Supporting Statement A

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Supporting Statement for Paperwork Reduction Act Submissions
Restrictions on Assistance to Noncitizens and Authorization to Release Information/Privacy Act (OMB# 2577-0295)

A. 	Justification

1.	Explain the circumstances that make the collection of information necessary.  Identify any legal or administrative requirements that necessitate the collection.  Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

To ensure that Federal financial assistance is directed to those individuals who are legally eligible to receive such assistance, 24 CFR part 5, Subpart E-Restrictions on Assistance to Noncitizens, requires written declaration of U.S. citizenship or U.S. nationality. Note, there is no OMB form for the Restrictions on Assistance to Noncitizens component of this PRA; this PRA covers the burden associated with the verification process. For U.S. citizens or U.S. nationals, each family member, regardless of age, must submit a signed declaration of U.S. citizenship or U.S. nationality. For noncitizens who are 62 years of age or older and receiving assistance or applying for assistance, they must provide a signed declaration of eligible immigration status and proof of age document. For all other noncitizens, they are required to submit: (1) a signed declaration of eligible immigration status; (2) the original of a document designated by U.S. Citizenship and Immigration Services (USCIS) as acceptable evidence of immigration status; and (3) a signed verification consent form. 

2.	Indicate how, by whom and for what purpose the information is to be used.  Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

This is a revision of a currently approved collection. The purpose of this information collection is to renew the information collection approved in 2023 for restrictions on assistance to noncitizens and authorization to release information/Privacy Act.  Section 904 of the Stewart B. McKinney Homeless Assistance Amendments Act of 1988, as amended by Section 903 of the Housing and Community Development Act of 1992, and Section 3003 of the Omnibus Budget Reconciliation Act of 1993 (42 U.S.C. 3544) requires applicants (initial application) and participants (reexaminations) sign a consent form authorizing: (1) HUD and the public housing agency (PHA) to request verification of salary and wages from current or previous employers; (2) HUD and the PHA to request wage and unemployment compensation claim information from the State agency responsible for keeping that information; and (3) HUD to request certain tax return information from the U.S. Social Security Administration and the U.S. Internal Revenue Service. 

Section 104 of the Housing Opportunity and Modernization Act (HOTMA) of 2016 (42 U.S.C. 1437) (implemented via 88 FR 9600 (February 14, 2023)) requires that applicants and participants sign a consent form authorizing the PHA to request verification of any financial record from any financial institutions as defined in the Right to Financial Privacy Act (12 U.S.C. 3401) whenever the PHA determines the record is needed to determine an applicant’s or participant’s eligibility for assistance or level of benefits. To determine eligibility and to assist HUD in managing and monitoring HUD-assisted housing programs, applicants and tenants applying for or receiving assistance in the Housing Choice Voucher, Public Housing, and Section 8 Moderate Rehabilitation programs are required to sign the Authorization for the Release of Information/Privacy Act Notice (Form HUD-9886-A). In verifying information provided by the applicant/tenant, PHAs must obtain consent from the applicant/tenant using Form HUD-9886-A to verify eligibility and income information provided through computer matching or by obtaining information directly from the third-party source. 

The submission of Form HUD-9886-A is necessary for PHAs to carry out the requirements of Section 904 of the Stewart B. McKinney Homeless Assistance Amendments Act of 1988, as amended by Section 903 of the Housing and Community Development Act of 1992; Section 3003 of the Omnibus Budget Reconciliation Act of 1993 (42 U.S.C. 3544); and Section 104 of HOTMA to ensure that HUD and PHAs can verify eligibility and income information for applicants and participants. PHAs have families sign this form as part of their reexaminations and generally send appropriate forms and documentation requests to families 3 to 4 months ahead of the reexamination date. Beginning January 1, 2024, PHAs utilized Form HUD-9886-A for families whose reexaminations are effective January 1, 2024 or later. After an applicant or participant has signed and submitted a consent form either on or after January 1, 2024, they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination except: (1) when any person 18 years or older becomes a member of the family, (2) when a member of the family turns 18 years of age, and (3) as required by HUD or the PHA in administrative instructions.

3.	Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection.  Also describe any consideration of using information technology to reduce burden.
	
