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Public Comments to Proposed FMR Methodology Changes

Jim Armstrong, Policy Analyst

On June 5, 2019, HUD published a Federal Register notice concerning proposed changes in the methods it used to estimate Fair Market Rents (FMRs). That proposal was discussed in the July 3 Advocate. Comments concerning the proposal were due July 5, and HUD received 28 comments through Regulations.gov by that date.

PHADA submitted comments that expressed general support for HUD’s efforts to (1) produce more accurate estimates of FMRs based on American Community Survey (ACS) data projected to the current year, and (2) produce FMR estimates that overcame year over year volatility that has characterized prior HUD estimates. The association also expressed concerns that (1) the notice failed to describe exactly the more local data HUD proposes to use or the geographic regions covered by that data, (2) that HUD would consider changing its methodology annually, raising uncertainties over FMR projections, and (3) that the notice failed to justify the application of SAFMR projections or the weighting practice HUD proposed. PHADA was also disappointed with the data HUD made available to justify its proposed changes. While the changes addressed year over year volatility, the data only presented differences between current year FMRs and hypothetical current year FMRs using proposed methodology changes. PHADA was also disappointed with the quality of HUD’s data which contained large numbers of duplicate entries tending to distort descriptive statistics for the data.

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