Comment on DOD-2009-OS-0090-DRAFT-0019

Concern with Criteria: The extended HAP is a great program for military members such as us who bought a home at or near the peak of home prices in 2005 and then received PCS orders at or near the low point of the housing crisis in 2009. In 2005 when we were looking for a home in the Virginia Beach/Norfolk area after receiving PCS orders from the Pentagon/Northern Virginia we coulld not find a suitable home for less than $700,000. We looked at over 75 homes and even the ones that we wouldn't even consider living in due to their condition or the neighborhood were going for $700,000.00 to $800,000.00 with very few available to select from to purchase and no base housing avalable unless we were willing to wait for over a year and then not guaranteed. The home that we have been trying to sell for the last five months was purchased for for well over the limit listed in the program of $458,850.00. Given what the housing market was in Virginia Beach City when we purchased in 2005, the current policy to use the Fannie Mae and Freddie Mac Maximum Loan Limits is unrealistic and doesn't paint a fair market picture of what was occurring at the time we purchased the home in 2005. Please take into consideration due to extenuating circumstances as outlined above the removal of the cap on the Maximum Home Purchase Price used in the eligibility criteria for HAP in 32 CFR Part 239 section 239.6.