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A recent memorandum issued by Acting General Counsel Tonya Robinson clarified that certain noncitizens who are “battered or subject to extreme cruelty” by a spouse or parent who is a U.S. citizen or lawful permanent resident (LPR) has the right to apply for and receive housing assistance under Section 214 of the Housing and Community Development Act of 1980. Section 214 covers public housing, Section 8 tenant-based and project-based rental assistance, Rent Supplement, Flexible Subsidy, and Section 221d(3) Below Market Interest Rate Programs.