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This comment responds to the US Department of Housing and Urban Development’s (HUD's) proposed revisions to a rule on Affirmatively Furthering Fair Housing (published on January 14, 2020). HUD’s proposal omits key information necessary to assess local jurisdictions' progress complying with the Fair Housing Act. Our analysis suggests that HUD's proposed race-neutral approach would be incomplete at best and risks obscuring and perpetuating discriminatory housing patterns and practices. In this comment, we focus primarily on HUD’s proposed reliance on metrics that do not reflect housing access for protected groups and the use of a ranking system to identify higher- or lower-performing jurisdictions. We provide the data from our analyses, which are drawn from HUD's publicly available Affirmatively Furthering Fair Housing data tools.

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