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Part III

Administrative, Procedural, and Miscellaneous

[26 CFR 601.201]: Rulings and determination letters

(Also: Part I, §§ 25, 103, 143

Rev. Proc. 2010-25

SECTION 1. PURPOSE

This revenue procedure provides issuers of qualified mortgage bonds, as defined

in section 143(a) of the Internal Revenue Code, and issuers of mortgage credit

certificates, as defined in section 25(c), with (1) the nationwide average purchase price

for residences located in the United States, and (2) average area purchase price safe

harbors for residences located in statistical areas in each state, the District of Columbia,

Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and

Guam.

SECTION 2. BACKGROUND

.01 Section 103(a) provides that, except as provided in section 103(b), gross

income does not include interest on any state or local bond. Section 103(b)(1) provides

that section 103(a) shall not apply to any private activity bond that is not a "qualified

bond" within the meaning of section 141. Section 141(e) provides, in part, that the term

"qualified bond" means any private activity bond if such bond (1) is a qualified mortgage

bond under section 143, (2) meets the volume cap requirements under section 146, and

(3) meets the applicable requirements under section 147.

.02 Section 143(a)(1) provides that the term "qualified mortgage bond" means a

bond that is issued as part of a qualified mortgage issue. Section 143(a)(2)(A) provides

that the term "qualified mortgage issue" means an issue of one or more bonds by a

state or political subdivision thereof, but only if: (i) all proceeds of the issue (exclusive of

issuance costs and a reasonably required reserve) are to be used to finance owneroccupied residences; (ii) the issue meets the requirements of subsections (c), (d), (e),

(f), (g), (h), (i), and (m)(7) of section 143; (iii) the issue does not meet the private

business tests of paragraphs (1) and (2) of section 141(b); and (iv) with respect to

amounts received more than 10 years after the date of issuance, repayments of

$250,000 or more of principal on mortgage financing provided by the issue are used by

the close of the first semiannual period beginning after the date the prepayment (or

complete repayment) is received to redeem bonds that are part of the issue.

Average Area Purchase Price

.03 Section 143(e)(1) provides that an issue of bonds meets the purchase price

requirements of section 143(e) if the acquisition cost of each residence financed by the

issue does not exceed 90 percent of the average area purchase price applicable to

such residence. Section 143(e)(5) provides that, in the case of a targeted area

residence (as defined in section 143(j)), section 143(e)(1) shall be applied by

substituting 110 percent for 90 percent.

.04 Section 143(e)(2) provides that the term "average area purchase price"

means, with respect to any residence, the average purchase price of single-family

residences (in the statistical area in which the residence is located) that were purchased

during the most recent 12-month period for which sufficient statistical information is

available. Under sections 143(e)(3) and (4), respectively, separate determinations are

to be made for new and existing residences, and for two-, three-, and four-family

residences.

.05 Section 143(e)(2) provides that the determination of the average area

purchase price for a statistical area shall be made as of the date on which the

commitment to provide the financing is made or, if earlier, the date of the purchase of

the residence.

.06 Section 143(k)(2)(A) provides that the term "statistical area" means (i) a

metropolitan statistical area (MSA), and (ii) any county (or the portion thereof) that is not

within an MSA. Section 143(k)(2)(C) further provides that if sufficient recent statistical

information with respect to a county (or portion thereof) is unavailable, the Secretary

may substitute another area for which there is sufficient recent statistical information for

such county (or portion thereof). In the case of any portion of a State which is not within

a county, section 143(k)(2)(D) provides that the Secretary may designate as a county

any area that is the equivalent of a county. Section 6a.103A-1(b)(4)(i) of the Temporary

Income Tax Regulations (issued under section 103A of the Internal Revenue Code of

1954, the predecessor of section 143) provides that the term “State” includes a

possession of the United States and the District of Columbia.

.07 Section 6a.103A-2(f)(5)(i) provides that an issuer may rely upon the average

area purchase price safe harbors published by the Department of the Treasury for the

statistical area in which a residence is located. Section 6a.103A-2(f)(5)(i) further

provides that an issuer may use an average area purchase price limitation different from

the published safe harbor if the issuer has more accurate and comprehensive data for

the statistical area.

Qualified Mortgage Credit Certificate Program

.08 Section 25(c) permits a state or political subdivision to establish a qualified

mortgage credit certificate program. In general, a qualified mortgage credit certificate

program is a program under which the issuing authority elects not to issue an amount of

private activity bonds that it may otherwise issue during the calendar year under section

146, and in their place, issues mortgage credit certificates to taxpayers in connection

with the acquisition of their principal residences. Section 25(a)(1) provides, in general,

that the holder of a mortgage credit certificate may claim a federal income tax credit

equal to the product of the credit rate specified in the certificate and the interest paid or

accrued during the tax year on the remaining principal of the indebtedness incurred to

acquire the residence. Section 25(c)(2)(A)(iii)(III) generally provides that residences

acquired in connection with the issuance of mortgage credit certificates must meet the

purchase price requirements of section 143(e).

Income Limitations for Qualified Mortgage Bonds and Mortgage Credit Certificates

.09 Section 143(f) imposes limitations on the income of mortgagors for whom

financing may be provided by qualified mortgage bonds. In addition, section

25(c)(2)(A)(iii)(IV) provides that holders of mortgage credit certificates must meet the

income requirement of section 143(f). Generally, under sections 143(f)(1) and

25(c)(2)(A)(iii)(IV), the income requirement is met only if all owner-financing under a

qualified mortgage bond and all mortgage credit certificates issued under a qualified

mortgage credit certificate program are provided to mortgagors whose family income is

115 percent or less of the applicable median family income. Section 143(f)(5), however,

generally provides for an upward adjustment to the percentage limitation in high housing

cost areas. High housing cost areas are defined in section 143(f)(5)(C) as any

statistical area for which the housing cost/income ratio is greater than 1.2.

