The following comments were submitted to HUD on behalf of the LOFTE Network in opposition to the proposed changes to HUD's Mixed Status Rule. Individuals wishing to submit their own comments should do so at: https://www.regulations.gov/commenton/HUD-2026-0199-0001.

Dear Sir/Madam:

            These comments are submitted on behalf of the Leaders and Organizers for Tenant Empowerment (LOFTE) Network and the National Alliance of HUD Tenants (NAHT) in response to the U. S. Department of Housing and Urban Development’s (HUD) proposed rule.   We write to express our strong opposition to the changes proposed by HUD regarding “verification of eligible status,” as published in the Federal Register on February 26, 2026.

              As elaborated below, the rule will needlessly cause massive hardship, disruption and homelessness for tens of thousands of families, including 37,000 children who are US citizens; inconvenience and potentially displace tens of thousands of low income citizens unable to meet stringent new identification requirements; reduce the supply of affordable housing; and create administrative havoc for owners and agencies who administer assisted housing. 

            Formed in 2022, Leaders and Organizers for Tenant Empowerment (LOFTE) is a national tenants coalition representing 5.5 million families in privately-owned, federally-assisted multifamily housing.  LOFTE’s mission is to empower residents to save and improve their homes as affordable housing.  Since 1992, NAHT has been the national tenants’ membership union representing tenants in HUD-assisted multifamily housing. 

            HUD’s rule will harm U.S. citizens.  Contrary to HUD’s justifications, the proposed rule will mostly harm U.S. citizens. Of the 80,000  people in “mixed status” families, 37,000 are children who are U.S. citizens or legal residents, and thousands more are adult citizen partners of noncitizens targeted by the proposed rule; 70% of mixed status families consist of eligible children living with ineligible parents.  These children need an adult member of the household, including those who do not receive public assistance, to sign the lease so they can have a roof over their heads.  By forcing out ineligible adults, the proposed rule would put these families in an impossible dilemma—either break up to allow eligible children to continue receiving assistance, or forgo subsidies so that families can stay together.

             The rule will promote homelessness, family breakup and trauma.  The rule will promote family breakup, resulting in lifelong trauma and massive homelessness for tens of thousands of vulnerable HUD tenants.  The rule offers no estimate whatsoever of the long-term social costs of these policies, contrary to administrative requirements to weigh social costs and policy alternatives.    

            Indeed, this appears to be HUD’s intent.    According to HUD  regulatory analysis in the 2019 version of the proposed rule, “HUD expects that fear of the family being separated would lead to prompt evacuation by most mixed households.” That HUD is embracing fear as a tool of public policy is profoundly disturbing, and deeply un-American.  

              The rule will force owners to become extensions of ICE.  Furthermore, the rule in Section 5.508(d)(4) requires that owners and PHAs must ‘immediately report to DHS” any undocumented immigrant household member.  This would force owners and PHAs to collaborate in the Administration’s vicious, fear-inducing ICE deportation policy targeting low income people of color.  With ICE lurking at the door, identifying and forcing out immigrants from HUD housing will fuel the Administration’s deportation agenda, which has overwhelmingly affected law-abiding, hard working immigrants, with no criminal background whatsoever.  Only a tiny fraction of ICE victims have any criminal background, and vanishingly few, if any, of these are residents of HUD housing, where owners and PHAs already perform criminal background checks and screen out serious offenders.  

            HUD’s rule will increase costs and reduce affordable housing.  HUD’s proposed rule will worsen, not abate, the quantity and quality of the nation’s subsidized housing and reduce the number of families receiving assistance. Since mixed status families receive only a pro-rated portion of rent subsidies in their units for eligible tenants only, and therefore pay more in rent, replacing them with families who are entirely eligible will cost more in federal subsidies.  Section 5.4.2 of HUD’s Regulatory Impact Analysis estimates that maintaining current coverage levels would require $311 to $385 million in additional appropriations each year.  HUD does not request these appropriations and does not propose to address this gap.   

             Acccordingly, the number of assisted households overall would decline by at least 55,000.  HUD further acknowledges that the proposed rule would reduce the “maintenance of the units and possibly <lead to> deterioration of the units that could lead to vacancy,” due to the shortfall of funds, as well as discourage landlords from accepting Section 8 vouchers. 

