FY 2013 Small Area FMR Pilot PHA's Named.

Tuesday Federal Register will have notice. PHA's are: 

1. The Chattanooga (TN) Housing Authority
2. The Housing Authority of the City of Laredo (TX)
3. The Housing Authority of the City of Long Beach (CA)
4. The Housing Authority of the County of Cook (IL)
5. The Town of Mamaroneck (NY) Public Housing Agency

Originally created and posted on the Oregon Housing Blog.

It "Appears" That 4 Areas Added to HUD Small Area Rent Demo, None in Northwest.

In using HUD website HERE that allows users to lookup documentation for individual small area rents, I discovered that 4 additional areas APPEAR to be added to  Dallas in participating in the HUD small area demonstration. They are: 

1. Hartford, CT
2. Houston, TX
3. Milwaukee, WI
4. Oklahoma City, OK

For now "appear to " is the operative phrase, as the documentation for the small area rents for these areas is NOT included in Federal Register addendum as is the case for Dallas HERE.

Originally created and posted on the Oregon Housing Blog. 

One Oregon Example, HUD FY 2012 Fair Market Rents Will be LOWER than LIHTC Allowable Rents.

I thought it might be useful to compare HUD FY 2012 proposed FMR's to allowable Low Income Housing Tax Credit rents for an Oregon area with a substantial decreased in FMR's, so I chose Hood River County, which is slated for a 21.1% decrease in their 2 BR FMR.   

Using the formula for conversion of LIHTC income to LIHTC bedroom size formula that I snipped from HUD website (see first image pasted below), I prepared the table below (see second image) showing how HUD FMR's for FY 2012 would compare to the current LIHTC rent limits for Hood River County.

Two observations:

1. Except for 3 and 4 bedroom LIHTC units reserved for families at incomes of 50% or below, ALL Hood River LIHTC allowable rents are HIGHER than the HUD proposed FY 2012 Fair Market Rents.
2. LIHTC owners are required to rent to voucher holders, but NOT at a discount. IF the LIHTC allowable rent is at street rent levels this would mean that LIHTC owners could refuse voucher tenants unless the PHA authorized a higher exception rent (or the family makes up 100% of the difference between FMR and street rent). Granting higher exception rents would reduce the number of families that could be served with voucher funding at the new FMR's; paying higher rents than 30% of income defeats the affordability purpose of the voucher program. 
3. These FMR to LIHTC rent relationships may change when HUD publishes new income limits.  If incomes go up, this would only increase the gap between HUD FMR's and LIHTC allowable rents.

If anyone has any additional insights on the impact of proposed FMR's on LIHTC rents and LIHTC projects I ENCOURAGE YOU to add observations below this post or drop me an email. [I am by no means a LIHTC expert]. Ditto if there are calculation issues that you see.

Originally created and posted on the Oregon Housing Blog. 

CORRECTION HUD Fair Market Rents Coming Tomorrow.

Thanks to some feedback it is clear that my original calculations of FMR changes [80% of counties seeing decreases were OFF] big time. My BIG apologies. 

I am taking down previous post and MIS[observations]  and linked table and time permitting will put up a new one, I continue to encourage you to look for the FMR's tomorrow.

HUD has posted a PDF of proposed FMR's for FY 2012 with the Federal Register public inspection desk, and I have reposted to my webspace HERE (Oregon FMR's are on page 107); I expect official publication in the Federal Register tomorrow. 

Tomorrow or perhaps later today I expect HUD will publish FY2012 proposed FMR's in Excel format along with documentation about how FMR's were calculated for each metro area. I would look later at the HUD FMR web site for that information HERE.

Originally created and posted on the Oregon Housing Blog.

Rural Oregon Counties Received the Largest HUD 2 Bedroom Fair Market Rent Increases Over Last 15 Years.

I prepared an interesting table HERE that shows HUD 2 BR Fair Market Rent increases over the last year, the last 5 years, the last 10 years, and the last 15 years. (Actual FMR's for these years are also included in the one page table).

Rather surprisingly, rural Oregon counties had the highest rate of increase over the last 15 years, with sparsely populated Wheeler and Sherman counties receiving 106%/100% 2 BR. Fair Market Rent increases over that 15 year period.

Note that these Sherman and Wheeler county increases were DOUBLE the 50% increase recorded for the Portland metro area for the same time period. Marion and Polk counties had the lowest 15 year increase in 2 BR. FMR's @31%.

Originally created and posted on the Oregon Housing Blog.

Updated: My FY 2010 FMR Comments Are FIRST Posted on Regulations.gov, Supportive Comments Sought.

Added link at bottom to allow tracking of ALL future comments on the proposed FY 2010 FMR's...
----

I have posted the FIRST comment on HUD's Proposed Fair Market Rents for FY 2010.

That comment recommends use of an Excel spreadsheet format I created to publish future Fair Market rent annual changes so that it is easier to compare FMR's between areas and to also see $ and % changes for any area of interest. (My earlier post about the spreadsheet is HERE).

I would WELCOME supportive comments from anyone, including blog subscribers; it will take you less than 5 minutes to do so, I promise.

To do so
1.Go to the regulation.gov web page for this DOCKET HERE.
2, Choose from the top "Submit Comment"
3, In the text box to the right that appears add a comment that references mine; some variant of THIS:

I am writing in support of Comment made by Tom Cusack of the Oregon Housing Blog. (Document ID:HUD-2009-0100-0002 with attachment).

HUD publication of Fair Market Rents in an Excel format similar to what he has suggested WOULD greatly facilitate local review of proposed changes to HUD Fair Market Rents. A single spreadsheet with all market area data and comparisons would save time now spent by individuals in retrieving a variety of documents and doing a series of these calculations for different market areas. I encourage you to do so starting with the FY 2010 final FMR publication in October.