.10 Under section 143(f)(5)(D), the housing cost/income ratio with respect to any

statistical area is determined by dividing (a) the applicable housing price ratio for such

area by (b) the ratio that the area median gross income for such area bears to the

median gross income for the United States. The applicable housing price ratio is the

new housing price ratio (new housing average area purchase price divided by the new

housing average purchase price for the United States) or the existing housing price ratio

(existing housing average area purchase price divided by the existing housing average

purchase price for the United States), whichever results in the housing cost/income ratio

being closer to 1.

Average Area and Nationwide Purchase Price Limitations

.11 Average area purchase price safe harbors for each state, the District of

Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin

Islands, and Guam were last published in Rev. Proc. 2009-18, 2009-11 I.R.B. 686.

.12 The nationwide average purchase price limitation was last published in

section 4.02 of Rev. Proc. 2009-18. Guidance with respect to the United States and

area median gross income figures that are to be used in computing the housing

cost/income ratio described in section 143(f)(5) was last published in Rev. Proc. 201023, 2010-24 I.R.B. 762.

.13 This revenue procedure uses FHA loan limits for a given statistical area to

calculate the average area purchase price safe harbor for that area. FHA sets limits on

the dollar value of loans it will insure based on median home prices and conforming loan

limits established by the Federal Home Loan Mortgage Corporation. In particular, FHA

sets an area's loan limit at 95 percent of the median home sales price for the area,

subject to certain floors and caps measured against conforming loan limits.

.14 To calculate the average area purchase price safe harbors in this revenue

procedure, the FHA loan limits are adjusted to take into account the differences

between average and median purchase prices. Because FHA loan limits do not

differentiate between new and existing residences, this revenue procedure contains a

single average area purchase price safe harbor for both new and existing residences in

a statistical area. The Treasury Department and the Internal Revenue Service have

determined that FHA loan limits provide a reasonable basis for determining average

area purchase price safe harbors. If the Treasury Department and the Internal Revenue

Service become aware of other sources of average purchase price data, including data

that differentiate between new and existing residences, consideration will be given as to

whether such data provide a more accurate method for calculating average area

purchase price safe harbors.

.15 The average area purchase price safe harbors listed in section 4.01 of this

revenue procedure are based on FHA loan limits released November 25, 2009. FHA

loan limits are available for statistical areas in each state, the District of Columbia,

Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and

Guam. See section 3.03 of this revenue procedure with respect to FHA loan limits

revised after November 25, 2009.

.16 OMB Bulletin No. 03-04, dated and effective June 6, 2003, revised the

definitions of the nation’s metropolitan areas and recognized 49 new metropolitan

statistical areas. The OMB bulletin no longer includes primary metropolitan statistical

areas.

SECTION 3. APPLICATION

Average Area Purchase Price Safe Harbors

.01 Average area purchase price safe harbors for statistical areas in each state,

the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa,

the Virgin Islands, and Guam are set forth in section 4.01 of this revenue procedure.

Average area purchase price safe harbors are provided for single-family and two to

four-family residences. For each type of residence, section 4.01 of this revenue

procedure contains a single safe harbor that may be used for both new and existing

residences. Issuers of qualified mortgage bonds and issuers of mortgage credit

certificates may rely on these safe harbors to satisfy the requirements of sections

143(e) and (f). Section 4.01 of this revenue procedure provides safe harbors for MSAs

and for certain counties and county equivalents. If no purchase price safe harbor is

available for a statistical area, the safe harbor for "ALL OTHER AREAS" may be used

for that statistical area.

.02 If a residence is in an MSA, the safe harbor applicable to it is the limitation of

that MSA. If an MSA falls in more than one state, the MSA is listed in section 4.01 of

this revenue procedure under each state.

.03 If the FHA revises the FHA loan limit for any statistical area after November

25, 2009, an issuer of qualified mortgage bonds or mortgage credit certificates may use

the revised FHA loan limit for that statistical area to compute (as provided in the next

sentence) a revised average area purchase price safe harbor for the statistical area

provided that the issuer maintains records evidencing the revised FHA loan limit. The

revised average area purchase price safe harbor for that statistical area is computed by

dividing the revised FHA loan limit by 1.00.

.04 If, pursuant to section 6a.103A-2(f)(5)(i), an issuer uses more accurate and

comprehensive data to determine the average area purchase price for a statistical area,

the issuer must make separate average area purchase price determinations for new

and existing residences. Moreover, when computing the average area purchase price

for a statistical area that is an MSA, as defined in OMB Bulletin No. 03-04, the issuer

must make the computation for the entire applicable MSA. When computing the

average area purchase price for a statistical area that is not an MSA, the issuer must

make the computation for the entire statistical area and may not combine statistical

areas. Thus, for example, the issuer may not combine two or more counties.

.05 If an issuer receives a ruling permitting it to rely on an average area purchase

price limitation that is higher than the applicable safe harbor in this revenue procedure,

the issuer may rely on that higher limitation for the purpose of satisfying the

requirements of section 143(e) and (f) for bonds sold, and mortgage credit certificates

issued, not more than 30 months following the termination date of the 12-month period

used by the issuer to compute the limitation.

Nationwide Average Purchase Price

.06 Section 4.02 of this revenue procedure sets forth a single nationwide average

purchase price for purposes of computing the housing cost/income ratio under section

143(f)(5).

.07 Issuers must use the nationwide average purchase price set forth in section

4.02 of this revenue procedure when computing the housing cost/income ratio under

section 143(f)(5) regardless of whether they are relying on the average area purchase

price safe harbors contained in this revenue procedure or using more accurate and

comprehensive data to determine average area purchase prices for new and existing

residences for a statistical area that are different from the published safe harbors in this

revenue procedure.

.08 If, pursuant to section 6.02 of this revenue procedure, an issuer relies on the

average area purchase price safe harbors contained in Rev. Proc. 2009-18, the issuer

must use the nationwide average purchase price set forth in section 4.02 of Rev. Proc.

2009-18 in computing the housing cost/income ratio under section 143(f)(5). Likewise,

if, pursuant to section 6.05 of this revenue procedure, an issuer relies on the nationwide

average purchase price published in Rev. Proc. 2009-18, the issuer may not rely on the

average area purchase price safe harbors published in this revenue procedure.