	HUD is not involved in the standard process for the information collected for Restriction on Assistance to Noncitizens and Authorization of Release of Information/Privacy Act. This information is collected at the PHA level. Procedures for collecting information on this form varies by PHA and in some cases PHAs may print out the form for participants to physically sign and in other cases the PHA may accept electronic signatures and submission.  PHAs may also store documents electronically, however, most PHAs still maintain paper files for tenants so most documents are likely printed.

	The regulations at 24 CFR 5.508 require evidence of citizenship or eligible immigration status to be presented to the PHA for eligibility for assistance or continued assistance under Section 214 covered programs, which includes the Housing Choice Voucher, Public Housing and Section 8 Moderate Rehabilitation programs. PHAs are required to verify citizenship or eligible immigration status of individuals and family members, regardless of age, applying for or currently receiving assisted housing in accordance with Section 214 of 24 CFR 5.512. Under Section 214, PHAs are required to use the USCIS Systematic Alien Verification for Entitlements (SAVE) Program as the primary source for the verification of: (1) immigration status, (2) nonimmigrant status, and (3) naturalized and derived U.S. citizenship of individuals applying for assistance under various housing programs. The data is stored in USCIS’ secured online Verification Information System (VIS) database and checks the immigration status of applicants/tenants against Department of Homeland Security (DHS) database records. The verification of current immigration status can be done by paper or electronically through the SAVE VIS database. The DHS SAVE VIS can be accessed through a web-based application here. This technology allows PHAs to confirm the immigration status of an individual without the necessity for substantial paperwork. The submission of the written declaration of citizenship, written declaration of eligible immigration status, and alien registration documents is necessary so that PHAs can carry out the requirements of Section 214 to ensure that only citizens and legal residents are the recipients of public benefits. The documents, once submitted to the PHA, will be verified and retained on file as evidence that the restrictions on financial assistance are met.

4.	Describe efforts to identify duplication.  Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
There is no duplication. 

Under Section 104 of HOTMA, after an applicant or participant has signed and submitted a consent form once after the implementation of the new HOTMA income rules, they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination except under the following circumstances: (1) when any person 18 years or older becomes a member of the family; (2) when a member of the family turns 18 years of age; and (3) as required by HUD or the PHA in administrative instructions. Prior to HOTMA, participants were required to sign a previous version, Form HUD-9886, at every annual recertification. 

No similar information concerning citizenship or eligible immigration status is required under other programs that are already available to HUD or PHAs. Although evidence of citizenship or age is required only once to avoid duplication, evidence of an individual’s eligible immigration status is to be submitted every year during the annual recertification of tenants. This is required to ensure continued eligibility status for financial assistance.

The statutes dictate information collection for the purpose of determining whether applicants applying for or tenants receiving housing subsidy under HUD assistance programs are eligible for such assistance. The collection conducted is the minimum necessary for statutory compliance.  

5.	If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.
	
	Small businesses are not impacted by this collection. Some small PHAs may be affected by the information collection requirements if the PHA has limited staffing and are technologically inexperienced. The information collection requirements are required by the statute. HUD has not imposed additional information collection requirements beyond those defined by the statute. Given the statutory requirements, there are no alternatives for submission of the required information. Electronic verification through the SAVE VIS and HUD’s computer matching system the Enterprise Income Verification (EIV) system minimizes burden. 

6.	Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If the collection is not conducted or collected less frequently, it may increase the risk that the incorrect levels of Federal benefits are paid on behalf of families receiving housing assistance under a covered HUD housing program. The Housing and Community Development Act of 1987 authorized HUD to require disclosure of Social Security numbers as a condition of initial or continuing eligibility, to ensure that the level of benefits provided under the programs is proper. It may also increase the risk of Federal financial assistance directed to those ineligible to receive such assistance. Section 214 of the Housing and Community Development Act of 1980, as amended, prohibits HUD from making financial assistance to persons who are ineligible for assistance with respect to citizenship or non-citizen immigration status, so HUD must collect information on citizenship and eligible immigration status at this frequency. There would be an increased burden on PHAs and applicant and participant families to supply the necessary documentation to determine eligibility and level of Federal benefits.

