Implementation timing varies by program
HUD Notice H 2025-07 extended the HUD Multifamily compliance deadline to January 1, 2027. Other programs have different implementation schedules. Confirm the applicable guidance with the agency responsible for your property.
| Program | Timing |
|---|---|
| HUD Multifamily | January 1, 2027 compliance deadline under Notice H 2025-07. |
| LIHTC | Many state agencies have converted. State guidance determines timing. |
| HOME and NHTF | Implementation depends on participating-jurisdiction guidance. |
| Rural Development | Confirm HOTMA-aligned requirements under current USDA guidance. |
Income and asset rules affect certification
HOTMA revises income determinations and asset treatment. Applicable thresholds and exemptions affect both calculations and the documentation needed to support them.
HousingIntellect’s calculation engine supports HOTMA rules with traceable results. Asset checks help identify missing documentation for reviewers to resolve.
Interim recertifications need program context
Interim recertification requirements depend on the applicable rules and household circumstances. Teams need to confirm the triggers and notice requirements for each program.
HousingIntellect supports recertification tracking and resident notices. Your team determines how the requirements apply to each household.
Verification records remain part of the file
Keep the evidence used in income determinations and document how discrepancies were resolved. EIV requirements should be checked against current HUD guidance.
HousingIntellect supports documentation checks and findings tracking. EIV integration remains on the roadmap.
Layered funding requires separate attention
A property may be subject to more than one program’s rules. Confirm the requirements of each funding source rather than treating one implementation date as applicable to the entire portfolio.
Regulatory information reflects the source page’s May 2026 guidance. Timing varies by program and property type. Confirm current requirements with HUD, your state housing finance agency, or qualified compliance counsel.