April 27, 2026
Regulations Division
Office of General Counsel
Department of Housing and Urban Development
451 7th Street SW, Room 10276
Washington, DC 20410-0500
Sent electronically via Regulations.gov.
RE: Docket No. [FR-6529-I-01] – Revocation of the 30-Day Notification Requirement Prior To Termination of Lease for Nonpayment of Rent
Dear colleagues,
The Poverty & Race Research Action Council (PRRAC) is a national civil rights organization bridging law, policy, social science, and grassroots organizing to advance racial and economic justice. PRRAC brings deep expertise on housing justice and educational equity to grassroots movement organizations and coalitions, through legal analysis, policy design, and research translation. Our work is grounded in empirical research, legal analysis, and demonstrated solutions to ensure that federal housing programs advance equity, inclusion, and opportunity. From this perspective, we strongly oppose the Interim Final Rule (IFR) (“the revocation”) and urge HUD to preserve the 30-Day Notification Requirement Prior to Termination of Lease for Nonpayment of Rent (89 FR 101270) (“30-day notice rule”).
The proposed revocation will exacerbate the current housing crisis, raise significant Fair Housing Act (FHA) concerns, have negative financial impacts, open up liability for defects and due process violations against vulnerable tenants in public housing, federally-assisted housing, and residential properties that have a federally-backed mortgage. Therefore, we urge HUD to maintain the status quo and rescind the revocation of the 30-day notice rule.
1. The revocation of the 30-day notice rule is ineffective, irresponsible, and dangerous during a housing crisis.
The United States is currently in the midst of an unprecedented affordable housing crisis.1 Ever-rising rents and stagnant incomes have caused more low- and moderate-income renters to pay more than ever before.2 22.7 million households in the country (half of all renters) are forced to spend more than 30% of their income on housing, classifying them as “cost-burdened.” More alarmingly, 26% are severely cost-burdened because they spend more than half of their income on rent and utilities. These households sit on an unstable precipice that could be tipped by a single unexpected expense or lost paycheck. Families without the financial buffers to absorb these costs face devastating results.
The existing 30-day notice rule recognizes and accounts for this reality faced by participating families and allows them the time and opportunity to seek out resources, plan/negotiate with their landlord, or work overtime to pay off their bills. If revoked, families will instead need to use their extremely limited time and money to prepare for the worst, disincentivizing collaboration between tenant and landlord. The mere filing of an eviction can inflict long-lasting harm. Depending on the jurisdiction, tenants who successfully cure their arrears and have their cases dismissed may still carry a permanent eviction record. This is a barrier to securing future housing and can effectively trap vulnerable families in a cycle of instability.
1 The Problem, Nat’l Low Income Housing Coal., https://nlihc.org/explore-issues/why-we-care/problem.
2 In 2024, the number of cost-burdened households (those spending more than 30% on rent and utilities) hit a record high for the third year in a row accounting for more than 22.7 million households or about 49 percent of renters. Less predictably, moderate income earners making between $45,000 and $75,000 are still cost-burdened at a rate of 49 percent. Since 2001, the average renter’s household income has increased by 9 percent. In contrast, the average rent has risen by 30 percent. Joint Center for Housing Studies of Harvard University America’s Rental Housing 2026 https://www.jchs.harvard.edu/sites/default/files/reports/files/Harvard_JCHS_Americas_Rental_Housing_2026.pdf; see also Jamie Forbes, February 2025 Average Rent Report: Rents Rise as Construction Slows, Rent. Research (Mar. 12, 2025), https://www.rent.com/research/average-rent-price-report/.