    7.  Explain any special circumstances that would cause an information collection to be conducted in a manner:

    • requiring respondents to report information to the agency more than quarterly; Not applicable.

    • requiring respondents to prepare a written response to a collection of information in fewer
    than 30 days after receipt of it; Not applicable.

    • requiring respondents to submit more than an original and two copies of any document; 
    Not applicable.

    • requiring respondents to retain records other than health, medical, government contract, 
    grant-in-aid, or tax records for more than three years; Not applicable.

    • in connection with a statistical survey, that is not designed to produce valid and reliable 
    results than can be generalized to the universe of study; Not applicable.

    • requiring the use of a statistical data classification that has not been reviewed and approved 
    by OMB; Not applicable.

    • that includes a pledge of confidentiality that is not supported by authority established in 
    statute or regulation, that is not supported by disclosure and data security policies that are 
    consistent with the pledge, or which unnecessarily impedes sharing of data with other 
    agencies for compatible confidential use; Not applicable. or 

    • requiring respondents to submit proprietary trade secret, or other confidential information 
    unless the agency can demonstrate that it has instituted procedures to protect the 
          information's confidentiality to the extent permitted by law. Not applicable.

    8.  If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.  Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.  Specifically address comments received on cost and hour burden.

    • Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.

    • Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods.  There may be circumstances that preclude consultation in a specific situation.  These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), the agency’s notice announcing this collection of information appeared in the Federal Register on June 22, 2026, Volume 91; No 118 Page 37121. The public was given until August 21, 2026, to submit comments on the proposed information collection. HUD received four comments on this proposed collection. 

60-Day Public Comment and Response

Relation Between Form HUD-9886-A and Restriction on Assistance to Noncitizens

Summary: A commenter expressed concern that the revised form would expand the scope of what the Social Security Administration (SSA) is authorized to do with respect to information received. On similar lines, the commenter asked whether additional SSA verification information would be used for immigration-status verification under Section 214 of the Housing and Community Development Act of 1980. Another commenter claims there is ambiguity about whether HUD is revising the Form HUD-9886-A to include the collection of information related to the restriction of assistance to noncitizens.

HUD Response: The form does not authorize SSA to disclose additional information that was not previously covered by the form. Rather, it makes explicit what HUD-SSA data matching practices provide. The form enumerates what SSA is authorized to do with the information disclosed through the HUD-SSA data match, which does not include immigration-status verification. Commenters may be confused by the fact that the 60-Day Notice covers the burden of both the Form HUD-9886-A and burdens associated with the verification required by Section 214 of the Housing and Community Development Act of 1980. There is no OMB form associated with the requirements of Section 214.

Summary: A commenter argues that by requiring all adult family members to provide Social Security numbers, dates of birth, and consent to the release of SSA and income information regardless of immigration status, the revised Form HUD-9886-A violates the Privacy Act and is inconsistent with current regulation. The commenter argues that the Notice does not explain the expanded scope of information to be provided or the information’s intended use and purpose. Further, the commenter argued that the Notice implied that the information collected on the revised Form HUD-9886-A would be used to verify family members’ immigration eligibility status.

HUD Response: HUD appreciates the opportunity to reiterate that the Form HUD-9886-A will not be used for purposes not described in the Notice. As noted in response to other comments, the information collection covers the burden of both the Form HUD-9886-A and those associated with the verification required by Section 214 of the Housing and Community Development Act of 1980. There is no OMB form associated with the requirements of Section 214.

Summary: A commenter argued that the authorization of the Social Security Administration to verify whether the name, date of birth, and Social Security number provided match SSA records is a fundamental alteration of the nature of the information collection.
HUD Response: HUD disagrees with this characterization. HUD’s data match with SSA has long validated the SSNs provided, and the results of such information have been provided in the Enterprise Income Verification Identity Verification Report. This information collection is consistent with that longstanding practice. 

Comments on Inclusion of Social Security Number Field for All Signatories

Summary: A commenter claims that requiring all family members to disclose Social Security numbers and consent to verification, the revised HUD-9886-A circumvents statutory exemptions for family members who neither request nor receive HUD assistance, as well as current regulations that exempt family members aged 62 and older from providing Social Security numbers. 

