Comment on DOD-2009-OS-0090-DRAFT-0060

With regard to Section 239.6. (3) "Maximum Home Purchase Price Eligibility", the interim rule states "The PFMV may not exceed an amount equal to the 2009 Fannie Mae/Freddie Mac conforming loan limits. These conforming loan limits range from $417,000 to $729,500. They apply for the duration of the Expanded HAP and are established for each city/county/parish as appropriate." I respectfully request a review and adjustment be done with regard to the values issued for individual counties under the Fannie Mae/Freddie Mac conforming loan limits. The final rule needs to take into account a different bench mark other than Fannie Mae/Freddie Mac numbers. DoD and HAP need to use active duty military housing allowances (BAH) as the standard to which to determine the house cap for eligibility. Military housing allowances are pegged to a certain standard of living assessment per zip code and metro area. Areas such as Miami, San Diego, and Washington DC are allowed higher BAH rates than would be more rural and less populated areas. Yet DoD uses Fannie Mae/Freddie Mac limits which don't match these geographic areas proportionally to established BAH rates. How does Miami-Dade county in the state of Florida which has a Fannie Mae limit of $423,750 when BAH rates for an O-3 is set at $2,268 per month. How does that account and proportionally equate to a value in Fairfax county, Virginia which Fannie Mae established at $729,750 but BAH is set at $2,433 under the same scenario. They are not mathmatically proportional. Bottom line...if a Navy LT in Miami is getting $2,268 per month for housing and is PCS'd to Washington, DC and recieves $2,433 in BAH, how does Fannie Mae justify a difference in $306,000 between Miami and Washington on the their values. They don't add up and those in Miami are at a severe disadvantage. I respectfully request the funding limits be raised and no longer use Fannie Mae/Freddie Mac conforming loan limits, but alternatively use BAH rates.