Hi all,

I saw an old post that OCC will rely on FFEIC for determining affordable income and rent. This is from 2012 - is this still the case? I'm seeing HUD published AMI often be higher than FFEIC MFI. I'm trying to determine affordable rents under CRA and would like to understand: 1) confirm reliance on FFEIC MFI; 2) How do we adjust the max rent for bedroom count; 3) do we need to adjust rent based on actual income of the renter?

For instance, let’s say the MFI of an area is $100K. 80% of that is $80K, which would translate to a max monthly rent of $2,000 (30% of $80K)
1) Do we need to adjust this $2K max rent for bedroom size (e.g., studio, 1BR, 2BR, 3BR, etc.)?
2) If a family comes in making $60K, do we need to adjust the rent down to 30% of their income or can we keep it at 30% of $80k?
3) Ultimately the answer may come down to how a regulator would evaluate the property for CRA purposes so would be good to understand what exactly are they testing/looking for.

thanks in advance