Common use of DESCRIPTION OF THE DATA MATCH PROCESSES Clause in Contracts

DESCRIPTION OF THE DATA MATCH PROCESSES. When a Presidential declaration or emergency authorizes federal assistance to individuals and households under section 408 of the Xxxxxxxx Act, the sharing or matching of data will occur through the following three processes: (1) Emergency Sheltering and FEMA Housing Assistance Data Matching; (2) CDBG-DR grants allocation formulation and CDBG-DR grantee planning and marketing; and (3) CDBG-DR Grantee Data Matching. The three processes are described below. Emergency Sheltering and FEMA Housing Assistance Data Matching HUD rental assistance programs are identified at 24 C.F.R. § 5.233, emergency sheltering is authorized under sections 403 or 502 (see above legal authorities), and FEMA housing assistance is provided through the Individuals and Households Program (IHP) under section 408(c) of the Xxxxxxxx Xxx, 00 X.X.X. § 0000(x). FEMA and HUD will compare and match data between the two agencies for HUD-assisted individuals receiving emergency sheltering (when section 408 has been authorized) or FEMA housing assistance using database queries that perform pattern analysis to establish a match. HUD will initiate the data sharing by providing information on pre-disaster HUD- assisted households within the geographic area designated in the declaration. FEMA and HUD will initiate the data matching by comparing names, addresses, dates of birth, and the last four digits of SSN. After confirmation of a definite match, FEMA and HUD will share the remaining data fields of the matched individuals to compare benefits and assess duplication of benefits and potential unmet needs. The data fields associated with this purpose are listed in Table 2, Table 3, and in Appendix A. This data sharing will be performed within the first 12 months of a new disaster declaration, and most of the data sharing will typically occur within the first 120 days of the event. Table 2: Data Fields HUD to Share with FEMA Data Fields Co-recipient First Name Co-recipient Last Name Co-recipient Date of Birth Co-recipient Last 4 digits of SSN Recipient First Name Recipient Last Name Recipient Date of Birth Recipient Street Address Recipient State Recipient City Recipient County Recipient Address 5 Digit Zip Code Recipient Last 4 digits of SSN Number of Household Members HUD Program Code* PROGRAM TYPE H1 - Section 8 (Multifamily) H4 - Section 236 (Multifamily) H7 - 202/PRAC (Multifamily) H8 - 811/PRAC (Multifamily) P - Public Housing PBV - Project Based Voucher TBV - Tenant Based Voucher HV - Homeownership Voucher CE - Certificate MR - Mod Rehab HUD Rehoused (Y/N/ Unknown) HUD Project Code HUD Public Housing Agency (PHA) Code HUD Date of Recertification Table 3: Data Fields FEMA to Share with HUD Data Fields Access and Functional Needs (Y/N) Applicant Alternate Phone Number Applicant Current Phone Number Applicant Date of Birth Applicant Email Address Applicant Last, First Name Applicant Last 4 Digits of SSN Applicant Registration Number Co-applicant Date of Birth Co-applicant Last, First Name Co-applicant Last 4 digits of SSN Co-applicant Current Phone Number Current Location (as identified in applicant registration and applicant information screen) Current Mailing Address 5 Digit Zip Code Current Mailing Address City Current Mailing Address County Current Mailing Address Street Current Mailing Address State Damaged Address City Damaged Address 5 Digit Zip Code Damaged Address Zip Code 4 Digit Extension Damaged Address County Damaged Address Street Damaged Address State Damaged Dwelling Latitude Damaged Dwelling Longitude Disaster Number Household Member Age (Age range) Under 5 years 5 to 17 years 18 to 64 years 65 and above Number of Household Members Current Hotel Address Current Hotel City Current Hotel County Current Hotel Name Initial Rental Assistance Approved Date Data Fields Direct Housing First Licensed-in Date (FEMA’s authority to allow an applicant to reside in a Direct Housing Unit) Last Continued Temporary Housing Assistance Date CDBG-DR grants allocation formulation and CDBG-DR Grantee Planning and Marketing The FEMA data HUD requires to perform its CDBG-DR grants formulation will be generated by FEMA using a database query extracting all data elements listed in Table 4 and Appendix B. FEMA will extract every registration for each distinct FEMA disaster declaration HUD submits in their official request for data. HUD requires each FEMA registration to assess assistance funds provided by FEMA and SBA to calculate unmet needs. FEMA and SBA provide the unique FEMA application registration number, or Registration ID, to enable HUD to match FEMA data to SBA data. Matching FEMA and SBA data allows HUD to perform the unmet needs analysis using a one-to-one comparison of each individual housing unit. This will not be used for determining individual benefits. HUD uses the FEMA inspection damage and award data to analyze and calculate unmet needs. This data is also used by HUD to generate their CDBG-DR formula allocations to inform OMB and Congress on the likely amount of unmet needs before OMB and Congress make their appropriation, and to determine allocation amounts for states, local governments, and Indian tribes after making an appropriation. The data shared with HUD will be utilized to identify damage estimates in major disaster areas. HUD also considers the contributions of insurance, FEMA awards, and SBA loans in estimating severe unmet needs not addressed by these sources. The complete methodology by which HUD estimates unmet needs is published in a Federal Register Notice identifying allocations and establishing the requirements of CDBG-DR grants. HUD is required to