Comment Submitted by Jesse Tennyson

The proposed rule is indefensible on legal grounds. It conflicts with the governing statute, which expressly authorizes prorated assistance for mixed-status families—and HUD’s inadequate justification for its proposed policy change also conflicts with its obligations under the Administrative Procedure Act. • The proposed rule will unfairly punish tens of thousands of women, children, and families, including many U.S citizens. More than half (56%) of people in mixed-status families whose housing is threatened by the proposed rule are women and girls. The vast majority of the children in mixed-status families who face potential eviction are U.S. citizens. And the proposed rule does not merely target people in mixed-status households; it threatens housing stability for many more people who rely on HUD assistance by imposing burdensome new documentation requirements. Erecting these additional barriers to housing assistance will particularly harm vulnerable groups, including survivors of gender-based violence, LGBTQIA+ people, and seniors. • The proposed rule reduces resources for HUD to advance its mission—harming not only immigrant families, but all families who rely on HUD programs, as well as our broader economy. The proposed rule rests on a false premise that immigrant families are driving the affordable housing crisis, when in fact implementing the rule would worsen that crisis for everyone. HUD’s own regulatory impact analysis acknowledges that the substantial costs associated with implementation would likely result in fewer families receiving assistance and a deterioration in the quality of housing support. By barring mixed-status families from HUD-assisted housing, the rule would increase costs, reduce available resources, and place more families at risk of eviction and homelessness. HUD to immediately withdraw its current proposal and instead dedicate its efforts to advancing policies that strengthen—rather than undermine—the ability of all immigrants and U.S. citizens in immigrant families to support themselves and their families in the future. If we want our communities to thrive, everyone in those communities must be able to stay together and get the care, services, and support they need to live healthy and productive lives.