Good news: HUD has officially extended the HOTMA implementation deadline to January 1, 2026. This extension, announced in HUD Notice H-2025-03 on May 29, 2025, gives owners and agents (O/As) more time to prepare for full compliance.

However, don’t mistake this delay for a break from responsibilities. HUD still expects your Tenant Selection Plan (TSP) and Enterprise Income Verification (EIV) policies and procedures to reflect HOTMA-related updates. These documents were due on March 1, 2025, and that deadline has not changed.

See the official HUD Notice H-2025-03 here

Visit Navigate’s HOTMA resources

Tuesday Tip: HUD Extends HOTMA Deadline

Your TSP and EIV Must Reflect Any HOTMA Changes

Even if your property hasn’t fully implemented HOTMA yet, HUD will still review your TSP and EIV procedures. Why? Because some O/As have already made partial HOTMA changes, for example, updating medical expense calculations or implementing income determination procedures based on HOTMA rules.

If that’s you, make sure these updates:

• Are written into your Tenant Selection Plan
• Are reflected in your resident files
• Include a clear reference to the portion of HOTMA you are following

Without this documentation, HUD reviewers may issue a finding.

New Forms Owners and Agents Must Use

With the HOTMA implementation deadline still approaching, HUD has started rolling out revised forms required for HOTMA compliance. Some of the most critical are the updated VAWA (Violence Against Women Act) forms:

• HUD-5380: Notice of Occupancy Rights
• HUD-5381: Model Emergency Transfer Plan
• HUD-5382: Certification of Domestic Violence
• HUD-5383: Emergency Transfer Request
• HUD-5384: Emergency Transfer Data Collection Form

These forms have improved clarity, stronger confidentiality protections, and a new data collection component. If your current forms do not show a revision date of January 31, 2028, they are outdated.

📎 Download the latest VAWA forms

Remember:

• Provide HUD-5380 and HUD-5382 at move-in
• Include those same forms in rejection letters

Navigate has also posted updated forms on our website and social channels.

Understanding the HOTMA and COLA Connection

Another HOTMA rule already in effect relates to COLA (Cost of Living Adjustment) for Social Security recipients. Starting with the 2025 COLA:

• O/As may begin using new COLA figures the day after SSA announces them (typically in October)
• This allows you to adjust income calculations early and issue 120-day notices with better accuracy

Per the 2025 SSA announcement, the current COLA increase is 2.5%

You’ll find this rule outlined in HUD Handbook 4350.3, Chapter 9, Paragraph 9-6.

📘 Read Chapter 9 of the 4350.3 Handbook

Why This Matters for Owners and Agents

The extra time to implement HOTMA is helpful, but don’t let it lull you into complacency. Use the next several months to:

• Finalize TSP and EIV updates
• Train staff on partial HOTMA implementations
• Ensure new VAWA forms are in use
• Incorporate COLA rules into income processes
• Keep resident files audit-ready

And don’t forget: if you’ve already implemented any portion of HOTMA, HUD expects you to show exactly how and why. That means written documentation in both your policies and your resident files.

Still have questions? Reach out to your HUD ED or contact Navigate. We’re here to help guide you through the transition.

🧩 Find your HUD Regional Office contact

📞 Contact Navigate Compliance

Get Ready for HOTMA Implementation Deadline

As the new deadline approaches, we’ll keep you updated on:

• TRACS 203A release requirements
• HOTMA lease updates
• Revised 9834 forms
• Additional field guidance and training

Be sure to follow Navigate on LinkedIn, Facebook, Instagram, and YouTube for the latest updates and Tuesday Tips.

👉 Follow us on LinkedIn

📺 Watch Tuesday Tips on YouTube

The post Tuesday Tip: New HOTMA Deadline appeared first on Navigate Housing.

On May 29, 2025, the U.S. Department of Housing and Urban Development (HUD) officially extended the HOTMA implementation deadline for Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). The new mandatory compliance date is now January 1, 2026, providing multifamily property owners and managers with an additional six months to meet the requirements outlined in the final rule.

