This short, 12-question survey of CLPHA membership on the Reducing Barriers to HUD-Assisted Housing proposed rule will help inform CLPHA's comments. Your responses and any anecdotes you provide will be anonymized.

Please also register for CLPHA's Member Feedback Gathering Session, on May 20th at 3:00 PM Eastern.

Question Title

* 1. The proposed rule defines “Currently engaging in or engaged in” as any criminal activity that occurred within the last 12 months for purposes of determining whether criminal activity is a basis for termination or eviction.

Is this an appropriate timeframe?

Question Title

* 2. The proposed rule provides that it is presumptively unreasonable for PHAs and owners to consider convictions that occurred more than 3 years ago in making admissions decisions.

Is this an appropriate timeframe? Are there specific crimes for which a longer or shorter lookback period should be considered?

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* 3. Under the proposed rule, PHAs and owners must provide applicants at least 15 days prior to notification of a denial of admission, and an opportunity to dispute the accuracy of the records relied upon.

Is 15 days prior to notification of a denial of admission an appropriate timeframe?

Question Title

* 4. Under the proposed rule, PHAs and owners will consider the following set of mitigating factors when making decisions to deny or terminate assistance or to evict based on a criminal record:
  • the facts or circumstances surrounding the criminal conduct,
  • the age of the individual at the time of the conduct,
  • evidence that the individual has maintained a good tenant history before and/or after the criminal conviction or the criminal conduct,
  • and evidence of rehabilitation efforts.
Are there other mitigating factors that should be considered? Should HUD define these mitigating factors in greater detail in regulation or guidance?

Question Title

* 5. Under the proposed rule, criminal activity in the past can be the basis for denying admission only if it would threaten the health, safety, or right to peaceful enjoyment of the premises by other residents or PHA/property employees.

Should HUD provide additional specificity in the rule or in subsequent guidance on this requirement, and if so, on what aspects?

Question Title

* 6. Owners of federally assisted housing (except owners of properties receiving tenant-based assistance, project-based voucher and moderate rehabilitation owners) would need to amend their tenant selection plans within 6 months.

Is this a reasonable timeframe? (if this wouldn't apply to you, please type N/A)

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 33% of survey complete.

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