Free resource
HOTMA Readiness Checklist
HUD Multifamily properties must comply with HOTMA income and asset rules by January 1, 2027. Use this checklist to see where your policies, files and team stand today. Print it, share it, or have a copy sent to your inbox.
1. Policies and plans
- Update the Tenant Selection Plan with HOTMA asset and real property ownership rules.
- Update house rules, lease addenda and resident notices that reference income or asset reviews.
- Write down your policy on when interim recertifications are processed for income changes.
- Decide which programs on each property follow HOTMA rules and on which effective date.
- Confirm your software and forms vendors have HOTMA-ready versions and know their release dates.
2. Assets
- Apply the net family asset limit and the real property ownership restriction at move-in and recertification.
- Use self-certification of assets when net family assets are at or below HUD's published threshold.
- Calculate imputed income on assets above the threshold using HUD's published passbook rate.
- Exclude assets HOTMA excludes, such as retirement accounts and education savings accounts.
- Track the annually adjusted thresholds HUD publishes so your calculations stay current.
3. Income
- Train staff on the updated definitions of annual income and the new income exclusions.
- Process interim decreases when income drops by the threshold in your written policy.
- Process interim increases only as HOTMA allows, and hold most earned income increases until the annual recertification.
- Decide whether you will accept income determinations from other means-tested programs (safe harbor).
4. Deductions
- Apply the updated elderly or disabled family deduction and dependent deduction amounts.
- Apply the higher threshold for unreimbursed health, medical and disability assistance expenses.
- Set up the hardship exemption process for families who qualify for relief.
- Review how child care expense deductions are documented and approved.
5. Files, layered programs and audits
- Map every property with more than one program and note which rule set wins on each test.
- Run a sample of current files against the new rules before your first HOTMA recertification.
- Prepare correction workflows so findings are fixed and documented before an audit.
- Keep a clear record of which rule version was applied to each certification.
6. People
- Train compliance, leasing and property staff on the changes, with refreshers as HUD issues guidance.
- Tell residents what will change in their recertification and what documents they will need.
- Assign one owner for HOTMA questions and keep a running log of guidance from HUD and your state agency.
This checklist is a planning aid, not legal advice. Thresholds and amounts are adjusted by HUD each year, and state agencies may add their own requirements. Always confirm against current HUD notices and your agency's guidance.