Background on HOTMA Compliance

HOTMA, enacted in 2016, introduced significant reforms to income and asset verification for HUD-assisted housing. Sections 102 and 104 specifically address tenant income calculations, asset limits, and streamlined recertification policies.

Originally, HUD required full compliance for income certifications effective on or after January 1, 2025, as stated in Notice H 2023–10. This deadline was later extended to July 1, 2025 via Notice H 2024–09. However, with the publication of Notice H 2025–03, HUD now provides an extended timeline to ensure smoother implementation across multifamily housing programs.

This deadline extension applies to owners and operators participating in HUD Multifamily Housing programs covered under Notice H 2023–10. These include property owners, contract administrators, regional center directors, asset management divisions, and field counsel.

The additional time allows these stakeholders to:

• Finalize and implement HOTMA-compliant policies and procedures
• Complete system updates for income and asset documentation
• Train staff and educate residents on the new requirements

Key Takeaway: New Compliance Deadline – January 1, 2026

HUD’s decision to extend the HOTMA compliance date to January 1, 2026, also offers much-needed flexibility for owners and agents working to align with complex regulatory changes. It also demonstrates HUD’s ongoing commitment to supporting housing providers through operational transitions.

For questions or clarification about the updated notice, stakeholders are encouraged to contact HUD directly.

Need help preparing for HOTMA compliance? Stay tuned to our blog for future updates, guidance, and practical tools to support the implementation.

The post HOTMA Implementation Deadline: New Date Set for January 2026 appeared first on Navigate Housing.

January 2025 HOTMA Check-In: The new year is here and so is a new HOTMA Implementation deadline from The Department of Housing and Urban Development.

In this week’s #TuesdayTip, Corporate Trainer Pam K. Dives into where the implementation process stands right now.

January 2025 HOTMA Update

The implementation date for the Housing Opportunity Through Modernization Act (HOTMA) has been updated to July 1, 2025. This change provides property owners and managers additional time to prepare for compliance with the new requirements. Below are key steps to ensure a smooth transition:

Stay Updated
Keep track of updates and final guidance by subscribing to HUD’s mailing lists and engaging with professional housing organizations. This will help you stay informed about any changes or clarifications.

Update EIV Policies and Tenant Selection Plans
EIV (Enterprise Income Verification) policies and tenant selection plans must be revised by May 2024. Early preparation is crucial to avoid last-minute compliance issues.

Prioritize Staff Training
Training staff responsible for HOTMA-related tasks is essential. However, Navigate recommends waiting for final guidance from HUD before initiating training programs.

Document Early Changes
If you choose to implement changes before the effective date, thorough documentation is critical. This ensures transparency and compliance during audits or reviews.

Adopt a Communication Plan
A clear communication plan for residents is necessary to explain how these changes might affect them. Transparent communication builds trust and minimizes confusion.

Prepare All Forms
Ensure that all relevant forms and documentation are updated and ready for use by the implementation date.

The January 2025 HOTMA Recommendation from Navigate Affordable Housing Partners is to wait until the effective date to implement changes unless otherwise directed. With proper planning, communication, and training, housing professionals can ensure compliance with HOTMA requirements while maintaining high standards of service.

The post Tuesday Tip: January 2025 HOTMA Check-In appeared first on Navigate Housing.

Key Updates and Guidance for Owner Agents

With new compliance extensions and income safe harbor provisions, owner agents must stay informed and proactive.

HUD has adjusted HOTMA compliance timelines for various stakeholders in 2025. The new dates accommodate system updates and provide additional guidance:

1. CPD Programs:
   • CPD grantees must comply with the HOTMA final rule by January 1, 2026. However, early compliance is allowed starting January 1, 2024.
   • Programs affected include HOME, Housing Trust Fund (HTF), HOPWA, and others tied to HUD’s 24 CFR part 5 income regulations.
2. PHAs and Multifamily Owners:
   • Public Housing Agencies (PHAs) must implement Sections 102 and 104 no later than January 1, 2025.
   • Multifamily housing owners must comply by July 1, 2025.

