HUD PIH Notice § 2010-50

____________________________________________________________________________
                                     __

Special Attention of:                              Notice PIH 2010-50 (HA)

Public Housing and Section 8 Program Administrators,
Public      Housing Hub Office Directors; Public Housing Issued:    January
1, 2011
Field Office Directors; Program Center Coordinators;
Resident Management Corporations; Resident Councils;     Expires:  January
31, 2012
Participants of Public Housing, Housing Choice Voucher
Voucher, Project-Based Certificate, and Project-Based
Voucher Programs; Section 8 Property Owners and
Landlords

                                              REVISED NOTICE
                                             Cross References: 24 CFR
           5.233,
                                             HUD OIG Audit Report Number
                                             2010-FW-0001,
                                             Notice PIH-2010-09
                                             Notice PIH-2010-15
                                             Notice PIH 2010-19
                                             Notice PIH 2010-25

SUBJECT:     Effective Use of the Enterprise Income Verification (EIV)
           System’s Deceased                     Tenants Report to Reduce
           Subsidy Payment & Administrative Errors


1. Purpose:  This Notice explains the procedures Public Housing Agencies
   (PHAs) are required to implement to deal with families with deceased
   household members.  The implementation of the procedures outlined in this
   Notice will ensure that PHAs submit accurate data to HUD via the Public
   and Indian Housing Information Center (PIC) and that PHAs do not make
   subsidy overpayments on behalf of deceased single member households.
   Where overpayments have been made, the PHA will recoup the overpayment
   from the landlord/owner of the rental property under the programs noted
   in Section 3 of this Notice, with the exception of the Public Housing
   program.


2. Summary of Revisions: Section 7 of this Notice modifies PIH-2010-09 to
   include reference to Notice PIH-2010-15, which outlines requirements for
   safeguarding personally identifiable information, such as social security
   numbers.  Section 8 of this Notice modifies PIH-2010-09 to remove the
   requirement that the PHA notify the live-in aide to vacate the unit by
   the end of the month; and Section 15 of this Notice modifies PIH-2010-09
   to clarify minimum and maximum time frames allotted for the removal of
   personal belongings from a public housing unit when the sole household
   member dies; to provide examples of how to correctly apply this guidance;
   and remind PHAs that they must comply with local and state
   tenant/landlord laws. Section 14 of this Notice modified PIH 2010-09 to
   remind PHAs of the timely PIC reporting requirement for updated forms HUD-
   50058 in accordance with Notice PIH-2010-25.

3. Applicability:  This Notice applies to the following HUD-PIH rental
   assistance programs:  Public Housing, Section 8 Moderate Rehabilitation,
   Project-Based Voucher, Project-Based Certificate; and Housing Choice
   Voucher programs.

4. Background:   In January and September, 2008, the Department encouraged
   PHAs to utilize the Deceased Tenants Report available in the Enterprise
   Income Verification (EIV) system.  In a letter sent to all PHA Executive
   Directors, the Department urged PHAs to use the report on a monthly basis
   to assist in identifying families with deceased household members, and
   reduce the occurrence of paying housing assistance on behalf of deceased
   single member households.  The Department also urged all PHAs to take
   appropriate corrective actions to address families with deceased
   household members and update the form HUD-50058 (Family Report) to
   reflect accurate household composition and transmit the updated form HUD-
   50058 in a timely manner.

   HUD has continued to provide informal guidance and training via satellite
   and webcast, related to effective use of the EIV system, including the
   Deceased Tenants Report.


   Many PHAs have taken corrective actions to transmit more accurate data to
   HUD via PIC, and have reduced the number of deceased single member
   households continuing to receive ineligible rental assistance.  PHAs with
   zero deceased household members reported on the Deceased Tenants Report
   are to be commended for their efforts.


   However, there are some PHAs that have not followed HUD’s informal
   guidance.  According to HUD’s Office of Inspector General (OIG),  audit
   report number 2010-FW-0001, issued on November 29, 2009, PHAs have paid
   approximately $7 million in questionable housing assistance payments for
   deceased tenants in single member households.  The OIG also determined
   that PHAs did not update family composition on the form HUD-50058 in a
   timely manner, which resulted in incorrect information in PIC.


