DuPage County staff say HUD guidance on immigration verification leaves tenant-based rental assistance unclear

DuPage County Human Services Committee · January 6, 2026

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Summary

County staff told the Human Services Committee they have not received operational guidance after HUD issued an interpretation that may require immigration-status checks in the SAVE database for some federally funded benefits, and county staff currently lack SAVE access.

County staff warned DuPage County's Human Services Committee on Jan. 6, 2026, that recent U.S. Department of Housing and Urban Development (HUD) guidance appears to require immigration-status verification for some federally funded benefits and suggested that eligibility information be entered into the SAVE (Systematic Alien Verification for Entitlements) database.

Mary, a county staff member speaking during discussion of a HOME tenant-based rental assistance (TBRA) agreement with DuPagePads, said HUD's guidance indicated beneficiaries receiving federal funds "needed to be basically vetted for immigration status" and that information would need to be entered into SAVE. She told the committee that no county staff currently have access to SAVE and the county has not yet received operational guidance on how to implement the requirement.

Staff noted two possible interpretations: that nonprofit organizations serving clients with federal funds may be exempt from SAVE access, or that nonprofits would still need to enter individual information even if the nonprofit's role differs. Mary said DuPagePads and Catholic Charities are already performing eligibility checks, collecting documents such as birth certificates, passports or proof of lawful permanent residence for clients they serve, but the county is uncertain whether those practices fully meet HUD's new direction.

Committee members and staff said the $139,000 DuPagePads TBRA agreement under consideration used 2025 HOME funds and that the continuation of HOME funding in 2026 remains uncertain while Congress considers program funding and changes. Staff said they are coordinating with the county state's attorney for legal and operational clarification and will continue current documentation practices until HUD issues further operational direction.

The committee approved the DuPagePads HOME TBRA agreement by voice vote. Staff recorded a follow-up task to monitor HUD guidance and report back once HUD clarifies how SAVE requirements should be implemented at the county level.