The proposed rule change would create a significant barrier to transgender people seeking shelter, many of whom are people with disabilities. Access to safe and secure housing is sometimes all that stands between transgender people and deadly violence. And people with disabilities already face high rates of chronic homelessness, heightened difficulty securing accessible shelter, and heightened risk from the COVID-19 global pandemic. The proposed rule change needlessly reinforces harmful stereotypes and promotes discrimination. Making these changes at a time when the country is facing its greatest public health crisis in over a century is unthinkably cruel. We strongly recommend that HUD completely withdraw the proposed rule change and instead focus on addressing longstanding housing barriers.