           HUD’s analysis does refer to a cost to local governments of $20,000 to $50,000 per person for people displaced by the proposed rule, but notes in Section 7.2 that this cost ‘would decrease if any of the displaced families were displaced from the United States”—the evident ‘solution’ to the problem of mixed status families that the Administration contemplates with this proposed rule. 

            HUD should seek more funds for affordable housing.      HUD has suggested that the proposed rule will abate the waiting list crisis faced by many owners and Public Housing Agencies nationwide, in effect scapegoating mixed status immigrant families for the nation’s housing crisis.  This explanation is presented to mask the Administration’s coordinated overall strategy to attack, demonize, exclude and punish immigrant families, in particular immigrants from predominantly black or brown countries. 

            We share the concern about lengthy wait lists and the need for housing.  The answer is to advocate for funding increases from Congress, not scapegoat HUD’s most vulnerable children and families and fueling divisive anti-immigrant sentiment.  

            The rule will needlessly burden housing providers and 9.5 million low income citizens.  The 37,000 US citizen children who face homelessness with HUD’s rule are not the only US citizens and legal residents who will be harmed.  The proposed rule creates a new “red tape” requirement for all 9.5 million tenants currently receiving HUD assistance, and all tenants that will seek benefits in the future, by requiring “proof of citizenship” as a condition of receiving assistance. 

            As with states seeking to impose similar punitive requirements as a condition of voting, this will create extreme hardship for older segments of the population.  A 2006 Brennan Center study, “Citizens without Proof,” found that at least 12% of citizens earning less than $25,000 a year do not have proof of citizenship; 18% of citizens over 65 do not have a photo ID; and 25% of African American citizens lack a photo ID.  Older individuals often face challenges in getting this kind of documentation, including difficulty in getting government offices to replace lost records, coming up with the funds for replacement, and some who may have never been issued a birth certificate in the first place.  It is well known in the Deep South, for example, that African-American births were routinely not recorded by many local governments prior to the civil rights movement.

            If HUD”s rule were implemented, tens of thousands of US citizens unable to produce the required documents in the specified time frame under the rule, could needlessly lose their housing assistance, be evicted and made homeless.  What is the point of imposing this ridiculous and administratively burdensome requirement on millions of low income citizens and property management companies? 

            HUD’s rule will undermine trust within our communities.  Moreover, HUD’s proposed rule will undermine housing communities and wreak administrative havoc among owners and public housing agencies charged with implementation.  Local managers will be forced to evict long-time tenants in good standing in the communities they administer.  The trauma of separating families at the household level and/or evicting family members will echo throughout the properties.  Friends, neighbors and social networks will be disrupted, affecting the social and community environment.

            In particular, the DHS reporting requirement in the proposed rule will undermine the trust between tenants and owners that is fundamental to effective property management and community-building.  If residents believe that disclosing family composition to their property manager may result in a referral to ICE and arrest and deportation of family members, they may withhold information or seek to conceal potential victims.

             Most on-site property managers will not welcome the new unfunded mandate to tear apart and evict children and their families; implementation will be difficult and traumatic for many of them, as well.  Carrying out evictions which will be perceived as unjust by the community will undermine the trust and respect which on-site managers need to perform their role.  

            The proposed rule imposes unfunded mandates and administrative burdens on managers.  The proposed rule would impose impossible new administrative burdens on property managers who are not trained to assess citizenship status, forcing them to become extensions of the ICE deportation machine.  Owners would moreover be forced to absorb these costs, with no reimbursement for the additional administrative costs.           

               HUD’s rule violates the law.  HUD’s proposed rule also violates the law.  It directly conflicts with Section 214 of the Housing and Community Development Act of 1980, which limits access to federally subsidized housing programs to U.S. citizens and a specific list of non-citizen, legal resident categories.  Section 214 clearly states Congress’ intention to ensure that individuals with eligible immigration status would receive assistance, as well as keeping mixed status families together in their homes. 

             By discriminating against vulnerable children, the elderly, and protected class racial and ethnic groups, the proposed rule also profoundly violates the Fair Housing Act and HUD’s affirmative duty to promote Fair Housing.  The proposed rule also directly conflicts with federal policy prioritizing ending homelessness, as declared by the U.S. Interagency Council on Homelessness.   

