HOTMA implementation reference

Implementation dates depend on the program

The HOTMA Final Rule became effective on January 1, 2024. Compliance schedules differ across programs. Confirm the requirements that apply to each property with its administering agency.

The HUD Multifamily checklist addresses the January 1, 2027 deadline. LIHTC owners should check their state housing finance agency's guidance. HOME and Rural Development properties should confirm the applicable program schedule.

Income calculations require updated rules

HOTMA changes the treatment of assets and student financial assistance. Teams also need to account for changes to the earned income disregard and verification requirements.

Prepare policies and supporting documentation

Preparation extends beyond calculation methods. Review interim recertification policies and EIV procedures, then confirm that resident notices reflect the applicable requirements.

• Maintain an implementation checklist for each program.
• Update asset verification reference materials.
• Document changes to interim recertification requirements.
• Review EIV protocols against current HUD guidance.
• Review resident notice language and delivery deadlines.

Additional reference materials are planned

The hub is being developed to include downloadable checklists and asset verification references. Further material will address EIV procedures and sample resident notices.