   In accordance with the new regulatory requirement at 24 CFR
   5.233(a)(2)(ii), which became effective on January 31, 2010, under the
   Final Rule:  Refinement of Income and Rent Determination Requirements in
   Public and Assisted Housing Programs:  Implementation of the Enterprise
   Income Verification System-Amendments, published at 74 FR 68924 on
   December 29, 2009, all PHAs are required to use the EIV system to reduce
   administrative and subsidy payment errors in accordance with HUD
   administrative guidance.  Accordingly, HUD is issuing this formal
   guidance to ensure that PHAs:


     a) Use EIV’s deceased tenant information for effective decision
        making, corrective action implementation, and reporting activities;
     b) Implement policies and procedures to minimize erroneous subsidy
        payments on behalf of deceased single member households; and
     c) Provide accurate and reliable information to HUD via PIC.

5. Effective Date:  This Notice is effective upon issuance.


6. Monitoring Deceased Tenants:  In accordance with PIH Notice 2010-19
   issued on May 17, 2010, PHAs must generate the Deceased Tenants Report at
   least once a month.  The purpose of generating the Deceased Tenants
   Report monthly is to eliminate and/or recover improper payments being
   made on behalf of deceased Section 8 tenants and ensure PHAs are aware of
    unoccupied public housing units which should be prepared for occupancy
   and made available for occupancy by the next eligible family.  PHAs who
   administer Section 8 programs are required to generate the report prior
   to disbursing the upcoming monthly housing assistance payment (HAP) to
   owners.  PHAs who administer the public housing program are required to
   generate the report when generating the new monthly rent roll to flag
   deceased tenants. PHAs must review the report and follow up with the
   listed families immediately and take the necessary corrective actions
   outlined in Section 8 of this Notice.

7. How to Access the Deceased Tenants Report:   The Deceased Tenants Report
   identifies deceased household members (whose identity has been confirmed
   by the Social Security Administration (SSA))* who are included in the
   family’s composition (including single member deceased households) as
   reported on Section 3 (Family Composition) of the form HUD-50058.  The
   death information is provided by the SSA.  Single member deceased
   households are denoted with a red asterisk (*) after the member’s
   deceased date (see example one below).  If the deceased date is listed as
   N/A, this means the date of death is not available (see example two
   below).


   *The individual’s social security number (SSN), date of birth, and
   surname reported on the form HUD-50058 must match SSA’s database.
   Deceased information is not displayed for any individual whose EIV
   identity verification status is failed (including individuals with a PIC-
   generated alternate identification number).

   Example 1:

   [pic]


   Example 2:

   [pic]




   Single Member Households.  Effective April 19, 2010, EIV’s Deceased
   Tenants Report was modified to isolate deceased single member households
   in addition to the previous consolidated report which contained deceased
   single and multiple member households.  This implemented system
   modification will reduce PHA administrative burden in identifying
   deceased single member households.


   Follow the following steps to access the Deceased Tenants Report:

   1:  To access the Deceased Tenant Report, log onto the EIV system at:
     https://hudapps.hud.gov/HUD_Systems.   If you do not have access to the
     EIV system, complete and submit the EIV Access Authorization Form and
     Rules of Behavior and User Agreement (form HUD-52676) to the EIV
     Coordinator in your local HUD office.  For more information, go to:
     http://www.hud.gov/offices/pih/programs/ph/rhiip/uivsystem.cfm.

   2:  Once logged into the system, scroll down the left side of the screen
     and double click on the Deceased Tenants Report link (located under the
     Verification Reports header). Select the program for which you desire
     to generate the report for (Public Housing, Section 8 or all PIH
     programs).  You may also select a specific reexamination month;
     however, the system automatically defaults to All (which HUD recommends
     that you use).  If you are responsible for more than one PHA, be sure
     to select the appropriate PHA code in the PHA drop down menu.

   3:  Double click the Get Report button.   The report will then display on
     the screen and can easily be downloaded into Excel or printed for your
     convenience.


   Note:  WARNING:  This report contains full social security numbers of
        tenants.  You must ensure that this report is adequately safeguarded
        to prevent improper disclosure of personally identifiable
        information (PII) as provided in PIH Notice 2010-15, U.S. Department
        of Housing and Urban Development (HUD) Privacy Protection
        Guidance for Third Parties.


   Report Selection Criteria for Deceased Tenants Report

   Program Type:  Select either All PIH Programs, Section 8, or Public
Housing

   Reexamination Month:  The default selection is All.  However, the user
   may select a specific month.