Income Safe Harbor Provisions

HUD also introduced income safe harbor options. The move aligns calculations across federal programs, easing administrative burdens and supporting early adoption:

• CPD Programs:
  Programs like ESG, HOPWA, and CoC may adopt the income determination safe harbor under 24 CFR 5.609(c)(3). This aligns income verification methods with federal assistance programs.
• HOME and HTF Provisions:
  Participating jurisdictions and HTF grantees may use safe harbor provisions outlined in 24 CFR 92.203(a) and 93.151(a). These allow acceptance of income determinations from federal or state project-based rental subsidies.

Preparing for HOTMA Compliance 2025

Owner/agents must take proactive steps to align with HUD’s revised timelines and provisions:

1. Assess Readiness:
   • Review your organization’s policies against HOTMA final rule requirements.
   • Evaluate whether early compliance or safe harbor adoption benefits your operations.
2. Revise Policies and Procedures:
   • If using safe harbor provisions, update your income determination policies to reflect these options.
   • Document and implement these changes into your workflows and software systems.
3. Leverage HUD Resources:
   • Stay updated with HUD notices, webinars, and FAQs for further clarification.
   • Seek guidance from HUD representatives if you encounter challenges.
4. Educate Staff and Residents:
   • Train your team to ensure accurate application of updated income rules.
   • Communicate these changes to residents, especially those affected by safe harbor adjustments.

Impact on Affordable Housing

The updated compliance timelines provide essential flexibility for stakeholders, allowing time to adapt while maintaining service quality. Owner agents can use this transition period to refine processes and ensure compliance. Early adoption of safe harbor provisions may also streamline operations and reduce administrative burdens.

As HOTMA compliance in 2025 approaches, proactive planning and clear communication will be crucial. By leveraging these updates, owner agents can effectively navigate the evolving regulatory landscape and continue delivering quality housing to residents.

For further details, access HUD’s HOTMA Implementation FAQs.

The post HOTMA Compliance 2025 appeared first on Navigate Housing.

1. Early Adoption and Transition Period

Navigate recommends you do not implement HOTMA provisions manually. We suggest you wait until the software is up-to-date!

Before the release of TRACS 203A, MFH Owners can implement HOTMA provisions manually:

• Manual Calculations: Using the rent override function, family incomes and tenant rents can be calculated manually and entered into TRACS 202D. Detailed instructions are available in HUD’s one-pager on this topic here.

Again, we suggest you wait until the software is up-to-date! Please watch the video below to learn why we recommend patience.

2. Tenant Selection Plans (TSPs)

During Management and Occupancy Reviews (MORs), both pre-HOTMA and HOTMA-compliant TSPs must be reviewed. Key points:

• No penalties for HOTMA-related tenant file errors will be issued before the July 1, 2025 compliance date.
• Owners must update and publicize their TSPs and EIV Policies by May 31, 2024, to avoid findings during MORs.

Recommendation: Redline your pre-HOTMA TSPs to align with HOTMA changes for smoother MOR processes.

3. HOTMA Model Leases and Forms

HUD will provide updated model leases and forms that are compliant with HOTMA. Until the compliance date:

• Owners who adopt HOTMA provisions must use the new forms as they become available.
• Families must receive at least 60 days’ notice about lease modifications, with clear instructions on accepting or refusing changes.

4. Inflationary Adjustments and Passbook Savings Rate

HOTMA introduces adjustments tied to inflation:

• Adjusted rates for 2025 can be found here.
• The Passbook Savings Rate is updated to 0.45% under HOTMA but remains at 0.06% for non-HOTMA properties until compliance is mandatory.

5. Safe Harbor and Hardship Provisions

MFH Owners can apply safe harbor provisions for income determinations based on means-tested federal assistance programs. Additionally:

• Medical hardship relief applies to families with deductions before January 1, 2024.
• General hardship provisions allow discretion in addressing significant deduction drops.

