From a HOTMA compliance update to evolving HUD staffing, the Owner-Agent Roundtable at this year’s SAHMA conference for Alabama and Mississippi addressed it all. The session featured crucial regulatory and operational updates for HUD-assisted housing workers. The discussion provided insights that all owners and agents should note.
HOTMA Compliance Update: Timeline, Enforcement, and Paycheck Stubs
HOTMA compliance remains the biggest shift in HUD policy in recent years. While most HOTMA guidelines have been adopted, the two-paycheck stub requirement is currently on hold due to concerns about inconsistent income data. HUD tentatively set the implementation date for July 1, 2025, though delays are expected as HUD finalizes guidance.
Key takeaway: HUD expects to update the policies by June 1, but no enforcement will begin until HUD grants full access and direction.
PBCA Updates and MOR Trends – Navigate Affordable Housing Partners
New staffing in Alabama and Mississippi aims to enhance oversight and resident relations. The addition of relationship managers and a third resident concerns specialist are already addressing recurring issues across more than 83,000 units.
Common MOR findings include:
- In Alabama: misuse of EIV, incomplete tenant selection plans, and outdated Affirmative Fair Housing Marketing Plans.
- In Mississippi: non-HOTMA-compliant leases and missing reserve reminders.
These findings directly impact HUD Form 9834 ratings, particularly in tenant management and unit maintenance areas.
Action tip: Review your tenant selection plans and emergency transfer procedures to ensure alignment with HOTMA compliance updates and MOR requirements.
HUD Staffing Changes and Implementation Delays
Hiring freezes continue to stall key appointments. These staffing gaps can delay HOTMA Handbook updates and FAQ finalizations.
We encourage owners and agents to track these changes, as policy enforcement depends heavily on HUD’s internal capacity.
NSPIRE System Glitches and Inspection Confusion
Technical issues with the NSPIRE inspection portal remain unresolved. Some inspections are showing as canceled without notice, often due to system errors or declared disasters. HUD is actively onboarding new vendors and recommends contacting the help desk for issues.
Reminder: Unresolved property issues can still impact your MOR results, even if your inspection was canceled.
Buy America, Build America Act: What You Need to Know
The Buy America Preference (BAP) now applies to PBRA-funded renovation and maintenance projects, including utility and housing repairs classified as infrastructure. Owners must comply with sourcing requirements when using federal funds.
HUD confirmed that BAP does apply to PBRA—clarifying earlier confusion.
Affirmative Fair Housing Marketing Plan (AFHMP) Updates
AFHMPs are still reviewed case-by-case for new construction or major updates. Regular five-year updates are required, but routine plans without changes may not be acknowledged—particularly in states like Texas.
Best practice: Submit AFHMPs with full documentation and follow up with local HUD contacts to ensure proper review and approval.
Other Key Regulatory Updates:
- Immigrant Eligibility: Still awaiting executive orders and HUD interpretation.
- Evictions Final Rule: Effective January 13, 2025, requiring a 30-day written notice for non-payment judicial evictions.
- Occupancy Decisions: Owners must make individualized assessments for applicants with pending arrests per Housing Notice 2015-10.
Final Action Steps for Owners and Agents
- Prepare for enforcement and HOTMA compliance after July 1, 2025.
- Align your policies with recent MOR findings to avoid future deductions.
- Stay updated on HUD Form 4350.3 and additional Buy America guidance.
- Use the HUD help desk for NSPIRE system errors.
- Ensure AFHMP documentation is current and acknowledged.
- Assess applicant criminal history fairly, not solely based on arrests.