   PHA:  The default selection is your PHA.  If you have multiple PHAs
   assigned to your user ID, be certain to select the applicable PHA you
   wish to generate the report.

   [pic]

Sample Deceased Tenants Report[pic]




8. Administrative Actions Required by PHAs:  When the Deceased Tenants
   Report identifies an individual as being deceased, PHAs are required to
   take the following actions:


     a) Immediately send a letter to the head of household (HOH) or
        emergency contact person (if the HOH is deceased and there is no
        other adult household member) to confirm the death of the listed
        household member.


     b) Section 8 Programs only – Notify the owner in writing of the
        deceased HOH.

9. Corrective Actions Required by PHAs for Single Member Households:

     a) Public Housing Program only: Conduct a home visit to determine if
        anyone is residing in the unit. (Optional for Section 8 program)


        If there are unauthorized persons (including a live-in aide) in the
        unit of a deceased single member household you must pursue judicial
        intervention to have them lawfully removed from the unit.  You may
        be found liable for a wrongful eviction if you change the locks on
        the unit to prevent the unauthorized occupants from entering the
        unit.  Follow your local Tenant and Landlord laws to regain
        possession of the unit.


     b)  Section 8 Programs only:  For deceased single member households or
        a household where the remaining household member is a live-in aide,
        PHAs are required to discontinue HAP to the owner no later than the
        first of the following month after the month in which the death
        occurred.  See Section 16 of this Notice for determining amount of
        owner housing assistance overpayments.

   Note:  PHAs are required to immediately terminate program assistance for
        deceased single member households which will result in termination
        of the HAP contract and HAP to the owner in accordance with the
        aforementioned provisions.  The owner is not entitled to HAP for any
        month following the month in which the death occurred.  There are no
        exceptions to this policy.


10. What to do when the remaining household member is a live-in aide:  When
   the HOH dies and the only remaining household member is the live-in aide,
   the live-in aide is not entitled or eligible for any rental assistance or
   continued occupancy in a subsidized unit.  By definition, the live-in
   aide would not be living in the subsidized unit except to provide the
   necessary supportive services on behalf of the elderly or disabled HOH.
   The PHA may not designate the live-in aide as the new HOH or change the
   relation code (line item 3h on the form HUD-50058) of the live-in aide to
   make him or her an eligible household member (eligible for assistance)
   nor pay HAP on behalf of the live-in aide for any month after the month
   in which the HOH died.


11. What to do if the HOH is deceased and the remaining household members
   are minors: PHAs should have an established policy for dealing with
   situations when the HOH dies during tenancy and the remaining household
   members are minors.  A common practice of PHAs includes (but is not
   limited to) allowing a temporary adult guardian to reside in the unit
   until a court-appointed guardian is established.

   In accordance with its screening policies, the PHA may add the new
   guardian as the new HOH.  PHAs are encouraged to work with the local
   Department of Social Services to ensure that the best interests of the
   children are addressed.


12. What to do if an identified household member is incorrectly reported to
   be deceased:  There are very few instances when an error has been made in
   the SSA’s Death Match File (DMF), where an individual is reported as
   deceased, but actually living.  In the event that a household member is
   misidentified as deceased on the Deceased Tenants Report, PHAs should
   immediately notify the individual in writing and advise the individual to
   contact SSA so that SSA may correct its records.  The individual may
   contact SSA at (800) 772-1213, or visit his/her local SSA office for
   assistance.

   The PHA should also provide the individual with his/her section of the
   EIV Income Report, which shows the death information.  PHAs are
   authorized to provide EIV information only to the individual the
   information pertains to.  The PHA may provide the minor’s information to
   the minor’s adult parent or guardian.


   Last, PHAs are required to make a note in the tenant file that the
   individual has been identified as deceased; however, the PHA has
   confirmed that the individual is actually alive.


   Note:  Only SSA can correct erroneous death information.

13. Time frame for removal of individual from the Deceased Tenants Report:
   The individuals that appear on the Deceased Tenants Report are based on
   current information reported on the form HUD-50058.  The Deceased Tenants
   Report is updated every weekend.  A deceased individual will be removed
   from the report when:

    a. The PHA transmits an updated form HUD-50058, that does not contain
       the previously identified deceased household member in Section 3
       (Family Composition) of the form HUD-50058; or


    b. HUD obtains the updated and corrected information from SSA’s DMF.