6. Key Dates to Remember

• May 31, 2024: Deadline for updating and publicizing TSPs and EIV Policies.
• Early 2025: Expected release of TRACS 203A for comprehensive HOTMA compliance.
• July 1, 2025: Final compliance date for implementing HOTMA provisions.

7. Additional Resources and Next Steps

MFH Owners are encouraged to:

• Subscribe to HUD’s Multifamily Housing mailing list for updates here.
• Review notices such as Notice H 2023-10 and Notice H 2024-04 for detailed guidance.

The post HOTMA Compliance: A Guide for Multifamily Housing Owners appeared first on Navigate Housing.

Tuesday Tip

Inflation-Adjusted Values and Passbook Rate

Have you looked at the CY2025 HUD Updates? This document includes updated thresholds for assets and income and a revised passbook savings rate. Effective January 1, 2025, the changes align with Sections 102 and 104 of the Housing Opportunity Through Modernization Act (HOTMA). We recommend you wait until your software is fully updated before using these numbers!

Understanding these updates is essential for compliance and planning for property managers, program administrators, and tenants. This week’s Tuesday Tip discusses all of this.

Takeaways: CY2025 HUD Updates

The updates include significant changes that impact how eligibility and rent calculations are performed across HUD programs. You can download the whole document below. The document covers:

• Asset Limitations
  • The new cap for net family assets is $103,200, up from $100,000 in 2024.
  • Self-certification thresholds have also increased to $51,600.
• Income Thresholds:
  • Imputed returns on net family assets are now required when the value exceeds $51,600.
  • Non-essential personal property valued above $51,600 is included in net assets.
• Mandatory Deductions:
  • Elderly and disabled households receive an increased deduction of $525, up from $400.
  • Dependent deductions remain unchanged at $480.
• Passbook Savings Rate:
  • The passbook rate, used to calculate imputed asset income, has been revised to 0.45%.

Why These Changes Matter

HUD’s adjustments aim to reflect inflation and ensure fair income and eligibility calculations for subsidized housing. For program administrators, the CY2025 HUD updates emphasize the importance of aligning operational processes with the latest regulations.

According to Vickie Bell, Navigate’s subject-matter expert, these adjustments help maintain compliance with HOTMA provisions and prepare the industry for the July 2025 full implementation of HOTMA software.

Compliance Challenges and Recommendations

Administrators must prepare for these changes while addressing potential implementation challenges:

HOTMA Compliance: If your property or program is not compliant with Sections 102 and 104, these tables may not apply immediately. HUD recommends waiting for updated software before implementing these changes.

Software Updates: HUD ensures systems like TRACS are prepared to handle the new data requirements. Until then, agencies should use the updated values for test calculations and await final software approval.

Resident Communication: Changes to asset limitations and deductions can affect residents’ rent calculations. To prevent misunderstandings, it is crucial to educate tenants about these updates through tools like newsletters and community meetings.

Practical Applications for Administrators

1. Updating Tenant Selection Plans:

• Ensure that self-certification thresholds and asset limits are included in your property’s tenant selection plan, and note that these values will adjust annually.

2. Calculating Adjusted Income:

• Use the revised mandatory deductions and income exclusions to calculate residents’ adjusted income accurately. This directly affects rent calculations and subsidy amounts.

3. Using the Passbook Savings Rate:

• The new rate of 0.45% applies to any assets exceeding $51,600. This ensures consistent treatment of imputed income across programs.

Preparing for Full Implementation

While the CY2025 HUD Updates values are effective starting January 2025, full HOTMA compliance is expected by July 2025. HUD advises waiting for the necessary software updates before fully implementing the changes. Early training and mock calculations can help your team prepare for the transition.

The post CY2025 HUD Updates appeared first on Navigate Housing.

The HOTMA compliance deadline extension for multifamily housing is good news for owners! HUD has extended the compliance date for implementing Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). Initially scheduled for January 1, 2025, the new deadline is now July 1, 2025. This gives property owners six months to align their operations with the updated income and asset documentation requirements.

What is HOTMA?