allocate CDBG-DR funds to address unmet disaster-related needs in the most impacted and distressed areas after a major disaster. Since 2015, HUD has relied on case-level data from FEMA and SBA to make these allocations. HUD must calculate the unmet needs for renters’ and owners’ homes experiencing serious damage, where unmet needs are determined based on an individual household’s severity of damage, insurance coverage for the damage incurred, income, flood plain status, and likely SBA approval. To calculate, HUD must have information regarding the address, extent of damage, and insurance information. Unmet needs cannot be calculated from FEMA public use data. In addition, HUD analysis will assess the data at the individual record level to factor in a combination of features for each disaster applicant to determine if and to what extent each row of data will be included in the grant formulation structure. HUD is responsible for performing the grant formulation process and must address any questions and issues raised by OMB and Congress. HUD publishes its grant formula allocations in the notice governing the use of grant funds. A recent example of the published allocation formula is found in Appendix A of the Federal Register Notice found here: xxxxx://xxx.xxxxxxx.xxx/content/pkg/FR-2020-01- 27/pdf/2020-01204.pdf. FEMA will use a database query, based on a list of distinct FEMA major disaster declaration numbers, that extracts all data elements listed in Table 4 and Appendix B to generate the CDBG-DR grants formulation data. HUD uses the FEMA Registration ID to map SBA and FEMA data to one registration. In addition, HUD applies repeatable programming code to factor in each distinct FEMA award data field in a single registration. CDBG-DR grantees will also use these data for planning purposes to identify the likely gaps in assistance (such as unmet needs) and what types of CDBG-DR eligible activities are most likely to close those gaps in assistance. CDBG-DR grantees will also use these data to market the planned assistance to FEMA-assisted individuals so that they are aware of the planned use of the CDBG-DR funds and how to seek CDBG-DR funded assistance. These uses will not involve matching with other data. Table 4: Data Fields FEMA to Share with HUD Data Fields Small Business Administration (SBA) HAPP Referral Flag (Y/N) Census Block Group ID (if applicable) Damaged Address Street Damaged Address City Damaged Address County Damaged Address State Damaged Address 5 Digit Zip Code Damaged Address Zip Code 4 Digit Extension Damaged Dwelling Latitude Damaged Dwelling Longitude Cause(s) of Damage from Inspection Current Mailing Address 5 Digit Zip Code Current Mailing Address City Current Mailing Address Street Current Mailing State Current Mailing Zip Code 4 Digit Extension Dependents (Number in Household) Destroyed Flag (Y/N) Disaster Number FEMA Registration Number Flood Zone High Water Xxxx Location High Water Depth in inches Habitability Repairs Required (Y/N) Gross Income (as reported at Registration) Data Fields Insurance Types (Insurance Code) Level of Damage Non-Compliant with Flood Insurance Requirement (NCOMP) Flag (Y/N) Owner/Renter Personal Property Total FEMA Verified Loss (FVL) Amount Personal Property Flood Damage FVL amount Real Property Total FVL Amount (Aggregated for all REAL PROPERTY FVL (one field replaces all fields related to real property damage) Real Property Flood Damage FVL Amount Residence Type Total Personal Property Assistance Approved Amount (Aggregated Eligibility Amount) Personal Property Assistance Flood Damage Approved Amount Total Repair Assistance Approved Amount (Aggregated Eligibility Amount) Repair Assistance Flood Damage Approval Amount Total Replacement Assistance Approved Amount (Aggregated Eligibility Amount) Use of Data by CDBG-DR Grantees to Prevent Duplication of Benefits This data sharing is for the purpose of determining individual benefit amounts for approved activities under a CDBG-DR action plan. This data sharing occurs after the allocation of HUD CDBG-DR grants, which historically has been six to 18 months after the disaster declaration. HUD will work directly with their CDBG-DR grantees to provide the specifications to FEMA for the data needed for the specific approved program(s). For example, most data requests from HUD to FEMA would indicate limiting criteria such as disaster survivor tenure (namely, homeowners for a homeowner rehabilitation program), geographic area the program will serve, and only those survivors receiving a specific type of FEMA benefit. FEMA will support HUD per the tenets of this CMA and provide the data described below for all survivors meeting the program requirements. This will expedite recovery for survivors, reduce duplication of benefits, and allow CDBG-DR grantees to determine benefits upon application because they have the FEMA assistance amounts immediately available to them. FEMA will perform data analysis and generate a file for HUD to provide to the CDBG- DR grantee describing each recipient meeting the specified approved program criteria in a datafile, as listed in Table 5 and Appendix C, and provide this data to HUD. FEMA does not receive any return data. HUD will provide the requested data on FEMA IHP assistance to the CDBG-DR grantee. The CDBG-DR grantee will match the FEMA assistance data to its list of grantee program applicants to determine what FEMA awards were received by its grantee program applicants. The CDBG-DR grantee has the responsibility to prevent the duplication of benefits using the data provided. For each grantee program applicant, the CDBG-DR grantee will use the amount of FEMA assistance received by that grantee program applicant to calculate the