Source: [Federal Register](https://www.huduser.gov/portal/datasets/fmr/fmr2013p/Trend_Comments.pdf)

Review of Alternative Tending Methodologies. One commenter addressed each of the alternative trending methods suggested in the notice. The commenter states that it does not support Alternative 1 (use of overall Consumer Price Index (CPI) data) because local and regional CPI provides a more accurate FMR calculation for specific geographic areas than national CPI data. It also recommends that should HUD use national CPI data rather than local or regional data, it should limit its use to rent and utility, instead of overall, CPI data. The commenter supports Alternative 2 (use of rent and utilities CPI) since, according to the commenter, the use of a local or regional trend factor is a more appropriate way to calculate FMRs. The commenter does not support the use of proprietary information (Alternative 3) since the likelihood of this data providing timely, complete, and usable data, particularly for rural and remote areas, is low. The commenter also supports alternative 4 (seeking legislative change, trending to the midpoint of the fiscal year) as providing a good balance between the use of the most recent local data available and the need to publish the trend factor in advance. Finally, the commenter does not support Alternatives 5 (seeking legislative change, trending to the beginning of the fiscal year) and requests more information to fully consider Alternative 6 (eliminating the need for trending by using the most recent half- yearly CPI and publishing final FMRs between October and December). HUD Response: HUD takes these comments under advisement, and continues to consider all of these methods as well as others suggested by different commenters.