What Owners Need to Know
HUD’s EIV Citizenship Verification Tool gives Multifamily owners and agents another way to identify potential discrepancies in tenant eligibility.
The tool compares tenant information submitted to HUD with federal citizenship and immigration records. However, a discrepancy does not automatically mean a household is ineligible for assistance.
The latest guidance builds on earlier citizenship verification requirements. In January, HUD directed Public Housing Agencies (PHAs) to review EIV-SAVE discrepancies and take corrective action. We covered those developments in our earlier EIV-SAVE update.
Now, HUD has introduced a separate project-level report for Multifamily owners and agents. For Section 8 Project-Based Rental Assistance (PBRA) properties, this distinction matters.
Owners and agents must review identified discrepancies, verify supporting documentation, and correct inaccurate records. Additionally, they must follow established procedures before reducing or terminating housing assistance.
Here’s what owners and agents need to know about the tool and their responsibilities.
How the EIV Citizenship Verification Tool Works
HUD introduced the EIV-SAVE Tenant Matching Report on May 21, 2026.
The report compares information from two federal systems:
- Tenant Rental Assistance Certification System (TRACS): Contains household information submitted through HUD-50059 certifications.
- Systematic Alien Verification for Entitlements (SAVE): Provides citizenship and immigration status information maintained by federal agencies.
The report identifies potential differences between information recorded in these systems. For example, a tenant’s citizenship classification in TRACS might not match the initial verification response returned through SAVE. However, these differences can occur for several reasons.
Some may involve incorrect information entered into a HUD-50059. Others may require additional documentation or verification. Therefore, owners and agents should treat the report as a starting point for further review.
What the report does not do
The EIV-SAVE Tenant Matching Report does not independently establish that a household is ineligible for assistance. HUD specifically cautions against making eligibility decisions based solely on an unresolved discrepancy.
Instead, owners and agents must follow the verification procedures outlined in HUD’s instructions. This distinction helps ensure that eligibility decisions rely on accurate records and appropriate documentation.
Which properties appear in the report?
Not every property will have an EIV-SAVE Tenant Matching Report. HUD explains that reports are available only for projects with identified discrepancies. Consequently, owners managing several properties may find reports for only some of their projects.
If a property does not appear in the report selection menu, HUD indicates that no discrepancies were identified for that project. Additionally, the original report was a point-in-time comparison. Correcting a record does not necessarily remove the tenant from the existing report.
Owners should retain documentation demonstrating how they addressed each discrepancy.
EIV Citizenship Verification: What Owners Must Review
HUD’s May 21 instructions established specific steps for reviewing and resolving discrepancies. The original bulletin required owners and agents to complete those actions within 30 calendar days. Although that deadline has passed, the instructions remain an important reference for understanding the verification process.
1. Access the EIV-SAVE Tenant Matching Report
Authorized users can access the report through EIV. From the EIV home page, select the USCIS-SAVE System option under External Links.
Next, select the appropriate contract or project number and retrieve the report. Only projects with identified discrepancies will appear in the selection menu.
Owners and agents should also confirm that appropriate staff have the necessary EIV and SAVE access. HUD’s EIV Multifamily User Administration Manual (PDF) provides instructions for assigning user roles, managing access, and completing user certifications.
HUD has also provided EIV-SAVE Tenant Matching Report Instructions for Owners and Agents (PDF). Owners and agents should review these instructions before addressing discrepancies or making changes to tenant records.
2. Review each identified discrepancy
For each tenant listed, owners and agents should review the initial USCIS verification response. HUD directs users to the SAVE Guide to Understanding SAVE Verification Responses for assistance interpreting results.
Additionally, owners should determine whether the individual still resides at the property and receives assistance. Under the original instructions, no further action is necessary when the tenant no longer resides at the property or receives assistance.
3. Verify supporting documentation
Next, review the tenant file for the documentation required under 24 CFR § 5.508.
Documentation requirements depend on the individual’s citizenship or immigration classification. For example, HUD identifies different requirements for U.S. citizens, certain noncitizens aged 62 or older, and other noncitizens.
Owners must also review previous SAVE verification results when applicable. If required evidence is missing, HUD instructs owners to obtain and verify the appropriate documentation.
Importantly, owners should follow the specific requirements for each classification rather than applying one standard to every household.
4. Check HUD-50059 information
Data entry errors can create discrepancies between federal systems. Therefore, owners should carefully compare household information in TRACS against supporting documents.