grantee program applicant’s unmet need and calculate a maximum award amount that will prevent duplication of benefits. This use of FEMA data is consistent with the original purpose of collection, as stated in the FEMA Disaster Recovery Assistance Files System of Records Routine Use H.1, 78 Fed. Reg. 25282 (April 30, 2013; Routine Use I.1 in the forthcoming update FEMA-008 Disaster Recovery Assistance Files System of Records). All data sharing between HUD and CDBG-DR grantees will be subject to separate agreements between HUD and the CDBG-DR grantees that address requirements related to the use and protection of the data. Table 5: Data Fields FEMA to Share with HUD Data Fields Alternate Current Contact Phone Number SBA Referral Flag (Y/N) Co-registrant Date of Birth Co-registrant First Name Co-registrant Last Name Co-registrant Last 4 Digits of SSN Current Contact Phone Number Current Location Current Mailing 5 Digit Zip Code Current Mailing Address City Current Mailing Address Street Current Mailing State Current Mailing Zip 4 Digit Extension Damaged Dwelling Address County Damaged Dwelling Latitude Damaged Dwelling Longitude Damaged Dwelling Address 5 Digit Zip Code Damaged Dwelling Address City Damaged Dwelling Address Street Data Fields Damaged Dwelling State Damaged Dwelling Zip Code 4 Digit Extension Dependents (Number in Household) Destroyed Flag (Y/N) Disaster Number FEMA Inspection Completed (Y/N) FEMA Registration Number Flood Zone Gross Income High Water Xxxx Location High Water Depth in Inches Household Member Age Household Member First Name Household Member Last Name Inspection Completion(Y/N) Insurance Settlement Flood Amount Insurance Settlement Other Amount Insurance Type (Insurance Code) NCOMP Flag (Y/N) Owner/Renter Personal Property Total FVL Amount (Aggregated for all PERSONAL PROPERTY FVL (one field replaces all fields related to personal property damage) Personal Property Flood Damage FVL Amount Primary Residence (RI) (Yes/No) Real Property Total FVL Amount (Aggregated for all REAL PROPERTY FVL (one field replaces all fields related to real property damage) Real Property Flood Damage FVL Amount Registrant Date of Birth Registrant First Name Registrant Last 4 Digits of SSN Registrant Last Name Residence Type Temporary Housing Unit (THU) – Latest Currently Licensed-in Date Data Fields Total Housing Assistance Approved Amount (Aggregated Eligibility Amount) Total Housing Assistance Approved Flood Damage Amount Total Other Assistance Approved Amount (Aggregated Eligibility Amount) Total Other Assistance Flood Damage Approved Amount Total Other Needs Assistance Approved Amount (Aggregated Eligibility Amount) Total Other Needs Assistance Flood Damage Approved Amount Total Personal Property Assistance Amount (Aggregated Eligibility Amount) Total Personal Property Assistance Flood Damage Amount Total Repair Assistance Approved Amount (Aggregated Eligibility Amount) Total Repair Assistance Flood Damage Amount Total Replacement Assistance Approved Amount (Aggregated Eligibility Amount)

DESCRIPTION OF THE DATA MATCH PROCESSES. When a Presidential declaration or emergency authorizes federal assistance to individuals and households under section Section 408 of the Xxxxxxxx Act, the sharing or matching of data will occur through one or more of the following three processes: (1) Emergency Sheltering and FEMA Housing Assistance Data Matching; (2) CDBG-DR grants allocation formulation Xxxxxx Allocation Formulation and CDBG-DR grantee planning Xxxxxxx Planning and marketingMarketing; and (3) CDBG-DR Grantee Xxxxxxx Data Matching. The three processes are described below. Emergency Sheltering and FEMA Housing Assistance Data Matching HUD rental assistance programs are identified at 24 C.F.R. § 5.233, emergency sheltering is authorized under sections Sections 403 or 502 (see above legal authorities), and FEMA housing assistance is provided through the Individuals and Households Program (IHP) under section Section 408(c) of the Xxxxxxxx XxxAct, 00 X.X.X. 42 U.S.C. § 0000(x5174(c). FEMA and HUD will compare and match data between the two agencies for HUD-assisted individuals receiving emergency sheltering (when section Section 408 has been authorized) or FEMA housing assistance using database queries that perform pattern analysis to establish a match. HUD will initiate the data sharing by providing information on pre-disaster HUD- assisted households within the geographic area designated in the declaration. FEMA and HUD will initiate the data matching by comparing names, addresses, dates of birth, and the last four digits of SSN. After confirmation of a definite match, FEMA and HUD will share the remaining data fields of the matched individuals to compare benefits and assess duplication of benefits and potential unmet needs. The data fields associated with this purpose are listed in Table 2, Table 3, and in Appendix A. This data sharing will be performed within the first 12 months of a new disaster declaration, and most of the data sharing will typically occur within the first 120 days of the event. Table 2: Data Fields HUD to Share with FEMA Data Fields Co-recipient First Name Co-recipient Last Name Co-recipient Date of Birth Co-recipient Last 4 digits Digits of SSN Recipient First Name Recipient Last Name Recipient Date of Birth Recipient Street Address Recipient State Recipient City Recipient County Recipient Address 5 Digit Zip Code Recipient Last 4 digits Digits of SSN Recipient Phone Number Household Member First Name Household Member Last Name Household Member Last 4 SSN Household Member Date of Birth Number of Household Members HUD Program Code* Data Fields PROGRAM TYPE H1 - Section 8 (Multifamily) H4 - Section 236 (Multifamily) H7 - 202/PRAC (Multifamily) H8 - 811/PRAC (Multifamily) P - Public Housing PBV - Project Based Voucher TBV - Tenant Based Voucher HV - Homeownership Voucher CE - Certificate MR - Mod Rehab HUD Rehoused (Y/N/ Unknown) Project Code HUD Project Code Name HUD Public Housing Agency (PHA) Code HUD Date of Recertification Table 3: IA Registrant Data Fields FEMA to Share with HUD Data Fields Access and Functional Needs (Y/N) Applicant Alternate Phone Number Applicant Current Phone Number Applicant Date of Birth Applicant Email Address Applicant Last, First Name Applicant Last 4 Digits of SSN Applicant Registration Number Co-applicant Date of Birth Co-applicant Last, First Name Co-applicant Last 4 digits Digits of SSN Co-applicant Current Phone Number Current Location (as identified in applicant registration and applicant information screen) Current Mailing Address 5 Digit Zip Code Current Mailing Address City Current Mailing Address County Current Mailing Address Street Current Mailing Address State Damaged Address City Damaged Address 5 Digit Zip Code Damaged Address Zip Code 4 Digit Extension Damaged Address County Damaged Address Street Damaged Address State Damaged Dwelling Latitude Data Fields Damaged Dwelling Longitude Disaster Number Household Member Age (Age range) 5 Under 5 years 5 to 17 years 18 to 64 years 65 and above Number of Individuals in Household Members Current Hotel Address Current Hotel City Current Hotel County Current Hotel Name Initial Rental Assistance Approved Unit Street Rental Unit City Rental Unit State Rental Unit Zip Code Current Location Date Data Fields Habitability Repairs Required (HRR) Direct Housing First Licensed-in Date (FEMA’s authority to allow an applicant to reside in a Direct Housing Unit) Last Continued Temporary Housing Assistance Date CDBG-DR grants allocation formulation Xxxxxx Allocation Formulation and CDBG-DR Grantee Xxxxxxx Planning and Marketing The FEMA data HUD requires to perform its CDBG-DR grants formulation will be generated by FEMA using a database query extracting all data elements listed in Table 4 and Table 5, and all IA registrant data in Appendix B. FEMA will extract every IA registration for each distinct FEMA disaster declaration HUD submits in their official request for data. HUD requires each FEMA IA registration to assess assistance funds provided by FEMA and SBA to calculate unmet needs. FEMA and SBA provide the unique FEMA application registration number, or Registration ID, to enable HUD to match FEMA data to SBA data. Matching FEMA and SBA data allows HUD to perform the unmet needs analysis using a one-to-one comparison of each individual housing unit. This analysis will not be used for determining individual benefits. HUD uses the FEMA inspection damage and award data to analyze and calculate unmet needs. This data is also used by HUD to generate their CDBG-DR formula allocations to inform OMB and Congress on the likely amount of unmet needs before OMB and Congress make their appropriation, and to determine allocation amounts for states, local governments, and Indian tribes after making an appropriation. The data shared with HUD will be utilized to identify damage estimates in major disaster areas. HUD XXX also considers the contributions of insurance, FEMA awards, and SBA loans in estimating severe unmet 5This data field will not determine eligibility for benefits. needs not addressed by these sources. The complete methodology by which HUD estimates unmet needs is published in a Federal Register Notice identifying allocations and establishing the requirements of CDBG-DR grants. HUD is required to allocate CDBG-DR funds to address unmet disaster-related needs in the most impacted and distressed areas after a major disaster. Since 2015, HUD has relied on case-level data from FEMA and SBA to make these allocations. HUD must calculate the unmet needs for renters’ and owners’ homes experiencing serious damage, where unmet needs are determined based on an individual household’s severity of damage, insurance coverage for the damage incurred, income, flood plain status, and likely SBA approval. To calculate, HUD must have information regarding the address, extent of damage, and insurance information. Unmet needs cannot be calculated from FEMA public use data. In addition, and as stated, HUD analysis will assess the data at the individual record level to factor in a combination of features for each disaster applicant to determine if if, and to what extent extent, each row of data will be included in the grant formulation structure. HUD XXX is responsible for performing the grant formulation process and must address any questions and issues raised by OMB and Congress. HUD publishes its grant formula allocations in the notice governing the use of grant funds. A recent example of the published allocation formula is found in Appendix A of the Federal Register Notice found here: xxxxx://xxx.xxxxxxx.xxx/content/pkg/FR-2020-01- 27/pdf/2020-01204.pdf. FEMA will use a database query, based on a list of distinct FEMA major disaster declaration numbers, that extracts all data elements listed in Table 4 and all registrant data in Appendix B to generate the CDBG-DR grants formulation data. HUD uses the FEMA Registration ID to map SBA and FEMA data to one registration. In addition, HUD applies repeatable programming code to factor in each distinct FEMA award data field in a single registration. In addition to the data in Table 4 FEMA will also share NFIP data in Table 5 to HUD for CDBG-DR xxxxxxx planning and marketing. HUD will provide a subset of the data it receives from FEMA for this purpose to the applicable CDBG-DR xxxxxxx along with the NFIP data so the CDBG-DR xxxxxxx can start planning and marketing the use of