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File #: 25-3476    Version: 1 Name:
Type: Discussion Item Status: Passed
File created: 8/28/2025 In control: HOUSING AUTHORITY
On agenda: 9/9/2025 Final action: 9/9/2025
Title: CONSIDER accepting a report concerning existing and upcoming HUD-required citizenship status reporting requirements.
To: Contra Costa County Housing Authority Board of Commissioners
From: Joseph Villarreal, Executive Director
Report Title: HUD Required Citizenship Status Reporting
?Recommendation of the County Administrator ? Recommendation of Board Committee


RECOMMENDATIONS:
CONSIDER accept a report concerning existing and upcoming HUD-required citizenship status reporting requirements.

BACKGROUND:
On August 27, 2025, the Washington Examiner published an article titled "HUD threatens funding for public housing authorities shielding illegal immigrants." The article previewed a letter that anonymous HUD sources said would be first sent to the Washington DC Housing Authority and then later to every housing authority in the country. According to the HUD sources cited in the article, each housing authority will be given 30 days to do the following:

1. Identify all "mixed family" units, all units "by one or more individuals who do not contend that they have immigration status", and any beneficiaries granted assistance without verifying immigration status
2. Provide the full names and mailing addresses of all tenants identified and Request 1, along with any Social Security numbers, alien administration numbers, alien file numbers, and proof of citizenship or legal immigration status
3. Provide any "spreadsheet, analysis, or other prepared or gathered data concerning the number and/or location of tenants with ineligible immigration status in all Public Housing covered programs"
4. Provide any documentation of a specific PHA's compliance with federal code regarding immigrant program eligibility
5. Provide names and full mailing address of any tenant found to have "misrepresented either his or her citizenship, national, or eligible immigration status"
6. Provide a "full tenant file" associated with any positive hits on requests 1 or 5

Under what is known as the mixed status rule, housing authorities have been more restrictive than most federal and state agencies in allowing non-cit...

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