HUD's Annual Collection of Information on LIHTC Tenants: Improve or Scrap?

The U.S. Department of Housing and Urban Development (HUD) recently issued a notice seeking public comments regarding its mandated annual collection of tenant information for properties financed with Low-Income Housing Tax Credits (LIHTC). This collection is statutorily required and designed to provide comprehensive data about residents living in LIHTC-funded housing developments. The notice can be found at www.federalregister.gov/d/2025-09866.

HUD, through its Office of Policy Development and Research, administers this annual information collection under Section 2835(d) of the Housing and Economic Recovery Act (HERA) of 2008. The collection gathers data related to tenant demographics such as race, ethnicity, family composition, age, income, disability status, rental assistance utilization under Section 8, and monthly rent payments.

The data is used to ensure accountability, compliance, and to inform policy decisions aimed at better serving low-income families. Specifically, the collection involves two forms: HUD-52695 (HUD LIHTC Property Data Collection Form) and HUD-52697 (HUD LIHTC Tenant Data Collection Form). In 2010, the U.S. Office of Management and Budget first approved the forms used for this collection. Each year, state and local agencies responsible for administering LIHTCs submit detailed tenant and property data.

Currently, 61 state and local LIHTC-administering agencies participate, with the collection process estimated to take a total of 2,928 hours annually, involving an average of 48 hours per response across two forms. The total annual cost associated with this data collection is estimated at approximately $163,002. HUD is seeking feedback on:

• Whether the proposed collection of information is necessary for the proper performance of HUD’s functions, including whether the information will have practical utility.
• The accuracy of its estimated burden on participating agencies.
• Potential enhancements to improve the quality, utility, and clarity of the collected information.
• Methods to minimize the collection burden through technological solutions or alternative processes.

Interested stakeholders, including LIHTC site owners, managers, and administering agencies, are encouraged to submit their comments to HUD by Aug. 1. Feedback can be provided electronically via regulations.gov or submitted via email to PDRPPublicComments@hud.gov.