HUD Response: The Form HUD-9886-A does not contradict the requirements of 24 CFR part 5, subpart B regarding the requirements to disclose and verify Social Security numbers.

Summary: A commenter argued that by including a line for Social Security numbers for all adult family members without the qualifier “if any”, PHA staff and households will misunderstand this line as a mandate. They recommended that HUD restore that qualifier and clarify which household members must provide Social Security numbers.

HUD Response: HUD believes that the relevant requirements are clear and declines to adopt the suggested change.

Other Comments

Summary: Several commenters asked whether this action should be characterized as an extension of a currently approved collection or a revision of a currently approved collection, given revisions made to the Form HUD-9886-A and the inclusion of the burden associated with verification under Section 214. One commenter alleged that this was a revision because the revised Form HUD-9886-A would be used to verify citizenship information.

HUD Response: Thank you for this comment. Since there are minor formatting changes being made to the Form HUD-9886-A, HUD is revising the type of request to revision of a currently approved collection. The claim that the revised form would be used to verify citizenship information is incorrect, however. The changes to the Form HUD-9886-A are in the interest of clarifying the existing process and procedures.

Summary: A commenter argues that the 60-Day Notice fails to provide sufficient specificity because it is unclear whether it represents a single information collection or encompasses two separate collections of information (i.e., “Restriction on Assistance to Noncitizens” and “Authorization to Release Information/Privacy Act”).

HUD Response: HUD disagrees that the 60-Day Notice did not provide sufficient specificity on this point. The 60-Day Notice, as noted in responses to other comments, was explicit that this PRA covers the burden associated with the verification required by Section 214 of the Housing and Community Development Act of 1980, although there is no OMB form associated with the requirements of Section 214. From this, it was clear that the Form HUD-9886-A was not being substantially revised to cover the requirements of Section 214. Rather, PHAs continue to be required to collect information related to the restriction on assistance to noncitizens as required by statute and regulation.

Summary: A commenter asked HUD to clarify that families who have already signed the Form HUD-9886-A would not be required to re-sign this revised version.

HUD Response: HUD has not claimed that all families would be required to re-sign the Form HUD-9886-A as a result of this extension. A previously executed Form HUD-9886-A would remain valid. 24 CFR 5.230 provides that a signed authorization remains effective until the earliest of the rendering of a final adverse decision for an assistance applicant; the cessation of a participant's eligibility for assistance from HUD and the PHA; or the express revocation by the assistance applicant or recipient (or applicable family member) of the authorization, in a written notification to HUD.

Summary: A commenter alleges that the revised form would impose new administrative responsibilities and burdens on PHAs, because the revised form clarifies that the individual is authorizing release of information from SSA to HUD as well as the PHA. The commenter argues that this is a substantive change that PHAs lack guidance on how to use such data.

HUD Response: The explanatory language in the revised Form HUD-9886-A clarifies longstanding existing practice. PHAs do not directly receive information from SSA. Rather, PHAs learn of the results of the HUD-SSA data matching through HUD’s Enterprise Income Verification system. This reflects no change in practice.

Summary: A commenter claims that the scope of the information collection is unclear and that PHAs could not inform families of who may receive the information or from whom income information may be sought.

HUD Response: HUD disagrees that the form is unclear on this point. The “Uses of Information to be Obtained,” “Sources of Information to be Obtained,” and “Privacy Advisory” sections enumerate these uses, and PHA staff can seek additional information from the privacy-related URL provided on the form.
 
Summary: A commenter asked HUD to revise the Form HUD-9886-A to only request signatures from members of the assisted family, not from other household members.

HUD Response: There is no change to the Form HUD-9886-A from previous versions in the instructions on who must sign the consent form.

Summary: A commenter requested the translated versions of the Form HUD-9886-A be released simultaneously with publication of the English Form HUD-9886-A.

HUD Response: Previously, Form HUD-9886-A was published in multiple languages, but those translations are no longer used in alignment with Executive Order 14224.

Summary: A commenter recommended that HUD revise Form HUD-9886-A to clarify that, while certain foster care payments may be excluded from income calculations, foster children and foster adults must still be included in the household when determining the applicable area median income (AMI) limits. The commenter asserts that some housing providers incorrectly exclude foster children and foster adults from the household count, which may result in the use of an incorrect AMI limit when determining eligibility. 