           Example 1:  Mr. Jones was listed on the Deceased Tenants Report
           dated December 14, 2009, with a deceased date of November 20,
           2009.  On December 1, 2009, the PHA confirmed that Mr. Jones was
           actually alive and advised Mr. Jones to visit his local SSA
           office to have the error corrected.  SSA corrected the DMF on
           December 20, 2009.  When HUD conducted computer matching with
           SSA on January 6, 2010, HUD obtained new SSA data which
           indicated that Mr. Jones was not deceased.  The Deceased Tenants
           Report was updated on the weekend of January 8, 2010.  When the
           PHA accessed the Deceased Tenants Report on January 11, 2010,
           Mr. Jones was no longer on the report.


           Example 2:  Mr. Williams was listed on the Deceased Tenants
           Report dated December 14, 2009, with a deceased date of June 10,
           2009.  On January 6, 2010, the PHA confirmed that Mr. Williams
           was deceased.  The PHA then completed and submitted an end of
           participation (EOP) form HUD-50058 on January 7, 2010.  The
           Deceased Tenants Report was updated on the weekend of January 8,
           2010.  When the PHA accessed the Deceased Tenants Report on
           January 11, 2010, Mr. Williams was no longer on the report.

14. Type of Action and Effective Date to Record on Form HUD-50058:  Below
   prescribes the applicable type of action and effective date the PHA is
   required to record on form HUD-50058 to report changes of family
   composition and income.  In accordance with Notice PIH 2010-25, PHAs are
   required to submit an updated form HUD-50058 to PIC no later than 60
   calendar days from the effective date of the action recorded on line 2b
   of the form HUD-50058.


     a. Deceased Single Member Households.  Once the PHA has confirmed the
        death of the HOH of a single member household or a household where
        the surviving household member is the live-in aide, the PHA is
        required to complete and submit a form HUD-50058 with the
        following:


        Line 2a – Type of Action = 6 (End of Participation)


        Line 2b – Effective Date of Action = Date of Death from Deceased
           Tenants Report,
        or as noted below. (If date is listed as “N/A”, enter the date of
           death as confirmed by
        Obituary, Death Record, or other information obtained.)


        Section 8 programs:  PHAs may list the date of death as the last
           day of the
        month in which the death occurred.  The landlord is entitled to
        receive the full HAP amount for the month in which the tenant death
        occurred.


        Public Housing program:  PHAs are required to list the EOP date as
           the date on
        which the family or designee of the deceased tenant’s estate
           returned the keys and
        signed a vacate notice; or the date the public housing lease was
           terminated; or the
        date the PHA legally regained possession of the unit, whichever
           occurs first.


     b. Multiple Household Members with Deceased Head of Household –
        Surviving Adult Household Member.   Once the PHA has confirmed the
        death of the HOH, the PHA is required to complete and submit a form
        HUD-50058 with the following:


            Line 2a – Type of Action = 3 (Interim Reexamination)

        Line 2b – Effective Date of Action = Date of Death from Deceased
        Tenants Report (if date is listed as “N/A”, enter the date of death
        as confirmed by Obituary, Death Record, or other information
        obtained.)


        Line 3a (Member 01) - delete the deceased HOH’s information and
        enter the information of the adult household member who has been
        designated HOH.


        Line 3a – delete the information of the other adult household
        member, whose information you entered on Line 3a (Member 01)


        Line 3w – enter the Social Security Number (SSN) of the former
        (deceased) HOH.


     c. Multiple Household Members with Deceased Head of Household – with
        Surviving Minor Household Members.   Once the PHA has confirmed the
        death of the HOH, the PHA is required to complete and submit a form
        HUD-50058 with the following:


        Line 2a – Type of Action = 3 (Interim Reexamination)


        Line 2b – Effective Date of Action = Date of Death from Deceased
        Tenants Report (if date is listed as “N/A”, enter the date of death
        as confirmed by Obituary, Death Record, or other information
        obtained.)


        Line 3a (Member 01) - delete the deceased HOH’s information and
        enter the adult household member’s information of the temporary or
        permanent guardian.


        Line 3w – enter the Social Security Number (SSN) of the former
        (deceased) HOH.


     d. Other Household Changes.  If, in scenario B or C above, there is
        also a change in family income and composition resulting in a
        change in the family’s total family share and/or unit size, the
        effective date on line 2b should be the effective date of the new
        total family share in accordance with PHA-established policies.

