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October 7, 2013: NHLP Submits VAWA Comments to HUD

On October 7, 2013, NHLP, the Shriver Center and sixteen advocacy organizations submitted comments to HUD in response to HUD's notice applying VAWA 2013 to the agency's programs. In short, the comments urge HUD to

  • Change its view that VAWA 2013's housing safeguards are not self-executing;
  • Apply VAWA 2013 to all Section 202 properties without exception;
  • Provide guidelines for determining when a "reasonable time" is for survivors to establish eligibility or find new housing, when a lease bifurcation occurs;
  • Translate the HUD VAWA Housing Rights Notice into multiple languages;
  • Clarify that all housing providers covered by VAWA 2013 must provide translated versions of the HUD VAWA Housing Rights Notice;
  • Clarify that survivors should not be required to provide multiple forms of certification, when one acceptable form chosen by the survivor is sufficient;
  • Provide guidance on how housing providers should handle conflicting certifications;
  • Emphasize the importance of maintaining the survivor's confidentiality in any VAWA 2013 guidance or regulations;
  • Clarify that the portability provision also applies to survivors of sexual assault; and
  • Establish an administrative mechanism to enforce VAWA.

The comments further provide

  • Detailed recommendations for HUD's model emergency transfer plan to be used by housing providers;
  • A sample HUD VAWA Housing Rights Notice and outline when this Notice should be distributed to applicants and tenants.
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