Comment Submitted by National Association of Housing and Redevelopment Officials (NAHRO)

Summary: The National Association of Housing and Redevelopment Officials (NAHRO) and four other housing industry groups (PHADA, NLHA, CLPHA, and HDLI) oppose the proposed System of Records notice (SORN) regarding the EIV-SAVE tenant matching report. They argue that HUD violated the Privacy Act by implementing the report before the required 30-day public comment period and contend that HUD lacks the statutory authority to conduct SAVE searches on U.S. citizens, nationals, or individuals aged 62 and older.