15. Removal of Personal Belongings from Public Housing Unit (Applicable to
   the Public Housing program only):  Upon notification of the death, either
   by HUD’s EIV system or a third party, the family or designee of the
   deceased tenant’s estate should be allotted a minimum of fourteen (14)
   consecutive days to remove personal belongings from the unit in
   accordance with the guidance below.  This guidance is designed to afford
   families a reasonable time frame to remove personal belongings from the
   public housing unit and enable the PHA to prepare the unit, as quickly as
   possible, for occupancy by the next eligible family in need of affordable
   housing.


   While there is no HUD requirement for the time frame allotted to the
   family or designee of the deceased tenant’s estate, HUD recommends an
   allotted time frame of fourteen (14) consecutive days, beginning the day
   after the date of notification, for the family or designee of the
   descendant’s estate to remove personal belongings from the public housing
   unit unless:


         1. There is a state or local law which requires a shorter or longer
            time frame to remove personal belongings. In  those instances,
            the PHA must comply with local and/or state law; or


         2. The rent has been paid for the month in which the death occurs,
            in advance of the date of death.  In those instances, the family
            or designee of the deceased tenant’s estate should be allotted
            time through the end of the month in which the rent has been
            paid, or fourteen consecutive days from the date the PHA is
            notified of the death, whichever is greater.


                a. Example 1:  As of August 1, 2010, Joe Jones has paid rent
                   through August 31, 2010.  Mr. Jones died on August 22,
                   2010, and the PHA is notified of the death by Mr. Jones’
                   sister on August 23, 2010.  The family or designee of the
                   deceased tenant’s estate has until September 6, 2010, to
                   remove personal belongings from the unit, unless state or
                   local landlord laws authorize a shorter or longer time
                   period.


                b. Example 2:  As of August 1, 2010, Mary Smith has paid
                   rent through September 30, 2010.  Ms. Smith died on
                   August 22, 2010, and the PHA is notified of the death by
                   a 3rd party on August 24, 2010.  The family or designee
                   of the deceased tenant’s estate has until September 30,
                   2010, to remove personal belongings from the unit, unless
                   state or local landlord laws authorize a shorter or
                   longer time period.


                c. Example 3:  As of August 1, 2010, John Doe has not paid
                   rent for August 2010.  Mr. Doe died on August 10, 2010,
                   and the PHA is notified of the death by Mr. Doe’s friend
                   on August 12, 2010.  The family or designee of the
                   deceased tenant’s estate has until August 26, 2010, to
                   remove personal belongings from the unit, unless state or
                   local landlord laws authorize a shorter or longer time
                   period.


   PHAs are reminded to comply with local and state established tenant-
   landlord laws with respect to lease termination, possession of premises
   upon death and removal of personal belongings from the public housing
   unit.

16. Retroactive Repayment of HAP by Owners:    If an owner receives HAP for
   any month in which the owner is ineligible to receive HAP because of a
   deceased tenant, the PHA must immediately notify the owner in writing of
   the ineligible HAP and require the owner to repay the overpayment to the
   PHA within 30 days.  If the owner does not comply, the PHA may deduct the
   amount due to the PHA from any amounts due to the owner under any other
   HAP contract. If there is no other HAP contract with the owner, the PHA
   may seek and obtain additional relief by judicial order or action in
   accordance with state and local laws.


   Example:  The Deceased Tenants Report dated December 14, 2009, indicates
   that Mr. Robert died on March 9, 2009.  The landlord/owner is not
   eligible for HAP in any month following March 2009.  The PHA erroneously
   paid the landlord/owner HAP of $500 each month during the period of April
   2009 through December 2009.  The landlord/owner must repay the PHA $4,500
   ($500 X 9 months).


   In instances where a deceased single member household has been deceased
   for a period greater than one (1) month and the owner received HAP, the
   PHA may determine that the owner has breached the HAP contract.  As such,
   the PHA may exercise any of its rights and remedies under the HAP
   contract, or any other available rights and remedies for such breach.

   The PHA must notify the owner of such determination, including a brief
   statement of the reasons for the determination. The notice by the PHA to
   the owner may require the owner to take corrective action, as verified or
   determined by the PHA, by a deadline prescribed in the notice.