CDBG- DR funds. As flood insurance provided through the NFIP is not tracked by disaster numbers, FEMA will extract all NFIP policyholder data filtered by State connected to the “Date of Loss” and will provide the NFIP policyholder data to IHP from the geographical region associated with the disaster number. IHP will then provide NFIP and IA data to HUD. The CDBG-DR grantees will also use these the data for planning purposes to identify the likely gaps in assistance (such as unmet needs) and what types of CDBG-DR eligible activities are most likely to close those gaps in assistance. CDBG-DR grantees xxxxxxxx will also use these the data to market the planned assistance to FEMA-assisted individuals so that they are aware of the planned use of the CDBG-DR funds and how to seek CDBG-DR funded assistance. These uses will not involve matching with other data. CDBG-DR xxxxxxxx will agree to the terms of this CMA and sign the grantee signatory page in Appendix D before any data is shared from HUD to the CDBG-DR xxxxxxx. Table 4: IA Registrant Data Fields FEMA to Share with HUD Data Fields Small Business Administration (SBA) HAPP Referral Flag (Y/N) Census Block Group ID (if applicable) Damaged Address Street Damaged Address City Damaged Address County Damaged Address State Damaged Address 5 Digit Zip Code Damaged Address Zip Code 4 Digit Extension Damaged Dwelling Latitude Damaged Dwelling Longitude Cause(s) of Damage from Inspection Current Mailing Address 5 Digit Zip Code Current Mailing Address City Current Mailing Address Street Current Mailing State Current Mailing Zip Code 4 Digit Extension Applicant email Number of Individuals in Household Household Member Age (Age range)6 Under 5 years 65 and above Dependents (Number in Household) Destroyed Flag (Y/N) Disaster Number FEMA Registration Number Flood Zone High Water Xxxx Mark Location High Water Depth in inches Habitability Repairs Required (Y/N) Gross Income (as reported at Registration) Data Fields Insurance Types (Insurance Code) Level of Damage Non-Compliant with Flood Insurance Requirement (NCOMP) Flag (Y/N) Owner/Renter 6 This data field will not determine eligibility for benefits. Data Fields Personal Property Total FEMA Verified Loss (FVL) Amount Personal Property Flood Damage FVL amount Amount Real Property Total FVL Amount (Aggregated for all REAL PROPERTY FVL ([one field replaces all fields related to real property damage]) Real Property Flood Damage FVL Amount Residence Type Total Personal Property Assistance Approved Amount (Aggregated Eligibility Amount) Personal Property Assistance Flood Damage Approved Amount Total Repair Assistance Approved Amount (Aggregated Eligibility Amount) Repair Assistance Flood Damage Approval Amount Total Replacement Assistance Approved Amount (Aggregated Eligibility Amount) Use of Data by CDBG-DR Grantees to Prevent Duplication of Benefits This data sharing is for the purpose of determining individual benefit amounts for approved activities under a CDBG-DR action plan. This data sharing occurs after the allocation of HUD CDBG-DR grants, which historically has been six to 18 months after the disaster declaration. HUD will work directly with their CDBG-DR grantees to provide the specifications to FEMA for the data needed for the specific approved program(s). For example, most data requests from HUD to FEMA would indicate limiting criteria such as disaster survivor tenure (namely, homeowners for a homeowner rehabilitation program), geographic area the program will serve, and only those survivors receiving a specific type of FEMA benefit. FEMA will support HUD per the tenets of this CMA and provide the data described below for all survivors meeting the program requirements. This will expedite recovery for survivors, reduce duplication of benefits, and allow CDBG-DR grantees to determine benefits upon application because they have the FEMA assistance amounts immediately available to them. FEMA will perform data analysis and generate a file for HUD to provide to the CDBG- DR grantee describing each recipient meeting the specified approved program criteria in a datafile, as listed in Table 5 and Appendix C, and provide this data to HUD. FEMA does not receive any return data. HUD will provide the requested data on FEMA IHP assistance to the CDBG-DR grantee. The CDBG-DR grantee will match the FEMA assistance data to its list of grantee program applicants to determine what FEMA awards were received by its grantee program applicants. The CDBG-DR grantee has the responsibility to prevent the duplication of benefits using the data provided. For each grantee program applicant, the CDBG-DR grantee will use the amount of FEMA assistance received by that grantee program applicant to calculate the grantee program applicant’s unmet need and calculate a maximum award amount that will prevent duplication of benefits. This use of FEMA data is consistent with the original purpose of collection, as stated in the FEMA Disaster Recovery Assistance Files System of Records Routine Use H.1, 78 Fed. Reg. 25282 (April 30, 2013; Routine Use I.1 in the forthcoming update FEMA-008 Disaster Recovery Assistance Files System of Records). All data sharing between HUD and CDBG-DR grantees will be subject to separate agreements between HUD and the CDBG-DR grantees that address requirements related to the use and protection of the data. Table 5: NFIP Policyholder Data Fields FEMA to Share with HUD Data Fields Alternate Current Contact Phone Community Number SBA Referral Flag (Y/N) Co-registrant Community Name Policy Number Insurance Company Number Insurance Company Name Policy Holder First Name Policy Holder Last Name Insured Property Address 1 Insured Property Address 2 Insured Property City Insured Property