SECTION 4. AVERAGE AREA AND NATIONWIDE AVERAGE PURCHASE PRICES

.01 Average area purchase prices for single-family and two to four-family

residences in MSAs, and for certain counties and county equivalents are set forth

below. The safe harbor for “ALL OTHER AREAS” (found at the end of the table below)

may be used for a statistical area that is not listed below.

2010 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

VALDEZ-CORDOVA

NORTH SLOPE

WRANGELL-PETERS

DENALI

FAIRBANKS NORTH

KETCHIKAN GATEW

KODIAK ISLAND

DILLINGHAM

ANCHORAGE

MATANUSKA-SUSIT

ALEUTIANS WEST

YAKUTAT CITY

JUNEAU

SITKA

One-Unit

Limit

$271,400

$307,050

$316,250

$322,000

$332,500

$347,500

$356,500

$388,700

$398,750

$431,250

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

$347,450

$393,050

$404,850

$412,200

$425,650

$444,850

$456,350

$497,600

$510,450

$552,050

$419,950

$475,150

$489,350

$498,250

$514,500

$537,750

$551,650

$601,500

$617,050

$667,350

$521,900

$590,500

$608,150

$619,250

$639,400

$668,250

$685,550

$747,500

$766,850

$829,350

BALDWIN

RUSSELL

$285,000

$289,800

$364,850

$371,000

$441,000

$448,450

$548,050

$557,300

APACHE

NAVAJO

PIMA

MOHAVE

GILA

MARICOPA

PINAL

YAVAPAI

COCONINO

$281,250

$308,750

$316,250

$322,500

$325,000

$346,250

$390,000

$450,000

$360,050

$395,250

$404,850

$412,850

$416,050

$443,250

$499,250

$576,050

$435,200

$477,750

$489,350

$499,050

$502,900

$535,800

$603,500

$696,350

$540,850

$593,750

$608,150

$620,200

$625,000

$665,850

$750,000

$865,400

LASSEN

GLENN

SISKIYOU

SIERRA

DEL NORTE

TEHAMA

IMPERIAL

KINGS

TULARE

KERN

FRESNO

HUMBOLDT

COLUSA

BUTTE

LAKE

PLUMAS

MARIPOSA

SHASTA

STANISLAUS

MADERA

SUTTER

YUBA

INYO

TUOLUMNE

$285,000

$287,500

$293,750

$304,750

$311,250

$312,500

$325,000

$368,750

$381,250

$393,750

$397,500

$400,000

$401,250

$410,000

$412,500

$423,750

$425,000

$437,500

$364,850

$368,050

$376,050

$390,100

$398,450

$400,050

$416,050

$472,050

$488,050

$504,050

$508,850

$512,050

$513,650

$524,850

$528,050

$542,450

$544,050

$560,050

$441,000

$444,900

$454,550

$471,550

$481,650

$483,550

$502,900

$570,600

$589,950

$609,300

$615,100

$618,950

$620,900

$634,450

$638,300

$655,700

$657,650

$677,000

$548,050

$552,900

$564,900

$586,050

$598,550

$600,950

$625,000

$709,150

$733,150

$757,200

$764,400

$769,250

$771,650

$788,450

$793,250

$814,900

$817,300

$841,350

AMADOR

CALAVERAS

MERCED

SAN JOAQUIN

RIVERSIDE

SAN BERNARDINO

MENDOCINO

MONO

ALPINE

SOLANO

NEVADA

EL DORADO

PLACER

SACRAMENTO

YOLO

SONOMA

SAN LUIS OBISPO

SAN DIEGO

ALAMEDA

CONTRA COSTA

LOS ANGELES

MARIN

MONTEREY

NAPA

ORANGE

SAN BENITO

SAN FRANCISCO

SAN MATEO

SANTA BARBARA

SANTA CLARA

SANTA CRUZ

VENTURA

$443,750

$462,500

$472,500

$488,750

$500,000

$512,500

$529,000

$547,500

$557,500

$562,500

$580,000

$662,500

$687,500

$697,500

$729,750

$568,050

$592,050

$604,900

$625,700

$640,100

$656,100

$677,200

$700,900

$713,700

$720,100

$742,500

$848,100

$880,100

$892,950

$934,200

CHAFFEE

MINERAL

LARIMER

ARCHULETA

$280,000

$300,000

$312,500

$317,500

$358,450

$384,050

$400,050

$406,450

$686,650

$853,350

$715,700

$889,450

$731,150

$908,650

$756,300

$939,900

$773,700

$961,550

$773,700

$961,550

$793,050

$985,600

$818,600 $1,017,300

$847,200 $1,052,900

$862,700 $1,072,150

$870,450 $1,081,750

$897,500 $1,115,400

$1,025,200 $1,274,050

$1,063,850 $1,322,150

$1,079,350 $1,341,350

$1,129,250 $1,403,400

$433,250

$464,200

$483,550

$491,300

$538,450

$576,900

$600,950

$610,550

EL PASO

TELLER

GRAND

MESA

ADAMS

ARAPAHOE

BROOMFIELD

CLEAR CREEK

DENVER

DOUGLAS

ELBERT

GILPIN

JEFFERSON

PARK

WELD

GARFIELD

SAN JUAN

GUNNISON

LA PLATA

BOULDER

OURAY

HINSDALE

SAN MIGUEL

ROUTT

EAGLE

LAKE

PITKIN

SUMMIT

$325,000

$356,250

$371,250

$406,250

$417,500

$425,000

$433,750

$443,750

$460,000

$482,500

$557,500

$651,250

$675,000

$729,750

$416,050

$456,050

$475,250

$520,050

$534,450

$544,050

$555,250

$568,050

$588,850

$617,700

$713,700

$833,700

$864,100

$934,200

$502,900

$625,000

$502,900

$625,000

$551,250

$685,100

$574,500

$713,950

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$628,650

$781,250

$646,050

$802,900

$657,650

$817,300

$657,650

$817,300

$671,200

$834,150

$686,650

$853,350

$711,800

$884,600

$746,650

$927,900

$862,700 $1,072,150

$1,007,750 $1,252,400

$1,044,550 $1,298,100