              HUD’s proposed rule is cut from the same cloth as the unconscionable policies of terrorizing our communities with masked federal agents, arresting and deporting long-time residents, separating children from their parents, caging them in unspeakable conditions, and traumatizing them for life. 

            We urge HUD to withdraw this proposal now.  It is immoral, illegal, unnecessary and cruel.  Instead, HUD should dedicate its efforts to policies and funding that strengthen, not undermine, the availability of housing assistance to all who need it, including both U.S. citizen and mixed-status immigrant families. 

For release: April 7, 2026

Contact: Michael Kane  617-233-1885       

[email protected]

HUD tenants from across the US today demanded that Congress reject President Trump’s proposal to cut $10.7 billion, or 13%, from HUD housing programs.   Overall, Trump proposes to decrease spending on domestic needs by $73 billion, while shifting discretionary funds to expanded ICE operations and the Pentagon.  The Pentagon is slated to receive $1.5 trillion, a 50% increase over current levels, in Trump’s budget plan. 

For HUD, Trump proposes to cut $3.3 billion from Community Development Block Grants and $1.1 billion in HOME Grants to cities, as well as ‘zeroing out’ funds for Fair Housing and Housing Counseling Grants and Housing for People with AIDS.  “We urge Congress to reject Trump’s budget proposals and instead invest in housing and other human needs,’ says Mari Temmer from the Big Thompson Manor II Tenants Union in Loveland, Colorado and a Board Member-Elect to the National Alliance of HUD Tenants (NAHT). “There is no part of the US not facing an acute shortage of housing affordable to poor and working people and the elderly.  Our communities desperately need more, not less, funds for affordable housing.”

Last year, Congress rejected Trump’s proposed abolition of Section 8 and Public Housing, to be replaced by Block Grants to the States with 44% less funding.  Instead, Section 8 was increased by $7 billion to keep up with inflation.  

For 2027, the Administration proposes to ‘level fund’ Section 8 and Public Housing Operating funds.  But level funding will effectively cut people off the program, unless subsidies increase to keep up with rent inflation.  Already, funds for FY 2026, have fallen short by more than $700 million dollars, causing housing authorities to freeze wait lists and trim Voucher rolls.  HUD’s 2027 proposal would make the freeze permanent and allow time limits and work requirements for housing assistance, subject to rule-making by HUD.   

“Only one in four people like me who need federal rent assistance can get it today—a major cause of the nation’s housing and homelessness crisis,” says Venus Little, President of the Tyler House Tenants Association in Washington, DC and Vice President of NAHT.  Adds Alice Robinson, a Voucher tenant, Executive Director of Vision for Families in Dallas and Board member of the Texas Tenants Union, “I’ve been homeless before, and don’t want to be homeless again.  We need more, not less, Section 8 assistance to meet the nation’s housing needs.” 

The proposed $73 billion cuts to domestic programs are in addition to the $1.5 trillion in 10 year cuts to programs such as Medicaid and SNAP already voted by Congressional Republicans, to pay for an extension of $5.5 trillion in tax cuts to mostly high income individuals. 

“Public dollars should reflect housing and other basic needs, not shift funds to ICE prisons and an expanded war budget,” said Felicia Alston-Singleton, a public housing leader from the Greater Newark HUD Tenant Coalition and Co-Chair of Leaders and Organizers for Tenant Empowerment (LOFTE).  “We urge Congress to reject these harmful cuts and instead invest in housing, dignity and opportunity for all.”

Formed in 2022, Leaders and Organizers for Tenant Empowerment (LOFTE) is the national tenants organization representing 5.5 million families in privately-owned, federally-assisted multifamily housing.  LOFTE’s mission is to empower residents to save and improve their homes as affordable housing.  NAHT is the national tenant’s union representing tenants in HUD assisted housing.

In February, at the direction of Trump and Secretary Scott Turner, HUD proposed three disastrous new rules that would leave tens of thousands of families homeless and burden the lives of millions more. These proposals would:

1) Eliminate the 30-day notice requirement for nonpayment evictions in HUD housing;

2) Allow owners to impose a two-year time limit in HUD housing, and 40-hour work requirements, on all “work-eligible” HUD tenants, including in households with disabled members; and

3) Repeal the Mixed-Status Rule that allows immigrants to stay with eligible family members in HUD housing, with reduced federal assistance

All proposals have been released to the public for an initial 60-day comment period, each with its own set of deadlines. HUD tenants, tenant organizers, and advocates have a chance to submit comments opposing these changes.