State Insured Property Zip Code Insured Property Zip Code + 4 Occupancy Type Insured Property County Post FIRM Building Type Date of Birth Co-registrant First Name Co-registrant Last Name Co-registrant Last 4 Digits of SSN Current Contact Phone Number Current Location Current Mailing 5 Digit Zip Code Current Mailing Address City Current Mailing Address Street Current Mailing State Current Mailing Zip 4 Digit Extension Damaged Dwelling Address County Damaged Dwelling Latitude Damaged Dwelling Loss Building Payment Contents Payment ICC Payment Insured Building Longitude Damaged Dwelling Address 5 Digit Zip Code Damaged Dwelling Address City Damaged Dwelling Address Street Data Fields Damaged Dwelling State Damaged Dwelling Zip Code 4 Digit Extension Dependents Insured Building Latitude Geocode Accuracy Repetitive Loss (FMA) Severe Repetitive Loss (FMA) Repetitive Loss (NFIP) Severe Repetitive Loss (NFIP) Repetitive Loss Number in Household) Destroyed Flag (Y/N) Disaster Number FEMA Inspection Completed (Y/N) FEMA Registration Number Flood Zone Gross Income High Water Xxxx Location High Water Depth in Inches Household Member Age Household Member First Storm ID Storm Name Household Member Last Name Inspection Completion(Y/N) Insurance Settlement Flood Amount Insurance Settlement Other Amount Insurance Type (Insurance Code) NCOMP Flag (Y/N) Owner/Renter Personal Property Total FVL Amount (Aggregated for all PERSONAL PROPERTY FVL (one field replaces all fields related to personal property damage) Personal Property Flood Damage FVL Amount Primary Residence (RI) (Yes/No) Real Property Total FVL Amount (Aggregated for all REAL PROPERTY FVL (one field replaces all fields related to real property damage) Real Property Flood Damage FVL Amount Registrant Date of Birth Registrant First Name Registrant Last 4 Digits of SSN Registrant Last Name Residence Type Temporary Housing Unit (THU) – Latest Currently Licensed-in Date Data Fields Total Housing Assistance Approved Amount (Aggregated Eligibility Amount) Total Housing Assistance Approved Flood Damage Amount Total Other Assistance Approved Amount (Aggregated Eligibility Amount) Total Other Assistance Flood Damage Approved Amount Total Other Needs Assistance Approved Amount (Aggregated Eligibility Amount) Total Other Needs Assistance Flood Damage Approved Amount Total Personal Property Assistance Amount (Aggregated Eligibility Amount) Total Personal Property Assistance Flood Damage Amount Total Repair Assistance Approved Amount (Aggregated Eligibility Amount) Total Repair Assistance Flood Damage Amount Total Replacement Assistance Approved Amount (Aggregated Eligibility Amount)Refresh Date

DESCRIPTION OF THE DATA MATCH PROCESSES. When a Presidential declaration or emergency authorizes federal assistance to individuals and households under section 408 of the Xxxxxxxx Act, the sharing or matching of data will occur through the following three processes: (1) Emergency Sheltering and FEMA Housing Assistance Data Matching; (2) CDBG-DR grants allocation formulation and CDBG-DR grantee xxxxxxx planning and marketing; and (3) CDBG-DR Grantee Xxxxxxx Data Matching. The three processes are described below. Emergency Sheltering and FEMA Housing Assistance Data Matching HUD rental assistance programs are identified at 24 C.F.R. § 5.233, emergency sheltering is authorized under sections 403 or 502 (see above legal authorities), and FEMA housing assistance is provided through the Individuals and Households Program (IHP) under section 408(c) of the Xxxxxxxx Xxx, 00 X.X.X. § 0000(x). FEMA and HUD will compare and match data between the two agencies for HUD-assisted individuals receiving emergency sheltering (when section 408 has been authorized) or FEMA housing assistance using database queries that perform pattern analysis to establish a match. HUD will initiate the data sharing by providing information on pre-disaster HUD- assisted households within the geographic area designated in the declaration. FEMA and HUD will initiate the data matching by comparing names, addresses, dates of birth, and the last four digits of SSN. After confirmation of a definite match, FEMA and HUD will share the remaining data fields of the matched individuals to compare benefits and assess duplication of benefits and potential unmet needs. The data fields associated with this purpose are listed in Table 2, Table 3, and in Appendix A. This data sharing will be performed within the first 12 months of a new disaster declaration, and most of the data sharing will typically occur within the first 120 days of the event. Table 2: Data Fields HUD to Share with FEMA Data Fields Co-recipient First Name Co-recipient Last Name Co-recipient Date of Birth Co-recipient Last 4 digits of SSN Recipient First Name Recipient Last Name Recipient Date of Birth Recipient Street Address Recipient State Recipient City Recipient County Recipient Address 5 Digit Zip Code Recipient Last 4 digits of SSN Number of Household Members HUD Program Code* PROGRAM TYPE H1 - Section 8 (Multifamily) H4 - Section 236 (Multifamily) H7 - 202/PRAC (Multifamily) H8 - 811/PRAC (Multifamily) P - Public Housing PBV - Project Based Voucher TBV - Tenant Based Voucher HV - Homeownership Voucher CE - Certificate MR - Mod Rehab HUD Rehoused (Y/N/ Unknown) HUD Project Code HUD Public Housing Agency (PHA) Code HUD Date of Recertification Table 3: Data Fields FEMA to Share with HUD Data Fields Access and Functional Needs (Y/N) Applicant Alternate Phone Number Applicant Current Phone Number Applicant Date of Birth Applicant Email Address Applicant Last, First Name Applicant Last 4 Digits of SSN Applicant Registration Number Co-applicant Date of Birth Co-applicant Last, First Name Co-applicant Last 4 