HOTMA, enacted in 2016, aims to streamline and modernize federal housing programs. It impacts various programs, including income certification and recertification processes for multifamily housing owners. Specifically, Sections 102 and 104 of HOTMA require owners to update their documentation and reporting protocols to comply with HUD’s final rule

What’s Changing?

Under the revised rule, multifamily owners must adopt new income and asset verification processes. This ensures that income certifications are accurate and transparent, helping HUD assess tenant eligibility and rent determinations more effectively.

The latest HOTMA compliance deadline extension provides breathing room, but it is vital to use this extra time to make the necessary changes.

Revised Compliance Date: July 1, 2025

In Notice H 2024-09, HUD officially moved the compliance deadline from January 1, 2025, to July 1, 2025. The HOTMA compliance deadline extension for multifamily housing allows owners to ensure their systems and staff are fully equipped to meet the updated requirements. Failure to comply by the revised date may lead to penalties, so timely action is critical.

What Should Multifamily Owners Do Now?

With this new deadline in place, now is the time to review your current income certification procedures. Ask yourself the following questions:

• Are my staff trained on the new income documentation standards?
• Have I updated my software to meet the new requirements?
• Am I clear on which programs are affected by HOTMA?

Taking these steps now ensures you’re prepared well ahead of the July 1, 2025 deadline.

Further Information
For any questions related to HOTMA compliance, HUD encourages multifamily owners to reach out via email at MFH_HOTMA@hud.gov.

The compliance extension is an excellent opportunity to finalize any lingering updates to your income and asset documentation processes. Stay ahead of the curve by using this extra time wisely to fully align with HOTMA requirements.

The post HOTMA Compliance Deadline Extended: What Multifamily Owners Need to Know appeared first on Navigate Housing.

She also outlines the essential documents that must be included in the EIV master file and explains the requirements for coordinators, users, and non-users, stressing the need to follow HUD’s authorization and training guidelines.

Reports & MOR Scores

Reports should be generated according to HUD standards and internal procedures, highlighting the difference between the existing tenant search and the multiple subsidy report. All reports should also be dated for proper documentation and tracking.

EIV discrepancies arise when file information conflicts, and they must be documented and resolved. Reports like the existing tenant search and multiple subsidy report help identify these discrepancies. Documentation should include the who, what, why, where, and when, along with contact and relevant details. The master file should also hold copies of periodic reports, while tenant files should document identified issues and the steps taken to resolve them.

How to Master Your Next Management & Occupancy Review

HUD gives owner agents flexibility in organizing tenant files, without a mandated order. However, files must contain key documents such as application screening, move-in information, certifications, EIV reports, and discrepancy resolutions. It’s essential to avoid duplicate, conflicting, or irrelevant information, like VAWA details or data tied to another regulatory body.

Tenant files must be organized securely, consistently, and restricted to authorized personnel. Social security numbers should be verified using HUD’s appendix three, without including specific disability diagnoses. Prior errors must be noted, along with corrective actions taken. Well-organized files should tell a clear, complete story that allows reviewers to understand decision-making and calculations easily.

Master your next Management & Occupancy Review by keeping well-organized, detailed tenant files and adhering to HUD guidelines. By ensuring proper documentation, maintaining the EIV master file, and resolving discrepancies promptly, owners and agents can streamline the review process. Clear, accurate files not only demonstrate compliance but also make decision-making transparent for HUD reviewers, ultimately contributing to more efficient and successful audits.

MOR Findings

So, what happens if you receive findings during your MOR? Corrective action is an important part of mastering the Management Occupancy Review process.

The post Master Your Next Management & Occupancy Review (MOR) appeared first on Navigate Housing.

HUD’s Annual Inflationary Adjustment and Passbook Rates

Did you know? HUD has released its annual inflationary adjustments, including updates to passbook rates. These adjustments will affect income calculations and asset limitations for many housing programs. Key figures to note for CY2025 include:

• Asset Limitation: Increased to $103,200.
• Annual Income Threshold: Now $51,600.
• Passbook Rate: Increased to 0.45% for CY2025.

These adjustments impact programs such as Section 8, Public Housing, and others. For detailed information, you can view the full document on revised inflation-adjusted amounts and passbook rates.

