Comment Submitted by David Wolf, Mohave County Housing Authority

We do not see how this would be beneficial to the PHA as the financial settlement is due at the end of the PHA’s fiscal year. This proposed rule change misses the connection between fiscal year end and utilization. We have to track vouchers and funding on a fiscal year basis as we cannot over utilize unit months at fiscal year end. We wouldn’t be paid by HUD for those months. By changing this indicator we would now have to perform double tracking-at fiscal year end, for fiscal year end settlement and at calendar year end for SEMAP which is actually more work. In addition, all other SEMAP measures would be tracked on fiscal year basis, creating more complexity and confusion. The only way this change would make sense to us is if HUD moved the year end settlement for PHAs from fiscal year to calendar year end and moved all the SEMAP indicators.