Comment: A hold-harmless policy, independent of the income limits in Section 8, cannot be applied without a change in the law to the Department of Finance`s tax liability program. According to one commentator, allowing income limits from one year to the next would create problems in some countries, including confusion and dissatisfaction among potential buyers and the administrative burden on public authorities. In addition, according to the commentator, Section 143(f) of the IRC specifies that the limitation of 115% of the income of mortgagors under the MRB programme is based on the average gross income of the area, taking into account the provisions of section 8 of the Data Protection Act 1937. Therefore, a Hold Harmless policy, independent of the income limits set out in point 8, cannot be applied to the MRB program without a change in the law. HUD RESPONSE: HUD doesn`t think a regulatory change is needed to implement a Hold Harmless policy for home rents. Currently, municipalities have a well-established and well-known rental structure, used by government officials, supporters, developers, lenders, and potential tenants. For example, anyone who wants to know what the maximum rents are in a new york tax credit project can go to a number of websites or go to city officials and find out easily. However, for many years, without a harmless policy, tax credits (as well as HOME or other locally supported projects) may require a number of different rents. A large number of rental structures would impede municipalities` efforts to accurately assess the nature of their stock and who it serves or describe their efforts to the public. In addition, agencies that use consolidated individual waiting lists would find it difficult to take into account real estate of different rent levels. In November 20095, CHPC engaged in the fight to end its security policy proposed by HUD5 and submitted written comments recommending that hud continue with the directive. We have identified six main reasons why it is a good idea to keep the Hold Directive unscathed. In February 2003, after 2000 census data led to a decline in revenue estimates for many metropolitan areas, HUD was forced to implement its security policy to protect affordable housing owners and managers from declining rental incomes.

As part of this policy, income ceilings have remained at the previously published level in regions where the estimate of the Median Land Income Rate has been lowered. In addition, the income ceilings of the Directive would not increase until income estimates reach the previously published limit. . . .