New HUD Forms

While everyone anticipated HOTMA-related changes, the latest HUD forms mainly focus on contract renewals. Vicki Bell mentioned that Nytira Mickel, who oversees contract renewals, will provide further details in next week’s session. In the meantime, there are 33 new HUD forms you should be aware of, which are available for review on HUD Clips.

Fair Housing Guidance: Application Screening

HUD recently published new guidance on application screening and fair housing compliance, touching on critical aspects such as the use of criminal history, credit scores, and AI in tenant screening. This guidance is particularly important for housing providers, as it outlines best practices to ensure compliance with the Fair Housing Act. One major change involves restrictions on using lookback periods in criminal background checks. HUD now advises against using arbitrary lookback periods (e.g., three, five, or seven years) when screening applicants with a criminal history.

Vicki also reminded participants that this guidance will likely impact tenant selection plans, so it’s crucial to review your policies. The full guidance document can be accessed below.

Renter’s Bill of Rights and Tenant Selection Plans

Vicki also briefly touched on the Renter’s Bill of Rights, emphasizing the importance of staying informed. For those who haven’t yet reviewed the White House Blueprint for Renters’ Rights, this document is critical for understanding upcoming changes to tenant rights and responsibilities. Stay tuned for updates as HUD integrates these guidelines into its policies.

To deeply dive into these changes, ensure you’ve reviewed your tenant selection plan to align it with HOTMA, EIV policies, and the latest screening guidelines. Adjusting your policies now will save time and confusion later when these new rules go into effect.

Key Takeaways:

1. Wait for Software Updates: Before making changes, wait for software updates that integrate HUD’s new regulations.
2. Keep an Eye on HOTMA Forms: Review the new forms and stay tuned for more detailed sessions.
3. Review Screening Policies: Ensure compliance with HUD’s latest fair housing guidance on tenant screening.

For more detailed discussions and upcoming topics, check our blog and stay updated on the latest tips and guidelines for housing professionals.

The post Tuesday Tip Recap: Hot Topics for Housing Professionals appeared first on Navigate Housing.

Please note HUD made corrections to the new HOTMA final rule on May 27, 2024. You can read them here.

Streamlining Access to Affordable Housing with the HOTMA Final Rule

The new rule introduces several critical enhancements aimed at increasing the efficiency of voucher programs. By simplifying the regulatory landscape, Public Housing Agencies (PHAs) can adapt to local housing needs while ensuring tenant protections.

Key Features of the HOTMA Final Rule:

1. Flexibility for PHAs:
   The rule grants PHAs the ability to utilize Small Area Fair Market Rents (SAFMRs) in non-metropolitan areas. In essence, this flexibility helps PHAs establish rent standards that more accurately mirror the local rental market conditions. This move potentially makes more neighborhoods accessible to voucher holders.
2. Enhancements to Project-Based Vouchers:
   The changes facilitate a more significant investment in affordable housing. It allows PHAs to link long-term federal PBV rental assistance directly to specific housing units or developments. As a result of providing more certainty to investors and developers, the shift could attract more private and public financing.
3. Efficiency and Tenant Protections:
   Streamlining processes is a cornerstone of the HOTMA final rule, which aims to expedite the provision of affordable housing. It improves tenant protections by setting up local project-specific waiting lists and codifying safeguards around inspections and property management.
4. Boosting Housing Supply:
   The rule addresses the critical affordable housing shortage by facilitating both the preservation and expansion of the housing supply. HUD expects to achieve this by equipping PHAs with the tools needed to enhance community housing availability.

Collaborative Efforts Under the HOTMA Final Rule

HUD Acting Secretary Adrianne Todman highlighted this new rule “represents collaboration between HUD and our stakeholders to build more affordable housing and make existing housing more affordable.” This collaborative strategy is essential. The HOTMA final rule aligns with both national and local objectives to rapidly expand affordable housing options.

The post PHA HOTMA Final Rule: A Major Update to Voucher Programs appeared first on Navigate Housing.