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Removal of SSN from tenant files

Although this is not yet a requirement, it is obvious that there is a push in the affordable housing industry to reduce the amount of times the SSN is disclosed in the tenant file to minimize the risk of identity fraud.  We were told during a recent TRACS Industry meeting that the SSN will not be masked is the HUD Form 50059.  Since the tenants signature is required to attest to the accuracy of the infomation that is reported on the 50059 this SSN cannot be masked.   

According to the HUD Notice 2010-10, Pg 17 there is a note that says:  “NOTE: To minimize the risk of exposing a tenant’s SSN, O/As may remove and destroy, at the time of recertification, copies of verification documentation received from the tenant at the time of disclosure of their SSN once the Identity Verification Status shows “Verified”. O/As are encouraged to minimize the number of tenant records that contain documents that display the full nine-digit SSN.  O/As must not include the full nine-digit SSN for a tenant in emails or other electronic communications. 

We suggest you check your Verification Forms and other tenant included documentation to begin masking the SSN to protect your tenants data.  You may want to check with your vendors as well to see if they can assist you in this matter.