HUD tenants and allies united to defeat similar proposals in 2017, during the first Trump administration. We can do it again! HUD tenants must organize, and unite, to defeat all three proposed rules!

Take Action NOW to oppose Fast-Tracked Evictions, Time Limits, Work Requirements, and Separation of Immigrant Families!!

Submit separate comments to HUD opposing each of the THREE proposals.

Repeal of the Mixed-Status Rule. This proposal, would end the ability of families with mixed immigration status to stay together in HUD housing while receiving prorated (less) housing assistance. Part of the administration’s broader anti-immigrant agenda, the rule would force families to choose between keeping their family together, or keeping their housing. The deadline for comments on this proposal is April 21st, 2026. Tenants and allies can submit comments opposing the rule using the guides prepared by the Keep Families Together Coalition or have them submit your comment anonymously on your behalf here. Find more information on the effects of the proposal at the NLIHC press release here.

Repeal of 30-Day Notice Requirement. Currently, owners and PHAs are federally required to give at least 30-days’ notice before moving to evict tenants for nonpayment of rent. The proposal would revoke that requirement, and allow owners to evict tenants in as little as 3-5 days, depending on the state. The deadline for comments on this proposal is April 27th, 2026. Tenants and allies can submit comments opposing the rule using the regulations.gov website here. Find more information on the NLIHC website here.

Work Requirements and Two-Year Term Limits. This proposal would allow owners and PHAs to force able-bodied adults in HUD housing to work up to 40 hours / week or risk losing their housing. Additionally, the rule would allow owners to set limits on the amount of time tenants can stay in HUD housing, with a minimum of two years for any “non-elderly, non-disabled” household. Additional, burdensome reporting requirements and limits on assistance will lead to many families having their assistance abruptly terminated, and turn them out on the streets. Leaving to owners decisions about who must report on their working hours in order to keep their home, and how long they can keep it, creates opportunities for severe discrimination. The deadline for comments on this proposal is May 1st, 2026. Tenants and allies can submit comments opposing the rule at the regulations.gov website here. Find state-by-state data here, or more information on the NLIHC website here or the NHLP website here.

Line up tenant leaders for quotes in local media stories about the proposals.

Issue a press release and call local media, to make tenant voices heard! Supplement your message with data on HUD Housing in your state from this state-by-state guide.

Start a social media campaign.

Post your messages to Facebook, Twitter and other social media. Keep Families Together has prepared a social media toolkit and other communications materials on their website. Find your elected officials’ social media handles here. Organize Instagram or Facebook users to post on the same day or in a specific time window using the same hashtag to get your topic “trending”.

Distribute this action alert to tenants, allies, and even OWNERS.

Most of these proposals, if implemented, will cost management and owners major time, money, and staff capacity. They have a stake in fighting back against these proposals alongside tenants! Find any allies you can, including your neighbors, your tenant association, your Local Housing Authority, and your management company and/or owner, and start reaching out now!

Stay tuned for more talking points and comment guides.

If you’re ready to raise your voice and submit your comments opposing the rules, do so as soon as you can! If you need a little more support, the LOFTE Network will release example comments, talking points to mention in your comments, and more resources surrounding each rule as we get closer to their respective deadlines. Email [email protected] to request to be added to the mailing list!

Attend the monthly LOFTE calls, the first Friday of each month at 2pm.

Email [email protected] to receive the meeting invitation and other important updates.

We are happy for our allies at the Metropolitan Tenants organization for continuing their efforts to help tenants realize their collective power. And congratulation to the tenants for organizing a tenant union and raising concerns about the poor conditions. Tenant organizing isn't always easy but this is proof that it can achieve positive results.

Following a meeting with representatives from the Department of Housing and Urban Development on December 5, 2025, LOFTE advocates successfully won updates from HUD about their current staff members and regulations, as well as a list of Millennium Properties that are under Abatement and Receivership. 

After meeting with advocates, LOFTE was updated on the standing of the anti-harassment rules and enforcement at HUD. Although HUD regulations prohibiting harassment are still in place, HUD's Fair Housing and Equal Opportunity branch was decimated by DOGE, meaning that there are far fewer staff to handle complaints. 