Information to review includes:
- Names and dates of birth
- Social Security numbers
- Citizenship or immigration status codes
- Alien registration numbers, when applicable
- Household relationship codes
If information was entered incorrectly, HUD directs owners to transmit a corrected HUD-50059 to TRACS. For example, HUD specifies that alien registration numbers should be entered without dashes.
These details may appear minor. However, accurate information is essential for verification.
5. Complete additional verification when necessary
Some discrepancies will remain after reviewing documentation and correcting data. In those situations, HUD’s instructions describe additional verification through SAVE. Owners and agents should follow Attachment B to determine when another SAVE case is appropriate.
They should also retain documentation supporting their review and any subsequent action.
6. Maintain records of the resolution
Documentation is critical to the process. HUD instructs owners and agents to retain the EIV-SAVE Tenant Matching Report in the project’s EIV Master File.
They must also retain the applicable report in the tenant file, along with notes documenting actions taken. Records should clearly explain how staff reviewed and resolved each discrepancy.
As a result, owners can demonstrate the steps taken if HUD requests additional information.
EIV Citizenship Verification and Tenant Assistance
One of the most important aspects of HUD’s guidance concerns decisions affecting housing assistance. An EIV-SAVE discrepancy alone does not authorize an owner to reduce or terminate assistance.
HUD makes clear that owners must complete the required verification process before determining eligibility. Owners must also follow applicable notification, appeal, and informal hearing procedures.
Under 24 CFR § 5.514, families have procedural protections when eligibility determinations may affect their assistance. These requirements remain important even when federal records initially indicate a potential discrepancy.
What about mixed-status households?
HUD’s eligibility rules also address households containing members with different immigration eligibility classifications. These are commonly called mixed-status families.
Under applicable HUD regulations, eligible household members may receive prorated assistance when other household members are ineligible. Therefore, review a household’s circumstances under the appropriate regulatory provisions.
Owners should not assume that one household member’s ineligibility automatically makes the entire household ineligible. Instead, they must apply HUD’s verification, proration, and procedural requirements.
What happens when federal records are incorrect?
Sometimes, a discrepancy may involve information maintained by another federal agency. For example, an individual may need to correct a record held by USCIS or the Social Security Administration.
HUD explains that SAVE cannot independently correct those source records. As a result, residents may need to contact the agency that maintains the information. Owners should distinguish between correcting information in TRACS and resolving issues in another federal agency’s records.
What PBRA Owners and Agents Should Do Next
The EIV Citizenship Verification Tool reinforces the importance of accurate tenant records and consistent verification practices. However, effective compliance involves more than reviewing a report.
Owners and agents should ensure their teams understand the applicable procedures and maintain appropriate documentation. A practical review should include:
- Confirm system access. Ensure authorized employees can access the appropriate EIV and SAVE resources.
- Review outstanding discrepancies. Determine whether any previously identified issues remain unresolved.
- Check tenant documentation. Confirm that files contain required citizenship or eligible immigration status records.
- Verify TRACS accuracy. Correct identified HUD-50059 errors through the appropriate submission process.
- Document completed reviews. Retain reports, supporting evidence, and notes explaining the resolution.
- Review eligibility procedures. Ensure staff understand applicable verification, proration, appeal, and hearing requirements.
Owners should also review HUD’s instructions before taking any action that could affect a household’s assistance. HUD has indicated that failure to complete required steps may result in EIV penalties or compliance flags. Therefore, consistent documentation and timely follow-through remain important.
Need More Information?
For additional details, review HUD’s EIV Citizenship Verification Tool instructions, including Attachments A and B. Owners and agents can also visit Navigate Affordable Housing Partners for additional HUD program updates and educational resources.
Frequently Asked Questions
What is the EIV Citizenship Verification Tool?
It is a HUD reporting tool that compares tenant information in TRACS with federal citizenship and immigration records through SAVE.
Does appearing on the EIV-SAVE report mean a tenant is ineligible?
No. A discrepancy requires further review and does not automatically establish ineligibility.
Do all PBRA properties have an EIV-SAVE report?
No. HUD’s original report includes only projects with identified discrepancies.
Can an owner terminate assistance based on an EIV-SAVE discrepancy?
Not based on the discrepancy alone. Owners must complete required verification and follow applicable appeal and hearing procedures.
Where should owners keep EIV-SAVE reports?
HUD instructs owners to retain reports in the project EIV Master File and applicable tenant files, with resolution notes.
