Kelly Patterson and Robert Silverman of the University at Buffalo have completed a review of first year implementation of the HUD Small Area Fair Market Rent rule (adopted in 2016, suspended in 2017, reinstated by litigation, and effective April 2018). One important takeaway of their survey is a troubling trend in a number of PHAs that are using their flexibility in setting “payment standards” to blunt the positive effect of the rule by raising rent caps in low income neighborhoods and lowering rent caps in higher income neighborhoods. The report also explores voluntary adoption of “SAFMRs” by looking at the potential in the Buffalo region.