Latino Network's Official Testimony on HUD's Proposed Rule Change

Dear Regulations Division:

Latino Network is thankful for the opportunity to provide public comment and strongly urge that the Department of Housing and Urban Development (“HUD”) withdraw this proposed rule immediately. Latino Network is a culturally specific service and advocacy organization located in Portland, Oregon. Our organization serves the greater Portland area, in Multnomah, Washington, and Clackamas counties. We provide wraparound services for Latinx youth, adults and families. This proposed rule would hurt our community and other immigrant communities in our city, state and country. 

We expect that the impact of this proposed rule will affect close to 1,500 people in our service area.  This means a huge number of people will be evicted, enter a tight rental market, and have difficulties in reaching financial and housing stability. 

We currently provide housing assistance to a number of immigrant families through a partnership with Multnomah County. We provide homeless re-entry and family stability programming that is intended to create stability for people working their way out of poverty. These services include partnering with both government agencies, housing authorities, and other nonprofit service providers to deliver key safety net and community support programs. Our programs include HUD funded programs. 

Our mission is to provide supports for Latino youth, families and community to build self-determination. In pursuit of this mission and in line with our values, our organization provided services to close to 8,000 families in the Portland metro area. This includes a vast network of programming and supports, including early childhood education, gang intervention services, after school programming, advocacy services, and housing stability. We understand the importance of having financial and housing stability for our participants to achieve their goals. Our services offered provide case management supports, and we have had a high success rate in transitioning families into housing stability.

Aside from our immediate work, we recognize the far larger impacts of this rule change nationally. According to HUD’s own analysis, approximately 108,000 people living in subsidized housing would be impacted by this proposed rule. Out of those 108,000 about 55,000 are children. 

Today, the Latino population in the United States is more than 55 million people. Despite the educational experience and economic diversity in our community, Latinos continue to struggle to find affordable and long term housing.  Being able to access federal housing assistance has helped Latinos lift themselves out of poverty. According to an analysis by UnidosUS, a national organization of which we are a member of, federal housing assistance including public and other subsidized housing lifted approximately 800,000 Latinos out of poverty in 2017, including more than 280,000 Latino children.

Latino Network would like to remind HUD, that while your agency argues the proposed rule would alleviate wait times for housing assistance, it will further put pressure on existing housing stock, homeless shelters, and due to the nature of HUD funding will result in fewer families receiving federal housing benefits.
We wholeheartedly condemn the scapegoating of immigrant families for the cause of housing instability, long wait times, and difficulty in attaining services. We would like to reiterate that we urge HUD to immediately withdraw this current proposal and dedicate its efforts to advancing policies that benefit rather than hurt immigrants looking to support themselves and their families.


Carmen Rubio

Executive Director

Latino Network