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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Section 888

Citation
Section 888
Parent Document
Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)
Effective Date
2017-12-23

Other Sections in This Document (99)

Full Text

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Although SAFMRs are a recent innovation, HUD recognized the shortcomings of FMR schedules based on metropolitan area-wide, rather than more localized, rent levels as early as 1977. See Comptroller Gen. of the U.S., CED-77-19, Major Changes Are Needed In The New Leased-housing Program 21 (1977) ("HUD's decision to prepare single FMR schedules for entire SMSAs [Standard Metropolitan Statistical Areas] or for counties grouped into areas totaling 250,000 population is questionable. This approach ignores important distinctions between metropolitan central cities and suburban areas as well as among suburban areas within SMSAs, and it does not adequately consider the economic and demographic differences among non-SMSA counties. For example, the San Francis co-Oakland, California, SMSA had identical FMRs for the counties of Alameda, Contra Costa, Marin, San Francisco, and San Mateo. HUD field office officials said that each of these counties' actual market rents could vary by 30 to 40 percent.").