Comment Submitted by John H. Johnson, Oklahoma City Housing Authority

The Oklahoma City Housing Authority disagrees with the statement "Financing proceeds under this part may not be used for administration or central office cost center costs (except for mixed-finance projects), management improvements, or other non-viable projects, such as those subject to required conversion." The provision establishes an undue burden on housing authorities when considering the requirements listed elsewhere in the proposed rule. These would include: the requirement to hire a third party to conduct a Management Assessment, and hiring a third party to declare terms and condidtions of financial transactions are reasonable. Capital Funds should be available to cover these costs.