HUD Response: This issue raised by the commenter concerns program administration and is outside the scope of this information collection renewal, which addresses the restrictions on assistance to noncitizens and the continued use of Form HUD-9886-A. Form HUD-9886-A is an authorization for the release of information and privacy notice and is not the appropriate vehicle for establishing or clarifying program eligibility requirements. Accordingly, HUD is not revising Form HUD-9886-A in response to this comment.

The information is collected from the sponsor during the initial application (new approval), revision of an established product approval (new technical data that was not previously reviewed by HUD), or renewal (basic editorial changes, such changing the contact personnel).

Each product approval is valid for a 3-year period. Ninety days prior to the expiration of the product approval, the Department contacts each sponsor via phone, email, and letter as to whether the product approval will be renewed (revision or renewal) or cancelled.

30-Day Public Comment and Response

Summary: Commenters asked for a copy of the proposed revised Form HUD-9886-A.

HUD Response: A copy of the form was provided to the commenter.

Summary: One requester asked for additional information outside the scope of this PRA.

HUD Response: HUD clarified the scope of the PRA for the requester.




9.	Explain any decision to provide any payment or gift to respondents, other than renumeration of contractors or grantees.
	
	There are no payments or gifts to respondents.

10.	Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

HUD shall comply with the Privacy Act of 1974 (5 U.S.C., § 552a) requirements in the conduct of the verification procedures, as well as in the safeguarding, maintenance, and disposition of any information used for determining the citizenship or eligible immigration status of individuals and family members applying for or currently receiving housing assistance and not for any other purpose. Section 404 of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 requires HUD (with respect to public and assisted housing programs provided under the U.S. Housing Act of 1937, as amended, 42 U.S.C. 1437, et seq.) and any PHA that enters into a contract for assistance under section 6 or 8 of Title I of the U. S. Housing Act of 1937, as amended, 42 U.S.C. 1437, et seq., to report to the USCIS, at least four times per year those individuals who HUD has verified are in the U.S. unlawfully. Additionally, the secured SAVE VIS database and the EIV system carries its own protective measures by assigning identification and passwords to authorized users.

11.	Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.  This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
	
	The only information required of a sensitive nature are signatures and the Social Security numbers of the heads of household.

12.	Provide estimates of the hour burden of the collection of information.  The statement should:

    • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.  Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates.  Consultation with a sample (fewer than 10) of potential respondents is desirable.  If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance.  Generally, estimates should not include burden hours for customary and usual business practices; 
    • If this request covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in chart below; and
    • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.  The cost of contracting out or paying outside parties for information collection activities should not be included here.  Instead, this cost should be included in Item 13.

Information Collection
Number of Respondents
Frequency of Response
Responses Per Annum
Burden Hour Per Response
Annual Burden Hours
Hourly Cost Per Response
Annual Cost
Restriction on Assistance to Noncitizens1
New tenant admissions in Public Housing and Section 8 programs
3,645
23
83,835
0.16
13,414.00
$30.49
$408,980.66
Annual recertification of tenants’ eligible immigration status in Public Housing and Section 8 programs
3,645
11
40,095
0.08
3,208.00
$30.49
$97,799.72
Subtotal
3,6452
34
123,930
0.24
16,621.00
$30.49
$506,780.39
Authorization of Release of Information/Privacy Act3
New tenant admissions of adult members in Public Housing and Housing Choice Voucher programs
144,920
1
144,920
0.16
23,187.00
$30.49
$706,977.73
Execution of Form HUD-9886-A by household members that turn 18 years old
36,488
1
36,488
0.08
2,919.00
$30.49
$89,001.53
Subtotal
181,408
2
181,408
0.24
26,106.00
$30.49
$795,979.26
Total
185,053
36
305,338
0.48
42,727.00
$30.49
$1,302,759.65
Data is from HUD’s Inventory Management System/Public & Indian Housing (PIH) Information Center (IMS/PIC).