HUD also clarified the timeline of long-awaited HOTMA regulations, which would change how income is calculated for Section-8 tenants. Currently, tenants in Section 8 housing must submit six months' worth of bank statements to management to certify their income. HOTMA would reduce this requirement to just one month. The implementation of these regulations is now delayed to January 2027, but HUD is still encouraging management and owners to abide by the one-month policy that will eventually be used.

HUD also sent LOFTE its staff locator list, which is no longer readily available on the HUD website after being removed DOGE. Organizers and tenants can access the link here: https://www.hud.gov/hud-partners/multifamily-regions#mfproperties.

Finally, LOFTE also received confirmation about which Millenia properties are in Abatement and receivership. Below is the list of properties and their current status:

Properties in Abatement:

Properties in Receivership: 

LOFTE will continue to fight for transparency from HUD, in these efforts and more, to support the most vulnerable among us.

You can view a recording of the meeting with HUD tenants and LOFTE here, and the notes from the meeting here. 

Tenants at Hickory View Apartment in North Little Rock came together on July 17th to vent their frustrations with deteriorating living conditions. These meeting were organized by Arkansas Community Organizations and Arkansas Renters United who have worked with tenants to get HUD's attention to address these issues. Among the issue are mold, water leaks, and crumbling infrastructure.

"I've been working with Hattie Temple and other tenants for years, and it's still the problems aren't being addressed," said Neal Sealy with Arkansas Community Organizations and Arkansas Renters United". Neal had been a prominent member of LOFTE in connecting tenants to HUD and fighting the federal budget cuts.

You can learn more about this in the 2 articles:

https://www.thv11.com/article/news/community/north-little-rock-tenants-unsafe-living-conditions/91-540e0055-e23f-4042-bdb4-859a23d77395

https://www.arkansasonline.com/news/2025/jul/17/central-arkansas-protesters-target-housing/

Today LOFTE members in Boston lead a rally outside the Massachusetts GOP Headquarters ahead of the July 14th vote. Around 50 people showed up to deliver a letter to Amy Carnavale, Chair of the State GOP, demanding they repudiate the cuts to medicaid, SNAP, HUD housing, and other programs. During the rally we ran into the executive director of the Mass GOP John Milligan. He was too busy to talk at that moment but he took at copy of the letter and promised to read it. There was an article in a local paper reporting on the rally and the potential cuts.

On June 11th members from Arkansas Community Organization, who has been a dedicated group in the LOFTE Network rallied to urge their senators to vote against Trump's "Big Beautiful Bill". The bill would be devastating to low income tenants across the United States, cutting funding to SNAP, Medicaid, and HUD housing. The small but vocal group was able to get some press:

https://www.kark.com/news/state-news/arkansans-getting-government-assistance-ask-senators-to-vote-down-big-beautiful-bill/

https://katv.com/news/local/members-of-arkansas-community-organizations-express-concern-as-federal-aid-cuts-loom-katv-news-share-community-assist-big-beautiful-bill-cost-cutting#

https://www.thv11.com/article/news/local/arkansas-advocacy-organization-pushes-back-on-snap-medicaid-cuts/91-37cb58f5-c23a-45e3-8e71-baffbf4b177b

Our members in Arkansas plan to continue to speak out and do what they can to appeal to their senators ahead of the July 14th vote. 

Leaders and Organizers for Tenant Empowerment

42 Seaverns Avenue/Jamaica Plain/MA/02130 * 617-522-5133 * lofte.ne[email protected] 

HUD Tenants Demand Congress Reject Trump’s “Dangerous” Plan to Slash HUD Rental Assistance by 44%

For release: May 9, 2025

Contact: Michael Kane  

617-233-1885  [email protected]

HUD housing tenants from across the US today demanded immediate rejection by Congress of President Donald Trump’s extremist proposal to slash HUD rental assistance by $27 billion, 44% below current levels, and impose a two year time limit for how long ‘able-bodied’ renters could receive assistance.  The proposed “deep cuts” affect every form of housing assistance, including Project Based Section 8, Section 8 Vouchers, Public Housing, and Elderly and Handicapped Housing.

The cuts were detailed in Trump’s “skinny” budget proposal released on May 2^nd, 2025, alongside catastrophic cuts to Health and Human Services, Environment and other programs, in order to pay for massive tax cuts to millionaires and billionaires

The budget is not yet final.  Trump is expected to file a more detailed budget request for 2026 later this spring.  Congress would then have to approve it to go into effect, as soon as October 1, 2025.  

