Comment Submitted by Great Plains Housing Authority
AnonymousSupportIndividual
Summary: The commenter supports the proposed action but suggests specific methodology changes for calculating Fair Market Rents (FMRs) and inflation factors. They argue that HUD should use a 40% income level to determine FMRs and utilize the larger of Per Unit Costs or income change percentages for inflation adjustments.
The voucher program is income based, and that is how the FMRs and inflation should calculate. HUD should use 40% income level to determine the FMR. If the income level goes down, the current clients stay at that level until the 40% FMR catches up. Use the largest allowed member size per bedroom for the voucher size... 2 people per room. HUD, IRS, Labor Department, and others receive regular updates on incomes.
Rents and local inflation are rarely accurate in American Community Survey (ACS) data. States and cities do not require rental reporting.
RFIF (Inflation) should use the larger of Per Unit Costs in the last year or income change percentage.