4. Add your name, organization, and then submit your comment.
5. Once you have submitted your comment will see a document ID at the top of the page--you may want to keep this as a record of the comment you submitted.

You can track all future comments on FY 2010 proposed FMR's HERE.

Originally created and posted on the Oregon Housing Blog.

Regulations.Gov Screws Up Docket # for Commenting on Proposed FY 2010 FMR's.

As of Tuesday 11 AM PDT, it appears to me that docket number provided by Federal Regulations.gov HERE (HUD-2008-0063) to comment on the proposed FY 2010 FMR's is WRONG--link refers back to comments made on LAST years FMR's. (The tip off is that there are already 6 pages of comments).

I would hold off commenting on FY 2010 Proposed FMR's until this clears up; otherwise you may end needing to make your comments twice.

Originally created and posted on the Oregon Housing Blog.

Formal HUD Proposed FY 2010 FMR's in Federal Register Today.

Link is HERE.

My Sunday blog post with Excel FY 2009-Proposed FY 2010 data and changes for 4,700+ areas is HERE.

Originally created and posted on the Oregon Housing Blog.

Compare FY 09 and Proposed FY 10 HUD Fair Market Rents and Changes for All 4,700+ Areas Nationwide.

The two things virtually all want to know when proposed HUD Fair Market Rents are published are:

1. "How much will the FMR change for X area
   
2. How does that compare to the change for other areas?"

After ALL of these years, it is amazing that HUD's PDR still does NOT directly publish data showing that change and allowing that comparison. (Maybe it's a "FMR envy" kind of thing?).

So....I took the same kind of data I used to construct the quick Oregon FMR rent comparison I did on Friday (HERE) and did a comparison of FY 2009 HUD FMR's with Proposed FY 2010 FMR's for ALL areas of the country--a total of 4,763 areas by my count.

You can find this complete NATIONWIDE listing of FY 2009 vs. Proposed FY 2010 HUD FMR's comparisons in the new Excel workbook HERE. (Read Tip 8 below to help you download/open this Excel 2007 formatted file).

This is the FIRST time I have ever seen a national spreadsheet that shows these direct FMR comparisons with the prior FMR year. Once the Proposed FMR's are published in the Federal Register I will make a formal comment that HUD use this kind of format in ALL future annual FMR comparisons. In a future blog post I will include a link to my Federal Register comment and also a link that will allow you to comment on the proposed FMR's. I will include supportive draft language that you can easily copy and paste into a comment that I encourage you to submit IF you like the comparisons that my Excel workbook permits.

Data Source: I added a HUD Region data field, a list order field, and the 09-10 change fields, but all other data was downloaded from HUD's FMR web page HERE.

Interesting Tidbits from the Data: (Comparing FY 2009 and Proposed FY 2010 FMR's):

• Biggest % INCREASE is 16% for Anne Arundel County, Baltimore County, Carroll County, Harford County, Howard County (ex. Columbia City),Queen Anne's County, Baltimore city in Maryland.
  
• Biggest % DECREASE is 6.6% for San Diego County in California.
  
• HIGHEST FY 2010 Proposed FMR is $1,800 for Darien, Greenwich, New Canaan, Norwalk, Stamford,Weston, Westport, Wilton in Fairfield County in Connecticut.
  
• LOWEST FY 2010 Proposed FMR is $399 for Adjuntas Municipio,Coamo Municipio, Culebra Municipio, Guánica Municipio, Guayanilla Municipio, Jayuya Municipio,Las Marías Municipio,Maricao Municipio, Peñuelas Municipio,Salinas Municipio,Santa Isabel Municipio, Utuado Municipio, Vieques Municipio, Yauco Municipio in Puerto Rico.
• Median FMR for FY 2009 was $643; the Proposed FY 2010 median FMR is $668, a 3.9% increase.
  

Tips for Using the Data:

1. DON"T just start printing the entire document, it's 100+ pages.
2. DO use the filtering arrows at the top of the columns to select the data of interest--I.E. Filter by state, or specific county etc.
3. Filtering can ALSO be used to select the HIGHEST or LOWEST FMR's or FMR changes, or FMR values higher than an input value etc.
4. Before you start filtering data, it is a good idea to copy worksheet and work with the copy so you still have the data in its original alpha by state/county order
5. Once you have filtered what you want you can then either try to print directly the filtered information OR copy and paste it into a new worksheet for more data analysis or organization.
6. It is easy to add a Pivot Table to the workbook for additional analysis.
7. Several geography columns are hidden to save space, you can use unhide command to reveal those columns, but width will be wider than legal sized paper.
8. The estimator is in Excel 2007 file format. Some users report when they save Excel 2007 files they end up with a compressed .zip file extension. My suggestion is to download and save the file to your pc. Find the downloaded file, and if necessary, change the .zip extension to Excel 2007 extension (.xlsx), and THEN open the file with Excel).

Originally created and posted on the Oregon Housing Blog.

HUD Publishes Proposed FY 2010 FMR's; Portland 2BR FMR Up $30.

HUD has published a notice of proposed Fair Market Rents for FY 2010, with Federal Register publication expected on August 4th.
Main page for FMR's is HERE.

A Quick Oregon Comparison Table.
I put together the table HERE to show Oregon comparisons of Final FY 2009 and PROPOSED FY 2010 FMR'S (table is legal sized paper, landscape orientation).

Some quick notes on 2 BR FMR changes I see:

1. Portland increases by 3.7% ($30) from $809 to $839.
2. Eugene decreases by .3% ($2) from $768 to $766.
3. Salem - no change.
4. Other counties, 2.7% to 2.9% increases, $17-$22.

Originally created and posted on the Oregon Housing Blog.