$1,129,250 $1,403,400

WINDHAM

LITCHFIELD

NEW HAVEN

NEW LONDON

HARTFORD

MIDDLESEX

TOLLAND

FAIRFIELD

$272,500

$375,000

$387,500

$398,750

$440,000

$708,750

$348,850

$480,050

$496,050

$510,450

$563,250

$907,350

$421,650

$524,050

$580,300

$721,150

$599,600

$745,200

$617,050

$766,850

$680,850

$846,150

$680,850

$846,150

$680,850

$846,150

$1,096,750 $1,363,000

DISTRICT OF COL

$729,750

$934,200

SUSSEX

KENT

NEW CASTLE

$375,000

$376,250

$420,000

$480,050

$481,650

$537,650

$580,300

$582,200

$649,900

$721,150

$723,550

$807,700

SUMTER

INDIAN RIVER

FLAGLER

BREVARD

HERNANDO

HILLSBOROUGH

PASCO

PINELLAS

CHARLOTTE

VOLUSIA

FRANKLIN

OKALOOSA

LAKE

ORANGE

OSCEOLA

SEMINOLE

LEE

WALTON

MARTIN

ST. LUCIE

BAKER

CLAY

DUVAL

NASSAU

ST. JOHNS

BAY

BROWARD

MIAMI-DADE

PALM BEACH

MANATEE

$278,750

$283,750

$287,500

$291,250

$292,500

$296,250

$303,750

$305,000

$312,500

$353,750

$356,250

$362,790

$375,000

$387,500

$396,250

$423,750

$442,500

$356,850

$363,250

$368,050

$372,850

$374,450

$379,250

$388,850

$390,450

$400,050

$452,850

$456,050

$464,400

$480,050

$496,050

$507,250

$542,450

$566,450

$431,350

$439,050

$444,900

$450,700

$452,600

$458,400

$470,000

$471,950

$483,550

$547,400

$551,250

$561,400

$580,300

$599,600

$613,150

$655,700

$684,750

$536,050

$545,650

$552,900

$560,100

$562,500

$569,700

$584,150

$586,550

$600,950

$680,300

$685,100

$697,650

$721,150

$745,200

$762,000

$814,900

$850,950

$1,129,250 $1,403,400

SARASOTA

COLLIER

MONROE

$442,500

$531,250

$729,750

$566,450

$680,100

$934,200

BRANTLEY

GLYNN

MCINTOSH

CHATTAHOOCHEE

HARRIS

MARION

MUSCOGEE

CLARKE

MADISON

OCONEE

OGLETHORPE

BARROW

BARTOW

BUTTS

CARROLL

CHEROKEE

CLAYTON

COBB

COWETA

DAWSON

DEKALB

DOUGLAS

FAYETTE

FORSYTH

FULTON

GWINNETT

HARALSON

HEARD

HENRY

JASPER

LAMAR

MERIWETHER

NEWTON

$276,250

$289,800

$298,750

$346,250

$353,650

$371,000

$382,450

$443,250

$684,750

$850,950

$822,050 $1,021,650

$1,129,250 $1,403,400

$427,450

$448,450

$462,300

$535,800

$531,250

$557,300

$574,500

$665,850

PAULDING

PICKENS

PIKE

ROCKDALE

SPALDING

WALTON

GREENE

$346,250

$662,500

$443,250

$848,100

$535,800

$665,850

$535,800

$665,850

$535,800

$665,850

$535,800

$665,850

$535,800

$665,850

$535,800

$665,850

$1,025,200 $1,274,050

HAWAII

KALAWAO

HONOLULU

MAUI

KAUAI

$618,750 $792,100

$716,250 $916,950

$793,750 $1,016,150

$790,000 $1,011,350

$773,750 $990,550

$957,500 $1,189,900

$1,108,350 $1,377,450

$1,228,300 $1,526,450

$1,222,500 $1,519,250

$1,197,350 $1,488,000

ADAMS

KOOTENAI

ADA

BOISE

CANYON

GEM

OWYHEE

VALLEY

TETON

BLAINE

$273,750

$286,250

$303,750

$462,500

$693,750

$729,750

$350,450

$366,450

$388,850

$592,050

$888,100

$934,200

$423,600

$526,450

$442,950

$550,450

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$715,700

$889,450

$1,073,550 $1,334,150

$1,129,250 $1,403,400

BOND

CALHOUN

CLINTON

JERSEY

MACOUPIN

MADISON

MONROE

ST. CLAIR

BOONE

WINNEBAGO

COOK

DEKALB

$281,250

$339,250

$410,000

$360,050

$434,300

$524,850

$435,200

$524,950

$634,450

$540,850

$652,400

$788,450

DUPAGE

GRUNDY

KANE

KENDALL

LAKE

MCHENRY

WILL

$410,000

$524,850

$634,450

$788,450

CLARK

FLOYD

HARRISON

WASHINGTON

DEARBORN

FRANKLIN

OHIO

JASPER

LAKE

NEWTON

PORTER

$302,500

$337,500

$410,000

$387,250

$432,050

$524,850

$468,100

$522,250

$634,450

$581,750

$649,050

$788,450

BULLITT

HENRY

JEFFERSON

MEADE

NELSON

OLDHAM

SHELBY

SPENCER

TRIMBLE

BOONE

BRACKEN

CAMPBELL

GALLATIN

GRANT

KENTON

PENDLETON

$302,500

$337,500

$387,250

$432,050

$468,100

$522,250

$581,750

$649,050

ASCENSION

EAST BATON ROUG

EAST FELICIANA

IBERVILLE

LIVINGSTON

POINTE COUPEE

ST. HELENA

WEST BATON ROUG

WEST FELICIANA

JEFFERSON

ORLEANS

PLAQUEMINES

ST. BERNARD

ST. CHARLES

ST. JOHN THE BA

ST. TAMMANY

$280,000

$287,500

$358,450

$368,050

FRANKLIN

HAMPDEN

HAMPSHIRE

WORCESTER

BARNSTABLE

BRISTOL

ESSEX

MIDDLESEX

NORFOLK

PLYMOUTH

SUFFOLK

DUKES

NANTUCKET

$318,750

$385,000

$462,500

$475,000

$523,750

$729,750

$408,050

$492,850

$592,050

$608,100

$670,500

$934,200

SOMERSET

WICOMICO

KENT

WASHINGTON

ST. MARY'S

CECIL

$328,750

$343,750

$377,500

$400,000

$420,000

$420,850

$440,050

$483,250

$512,050

$537,650

$433,250

$444,900

$538,450

$552,900

$493,250

$613,000

$493,250

$613,000

$493,250

$613,000

$595,750

$740,400

$715,700

$889,450