The two-year time limit would force millions of able-bodied, low income working renters out on the street.  “If this present administration takes my housing voucher away, my daughter and I will be homeless.  It’s that simple,” says Desi Lou, 65, of Empower DC in Washington, DC.  “Trump’s proposal would snatch away the livelihoods of some of the very people who voted him into office.”

 “This isn’t just policy—it’s punishment,” said Alice Robinson, a Voucher tenant, Executive Director of Vision for Families in Dallas, and board member of the Texas Tenants Union.  “You cannot gut HUD, cut staff by nearly half, slash fair housing enforcement, and then say you care about American families.”

“Replacing Section 8 with Block Grants will devastate already underserved communities. Families, seniors, and people with disabilities will be pushed further into poverty, segregation will surge, and the very promise of equal opportunity will be stripped away.”

Adds Robinson, “I’ve been homeless before, and don’t want to be homeless again.  We urge Congress to listen to the people and reject this dangerous and inhumane proposal.”

“These HUD cuts will negatively impact people like me who live in an aging complex in dire need of repairs,” says Filian Ferguson-Rivers of Hillcrest Towers in Fayetteville, Arkansas. Fillian is a member of Arkansas Renters United. “I want to live with some peace of mind that the programs I rely on to stay housed are going to continue existing for me and my neighbors "

“Only one in four people like me who need federal rent assistance can get it today—a major cause of homelessness,” says Eric Colin-Smith, a disabled, elderly Voucher tenant in Boston, Massachusetts.   Adds Charlotte Rodgers, a long-time Brooklyn tenant leader and co-founder of the Leaders and Organizers for Tenant Empowerment (LOFTE) Network, “We need more, not less, Section 8 assistance to meet peoples housing needs.” 

The proposed cuts come in the wake of DOGE plans to reduce HUD staff by 48%, including 50% of Public Housing staff who administer Section 8 and Public Housing programs, and a 77% cut to HUDs Fair Housing enforcement staff.  One result will be a spike in racial and economic segregation as both Vouchers and HUD’s enforcement capacity are slashed.  

In 2018 and 2019, then OMB Director Russell Vought, who has now returned to his previous OMB role, proposed to phase out all federal rent subsidies for 9 million extremely low income people over 10 years, starting with a rent increase from 30 to 35% of income for rent—an immediate 22% rent hike in the first year.   Tenants and allies were able to defeat these cuts with bipartisan support on Capitol Hill. 

“Vought’s latest proposal is even more extreme,” comments LOFTE Co-Chair Michael Kane, a long-time housing advocate in Boston. “Replacing all HUD rental assistance with 44% less money and a two year time limit,  would force States, housing authorities and owners to displace millions from their homes within the first two years—not over 10 years.”

Kane noted that converting federal programs into Block Grants to local governments, at reduced funding levels, is a favorite nostrum of far right opponents of social programs since the 1970’s. “Block grants mask funding cuts and shift blame onto local governments and owners and away from federal elected officials when the inevitable cutbacks occur,” adds Kane.   

The proposed Section 8 cuts are in addition to the $1.5 trillion in 10 year cuts to programs such as Medicaid and SNAP already voted by Congressional Republicans, to pay for an extension of $5.5 trillion in tax cuts to the rich, which are set to expire this year.  

“Trump’s Section 8 proposal is a recipe of inequality, segregation, and crime against the most vulnerable.  If adopted, it would increase homelessness and poverty across the US.   It will only make the billionaire class richer, at the expense of the working class,” said Yanira Cortes, a Voucher tenant in Ocean County, New Jersey, and a leader in the Greater Newark HUD Tenant Coalition.  “We demand Congress reject this proposal.” 

Formed in 2022, Leaders and Organizers for Tenant Empowerment (LOFTE) is the national tenants organization representing 5.5 million families in privately-owned, federally-assisted multifamily housing.  LOFTE’s mission is to empower residents to save and improve their homes as affordable housing.

HUD Tenants Demand Congress Reject Trump’s Plan to Replace 2.3 Million Section 8 Vouchers with Block Grant

For release:  April 24, 2025

Contact:    Michael Kane  617-233-1885    [email protected]