   The PHA’s rights and remedies for owner breach of the HAP contract may
   include recovery of overpayments, suspension of HAP, abatement or other
   reduction of HAP, termination of HAP, and termination of all HAP
   contracts.   The PHA may seek and obtain additional relief by judicial
   order or action, including specific performance, other injunctive relief
   or order for damages.

17. Penalties for Non-Compliance with Use of EIV’s Deceased Tenants Report:




    Section 8 Programs:  If the PHA overpaid HAP on behalf of a single
    member deceased household and fails to collect the overpayment from the
    owner, the PHA is required to reimburse 100 percent of the overpayment
    to the HCV HAP account from the Administrative Fee Equity account,
    Central Office Cost Center (COCC) account, or other non-Federal funds.
    In addition, if such errors impacted any funding baseline
    determinations, funding for the affected renewal periods may be
    adjusted.


   Note:   A PHA cannot reimburse prior year HAP costs with current year HAP
        funding because the funding carries forward but does not carry
        back.


   HUD will monitor each PHA’s Deceased Tenants Report on a quarterly basis.
    If at any time the report identifies deceased single member households
   who have been deceased for a period exceeding six months, and HUD
   determines that the PHA has not taken the necessary corrective action,
   the PHA may be subject to a withholding of its monthly administrative fee
   each month that the number of single deceased household members is
   greater than zero.


   Public Housing Program:  HUD will monitor each PHA’s Deceased Tenants
   Report on a quarterly basis.  If at any time, the report identifies
   deceased single member households who have been deceased for a period
   exceeding six months, and HUD determines that the PHA has not take the
   necessary corrective action, the PHA may be subject to a monetary
   penalty, as determined by the Assistant Secretary, each month that the
   number of single deceased household members deceased for a period of one
   year or longer is greater than zero. HUD may offset the PHA’s monthly
   operating subsidy by the amount of the imposed penalty or require the PHA
   to pay the amount of the penalty from non-Federal funds, directly to HUD.


   For any imposed penalty, HUD will notify the PHA in writing of such
   penalty and afford the PHA a 30-day period to appeal HUD’s decision.
   Appeals must be postmarked no later than 30 days from the date of the
   penalty Notice and sent by certified mail or carrier service (UPS, FEDEX,
   DHL, etc.) to:


            U.S. Department of Housing and Urban Development
            Office of Public and Indian Housing
            Real Estate Assessment Center
            Attention:  Nicole Faison
            451 7th Street, SW, Room PCFL1
            Washington, DC 20410

   Appeals by fax or email will not be processed.  HUD will provide a
   written response to your appeal request within 60 days of receiving the
   appeal request.

18. EIV System Training:  HUD offers free EIV system training via webcast
   and can be viewed by staff at any time at:
   http://portal.hud.gov/portal/page/portal/HUD/press/multimedia/videos.
   Past and future training opportunities, including training materials are
   available at:
   http://www.hud.gov/offices/pih/programs/ph/rhiip/training.cfm.  As a
   condition of initial and continued EIV system access, all system users
   are required to view HUD Headquarters-provided EIV system training and
   annual Security Awareness training.


   EIV system users must self-certify within the EIV system at the log-in
   page that the training has been completed.  Staff is not required to
   possess a Certificate of Completion for EIV training in order to gain or
   continue accessing the EIV system, or be certified by the User
   Administrator on a semi-annual basis.


19. For inquiries about this Notice contact:  your local HUD field office
   or Nicole Faison of HUD Headquarters’ Office of Public and Indian
   Housing: Real Estate Assessment Center at (202) 475-7963, or via email at
   PIH.RHIIP.TA@HUD.GOV.

20. Paperwork Reduction Act:  The information collection requirements
   contained in this Notice have been approved by the Office of Management
   and Budget (OMB under the Paperwork Reduction Act of 1995 (44 U.S.C.
   3520) and assigned OMB control number(s) 2577-0083.  In accordance with
   the Paperwork Reduction Act, HUD may not conduct or sponsor, and a person
   is not required to respond to, a collection of information unless the
   collection displays a currently valid OMB control number.


                                        /s/
                             Sandra B. Henriquez, Assistant Secretary for
                             Public and Indian Housing
-----------------------
[pic]

U.S. Department of Housing and Urban Development
Office of Public and Indian Housing