$735,050

$913,450

$810,450 $1,007,200

$1,129,250 $1,403,400

$508,700

$531,900

$584,150

$618,950

$649,900

$632,200

$661,050

$725,950

$769,250

$807,700

GARRETT

WORCESTER

TALBOT

ANNE ARUNDEL

BALTIMORE

BALTIMORE CITY

CARROLL

HARFORD

HOWARD

QUEEN ANNE'S

CALVERT

CHARLES

FREDERICK

MONTGOMERY

PRINCE GEORGE'S

$437,500

$443,750

$560,000

$729,750

$560,050

$568,050

$716,900

$934,200

HANCOCK

KNOX

LINCOLN

CUMBERLAND

SAGADAHOC

YORK

$272,500

$279,450

$318,750

$337,500

$348,850

$357,750

$408,050

$432,050

$421,650

$432,400

$493,250

$522,250

$524,050

$537,400

$613,000

$649,050

KALAMAZOO

VAN BUREN

LAPEER

LENAWEE

LIVINGSTON

MACOMB

MONROE

OAKLAND

ST. CLAIR

WAYNE

BERRIEN

WASHTENAW

$286,250

$297,500

$298,750

$345,000

$366,450

$380,850

$382,450

$441,650

$442,950

$460,350

$462,300

$533,850

$550,450

$572,100

$574,500

$663,450

COOK

$296,250

$379,250

$458,400

$569,700

$677,000

$841,350

$677,000

$841,350

$686,650

$853,350

$866,550 $1,076,950

$1,129,250 $1,403,400

ANOKA

CARVER

CHISAGO

DAKOTA

HENNEPIN

ISANTI

RAMSEY

SCOTT

SHERBURNE

WASHINGTON

WRIGHT

$365,000

$467,250

$564,800

$701,900

CRAWFORD

FRANKLIN

JEFFERSON

LINCOLN

ST. CHARLES

ST. LOUIS

ST. LOUIS CITY

WARREN

WASHINGTON

$281,250

$360,050

$435,200

$540,850

MADISON

CARBON

MISSOULA

YELLOWSTONE

LAKE

FLATHEAD

RAVALLI

JEFFERSON

LEWIS AND CLARK

SWEET GRASS

GALLATIN

$281,750

$291,250

$301,250

$301,300

$303,750

$341,250

$346,250

$386,250

$360,700

$372,850

$385,650

$385,700

$388,850

$436,850

$443,250

$494,450

$436,000

$450,700

$466,150

$466,250

$470,000

$528,050

$535,800

$597,700

$541,800

$560,100

$579,300

$579,400

$584,150

$656,250

$665,850

$742,800

WATAUGA

CARTERET

TRANSYLVANIA

$285,000

$287,500

$293,750

$364,850

$368,050

$376,050

$441,000

$444,900

$454,550

$548,050

$552,900

$564,900

FRANKLIN

JOHNSTON

WAKE

ANSON

BRUNSWICK

BUNCOMBE

CABARRUS

GASTON

HAYWOOD

HENDERSON

MADISON

MECKLENBURG

NEW HANOVER

PENDER

UNION

ONSLOW

CHATHAM

DURHAM

ORANGE

PERSON

CURRITUCK

DARE

HYDE

CAMDEN

PASQUOTANK

PERQUIMANS

$295,000

$303,750

$306,250

$334,650

$458,850

$460,000

$483,000

$729,750

$377,650

$388,850

$392,050

$428,400

$587,400

$588,850

$618,300

$934,200

$456,500

$567,300

$456,500

$567,300

$456,500

$567,300

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$470,000

$584,150

$473,900

$588,950

$517,850

$643,550

$517,850

$643,550

$517,850

$643,550

$517,850

$643,550

$710,050

$882,400

$711,800

$884,600

$747,400

$928,850

$1,129,250 $1,403,400

BELKNAP

GRAFTON

MERRIMACK

HILLSBOROUGH

ROCKINGHAM

STRAFFORD

$281,250

$302,500

$402,500

$523,750

$360,050

$387,250

$515,250

$670,500

$435,200

$540,850

$435,200

$540,850

$468,100

$581,750

$622,850

$774,050

$810,450 $1,007,200

WARREN

CUMBERLAND

BURLINGTON

$402,500

$405,000

$420,000

$515,250

$518,450

$537,650

$622,850

$626,700

$649,900

$774,050

$778,850

$807,700

CAMDEN

GLOUCESTER

SALEM

MERCER

ATLANTIC

CAPE MAY

BERGEN

ESSEX

HUDSON

HUNTERDON

MIDDLESEX

MONMOUTH

MORRIS

OCEAN

PASSAIC

SOMERSET

SUSSEX

UNION

$420,000

$440,000

$453,750

$487,500

$729,750

$537,650

$563,250

$580,850

$624,100

$934,200

SAN JUAN

LOS ALAMOS

SANTA FE

$281,250

$380,650

$427,500

$360,050

$487,300

$547,250

$435,200

$589,000

$661,500

$540,850

$732,000

$822,100

ELKO

EUREKA

NYE

LYON

CARSON CITY

CLARK

STOREY

WASHOE

DOUGLAS

$325,000

$331,250

$398,750

$400,000

$403,750

$468,750

$416,050

$424,050

$510,450

$512,050

$516,850

$600,100

$502,900

$512,600

$617,050

$618,950

$624,750

$725,350

$625,000

$637,000

$766,850

$769,250

$776,450

$901,450

COLUMBIA

ERIE

NIAGARA

MADISON

$276,250

$281,250

$353,650

$360,050

$427,450

$435,200

$531,250

$540,850

$649,900

$807,700

$649,900

$807,700

$649,900

$807,700

$680,850

$846,150

$702,150

$872,600

$754,350

$937,500

$1,129,250 $1,403,400

ONONDAGA

OSWEGO

ALBANY

RENSSELAER

SARATOGA

SCHENECTADY

SCHOHARIE

ULSTER

DUTCHESS

ORANGE

BRONX

KINGS

NASSAU

NEW YORK

PUTNAM

QUEENS

RICHMOND

ROCKLAND

SUFFOLK

WESTCHESTER

$281,250

$312,500

$406,250

$443,750

$729,750

$360,050

$400,050

$520,050

$568,050

$934,200

GREENE

MIAMI

MONTGOMERY

PREBLE

CARROLL

STARK

ASHTABULA

MERCER

CUYAHOGA

GEAUGA

LAKE

LORAIN

MEDINA

VAN WERT

PORTAGE

SUMMIT

$271,250

$277,500

$291,250

$292,500

$298,750

$301,250

$330,000

$347,250

$355,250

$372,850

$374,450

$382,450

