QUESTION Does HUD require a picture ID for adult family members? Our administrative plan and ACOP policies require a state-issued picture ID but we are finding that some applicants have difficulty in obtaining one. What if there is a birth certificate on file? Is that acceptable as proof of identity under the HUD regulations?
ANSWER There is no regulatory requirement for proof of identity, but PHAs may establish such a requirement in policy. Proof of identity is not limited to state-issued ID documents.
Here is a clarification from HUD’s Rental Integrity Summit FAQs (please see Q & A #50):
Question: Is a picture ID required, if there is a birth certificate in the adult tenant's file for establishing legal identity?
Answer: A birth certificate does not establish an adult's legal identity in determining citizenship for eligibility. Therefore, a PHA may request a picture ID from an adult for this purpose. HUD regulations give PHAs the discretion to determine what appropriate documentation an applicant or participant is required to furnish to the PHA. Although not inclusive, the following are acceptable documents to establish identity:
- U.S. passport
- Certificate of U.S. Citizenship (INS Form N-560 or N-561)
- Certificate of Naturalization (INS Form N-550 or N-570)
- Valid foreign passport, with I-551 stamp or attached INS Form I-94 indicating unexpired employment authorization
- Permanent resident card or alien registration receipt card with photograph (INS Form I-151 or I-551)
- Valid employment authorization card (INS Form I-688)
- Valid reentry permit (INS Form I-571)
- Valid employment authorization document issued by INS, which contains a photograph (INS Form I-688B)
- Driver's license or ID card issued by a state or outlying possession of the United States
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