1 Restriction on Assistance to Noncitizens data is an average of FYs 2022, 2023 and 2024. New tenants that are citizens or have permanent eligible immigration status must submit verification only once.
2 The respondents are PHAs. Since the respondents for both information collections related to Restriction on Assistance to Noncitizens are not unique, the subtotal remains 3,645.
3 Authorization of Release of Information/Privacy Act data is from CY 2024. Prior to January 1, 2024, participants signed and submitted consent forms at each regularly scheduled income reexamination. On or after January 1, 2024, a participant must sign and submit consent forms at their next interim or regularly scheduled income reexamination. After all applicants or participants over the age of 18 in a family have signed and submitted a consent form once on or after January 1, 2024, family members do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination except: (i) when any person 18 years or older becomes a member of the family, that family member must sign and submit a consent form; (ii) when a member of the family turns 18 years of age, that family member must sign and submit a consent form; and (iii) as required by HUD or the PHA in administrative instructions.

The total annual burden of this collection is expected to be 42,727.44 hours. The total estimated annual cost for this information collection is $1,302,759.65. To estimate the hourly cost per respondent, HUD used the Department of Labor Bureau of Labor Statistics’ most recent (May 2025) data on Occupational Employment and Wage Statistics for Community and Social Service Occupations. The estimated hourly wage is $30.49. 

13.	Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet shown in Items 12 and 14).
 	
	There are no additional costs to respondents other than the costs shown in Question 12.

14.	Provide estimates of annualized cost to the Federal government.  Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.  Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
	
	HUD is not involved in the standard process for the information collected for Restriction on Assistance to Noncitizens and Authorization of Release of Information/Privacy Act. This information is collected at the PHA level. HUD only reviews this information as part of compliance reviews and monitoring. HUD estimates that PIH’s Office of Field Operations conducts approximately 10,000 file reviews annually. These reviews may be done for a variety of reasons, including comprehensive file reviews. While reviews may vary in length, the information collected in this PRA takes approximately 0.5 hours to review each file. This includes hours associated with staff preparation, notification, and verification. The total annual burden of this collection is expected to be 5,000 hours. The total estimated annual cost for this information collection is $217,850.00. To estimate the hourly cost per respondent, HUD assumes more than one HUD federal employee with an hourly rate of $43.57 at the 2026 General Schedule base pay of GS-13/Step 1 level with no locality pay as published by the U.S. Office of Personnel Management.

Information Collection
Number of Respondents
Frequency of Response
Responses Per Annum
Burden Hour Per Response
Annual Burden Hours
Hourly Cost Per Response
Annual Cost
Compliance Monitoring
10,000
1
10,000
0.5
5,000
$43.57 
$217,850.00 
Total
10,000
1
10,000
0.5
5,000
$43.57 
$217,850.00 
 
15.	Explain the reasons for any program changes or adjustments reported in Items 12 and 14 of the Supporting Statement.

This is a revision of a currently approved collection that reflects changes made by HOTMA. Form HUD-9886-A is to be used on/after the HOTMA effective date of January 1, 2024. After an applicant or participant has signed and submitted a Form HUD-9886-A once after January 1, 2024, they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income examination except under limited circumstances. Furthermore, the adjustments in the number of respondents for question 12 reflect the updated number of PHAs and the number of new admissions and individuals that turn 18 years old, which may vary from year to year. Note: Previously Form HUD-9886-A was published in multiple languages; however, those translations are no longer used in alignment with Executive Order 14224. 

HUD is making minor formatting and clarificatory changes to the Form HUD-9886-A that do not change its purpose. Under “Sources Information to be Obtained,” HUD is adding detail to explain what information continues to be collected from the Social Security Administration (SSA). Two paragraphs have been added to the consent statement signatures are asked to read, largely repeating information from the “Use of Information to be Obtained” and “Sources of Information to be Obtained” sections, to further ensure signatories are aware of what information is collected and how it is used. Fields for date of birth and Social Security number are added to the form; these pieces of information have been and continue to be necessary for SSA to match data against its database.  

16.	For collection of information whose results will be published, outline plans for tabulation and publication.  Address any complex analytical techniques that will be used.  Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
	
	The information collection will not be published

17.	If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

HUD will display the expiration date on the collection.

18.	Explain each exception to the certification statement identified in item 19.

There is no exception to the certification.