$385,650

$422,450

$435,200

$540,850

$435,200

$540,850

$483,550

$600,950

$483,550

$600,950

$483,550

$600,950

$483,550

$600,950

$483,550

$600,950

$628,650

$781,250

$686,650

$853,350

$686,650

$853,350

$1,129,250 $1,403,400

$419,750

$429,400

$450,700

$452,600

$462,300

$466,150

$510,650

$521,650

$533,650

$560,100

$562,500

$574,500

$579,300

$634,600

BROWN

BUTLER

CLERMONT

HAMILTON

WARREN

DELAWARE

FAIRFIELD

FRANKLIN

LICKING

MADISON

MORROW

PICKAWAY

UNION

ATHENS

$337,500

$341,250

$432,500

$432,050

$436,850

$553,650

$522,250

$528,050

$669,250

$649,050

$656,250

$831,750

MARION

POLK

LINCOLN

JOSEPHINE

BENTON

LANE

TILLAMOOK

CLATSOP

CURRY

HOOD RIVER

CLACKAMAS

COLUMBIA

MULTNOMAH

WASHINGTON

YAMHILL

JACKSON

DESCHUTES

$295,000

$312,500

$325,000

$337,500

$343,750

$347,500

$351,250

$393,750

$418,750

$422,500

$447,500

$377,650

$400,050

$416,050

$432,050

$440,050

$444,850

$449,650

$504,050

$536,050

$540,850

$572,850

$456,500

$483,550

$502,900

$522,250

$531,900

$537,750

$543,550

$609,300

$648,000

$653,800

$692,450

$567,300

$600,950

$625,000

$649,050

$661,050

$668,250

$675,500

$757,200

$805,300

$812,500

$860,600

CENTRE

BERKS

ALLEGHENY

ARMSTRONG

$280,000

$300,000

$327,500

$358,450

$384,050

$419,250

$433,250

$464,200

$506,800

$538,450

$576,900

$629,800

BEAVER

BUTLER

FAYETTE

WASHINGTON

WESTMORELAND

LANCASTER

CARBON

LEHIGH

NORTHAMPTON

BUCKS

CHESTER

DELAWARE

MONTGOMERY

PHILADELPHIA

YORK

PIKE

$327,500

$383,750

$402,500

$420,000

$425,000

$729,750

$419,250

$491,250

$515,250

$537,650

$544,050

$934,200

BRISTOL

KENT

NEWPORT

PROVIDENCE

WASHINGTON

$475,000

$608,100

$735,050

$913,450

HORRY

GREENVILLE

LAURENS

PICKENS

YORK

BERKELEY

CHARLESTON

DORCHESTER

BEAUFORT

JASPER

GEORGETOWN

$286,250

$295,000

$303,750

$335,000

$387,500

$395,000

$366,450

$377,650

$388,850

$428,850

$496,050

$505,650

$442,950

$456,500

$470,000

$518,400

$599,600

$611,250

$550,450

$567,300

$584,150

$644,250

$745,200

$759,600

CANNON

CHEATHAM

$432,500

$553,650

$669,250

$831,750

$506,800

$629,800

$506,800

$629,800

$506,800

$629,800

$506,800

$629,800

$506,800

$629,800

$593,800

$738,000

$622,850

$774,050

$622,850

$774,050

$622,850

$774,050

$649,900

$807,700

$649,900

$807,700

$649,900

$807,700

$649,900

$807,700

$649,900

$807,700

$657,650

$817,300

$1,129,250 $1,403,400

DAVIDSON

DICKSON

HICKMAN

MACON

ROBERTSON

RUTHERFORD

SMITH

SUMNER

TROUSDALE

WILLIAMSON

WILSON

$432,500

$553,650

$669,250

$831,750

JEFF DAVIS

BASTROP

CALDWELL

HAYS

TRAVIS

WILLIAMSON

ATASCOSA

BANDERA

BEXAR

COMAL

GUADALUPE

KENDALL

MEDINA

WILSON

$271,250

$288,750

$332,500

$347,250

$369,650

$425,650

$419,750

$446,800

$514,500

$521,650

$555,300

$639,400

RICH

DAGGETT

JUAB

UTAH

WASHINGTON

KANE

DAVIS

MORGAN

WEBER

WASATCH

$296,700

$302,450

$323,750

$372,500

$383,750

$397,500

$431,250

$379,800

$387,200

$414,450

$476,850

$491,250

$508,850

$552,050

$459,100

$468,000

$500,950

$576,400

$593,800

$615,100

$667,350

$570,550

$581,650

$622,600

$716,350

$738,000

$764,400

$829,350

SALT LAKE

SUMMIT

TOOELE

$729,750

$934,200

HARRISONBURG

ROCKINGHAM

MADISON

BOTETOURT

CRAIG

FRANKLIN

ROANOKE

ROANOKE IND

SALEM

HIGHLAND

AMHERST

APPOMATTOX

BEDFORD

BEDFORD IND

CAMPBELL

GILES

LYNCHBURG

MONTGOMERY

PULASKI

RADFORD

LEXINGTON

RICHMOND

MIDDLESEX

ORANGE

RAPPAHANNOCK

ESSEX

CULPEPER

KING GEORGE

NORTHUMBERLAND

ALBEMARLE

CHARLOTTESVILLE

FLUVANNA

GREENE

$277,150

$277,500

$280,000

$287,500

$292,100

$296,250

$300,000

$330,000

$331,250

$359,950

$375,000

$382,500

$386,250

$392,500

$437,000

$354,800

$355,250

$358,450

$368,050

$373,950

$379,250

$384,050

$422,450

$424,050

$460,800

$480,050

$489,650

$494,450

$502,450

$559,450

$1,129,250 $1,403,400

$428,850

$429,400

$433,250

$444,900

$452,000

$458,400

$464,200

$510,650

$512,600

$557,000

$580,300

$591,900

$597,700

$607,350

$676,200

$532,950

$533,650

$538,450

$552,900

$561,700

$569,700

$576,900

$634,600

$637,000

$692,200

$721,150

$735,600

$742,800

$754,800

$840,400

NELSON

CHESAPEAKE

GLOUCESTER

HAMPTON

ISLE OF WIGHT

JAMES CITY

MATHEWS

NEWPORT NEWS

NORFOLK

POQUOSON

PORTSMOUTH

SUFFOLK

SURRY

VIRGINIA BEACH

WILLIAMSBURG

YORK

FREDERICK

WINCHESTER

AMELIA

CAROLINE

CHARLES CITY

CHESTERFIELD

COLONIAL HEIGHT

CUMBERLAND

DINWIDDIE

GOOCHLAND

HANOVER

