Crucial Update: HOTMA Guidance for Multifamily Owners

Posted On: November 29, 2023

The U.S. Department of Housing and Urban Development (HUD) is on the brink of releasing essential supplemental guidance concerning the Housing Opportunity Through Modernization Act (HOTMA). Specifically, this HOTMA guidance will shed light on the asset limitation outlined in Attachment A of Notice H 2023-10. Before you contemplate any changes to your current management policies, we urge you to review this forthcoming guidance diligently.

As a reminder, full compliance with the HOTMA final rule becomes mandatory on January 1, 2025. HOTMA brings statutory changes to enhance and modernize federal housing programs. To ensure that your operations align with the latest regulations and best practices, you must stay informed about updates that may impact your multifamily housing endeavors.

But here’s the key message: Until new guidance is released, please be aware of the following:

MFH Owners must not enforce the asset limitation or the real property exemption until both the owner’s software is HOTMA compliant (with TRACS 203A) and the family has signed a model lease detailing the new HOTMA provisions.

Your ability to follow the HOTMA guidance will affect your compliance. Please remain committed to staying up-to-date with regulatory guidance. HUD will communicate any developments. If you have questions or concerns in the meantime, don’t hesitate to reach out to HUD at

We have HOTMA information on our website here.


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