digits of SSN Co-applicant Current Phone Number Current Location (as identified in applicant registration and applicant information screen) Current Mailing Address 5 Digit Zip Code Current Mailing Address City Current Mailing Address County Current Mailing Address Street Current Mailing Address State Damaged Address City Damaged Address 5 Digit Zip Code Damaged Address Zip Code 4 Digit Extension Damaged Address County Damaged Address Street Damaged Address State Damaged Dwelling Latitude Damaged Dwelling Longitude Disaster Number Household Member Age (Age range) Under 5 years 5 to 17 years 18 to 64 years 65 and above Number of Household Members Current Hotel Address Current Hotel City Current Hotel County Current Hotel Name Initial Rental Assistance Approved Date Data Fields Direct Housing First Licensed-in Date (FEMA’s authority to allow an applicant to reside in a Direct Housing Unit) Last Continued Temporary Housing Assistance Date CDBG-DR grants allocation formulation and CDBG-DR Grantee Xxxxxxx Planning and Marketing The FEMA data HUD requires to perform its CDBG-DR grants formulation will be generated by FEMA using a database query extracting all data elements listed in Table 4 and Appendix B. FEMA will extract every registration for each distinct FEMA disaster declaration HUD submits in their official request for data. HUD requires each FEMA registration to assess assistance funds provided by FEMA and SBA to calculate unmet needs. FEMA and SBA provide the unique FEMA application registration number, or Registration ID, to enable HUD to match FEMA data to SBA data. Matching FEMA and SBA data allows HUD to perform the unmet needs analysis using a one-to-one comparison of each individual housing unit. This will not be used for determining individual benefits. HUD uses the FEMA inspection damage and award data to analyze and calculate unmet needs. This data is also used by HUD to generate their CDBG-DR formula allocations to inform OMB and Congress on the likely amount of unmet needs before OMB and Congress make their appropriation, and to determine allocation amounts for states, local governments, and Indian tribes after making an appropriation. The data shared with HUD will be utilized to identify damage estimates in major disaster areas. HUD XXX also considers the contributions of insurance, FEMA awards, and SBA loans in estimating severe unmet needs not addressed by these sources. The complete methodology by which HUD estimates unmet needs is published in a Federal Register Notice identifying allocations and establishing the requirements of CDBG-DR grants. HUD is required to allocate CDBG-DR funds to address unmet disaster-related needs in the most impacted and distressed areas after a major disaster. Since 2015, HUD has relied on case-level data from FEMA and SBA to make these allocations. HUD must calculate the unmet needs for renters’ and owners’ homes experiencing serious damage, where unmet needs are determined based on an individual household’s severity of damage, insurance coverage for the damage incurred, income, flood plain status, and likely SBA approval. To calculate, HUD must have information regarding the address, extent of damage, and insurance information. Unmet needs cannot be calculated from FEMA public use data. In addition, HUD analysis will assess the data at the individual record level to factor in a combination of features for each disaster applicant to determine if and to what extent each row of data will be included in the grant formulation structure. HUD XXX is responsible for performing the grant formulation process and must address any questions and issues raised by OMB and Congress. HUD publishes its grant formula allocations in the notice governing the use of grant funds. A recent example of the published allocation formula is found in Appendix A of the Federal Register Notice found here: xxxxx://xxx.xxxxxxx.xxx/content/pkg/FR-2020-01- 27/pdf/2020-01204.pdf. FEMA will use a database query, based on a list of distinct FEMA major disaster declaration numbers, that extracts all data elements listed in Table 4 and Appendix B to generate the CDBG-DR grants formulation data. HUD uses the FEMA Registration ID to map SBA and FEMA data to one registration. In addition, HUD applies repeatable programming code to factor in each distinct FEMA award data field in a single registration. CDBG-DR grantees xxxxxxxx will also use these data for planning purposes to identify the likely gaps in assistance (such as unmet needs) and what types of CDBG-DR eligible activities are most likely to close those gaps in assistance. CDBG-DR grantees xxxxxxxx will also use these data to market the planned assistance to FEMA-assisted individuals so that they are aware of the planned use of the CDBG-DR funds and how to seek CDBG-DR funded assistance. These uses will not involve matching with other data. Table 4: Data Fields FEMA to Share with HUD Data Fields Small Business Administration (SBA) HAPP Referral Flag (Y/N) Census Block Group ID (if applicable) Damaged Address Street Damaged Address City Damaged Address County Damaged Address State Damaged Address 5 Digit Zip Code Damaged Address Zip Code 4 Digit Extension Damaged Dwelling Latitude Damaged Dwelling Longitude Cause(s) of Damage from Inspection Current Mailing Address 5 Digit Zip Code Current Mailing Address City Current Mailing Address Street Current Mailing State Current Mailing Zip Code 4 Digit Extension Dependents (Number in Household) Destroyed Flag (Y/N) Disaster Number FEMA Registration Number Flood Zone High Water Xxxx Mark Location High Water Depth in inches Habitability Repairs Required (Y/N) Gross Income (as reported at Registration) Data Fields Insurance Types (Insurance Code) Level