HUD has extended the HOTMA compliance deadline for Sections 102 and 104, giving multifamily housing owners an extra six months to align with the new income and asset documentation requirements. The updated deadline is now July 1, 2025—but this doesn’t mean it’s time to relax!
View this extension as an opportunity to prepare thoroughly rather than an invitation to pause. Staying proactive is essential to avoid last-minute rushes leading to compliance risks or penalties. With this new timeline, multifamily owners have a strategic window to ensure their operations and processes fully meet the updated standards under the Housing Opportunity Through Modernization Act of 2016 (HOTMA).
What the Compliance Extension Means for Multifamily Owners
Sections 102 and 104 of HOTMA are part of an effort to modernize and streamline federal housing programs, focusing on income certification and asset documentation. The HOTMA extended compliance deadline affects certifications effective on or after July 1, 2025. Any income certification with an effective date on or after the revised deadline must fully comply with HUD’s new rules. This requirement applies specifically to the HUD programs listed in section 4 (Applicability) of Notice H 2023–10.
The six-month extension allows multifamily owners and agents additional time to prepare, but it also signals the significance HUD places on these updates. HOTMA’s changes aim to increase transparency, accuracy, and accountability across federal housing programs, ensuring that tenant eligibility assessments are both fair and consistent.
The new requirements under HOTMA are designed to enhance HUD’s oversight and streamline documentation processes, standardizing income verification practices across the board. For multifamily housing owners, this means adapting their operations to meet more stringent standards.
Some of the major compliance requirements under HOTMA include:
Enhanced Income and Asset Documentation: Multifamily owners must adopt detailed income and asset verification processes. This ensures that tenant income certifications are accurate, allowing HUD to assess eligibility and rent determinations effectively.
Standardized Verification Methods: By implementing uniform standards across programs, HUD reduces inconsistencies, creating a more equitable system for assessing tenant eligibility.
Increased Transparency and Accountability: HOTMA’s updated rules provide HUD with more consistent data, helping to ensure that affordable housing assistance reaches those who are truly eligible.
These requirements are mandatory for owners participating in the HUD programs identified in Notice H 2023–10. Compliance with these updates represents not just regulatory adherence but a commitment to the integrity and sustainability of affordable housing.
The Importance of Staying Proactive
The extended compliance deadline of July 1, 2025, allows multifamily owners to review and refine their compliance processes. However, delaying these preparations can lead to rushed implementations, often resulting in errors or non-compliance. Proactive planning ensures owners can address potential challenges well in advance and align with HUD’s expectations smoothly.
HUD’s extension reflects the complexities of meeting these new standards, yet it also underscores the importance of these updates for the affordable housing sector. Multifamily housing owners should use this time to focus on thorough preparations, including system upgrades, staff training, and a careful review of income and asset documentation practices. Staying on track with these activities can prevent complications later, especially as the final deadline approaches.
HOTMA’s Impact on the Affordable Housing Sector
HOTMA’s regulatory changes are part of a broader vision to improve transparency and trust within the affordable housing sector. By standardizing income and asset documentation, HUD aims to provide fair and equitable access to affordable housing resources for those who qualify.
For multifamily owners, compliance with HOTMA’s standards promotes industry-wide confidence in the integrity of resident eligibility assessments. HOTMA’s provisions may contribute to a stronger, more reliable affordable housing sector that serves eligible tenants effectively and responsibly.
Preparing for the Final Deadline
This compliance extension is an excellent opportunity to fine-tune your processes and demonstrate your commitment to affordable housing’s evolving standards. Don’t delay—use this additional time to reinforce the integrity of your income and asset documentation practices and stay ahead of the curve.
For any questions or further guidance, HUD has provided support through MFH_HOTMA@hud.gov. Reach out for assistance, and make sure your team is ready to meet the new standards by the final deadline.
