Last Friday, September 20, the Department of Housing and Urban Development (HUD) announced a six-month delay to compliance requirements for the Housing Opportunity Through Modernization Act (HOTMA).

 The current compliance date of January 1, 2025, has been revised to July 1, 2025.

Implications for Multifamily Housing Owners

HUD is now requiring Multifamily Housing Owners to be in full compliance with the HOTMA final rule and HUD’s updated income and asset documentation requirements for income certifications having an effective date on or after July 1, 2025.

HOTMA makes many key changes to affordable housing rules, including establishing a limit on resident assets in order to be eligible for certain HUD rental assistance. Housing providers can opt out of enforcing the new asset limit on in-place residents by adding an exemption policy to their HOTMA-compliant Tenant Selection Plans (TSPs). Housing providers should continue using current (pre-HOTMA) rules and policies in the meantime.

LeadingAge Pushes for Clear Communication

LeadingAge had advocated for clear communication from HUD on delays, compliance requirements, and resources. HUD has yet to release additional materials, such as a HOTMA-compliant model lease or updated forms. TRACS has also not yet been updated to reflect HOTMA changes.