theft.
If the applicant receives FEMA financial assistance and it is later determined the
assistance was awarded improperly or due to the applicant providing false
information, the applicant’s information may be provided to the Department of
Treasury (DOT) to recoup the previously awarded funds.

FEMA will share disaster applicant information, for applicants who exceed the Small

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Business Administration (SBA) provided income threshold, to the SBA Credit
Management Systems for low-interest loan consideration. Personal information such
as name, address, social security number, assets and salary are securely transmitted
from FEMA to SBA for processing. SBA will return a status code for each application
received from FEMA, reflecting their SBA disaster loan eligibility.

FEMA has contracted with risk management vendors to provide information received
from applicants during registration intake for identity verification purposes. The
vendor returns a pass/fail result to FEMA and assists in verifying applicant
occupancy of the residence damaged by the disaster as needed.
A Memorandum of Understanding (MOU) and Interconnects Security Agreement
(ISA) between FEMA and each participating agency defines the conditions for
security and data use, from data exchanges, to the extent they are not covered by
other formal arrangements or agreements between the Parties. This agreement also
covers any existing data exchanges covered in the DHS/FEMA – REG 2 DRA SORN.

FEMA has a Computer Matching Agreement (CMA) with the Department of Housing
and Urban Development (HUD). The purpose of the matching program is to:
• Establish or verify initial or continuing eligibility for DHS/FEMA disaster
assistance programs;
• Verify compliance with statutory or regulatory program requirements; and
• Recoup payments or delinquent debts under an identified program.
• Specifically, DHS/FEMA and HUD seek to ensure that individuals do not receive
duplicate or erroneous disaster assistance for the same disaster or emergency
and/or housing benefits from either agency.

Legal authorities
This agreement is executed in compliance with Privacy Act of 1974 (5 U.S.C.552a), as
amended.
The Robert T. Stafford Disaster Relief and Emergency Assistance Act P.L. 93-288, (42
U.S.C. 5121, 42 U.S.C. 5155, 42 U.S.C. 5174); 44 C.F.R. 206.2(a)(27), 206.110(e),
206.115(f), and 206.44.
The Debt Collection Improvement Act of 1996, 31 U.S.C. 3325(d) and 7701(c)(1), as
amended.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

HUD regulations 24 CFR 5.233, Community Development Block Grant (CBDG) program
as required by Title I of the Housing and Community Development Act of 1974, 12
U.S.C. 1706e, as amended by the Community Development Block Grant-Disaster
Recovery (CDBG-DR) Appropriations Acts (Pub. L. 113-2), and by the notices published
in Federal Register that govern these CDBG-DR Appropriations Acts.
☐ No. Information on this form is not shared outside of the collecting office.

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:
Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

Janica Woodley
August 11, 2021
August 11, 2021

☒ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
FEMA Privacy recommends compliance coverage as follows:
 SORN: DHS/FEMA-008 Disaster Recovery Assistance Files - Explicit coverage is
provided in the categories of records provided in the pending update. FEMA is
seeking interim coverage under the existing SORN pending the update. The existing
SORN provides implicit coverage in the “temporary housing assistance” and
“assistance from other sources” categories. The Registration Records category
provides patchwork coverage for the data collected via the various document types.


PIA: DHS/FEMA/PIA-049 Individual Assistance (IA) Program

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Joseph Thomas

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

Click here to enter text.
August 12, 2021
August 12, 2022

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

Choose an item.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☒ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☒ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Choose an item.
Statement:
E(3) statement has been reviewed and approved.
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

If covered by existing PIA, please list: DHS/FEMA/PIA-049 Individual
Assistance (IA) Program
If a PIA update is required, please list: Click here to enter text.
SORN:
SORN update is required.
If covered by existing SORN, please list: Click here to enter text.
If a SORN update is required, please list: DHS/FEMA-008 Disaster
Recovery Assistance Files, April 30, 2013, 78 FR 25282
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.

FEMA has submitted this PTA to expand on the types of additional documents that will be
requested and accepted from FEMA applicants when verifying ownership or occupancy
during the application process for FEMA Individuals and Households Program assistance.
When FEMA applicants are unable to provide previously requested occupancy or
ownership verification documents, FEMA will now accept a self-declarative statement of
occupancy or ownership.
Individuals and households applying for assistance must provide information detailing
their losses (disaster-related medical, dental, funeral, child care, personal property,
transportation, and other necessary expenses) and needs through this information
collection. Applicants (both owners and renters) must be able to prove they occupied the
disaster-damaged primary residence before receiving HA/ONA.

When FEMA is unable to verify an applicant’s occupancy of their disaster-damaged primary
residence, FEMA informs the applicant via letter that additional information is required to
verify occupancy. The applicant may provide FEMA with any of the documents included in
the included appendix for occupancy verification. If the listed documentation is
unavailable, FEMA may accept a written self-declaration of occupancy as a last resort from
applicants whose pre-disaster residence was a mobile home or travel trailer. FEMA may
also accept a written self-declaration from applicants living in any type of housing located
in insular areas, e.g. Guam, the Commonwealth of the Northern Mariana Islands, American
Samoa, the U.S. Virgin Islands, Puerto Rico, or otherwise remote areas such as the interior
of Alaska, tribal lands, and islands.

DHS PRIV concurs with FEMA that this collection remains privacy-sensitive, and requires
both PIA and SORN coverage. PIA coverage is provided by DHS/FEMA/PIA-049 Individual
Assistance (IA) Program, which addresses the collection and processing of disaster
survivor information related to IA.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Interim SORN coverage is provided by DHS/FEMA-008 Disaster Recovery Assistance Files,
which is currently undergoing an update approval process to clarify that FEMA will be
collecting additional/supplemental information explicitly supporting this revised
collection.
PRIV has reviewed the Privacy Act Statement available at www.disasterassistance.gov
and finds it appropriate for the collection.

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