Tuesday Tip: New HOTMA Deadline

Heads Up: HOTMA Implementation Deadline Now January 1, 2026

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 If your current forms do not show a revision date of January 31, 2028, they are outdated.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