On June 10, 2024, the ACLU submitted a comment to the Department of Housing and Urban Development (“HUD”) on a proposed rulemaking regarding reducing barriers to HUD-assisted housing. In its comment, the ACLU urged HUD to adopt the proposed rule and specifically (1) provide further limits and clarity regarding what criminal records PHAs and owners may consider; (2) further limit and clarify relevant lookback periods; (3) require PHAs and owners to impose additional procedural requirements before and after any potential denial; (4) modify and more fully explain the factors relevant to an individualized assessment that PHAs and owners must consider; (5) clarify the preponderance of evidence standard; and (6) strengthen tenant engagement requirements.