HENRICO

HOPEWELL

KING AND QUEEN

KING WILLIAM

LOUISA

NEW KENT

PETERSBURG

POWHATAN

PRINCE GEORGE

RICHMOND IND

$437,000

$458,850

$475,000

$535,900

$559,450

$587,400

$608,100

$686,050

$676,200

$840,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$710,050

$882,400

$735,050

$913,450

$735,050

$913,450

$829,250 $1,030,600

SUSSEX

LANCASTER

ALEXANDRIA

ARLINGTON

CLARKE

FAIRFAX

FAIRFAX IND

FALLS CHURCH

FAUQUIER

FREDERICKSBURG

LOUDOUN

MANASSAS

MANASSAS PARK

PRINCE WILLIAM

SPOTSYLVANIA

STAFFORD

WARREN

$535,900

$545,000

$729,750

$686,050

$697,700

$934,200

LAMOILLE

BENNINGTON

ORANGE

WINDSOR

CHITTENDEN

FRANKLIN

GRAND ISLE

$276,000

$277,150

$281,250

$318,750

$353,300

$354,800

$360,050

$408,050

$427,100

$428,850

$435,200

$493,250

$530,750

$532,950

$540,850

$613,000

BENTON

FRANKLIN

MASON

KITTITAS

CHELAN

DOUGLAS

THURSTON

SKAGIT

WHATCOM

ISLAND

CLALLAM

$275,000

$310,000

$328,750

$342,700

$361,250

$373,750

$375,000

$381,250

$383,750

$352,050

$396,850

$420,850

$438,700

$462,450

$478,450

$480,050

$488,050

$491,250

$425,550

$479,700

$508,700

$530,300

$559,000

$578,350

$580,300

$589,950

$593,800

$528,850

$596,150

$632,200

$659,050

$694,700

$718,750

$721,150

$733,150

$738,000

$829,250 $1,030,600

$843,350 $1,048,100

$1,129,250 $1,403,400

CLARK

SKAMANIA

JEFFERSON

KITSAP

KING

PIERCE

SNOHOMISH

SAN JUAN

$418,750

$437,500

$475,000

$567,500

$593,750

$536,050

$560,050

$608,100

$726,500

$760,100

$648,000

$805,300

$648,000

$805,300

$677,000

$841,350

$735,050

$913,450

$878,150 $1,091,350

$918,800 $1,141,850

WALWORTH

COLUMBIA

DANE

IOWA

MILWAUKEE

OZAUKEE

WASHINGTON

WAUKESHA

PIERCE

ST. CROIX

KENOSHA

$278,750

$293,750

$315,000

$365,000

$410,000

$356,850

$376,050

$403,250

$467,250

$524,850

$431,350

$454,550

$487,450

$564,800

$634,450

BERKELEY

MORGAN

HAMPSHIRE

JEFFERSON

$377,500

$475,000

$729,750

$483,250

$608,100

$934,200

$584,150

$725,950

$584,150

$725,950

$735,050

$913,450

$1,129,250 $1,403,400

SHERIDAN

SUBLETTE

TETON

$272,500

$298,750

$693,750

$348,850

$382,450

$888,100

$421,650

$524,050

$462,300

$574,500

$1,073,550 $1,334,150

MANUA

$305,000

$390,450

GUAM

$651,250

$833,700

$1,007,750 $1,252,400

ROTA

NORTHERN ISLAND

SAIPAN

$473,750

$605,000

$610,000

$606,500

$774,500

$780,900

$733,100

$911,050

$936,200 $1,163,500

$943,950 $1,173,100

$471,950

$536,050

$564,900

$605,750

$701,900

$788,450

$586,550

TINIAN

$613,750

$785,700

$949,750 $1,180,300

AGUAS BUENAS

AIBONITO

ARECIBO

BARCELONETA

BARRANQUITAS

BAYAMON

CAGUAS

CAMUY

CANOVANAS

CAROLINA

CATANO

CAYEY

CEIBA

CIALES

CIDRA

COMERIO

COROZAL

DORADO

FAJARDO

FLORIDA

GUAYNABO

GURABO

HATILLO

HUMACAO

JUNCOS

LAS PIEDRAS

LOIZA

LUQUILLO

MANATI

MAUNABO

MOROVIS

NAGUABO

NARANJITO

OROCOVIS

QUEBRADILLAS

$606,250

$325,000

$606,250

$325,000

$606,250

$325,000

$606,250

$776,100

$416,050

$776,100

$416,050

$776,100

$416,050

$776,100

$938,150 $1,165,900

$502,900

$625,000

$938,150 $1,165,900

$502,900

$625,000

$938,150 $1,165,900

$502,900

$625,000

$938,150 $1,165,900

RIO GRANDE

SAN JUAN

SAN LORENZO

TOA ALTA

TOA BAJA

TRUJILLO ALTO

VEGA ALTA

VEGA BAJA

YABUCOA

$606,250

$776,100

$938,150 $1,165,900

ST. CROIX

ST. THOMAS

ST. JOHN,VI

$327,750

$446,200

$623,300

$419,550

$571,200

$797,950

$507,150

$630,300

$690,450

$858,100

$964,500 $1,198,650

$271,050

$347,000

$419,400

All other areas (floor):

$521,250

.02 The nationwide average purchase price (for use in the housing cost/income

ratio for new and existing residences) is $217,300.

SECTION 5. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 2009-18 is obsolete except as provided in section 6 of this revenue

procedure.

SECTION 6. EFFECTIVE DATES

.01 Issuers may rely on this revenue procedure to determine average area

purchase price safe harbors for commitments to provide financing or issue mortgage

credit certificates that are made, or (if the purchase precedes the commitment) for

residences that are purchased, in the period that begins on June 16, 2010, and ends on

the date as of which the safe harbors contained in section 4.01 of this revenue

procedure are rendered obsolete by a new revenue procedure.

.02 Notwithstanding section 5 of this revenue procedure, issuers may continue to

rely on the average area purchase price safe harbors contained in Rev. Proc. 2009-18,

