On July 9, 2019, Funders Together to End Homelessness submitted a public comment to the U.S. Department of Housing and Urban Development (HUD) to show our opposition to its recent proposed rule that would prohibit “mixed-status” immigrant families from public or subsidized housing.

These families consist of U.S. citizens or legal permanent residents who may have a member that is ineligible for housing assistance due to their immigration status. While these families are currently pro-rated to only provide assistance for those members who are eligible, these proposed changes would instead require the family to remove the ineligible member (which is most likely a parent or income provider) or be evicted from their home.

We are in strong opposition of this proposed rule as it would force families and children who are U.S. citizens or legal permanent residents from homes and put them at risk of experiencing homelessness, thus adding to the current crisis. If finalized, this rule would evict 25,000 families, including more than 55,000 children. In addition, the proposal contradicts our value in addressing racial disparities in as 95% of those who would be affected are people of color.

HUD’s own analysis found that this rule change would worsen the subsidizing housing waitlist and actually decrease the number of families assisted as well as cost the department up to nearly $440 million annually. It is important for HUD to understand that despite past comments and assumptions from the Administration, philanthropy cannot “fill the funding gap” for ongoing and additional housing needs because of this rule. If philanthropy is expected to invest additional funds to address housing needs created by the rule, it could take away critical resources from other investments in housing, homelessness, and preventative programs and solutions.

In our comments, we urged our partners at HUD to rescind the proposed rule which directly conflicts with the department’s mission and work with philanthropy through public-private partnerships to protect immigrant families in our communities from homelessness.

As of July 9, when the public comment period ended, a total of nearly 29,000 comments had been submitted, including those from Funders Together members such as The Campion Advocacy Fund, The Melville Charitable Trust, Meyer Memorial Trust, and The Simmons Foundation. These 29,000 comments surpassed the 25,000 goal -- one comment for each family that would be at risk of losing housing because of this rule.

We are proud to stand united with our members, national partners, and other philanthropy-serving organizations and support the work to ensure that all individuals in our communities have access to a safe and affordable place to call home.

Read our full comments here.

Funders: If you submitted public comments, please let us know so we can add your name to the list!