of Damage Non-Compliant with Flood Insurance Requirement (NCOMP) Flag (Y/N) Owner/Renter Personal Property Total FEMA Verified Loss (FVL) Amount Personal Property Flood Damage FVL amount Real Property Total FVL Amount (Aggregated for all REAL PROPERTY FVL (one field replaces all fields related to real property damage) Real Property Flood Damage FVL Amount Residence Type Total Personal Property Assistance Approved Amount (Aggregated Eligibility Amount) Personal Property Assistance Flood Damage Approved Amount Total Repair Assistance Approved Amount (Aggregated Eligibility Amount) Repair Assistance Flood Damage Approval Amount Total Replacement Assistance Approved Amount (Aggregated Eligibility Amount) Use of Data by CDBG-DR Grantees Xxxxxxxx to Prevent Duplication of Benefits This data sharing is for the purpose of determining individual benefit amounts for approved activities under a CDBG-DR action plan. This data sharing occurs after the allocation of HUD CDBG-DR grants, which historically has been six to 18 months after the disaster declaration. HUD will work directly with their CDBG-DR grantees to provide the specifications to FEMA for the data needed for the specific approved program(s). For example, most data requests from HUD to FEMA would indicate limiting criteria such as disaster survivor tenure (namely, homeowners for a homeowner rehabilitation program), geographic area the program will serve, and only those survivors receiving a specific type of FEMA benefit. FEMA will support HUD per the tenets of this CMA and provide the data described below for all survivors meeting the program requirements. This will expedite recovery for survivors, reduce duplication of benefits, and allow CDBG-DR grantees to determine benefits upon application because they have the FEMA assistance amounts immediately available to them. FEMA will perform data analysis and generate a file for HUD to provide to the CDBG- DR grantee xxxxxxx describing each recipient meeting the specified approved program criteria in a datafile, as listed in Table 5 and Appendix C, and provide this data to HUD. FEMA does not receive any return data. HUD will provide the requested data on FEMA IHP assistance to the CDBG-DR granteexxxxxxx. The CDBG-DR grantee xxxxxxx will match the FEMA assistance data to its list of grantee program applicants to determine what FEMA awards were received by its grantee program applicants. The CDBG-DR grantee xxxxxxx has the responsibility to prevent the duplication of benefits using the data provided. For each grantee program applicant, the CDBG-DR grantee xxxxxxx will use the amount of FEMA assistance received by that grantee program applicant to calculate the grantee program applicant’s unmet need and calculate a maximum award amount that will prevent duplication of benefits. This use of FEMA data is consistent with the original purpose of collection, as stated in the FEMA Disaster Recovery Assistance Files System of Records Routine Use H.1, 78 Fed. Reg. 25282 (April 30, 2013; Routine Use I.1 in the forthcoming update FEMA-008 Disaster Recovery Assistance Files System of Records). All data sharing between HUD and CDBG-DR grantees will be subject to separate agreements between HUD and the CDBG-DR grantees that address requirements related to the use and protection of the data. Table 5: Data Fields FEMA to Share with HUD Data Fields Alternate Current Contact Phone Number SBA Referral Flag (Y/N) Co-registrant Date of Birth Co-registrant First Name Co-registrant Last Name Co-registrant Last 4 Digits of SSN Current Contact Phone Number Current Location Current Mailing 5 Digit Zip Code Current Mailing Address City Current Mailing Address Street Current Mailing State Current Mailing Zip 4 Digit Extension Damaged Dwelling Address County Damaged Dwelling Latitude Damaged Dwelling Longitude Damaged Dwelling Address 5 Digit Zip Code Damaged Dwelling Address City Damaged Dwelling Address Street Data Fields Damaged Dwelling State Damaged Dwelling Zip Code 4 Digit Extension Dependents (Number in Household) Destroyed Flag (Y/N) Disaster Number FEMA Inspection Completed (Y/N) FEMA Registration Number Flood Zone Gross Income High Water Xxxx Mark Location High Water Depth in Inches Household Member Age Household Member First Name Household Member Last Name Inspection Completion(Y/N) Insurance Settlement Flood Amount Insurance Settlement Other Amount Insurance Type (Insurance Code) NCOMP Flag (Y/N) Owner/Renter Personal Property Total FVL Amount (Aggregated for all PERSONAL PROPERTY FVL (one field replaces all fields related to personal property damage) Personal Property Flood Damage FVL Amount Primary Residence (RI) (Yes/No) Real Property Total FVL Amount (Aggregated for all REAL PROPERTY FVL (one field replaces all fields related to real property damage) Real Property Flood Damage FVL Amount Registrant Date of Birth Registrant First Name Registrant Last 4 Digits of SSN Registrant Last Name Residence Type Temporary Housing Unit (THU) – Latest Currently Licensed-in Date Data Fields Total Housing Assistance Approved Amount (Aggregated Eligibility Amount) Total Housing Assistance Approved Flood Damage Amount Total Other Assistance Approved Amount (Aggregated Eligibility Amount) Total Other Assistance Flood Damage Approved Amount Total Other Needs Assistance Approved Amount (Aggregated Eligibility Amount) Total Other Needs Assistance Flood Damage Approved Amount Total Personal Property Assistance Amount (Aggregated Eligibility Amount) Total Personal Property Assistance Flood Damage Amount Total Repair Assistance Approved Amount (Aggregated Eligibility Amount) Total Repair Assistance Flood Damage Amount Total Replacement Assistance Approved Amount (Aggregated Eligibility Amount)