with respect to bonds sold, or for mortgage credit certificates issued with respect to

bond authority exchanged, before July 16, 2010, if the commitments to provide

financing or issue mortgage credit certificates are made on or before August 15, 2010.

.03 Except as provided in section 6.04, issuers must use the nationwide average

purchase price limitation contained in this revenue procedure for commitments to

provide financing or issue mortgage credit certificates that are made, or (if the purchase

precedes the commitment) for residences that are purchased, in the period that begins

on June 16, 2010, and ends on the date when the nationwide average purchase price

limitation is rendered obsolete by a new revenue procedure.

.04 Notwithstanding sections 5 and 6.03 of this revenue procedure, issuers may

continue to rely on the nationwide average purchase price set forth in Rev. Proc. 200918 with respect to bonds sold, or for mortgage credit certificates issued with respect to

bond authority exchanged, before July 16, 2010, if the commitments to provide

financing or issue mortgage credit certificates are made on or before August 15, 2010.

SECTION 7. REQUEST FOR COMMENTS

The Treasury Department and the IRS are reviewing the available data sources and

method used to determine the average area purchase price safe harbors listed in

section 4.01 of this revenue procedure and are considering possible changes in the

data used to determine these safe harbors for future years. One possible alternative

method under consideration would involve the use of certain current available data from

the Department of Housing and Urban Development (“HUD”) regarding county median

housing purchase prices. The Treasury Department and the IRS solicit public

comments generally on whether the average area purchase price safe harbors listed in

section 4.01 of this revenue procedure should continue to be based on FHA loan limits

or whether the data used to calculate these safe harbors should be changed in any way,

such as, without limitation, a change to an alternative method using current HUD data

on county median housing purchase prices.

Comments should be submitted in writing and can be e-mailed to

notice.comments@irscounsel.treas.gov (include “Rev. Proc. 2010-25“ in the subject

line) or mailed to Office of Associate Chief Counsel (Financial Institutions & Products),

Re: Rev. Proc. 2010-25, CC:FIP:B5, Room 3547, 1111 Constitution Avenue, NW,

Washington, DC 20224. The due date for the public comments is September 6, 2010.

Comments that are submitted will be made available to the public.

SECTION 8. PAPERWORK REDUCTION ACT

The collection of information contained in this revenue procedure has been

reviewed and approved by the Office of Management and Budget in accordance with

the Paperwork Reduction Act (44 U.S.C. 3507) under control number 1545-1877.

An agency may not conduct or sponsor, and a person is not required to respond

to, a collection of information unless the collection of information displays a valid OMB

control number.

This revenue procedure contains a collection of information requirement in

section 3.03. The purpose of the collection of information is to verify the applicable FHA

loan limit that issuers of qualified mortgage bonds and qualified mortgage certificates

have used to calculate the average area purchase price for a given metropolitan

statistical area for purposes of section 143(e) and 25(c). The collection of information is

required to obtain the benefit of using revisions to FHA loan limits to determine average

area purchase prices. The likely respondents are state and local governments.

The estimated total annual reporting and/or recordkeeping burden is: 15 hours.

The estimated annual burden per respondent and/or recordkeeper: 15 minutes.

The estimated number of respondents and/or recordkeepers: 60.

Books or records relating to a collection of information must be retained as long

as their contents may become material in the administration of any internal revenue law.

Generally tax returns and tax return information are confidential, as required by 26

U.S.C. 6103.

SECTION 9. DRAFTING INFORMATION

The principal authors of this revenue procedure are David E. White and Timothy

L. Jones of the Office of Division Counsel/Associate Chief Counsel (Tax Exempt &

Government Entities). For further information regarding this revenue procedure contact

David E. White on (202) 622-3980 (not a toll free call).

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.